Quality Assurance Project Plan for the 

Steam Electric Effluent Guidelines 

Rulemaking 

Prepared for:

U.S. Environmental Protection Agency

Engineering and Analysis Division 

Office of Water 

1200 Pennsylvania Avenue, NW 

Washington, D.C. 20460 

Prepared by: 

Eastern Research Group, Inc.

14555 Avion Parkway 

Suite 200 

Chantilly, VA 20151 

Original prepared September 25, 2009 

Revision 1 prepared March 22, 2010 

Revision 2 prepared April 6, 2010 

Revision 3 prepared October 26, 2010 

Revision 4 prepared April 5, 2013 

EPA Contract No. EP-C-12-021 

Work Assignment 0-29




History of QAPP for Steam Electric Effluent Guidelines Rulemaking

Revision 0 Revision 1 Revision 2/3 Revision 4 

Delivery Date 9/25/2009 3/12/2010 4/6/2010; 10/26/2010 4/5/2013 

Contract/Work 

Assignment 

68-C-02-095 

WA 6-22 

68-C-02-095 

WA 7-29 

68-C-02-095 

WA 7-29, 8-29 

EP-C-12-021 

WA 0-29 

Scope Site visits, sampling, 

long-term monitoring 

program, questionnaire 

data collection and 

management, 

secondary data 

Updated details of 

sampling program and 

added analytical data 

review 

Updated details of ICR 

development and 

added survey 

implementation and 

review (Rev 2) and 

updated details of 

industry monitoring 

program and survey 

review activities and 

added EA and cost 

model development 

(Rev 3) 

Made changes 

throughout to make 

tense consistent, 

update references to 

new contract, and add 

additional details of 

ICR survey review 

Updated description of 

subcontractor roles, 

project management 

and organization, and 

validation/verification 

methods used. 

Comments 

Received 

11/11/2009 3/22/2010 11/2/2010; 12/1/2010 4/16/2013 

Comments 

Addressed 

11/12/2009 3/22/2010 12/1/2010 4/16/2013 

Approval 11/24/2009 3/23/2010 11/30/2010 4/19/2013 
i

TABLE OF CONTENTS 

Page

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

2.0 PROJECT MANAGEMENT ELEMENTS ..................................................................... 2-1

2.1 Element A.3: Distribution List ................................................................. 2-1

2.2 Element A.4: Project Organization .......................................................... 2-1

2.3 Element A.5: Problem Definition/Background ........................................ 2-3

2.3.1 Background .................................................................................. 2-3

2.3.2 Statement of Key Questions and Project Outcome ...................... 2-4

2.4 Element A.6: Project/Task Description ................................................... 2-6

2.4.1 Steam Electric Plant Visits and Sampling ................................... 2-6

2.4.2 Industry Self-Monitoring Program .............................................. 2-8

2.4.3 Questionnaire for the Steam Electric Power Generating Effluent 

Guidelines .................................................................................... 2-9

2.4.4 Candidate Technology Options .................................................... 2-9

2.4.5 Pollutant Discharge Estimates ................................................... 2-10

2.4.6 Costs and Pollutant Reductions Estimates ................................. 2-10

2.4.7 Environmental Assessment Analysis ......................................... 2-10

2.5 Element A.7: Quality Objectives and Acceptance Criteria ................... 2-11

2.5.1 Field Sampling Data .................................................................. 2-11

2.5.2 Data Collected through the Questionnaire for the Steam Electric 

Power Generating Effluent Guidelines ...................................... 2-19

2.5.3 Pollution Control Technology Costs .......................................... 2-20

2.5.4 Pollution Control Technology Cost Estimates ........................... 2-21

2.5.5 Secondary Data .......................................................................... 2-22

2.6 Element A.8: Special Training/Certification ......................................... 2-25

2.7 Element A.9: Documents and Records .................................................. 2-26

3.0 DATA GENERATION AND ACQUISITION ................................................................. 3-1

3.1 Steam Electric Site Visits and Sampling and Analysis ............................ 3-1

3.1.1 Element B.1 - Sampling Process Design ..................................... 3-1

3.1.2 Element B.2 - Sampling Methods ................................................ 3-2

3.1.3 Element B.3 - Sample Handling and Custody ............................. 3-4

3.1.4 Element B.4 - Analytical Methods............................................... 3-6

3.1.5 Element B.5 - Sampling Quality Control ..................................... 3-6

3.1.6 Element B.6 - Instrument/Equipment Testing, Inspection, and 

Maintenance ............................................................................... 3-12

3.1.7 Element B.7 - Instrument/Equipment Calibration and 

 Frequency ................................................................................... 3-12

3.1.8 Element B.8 - Inspection/Acceptance Criteria for Supplies and 

Consumables .............................................................................. 3-13

3.1.9 Element B.9 - Non-Direct Measurements .................................. 3-14

3.1.10 Element B.10 - Data Management ............................................. 3-14

3.2 Industry Self-Monitoring Program ........................................................ 3-18

3.2.1 Element B.1 - Sampling Process Design ................................... 3-18
TABLE OF CONTENTS (Continued) 

Page 

ii

3.2.2 Element B.2 - Sampling Methods .............................................. 3-19

3.2.3 Element B.3 - Sample Handling and Custody ........................... 3-21

3.2.4 Element B.4 - Analytical Methods............................................. 3-22

3.2.5 Element B.5 - Sampling Quality Control ................................... 3-23

3.2.6 Element B.6 - Instrument/Equipment Testing, Inspection, and 

Maintenance ............................................................................... 3-24

3.2.7 Element B.7 - Instrument/Equipment Calibration and 

 Frequency ................................................................................... 3-24

3.2.8 Element B.8 - Inspection/Acceptance Criteria for Supplies and 

Consumables .............................................................................. 3-25

3.2.9 Element B.9 - Non-Direct Measurements .................................. 3-25

3.2.10 Element B.10 - Data Management ............................................. 3-25

3.3 Questionnaire for the Steam Electric Power Generating Effluent 

Guidelines .............................................................................................. 3-25

3.3.1 Element B.1 - Questionnaire Sampling (Data Collection) 

 Process Design ........................................................................... 3-25

3.3.2 Element B.2 - Questionnaire Sampling (Data Collection) 

 Methods...................................................................................... 3-26

3.3.3 Element B.3 - Questionnaire Sample (Data) Handling and 

 Custody ...................................................................................... 3-28

3.3.4 Element B.5 - Questionnaire Quality Control............................ 3-28

3.3.5 Element B.9 – Questionnaire Non-Direct Measurements .......... 3-32

3.3.6 Element B.10 - Questionnaire Data Management ..................... 3-32

3.4 Technology Option Costs and Pollutant Reductions ............................. 3-35

3.4.1 B.9: Non-Direct Measurements ................................................. 3-35

3.4.2 B.10: Data Management ............................................................ 3-37

3.5 Environmental Assessment Analysis ..................................................... 3-38

3.5.1 B.9: Non-Direct Measurements ................................................. 3-38

3.5.2 B.10: Data Management ............................................................ 3-39

4.0 ASSESSMENT AND OVERSIGHT ELEMENTS ........................................................... 4-1

4.1 Element C.1: Assessments and Response Actions .................................. 4-1

4.1.1 Technical Support ........................................................................ 4-1

4.1.2 Industry Self-Monitoring On-Site Audits .................................... 4-1

4.1.3 Sampling and Analysis ................................................................ 4-2

4.1.4 Corrective Actions ....................................................................... 4-2

4.2 Element C.2: Reports to Management ..................................................... 4-3

5.0 DATA VALIDATION AND USABILITY ELEMENT ..................................................... 5-1

5.1 Elements D.1 and D.2: Data Review, Verification, and Validation; and 

Validation Methods .................................................................................. 5-1

5.1.1 Site Visits, Sampling, Industry Monitoring, and Analysis .......... 5-1

5.1.2 Questionnaire for the Steam Electric Power Generating Effluent 

Guidelines .................................................................................... 5-7

5.1.3 Technology Option Costs and Pollutant Reductions ................... 5-8

5.1.4 Environmental Assessment Analysis ........................................... 5-9

5.2 Element D.3: Reconciliation with User Requirements .......................... 5-10
TABLE OF CONTENTS (Continued) 

Page 

iii

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

Appendix A: LIST OF SITE VISIT OBJECTIVES 

Appendix B: GENERIC SAMPLING AND ANALYSIS PLAN FOR COAL-FIRED STEAM 

ELECTRIC POWER PLANTS [FEBRUARY 24, 2010 VERSION] 

Appendix C: INFORMATION COLLECTION REQUEST FOR THE STEAM ELECTRIC 

GENERATING INDUSTRY [FINAL VERSION] 

Appendix D: ANALYTICAL DATA REVIEW CHECKLISTS 

Appendix E: DATA REVIEW GUIDELINES 

Appendix F: COMPLETENESS CHECKLIST 

Appendix G: ENVIRONMENTAL SAMPLING SUPPLY PRODUCT DOCUMENTATION 

Appendix H: INDUSTRY SELF-MONITORING ON-SITE AUDIT CHECKLISTS 
iv

LIST OF TABLES 

Page 

Table 2-1. Sampling Data Quality Review Criteria ................................................................... 2-14 

Table 2-2. Steam Electric Questionnaire Data Acceptance Criteria .......................................... 2-19 

Table 2-3. Pollution Control Technology Cost Data Acceptance Criteria ................................ 2-21 

Table 2-4. Cost Estimate Quality Specifications ....................................................................... 2-21 

Table 2-5. Secondary Data Acceptance Criteria ........................................................................ 2-27 

Table 3-1. Field Quality Control Samples ................................................................................... 3-8 

Table 3-2. Data Quality Qualifiers for Sampling Program ........................................................ 3-17 

Table 3-3. Typical Analytical Database Structure ..................................................................... 3-18 

Table 3-4. Analytes and Analytical Methods Included in the Industry Self-Monitoring 

 Program .............................................................................................................. 3-23 

Table 5-1. Data Package Detail Expected for Project Categories ............................................... 5-2 

LIST OF FIGURES 

Page 

Figure 2-1. Project-Level QA Organization for ERG’s Support for the Steam Electric 

Rulemaking .......................................................................................................... 2-2 

Figure 3-1. Telephone Contact Report Form ............................................................................. 3-36 
Section No. 1 

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Date: April 5, 2013 

Page 1 of 2 

1.0 INTRODUCTION

ERG is providing technical support to the U.S. Environmental Protection Agency 

(EPA) for development of effluent limitations guidelines and standards (effluent guidelines) for 

the Steam Electric Power Generating Industry. The Steam Electric Power Generating effluent 

guidelines apply to a subset of the electric power industry, namely those plants “primarily 

engaged in the generation of electricity for distribution and sale which results primarily from a 

process utilizing fossil-type fuel (coal, oil, or gas) or nuclear fuel in conjunction with a thermal 

cycle employing the steam water system as the thermodynamic medium.” The effluent 

guidelines are codified in the Code of Federal Regulations (CFR) at Title 40, Part 423 (40 CFR 

Part 423). EPA’s most recent revisions to the effluent guidelines for this industry sector were 

promulgated in 1982 (see 47 Fed. Reg. 52290; November 19, 1982). 

EPA is required by section 304 of the Clean Water Act (CWA) to periodically 

review all effluent guidelines to determine whether revisions are warranted. EPA first identified 

this industry for study during the 2005 annual review of effluent guidelines. At that time, 

publicly available data reported through the National Pollutant Discharge Elimination System 

(NPDES) permit program and the Toxics Release Inventory (TRI) indicated that this industry 

ranked high in discharges of toxic and nonconventional pollutants1

. Because of these findings, 

EPA studied this industry and concluded that the existing effluent guidelines for water 

discharges from steam electric power plants should be revised. In support of the development of 

revised effluent guidelines, EPA is carrying out an Information Collection Request (ICR), site 

visits and sampling, secondary data review, and modeling. 

EPA is collecting information and data regarding the sources and characteristics 

of wastewater discharges from steam electric power generating operations, including 

wastewaters associated with the following processes and byproducts: flue gas desulfurization 

(FGD), fly ash, bottom ash, flue gas mercury control, combustion residual leachate from landfills 

and surface impoundments, nonchemical metal cleaning wastes, and gasification of fuels such as 

coal and petroleum coke. EPA is also collecting information on the technologies and practices 

available to control the pollutants responsible for the majority of the toxic-weighted loads from 

steam electric power generating facilities. Data sources include both secondary data (e.g., 

literature and publicly available sources of information and data) and primary data collection, 

including plant visits, wastewater sampling, and an ICR sent to selected power generating 

facilities. This plan addresses the primary and secondary data sources, as well as all technical 

analyses that EPA is conducting for this rulemaking. 

As directed by EPA, ERG prepared this detailed Quality Assurance Project Plan 

(QAPP). It is responsive to all applicable elements specified in EPA Requirements for Quality 

Assurance Project Plans (1). This QAPP is a project-specific supplement to ERG’s Quality 

Management Plan for Technical Support for the Strategy for National Clean Water Industrial 

Regulations, June 2002 (QMP) (2a), prepared for Contract 68-C-02-095, as well as ERG’s 

Environmental Engineering Support for Clean Water Regulations Quality Management Plan, 

January 2013 (2b), prepared for Contract EP-C-12-021. Both QMPs were prepared in accordance 

 

1

EPA’s 2005 Annual Screening Level Analysis can be accessed at www.regulations.gov, Document EPA-HQ-OW2004-0032-0901. 
Section No. 1 

Revision No. 4 

Date: April 5, 2013 

Page 2 of 2 

with EPA Requirements for Quality Management Plans (3). ERG’s QMP details the 

responsibilities of the ERG Quality Assurance (QA) coordinators and Project Management Team 

and describes procedures used to plan, implement, and assess project quality. These procedures, 

tailored to the needs of the tasked activities, will be used on ERG’s work assignments associated 

with this program. 

References are presented in Section 6.0. Throughout this document, each time a 

reference is cited, a number corresponding to the Section 6.0 listing is shown in parentheses.
Section No. 2 

Revision No. 4 

Date: April 5, 2013 

Page 1 of 28 

2.0 PROJECT MANAGEMENT ELEMENTS

 This section addresses project management, including project history and 

objectives, roles and responsibilities, and project goals. In addition, this section presents the 

mechanisms ERG is using to ensure that all participants understand the goals and the approaches 

used for the steam electric rulemaking project. 

EPA Requirements for Quality Assurance Project Plans (1) identifies nine 

elements to be discussed in this section. Element A.1, Title and Approval Sheet, and Element 

A.2, Table of Contents, have been provided earlier in this document. The remaining elements are 

presented below. 

2.1 Element A.3: Distribution List

 This QAPP is distributed to the EPA Work Assignment Manager (WAM), Task 

Managers, Project Officer, and QA Coordinator, to all ERG staff providing support on the 

project, and to the laboratories selected to perform analysis of the wastewater samples collected 

as part of the sampling program. The ERG distribution list for the QAPP is company privileged 

and confidential and will be provided to EPA in the final CBI version of the QAPP. 

2.2 Element A.4: Project Organization

 Project Organization for ERG’s support of the Steam Electric Rulemaking is 

depicted in Figure 2-1. The ERG Program Manager is responsible for management and 

administrative aspects of the work performed. The ERG Work Assignment Manager (WAM) is 

responsible for ensuring that the quality of work, schedule, and budget meet the requirements of 

the EPA effluent guidelines program. The ERG WAM provides technical direction to ERG staff, 

is responsible for the daily activities on the project, and obtains appropriate technical review of 

all deliverables. The ERG WAM ensures deliverables conform to EPA’s technical review 

requirements. The ERG WAM is the principal contact for the EPA WAM on project issues, 

deliverables, and schedule. The ERG WAM also keeps the Project QA Coordinator and the 

Project Manager advised of any quality problems that arise. 

 The Project QA Coordinator is responsible for the development and execution of 

QA activities throughout the course of the project, including work plan development and 

execution, data analysis, and data reporting. The Project QA Coordinator also ensures that the 

ERG WAM is obtaining appropriate technical review of all deliverables. The ERG Program 

Manager and WAM provide senior technical support for the rulemaking activities (see Section 

2.3.2) and the ERG project staff support all tasks. 

ERG is supported by two subcontractors, TestAmerica, Inc. and Frontier Global 

Sciences, Inc., to perform the analyses of the wastewater samples collected during the sampling 

program. ERG is responsible for scheduling and tracking analytical samples and reviewing 

analytical data quality for all analyses. ERG reports measures of data quality to the EPA WAM 

via episode-specific data review narratives. ERG is also supported by Avanti Corporation for the 

technical review of the ICR responses. 
Section No. 2 

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Date: April 5, 2013 

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Contract QA 

Coordinator

Project QA 

Coordinator

Technical Reviewers

To be assigned

Program Manager

ERG Work 

Assignment Managers

Project Staff

EPA Work 

Assignment Manager

EAD QA Coordinator Subcontractors

Lines of communication

Reporting and authority

Figure 2-1. Project-Level QA Organization for ERG’s Support for the Steam Electric 

Rulemaking 

 ERG’s subcontractors function within ERG’s quality system, and ERG is 

responsible for the quality of their work. ERG’s subcontractors are responsible for following the 

specifications contained in their subcontracts with ERG. The subcontractors are also responsible 

for following the applicable procedures noted in this QAPP and all instructions and performance 

requirements in the analytical method. The analytical laboratories were provided with a copy of 

this QAPP. For ICR review, Avanti staff worked on site at ERG under direct supervision of the 

ERG WAM. The ERG WAM communicated the QA/QC requirements of the task to the 

subcontractor staff at the start of the work and provided all data review guidelines and QA/QC 

documentation directly to the staff. The ERG WAM is responsible for verifying that the 

subcontractors’ quality-related procedures are adequate and executed. The ERG WAM reviews 

subcontractors’ performance and does not approve the payment of invoices unless subcontractor 

performance meets contract requirements. If ERG identifies any quality issues while working 

with a subcontractor, ERG’s Program and Work Assignment Managers and the subcontractor’s 

Program and Work Assignment Manager’s meet and identify any necessary corrective actions. 
Section No. 2 

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 In conducting the sampling analyses, the subcontractors used for analytical 

laboratory services are responsible for: 

 Following the applicable procedures noted in this QAPP and the 

specifications contained in their subcontracts with ERG; 

 Following their laboratory QA program to ensure all data meet EPA 

requirements; 

 Providing qualified laboratory analysts (i.e., education and bench 

experience with the target analytes); 

 Contacting ERG, as appropriate, when performance criteria or data quality 

objectives are not met so that appropriate corrective actions may be 

implemented; 

 Providing analytical data in the format specified by ERG within the 

prescribed turnaround times; and 

 Providing all other necessary quality assurance/quality control (QA/QC) 

documentation as described in this QAPP and their subcontracts with 

ERG. 

 ERG is responsible for scheduling and tracking the samples analyzed by the 

analytical laboratories, resolving any analytical problems and implementing any necessary 

corrective actions, reviewing analytical data quality, and creating and providing to EPA an 

electronic or hard-copy data package with a written statement of data quality and an electronic 

analytical database suitable for the steam electric rulemaking sampling program. 

In conducting ICR review, Avanti staff are responsible for following ERG’s 

technical review procedures, completing the technical review checklists, and resolving questions 

with ERG staff and ICR respondents. ERG is responsible for ensuring the technical reviews 

completed by Avanti staff are complete and reasonable, communicating any corrective actions to 

them for future reviews, and assisting with resolution of issues with ICR respondents. 

2.3 Element A.5: Problem Definition/Background

 This section explains the purpose of the Steam Electric Effluent Guidelines 

Rulemaking. It also presents a brief overview of the background of the Steam Electric Power 

Generating Point Source Category and a summary of EPA’s review of the existing effluent 

guidelines. 

2.3.1 Background 

 EPA identified the need for detailed study of the Steam Electric Industry in 2005 

during its annual review of discharges from categories with existing regulations. At that time, 

publically available data reported through the National Pollutant Discharge Elimination System 
Section No. 2 

Revision No. 4 

Date: April 5, 2013 

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(NPDES) permit program and the Toxics Release Inventory (TRI) indicated that this industry 

ranked high in discharges of toxic and nonconventional pollutants. From these findings, EPA 

decided to initiate a more detailed study of this category. 

 During the detailed study, EPA performed an in-depth analysis of the reported 

pollutant discharges, and reviewed technology innovation and process changes. Additionally, 

EPA evaluated certain electric power and steam generating activities that are similar to the 

processes regulated for the Steam Electric Power Generating Point Source Category (“steam 

electric”), but that are not currently subject to ELGs. EPA found that the existing data were 

insufficient to fully evaluate the industry’s discharges and the potential for further control of 

those discharges. In order to obtain these missing data, EPA collected information on the 

wastewater characteristics and treatment technologies used at steam electric plants. EPA 

collected information through plant site visits, water sampling, a questionnaire sent to the 

industry, and various secondary data sources.

 

 The information obtained from the site visits, water sampling, questionnaire, and 

secondary data sources suggest that the current effluent limitations guidelines and standards 

(ELGs) do not adequately control pollutant discharges from the Steam Electric Point Source 

Category. EPA concluded that current regulations, which were issued in 1982, have not kept 

pace with changes that have occurred in the electric power industry over the last three decades, 

and should be revised. 

2.3.2 Statement of Key Questions and Project Outcome 

 ERG is supporting EPA in developing an updated industry profile. The steam 

electric rulemaking affects over 1,200 fossil- and nuclear-fueled power plants regulated by the 

current steam electric ELGs. These steam electric power plants are providing a major source of 

information through an ICR, site visits, and sampling episodes. The main focus of the 

information collection is coal-fired facilities, as it was during the detailed study. The results of 

this information may result in the development of industry groupings for the steam electric 

ELGs. 

 The rulemaking activities concentrate on identifying the best technologies 

available for controlling pollutant discharges from the steam electric power industry and 

evaluating the performance, economic achievability, and non-water quality impacts of these 

technologies. EPA is using these evaluations to develop proposed revisions of the current ELGs. 

ERG is providing technical support to EPA in conducting an industry information collection 

program, including a questionnaire and site visit and sampling program. This QAPP addresses 

technical tasks required to ensure these activities produce reliable data that can be used to meet 

the project's overall objectives and goals. These tasks include: 

 Conducting site visits to steam electric power generating plants to evaluate 

process wastewater generation, wastewater characteristics (i.e., flow 

rates/volumes, pollutant concentrations), and the wastewater handling, 

treatment, and pollution prevention/recycle practices of the industry; 
Section No. 2 

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 Conducting wastewater sampling episodes at coal-fired power plants to 

obtain wastewater characterization data and wastewater treatment 

technology performance data; 

 Collecting data from steam electric power plants through a questionnaire 

sent to fossil- and nuclear-fueled power plants regulated by steam electric 

ELGs; 

 Compiling existing information on pollutant discharges, pollutant controls, 

and the costs and benefits of pollutant controls for the steam electric 

industry; 

 Performing analyses of available data to calculate pollutant discharges, 

develop candidate technology options, and estimate costs and pollutant 

reductions of specific options; 

 Using available data to model the potential effects of pollutant reduction 

from specific technology options on water quality, ecosystems, and human 

health; and 

 Preparing documentation of EPA’s rulemaking activities that will support 

the revision of the current steam electric ELGs. 

Primary Objectives/Key Questions 

 The rulemaking addresses all nuclear- and fossil-fueled power plants, but will 

place substantial emphasis on certain discharges from coal-fired power plants. Further, the 

rulemaking concentrates on a subset of plants that are believed to be responsible for a 

disproportionately large share of the toxic-weighted pollutant loading released in wastewater 

discharges from the steam electric power generating industry. EPA’s past study efforts indicate 

that a substantial fraction of the toxic-weighted loadings are associated with wet ash handling 

and wet FGD systems present at coal-fired plants. As such, ERG is supporting EPA with 

collecting information to characterize ash transport wastewater, untreated FGD scrubber purge 

wastewater, and treated FGD wastewater from chemical precipitation, biological treatment, and 

vapor-compression evaporation FGD wastewater treatment systems. ERG is also supporting the 

evaluation of other wastewaters, including those associated with flue gas mercury control, 

combustion residual leachate from landfills and surface impoundments, nonchemical metal 

cleaning wastes, and gasification of fuels such as coal and petroleum coke. 

 ERG is supporting EPA in answering the following key questions: 

1. What are the primary sources of wastewater within steam electric power 

plants? What are the characteristics of the raw wastewaters (i.e., pollutants, 

concentrations, flow rate/volume)? 
Section No. 2 

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2. What pollutants are discharged in the final effluent from steam electric plant 

operations? What pollutant discharges require additional control? That is, 

what are the pollutants of concern? 

3. What are the concentrations and loadings of pollutants currently being 

discharged (i.e., “baseline” concentration) between 2009 and 2010? 

4. What are the best available technologies for pollution prevention and 

wastewater treatment that reduce discharges of pollutants of concern? 

5. How will industry discharges change if plants control pollutants using these 

technologies? 

6. What are the capital and operating costs of the best available 

technologies/practices? Are the costs economically achievable? 

7. What are the non-water quality environmental impacts of the best available 

technologies? 

8. What are the predicted environmental and human health benefits of 

implementing the best available technology options under consideration? 

2.4 Element A.6: Project/Task Description

 This section provides a management level overview of the work performed by 

ERG to support EPA’s revision of the steam electric ELGs, as well as ERG’s approach to 

accomplishing the project objectives and the project schedule. ERG is using existing information 

and data provided by other EPA programs (e.g., OAR, ORD, OSWER); industry groups (e.g., 

UWAG, EPRI); data obtained from existing databases (e.g., ICIS-NPDES, PCS, TRI, U.S. 

DOE’s Energy Information Administration (EIA) database); other existing data sources; new 

information and data collected by EPA for this rulemaking; and existing monitoring data 

collected by plants. The acceptance criteria ERG is using to identify information and data that 

can be used to accomplish the project objectives are detailed in Section 2.5. 

2.4.1 Steam Electric Plant Visits and Sampling 

 Site Visits. ERG is supporting EPA in planning and conducting visits to steam 

electric plants to gather data and information to answer the key questions listed in Section 2.3.2, 

including information about plant operations, process wastewater generation and management 

practices, and wastewater treatment systems. ERG is supporting EPA in identifying plants to 

visit that have some or all of the following characteristics: 

 Use fossil or nuclear fuels; 

 Manage ponds/impoundments and/or landfills for coal combustion 

residue; 

 Operate integrated gasification combined cycle (IGCC) units; 

 Operate combined cycle units; 
Section No. 2 

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 Operate carbon capture technology; 

 Operate or are planning to install wet FGD systems; 

 Operate wet ash handling systems or have installed dry ash handling 

systems; 

 Operate flue gas mercury control systems; and 

 Operate a leachate collection and treatment system. 

 The primary purpose of these site visits is to evaluate candidate best available 

technologies and best available demonstrated control technologies, the changes necessary to 

implement new processes or technologies, and evaluate plants for potential inclusion in EPA’s 

field sampling program. ERG is assisting EPA in using information provided by UWAG, 

responses from the detailed study data request, industry survey data, and information learned 

from contacts with industry representatives to identify site visit candidates. The visits also help 

EPA select plants for sampling and to plan for subsequent sampling activities. ERG is supporting 

EPA in identifying plants for pre-sampling visits that have some or all of the following 

characteristics: 

 Use coal as a fuel source; 

 Operate a wet FGD system, depending on the type and age of the system 

and whether additives are used; 

 Operate a FGD wastewater treatment system, depending on the type and 

age of the system; and 

 Operate NOx controls. 

Facilities may be prioritized for visits based on the use of multiple types of coal, use of a flue gas 

mercury control system, type of boiler, age of boiler and FGD unit, source of lime/limestone 

used in wet FGD system, and plant location. 

 ERG is collecting detailed information from the plants visited, such as the 

operations associated with wastewater generation, in-process treatment and recycling systems, 

end-of-pipe treatment technologies, and, if the plant is a candidate for sampling, the logistics of 

collecting samples. EPA also is collecting information regarding zero discharge options 

associated with the various operations and how the plants could potentially achieve zero 

discharge for some or all of these operations. ERG is collecting information on the coal pile, ash 

handling systems, process equipment cleaning, and air pollution controls (e.g., flue gas 

scrubbers), and the wastewaters generated by these processes. In addition to these internal waste 

streams, ERG is evaluating the wastewater treatment systems with a focus on chemical 

precipitation, biological treatment, and vapor-compression evaporation. Appendix A includes a 

detailed list of questions to guide each plant visit. ERG is using the information collected during 

these plant visits to recommend plants to be sampled and to develop plant-specific sampling 

plans for those plants that will be sampled. ERG also used the information collected during the 

plant visits to develop the questionnaire for steam electric facilities (see below). 

 Wastewater Sampling. ERG is supporting EPA in planning and conducting 

sampling at steam electric plants. In general, EPA used the following criteria to identify the 

plants included in the sampling program: 
Section No. 2 

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 The plant performs steam electric power generation activities 

representative of steam electric power plants (i.e., the plant’s operations 

are typical of operations observed at other power plants, and therefore, are 

representative of more than just itself); 

 The plant uses coal and/or petroleum coke (the wastestreams of interest 

and pollutants of concern are primarily associated with plants using these 

types of fuels); and 

 The plant has the wastestreams or treatment technologies of interest. 

The sampling efforts focus on characterizing wastewaters from plants operating candidate best 

available treatment technologies. Ultimately, EPA plans to use these data to establish effluent 

limitations for FGD waste streams, and potentially other waste streams associated with steam 

electric power plant operations. ERG developed a generic sampling plan based on the sampling 

episodes conducted during the detailed study, which is included as Appendix B of this QAPP. 

 As part of the wastewater sampling program, ERG is subcontracting the analysis 

of the samples to the analytical laboratories. ERG is responsible for ensuring that the laboratories 

analyze the samples using the correct methods as specified in their subcontracts and that they 

following all QA/QC procedures. ERG is also performing the review of the analytical data 

generated by the laboratories. ERG is reviewing all analytical data generated from the sampling 

program, generating data review summaries, and providing them to EPA. 

 Information and data from the plant visits and sampling are documented in site 

visit reports and sampling episode reports (SERs), which are used by EPA and ERG in 

conducting additional technical analyses to investigate best available technologies for reducing 

pollutant discharges, particularly from FGD scrubber purge wastewater. 

2.4.2 Industry Self-Monitoring Program 

 ERG is supporting EPA in planning and implementing an industry selfmonitoring program to collect data from a subset of steam electric power plants. EPA is using 

the industry self-monitoring data to supplement EPA-collected sampling data. This program 

includes the plants selected for the sampling program so EPA can conduct further evaluation of 

the variability associated with the FGD wastewaters and the performance of the treatment 

systems operated. The program also includes data collection for other industry wastewaters, 

including, but not limited to, coal or petroleum coke gasification wastewaters, distillate from 

vapor-compression evaporation systems, and untreated and treated carbon capture wastewater. 

Ultimately, EPA plans to use these data to establish effluent limitations guidelines for the FGD 

waste stream, and the other waste streams included as part of the industry self-monitoring 

program. 

 The plants EPA selects for this program are responsible for obtaining necessary 

supplies, collecting samples, and shipping the samples to the appropriate laboratories for 

analysis. ERG is prepares sample collection and sample shipment instructions for each plant. 

Self-monitoring plants ship their samples to the same laboratories ERG has contracted to analyze 

EPA-collected samples. ERG is responsible for ensuring that the contracted laboratories analyze 

the samples using the correct methods and that they follow all QA/QC procedures. ERG reviews 
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all analytical data generated from the industry self-monitoring program, generates data review 

summaries, and provides them to EPA. 

 As part of this industry self-monitoring program, ERG also supports EPA in 

identifying appropriate field measurements and engineering data that EPA requires each plant to 

provide. ERG is responsible for obtaining the field measurement and engineering data from the 

plants once the program is complete. The field measurement and engineering data are 

documented in the public record and are used by EPA and ERG in conducting additional 

technical analyses to investigate best available technologies for reducing pollutant discharges 

and assessing the variability of the treatment system operations. 

 ERG is supporting EPA in performing on-site audits of self-monitoring plant 

sample collection activities. ERG uses the results of the audits to verify that the plant personnel 

are using the sampling techniques that comply with this project QAPP. 

 

2.4.3 Questionnaire for the Steam Electric Power Generating Effluent Guidelines 

 ERG is supporting EPA in developing, administering, and analyzing results of an 

electronic questionnaire that was sent to steam electric power generating facilities regulated by 

the steam electric ELGs codified at 40 CFR Part 423. The questionnaire consists of nine parts 

(Parts A through I) with the various parts targeting certain types of power plants or power plant 

operations. EPA distributed the questionnaire to all coal- and petroleum coke-fired power plants 

and a statistically sampled subset of the rest of the steam electric industry, including oil-fired, 

gas-fired, and nuclear power plants. ERG assisted EPA in defining the sample frame based on 

publicly available data and data collected during the detailed study and rulemaking. EPA’s 

statistics team selected the sample populations, and ERG developed the questionnaire mailing 

list to be used for distributing the questionnaire. Appendix C includes the final version of the 

Steam Electric Questionnaire. ERG developed mailout and helpline procedures to appropriately 

distribute the questionnaire and data review procedures and guidelines to appropriately handle 

responses, review, and follow-up. ERG compiles the responses into a questionnaire database for 

use in technical analyses to answer key questions presented in Section 2.3.2. 

2.4.4 Candidate Technology Options 

 ERG is supporting EPA by developing candidate technology options. EPA 

evaluates these options to determine which (if any) represent Best Available Technology 

Economically Achievable (BATEA) or best demonstrated technology. Specific options that EPA 

is currently researching for the coal-fired power plants include chemical, biological, and thermal 

treatment technologies. 

 In conducting this task, ERG uses existing data sources, including data from other 

EPA program offices, industry groups, treatment equipment vendors, and other sources identified 

through literature and internet searches. ERG also uses primary data and information collected 

through site visits, sampling, and the questionnaire. 
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2.4.5 Pollutant Discharge Estimates 

 ERG is supporting EPA by developing estimates of wastewater generation and 

pollutant discharge. ERG characterizes sources of wastewater in terms of flow, frequency of 

discharge, the types and amounts of pollutant constituents, and the total pollutant discharge load. 

ERG uses data collected from the questionnaire, site visits, sampling efforts, and secondary data 

to characterize wastewater generation and pollutant loads. ERG also uses existing data sources 

including 2009 PCS, ICIS-NPDES, and TRI discharge data. 

2.4.6 Costs and Pollutant Reductions Estimates 

ERG is supporting EPA by developing a methodology to estimate candidate 

technology costs, pollutant reductions, and non-water quality environmental impacts (such as air 

pollution, solid waste, and energy use). ERG estimates the costs, pollutant reductions, and nonwater quality environmental impacts associated with each candidate technology option. The cost 

estimates consider elements such as equipment, installation, indirect costs (e.g., spare parts, 

engineering, construction, and contractor fees), contingency, and annual costs (e.g., labor, 

maintenance, chemicals, energy, disposal of residuals, monitoring). ERG compares the estimated 

costs to the estimated reductions and provides preliminary summaries of cost per toxic pound 

removed for each option considered. 

 ERG’s estimated technology option costs are used by EPA and its economics 

contractor to evaluate the economic achievability and cost-effectiveness of the regulatory 

options. 

 In conducting this task, ERG uses the existing and primary data sources described 

previously in Section 2.4.4 for the Candidate Technology Options. Refer also to Section 2.4.5 for 

a description of ERG’s activities in estimating pollutant discharges. 

2.4.7 Environmental Assessment Analysis 

 ERG is supporting EPA by developing a methodology to qualitatively and 

quantitatively predict the environmental and human health benefits from estimated pollutant 

reductions under different regulatory options. As part of the environmental assessment analysis, 

ERG is conducting a literature search to collect peer-reviewed journal articles, academic reports, 

and state and federal documents that document and describe environmental impacts caused by 

steam electric discharges. For the quantitative analyses, ERG estimates the changes in water 

quality and wildlife impacts associated with baseline conditions and each regulatory option using 

environmental models. The water quality analysis considers elements such as type of receiving 

water, predicted receiving water flow or volume, plant-specific total pollutant loads and 

discharge flows entering a given water body to estimate receiving water concentrations. The 

wildlife impacts analysis uses estimated water body concentrations, bioaccumulation factors, and 

reference species to predict fish and wildlife tissue concentrations. ERG compares the estimated 

water body concentration values and wildlife tissue concentrations to known environmental 

threshold values (e.g., national recommended water quality criteria, drinking water standards, 

and fish consumption advisory levels) to determine the number of water body exceedances under 

baseline and regulatory options. 
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 ERG’s estimated changes in environmental threshold exceedances are used by 

EPA and its economics contractor to evaluate the environmental benefits from changes in 

discharged pollutant loads under different regulatory options. 

 In conducting this task, ERG uses primary data and information collected through 

the site visits, sampling, and the questionnaire, as well as the data previously described in 

Section 2.4.6. In addition, ERG uses secondary data collected from peer-reviewed journals, 

academic, state, and federal sources. 

2.5 Element A.7: Quality Objectives and Acceptance Criteria

 This QAPP is intended to ensure that data collected for the Steam Electric 

Rulemaking are of the quality necessary to support EPA in revising the existing ELGs for this 

category. The main sources of data for the rulemaking are EPA/ERG sampling and analysis, 

monitoring data collected by the industry, the industry questionnaire, and secondary data. 

 ERG is evaluating the quality of collected data using the criteria described below. 

Final reports to EPA include the results of this evaluation. Factors ERG considers in reviewing 

data quality include completeness, sensitivity, representativeness, precision, sample 

contamination, accuracy, and comparability. 

 All project deliverables will meet EPA’s standards of transparency, objectivity, 

integrity, and utility as specified in EPA’s Guidelines for Ensuring and Maximizing the Quality, 

Objectivity, Utility, and Integrity of Information Disseminated by the Environmental Protection 

Agency, EPA/260R-02-008, October 2002 (4). This is accomplished by preparing documentation 

for the work presented in deliverables that identifies the sources of data, assumptions made, and 

calculations used in their development with sufficient detail that the work can be reproduced by 

qualified third parties. 

2.5.1 Field Sampling Data 

 ERG is supporting EPA in designing sample plans, collecting samples, shipping 

samples to the laboratories, and analyzing the samples. ERG is collecting engineering data 

during the sampling episodes to characterize production and flow during sample collection. ERG 

reviews these data for completeness (i.e., that data are collected for each day and each sample 

point) and comparability (i.e., that data compare to production and flow data reported in the 

plant’s questionnaire and other plant-specific documentation). ERG also supports EPA in 

designing the industry self-monitoring program, ensuring the samples are collected properly, 

shipped to the laboratories, arrive at the laboratories on time and in good condition, and are 

analyzed. ERG also ensures that the plants provide engineering data associated with the industry 

self-monitoring program. ERG reviews these engineering data for completeness and 

comparability. 

 ERG subcontracts the analysis of the EPA- and industry-collected samples to 

analytical laboratories. To be considered for use under this project, participating laboratories 

must have an acceptable QA program in place to ensure that all data meet EPA requirements. 
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The laboratory’s standard operating procedures (SOPs) must ensure that method performance 

meets or exceeds the requirements specified in the analytical method and in the subcontract with 

ERG. The following are the QA/QC requirements that the laboratories must follow during the 

sampling program: 

 The laboratory must have a comprehensive laboratory QA program in 

place and operating at all times during the performance of tasks supporting 

this study. The laboratory must adhere closely to all QA/QC requirements 

in this QAPP, which is in conformance with EPA Requirements for 

Quality Assurance Project Plans2

. The laboratory may perform additional 

QC to assure the validity and reliability of results and a description of any 

additional QC must be provided in the data package submitted to ERG. 

 The laboratory must have a comprehensive data management plan that is 

consistent with the principles set forth in EPA 2185 – Good Automated 

Laboratory Practices, EPA Office of Administration and Resources 

Management, August 10, 1995. This data management plan must be in 

place and in use at all times during the performance of tasks for this 

project. 

 The laboratory must maintain internal records in an organized manner to 

document adherence to the ERG subcontract, and these records must be 

available for review upon request. 

 The laboratory must perform all necessary QA/QC requirements specified 

in the analytical methods (or the SOP developed by EPA for EPA Method 

200.8 in conjunction with collision cell). 

 The laboratory shall perform method detection limit (MDL) studies for all 

analytes based on the analytical method that will be used for the sampling 

program. The procedures and calculations for performing the MDL studies 

are specified in 40 CFR Part 136, Appendix B. Subsequently, the 

laboratory must also determine a quantitation limit (QL) for all analytes. 

For laboratories that are analyzing metals, the laboratory must perform the 

MDL study using a synthetic FGD matrix specified by the SOP developed 

by EPA for EPA Method 200.8 in conjunction with a collision cell. For 

laboratories that are analyzing the classical analytes, the laboratory may 

provide historical MDL and quantitation limit data generated by the 

methods to be used if they are less than one year old; however, the 

laboratory must additionally perform a matrix spike and matrix spike 

duplicate (MS/MSD) analysis on the synthetic FGD matrix with a spiking 

level of five times the MDL for the target analytes. 

 

2

EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5, U.S. Environmental Protection Agency, 

Quality Staff, March 2001 (Reissued May 2006). 
Section No. 2 

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 The laboratory must perform the MS/MSD analyses on the samples 

specified by EPA and EPA samples must be run in the same batch as the 

EPA MS/MSD samples. Additionally, the laboratory must spike the 

samples within the spiking range specified by the analytical method or 

SOP. If a MS or MSD fails to meet the method specified criteria, the 

laboratory must communicate the failure to ERG and work on resolving 

the issue (e.g., attempt to rerun the analysis with a higher dilution). If the 

MS or MSD analysis cannot be met using procedures described in the 

method (e.g., dilutions), then the laboratory must perform a post digestion 

spike on the parent sample after digestion to verify that the MS/MSD 

failure is due to matrix interferences. 

 For samples that require dilutions to reduce the TDS concentration to less 

than 0.2%, the laboratory must dilute the sample to a TDS concentration in 

the range of 0.15 and 0.2% to prevent over-diluting the sample. 

 Section 3.1.5 describes the sampling and analysis quality control measures for this 

program. In general, data quality issues are identified and corrected via frequent communications 

with the analytical laboratories. In cases where a quality control failure is not the result of matrix 

failures or other sample-specific analytical issues, ERG requires the laboratories to reanalyze the 

sample where appropriate. As a result of these measures, analytical data are typically excluded 

only in cases of grossly deficient quality control data (e.g., laboratory documentation is 

inadequate to evaluate quality control measures, or quality control sample results differ 

significantly from method requirements). 

 Following the laboratory’s determination that the method QC specifications have 

been met, ERG reviews the laboratory results, documents the findings of the quality control 

review in data review narratives, and describes the limitations of the data, if any. Prior to use in 

the SER and technical analyses, ERG reviews the results of chemical analyses of the wastewater 

samples for completeness, comparability, precision, accuracy, and sensitivity as described below. 

 The analytical laboratories deliver electronic data packages consisting of 

Microsoft® Excel spreadsheets containing the analytical results and documentation packages 

consisting of traffic reports and sample receipt information, laboratory analysis sheets and 

checklists, instrument data, and analyte chromatograms, where applicable. ERG developed 

method-specific checklists that are used to review, verify, and validate the chemical analysis 

results and the supporting documentation provided by the laboratory. Appendix D contains the 

method-specific checklists developed by ERG. The checklists provide the method-specific QC 

objectives for each parameter in the review (e.g., acceptable instrument signal to noise ratio, use 

of correct spiking concentration, acceptable recovery ranges). Each checklist contains the 

following standard sections listing the detailed criteria ERG uses to verify and validate the 

results of chemical analyses: 

 General Review of Sample Identity and Handling – ERG verifies sample 

identity and traceability. ERG confirms that all data required for the data 

review, verification, and validation are contained in the laboratory data 
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package and reviews information in the data package to verify that the 

laboratory identified and handled samples properly; 

 Review of General QC Requirements – ERG evaluates the common QC 

requirements in all methods which include sample preparation and 

extraction procedures; and 

 Detailed Review of Method-Specific Parameters – ERG performs methodspecific QC validation which includes reviewing the primary instrument 

calibrations and performance evaluation samples. 

 ERG includes the completed checklists in the final analytical data review, 

verification, and validation package, which are provided to EPA. ERG also provides a data 

review narrative that summarizes the results documented in the checklist for each group of 

compounds analyzed. The data review narratives are included in the public docket for the steam 

electric rulemaking. 

 ERG reviews the data against the specifications listed in Table 2-1 and reports the 

results to EPA. EPA considers the completeness, sensitivity, representativeness, precision, 

sample contamination, accuracy, and comparability of the EPA sampling data in determining 

their use in the rulemaking. The methods by which these factors are measured are described 

further in the sections below. 

Table 2-1. Sampling Data Quality Review Criteria 

Data Quality 

Review Criterion: 

Sampling Description/Definition

Sampling Techniques to 

Control this Quality 

Criterion 

How this Quality 

Criterion will be 

Measured 

Goal for this 

Measurement 

Completeness The degree to which the 

planned sampling 

program yields usable 

results 

 Use method-specified 

preservation and type of 

bottles 

 Shipping – meets hold 

time 

 Packing/shipping – no 

breakage 

 Sample collection – no 

breakage or missed 

samples 

 Sample collection, 

shipping and storage – 

meets method-specified 

temperature 

requirements 

% of planned 

samples for which 

lab provides usable 

results 

100% complete 

Sensitivity Degree to which a signal 

(measurement) can be 

distinguished from 

background 

Collect method-specified 

volume (insufficient 

volume can result in high 

detection limits) 

Laboratory reported 

detection limits 

Meet method 

specifications 
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Table 2-1. Sampling Data Quality Review Criteria 

Data Quality 

Review Criterion: 

Sampling Description/Definition

Sampling Techniques to 

Control this Quality 

Criterion 

How this Quality 

Criterion will be 

Measured 

Goal for this 

Measurement 

Precision 

(reproducibility) 

Degree to which 

repeated measurements 

give the same results 

Use standard operating 

procedures 

Collect duplicates of 

not less than 10% of 

study samples and 

calculate relative 

percent difference 

(RPD) 

All duplicates 

have a RPD ≤

20% 

Representativeness The degree to which the 

sample has the same 

properties as the 

population as a whole 

 Select appropriate 

sampling point 

 Use appropriate sample 

techniques 

Can’t measure 

directly. Poor 

comparison of 

duplicates will 

indicate if samples 

may not be 

representative 

All duplicates 

have a RPD ≤

20% 

Sample 

Contamination 

Difference between the 

measured value and the 

true value 

Techniques to control 

contamination: 

 New sample tubing at 

each sampling point 

 Use of clean gloves at 

each sampling point 

 Conformance to clean 

hands/dirty hands 

collection methods, 

where necessary 

Blank samples 

(equipment blanks, 

trip blanks, lab 

blanks) will be used 

to measure 

contamination 

No target 

analytes 

detectable (i.e., 

above the 

detection limit) 

Accuracy How close the measured 

value is to the true value

Results can be inaccurate 

if the target analyte is lost 

or degraded during sample 

collection and handling. 

Techniques to control loss 

of sample: 

 Use method-specified 

sample containers, hold 

times, sample collection 

procedures 

 Use method-specified 

preservation, including 

chilling samples as 

required during 

shipment and storage 

Accuracy can’t be 

measured directly. 

Lab spike recovery 

will provide some 

insight 

Recovery of all 

compounds 

(native and 

labeled) in lab 

spike within 

methodspecified QC 

limits 
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Table 2-1. Sampling Data Quality Review Criteria 

Data Quality 

Review Criterion: 

Sampling Description/Definition

Sampling Techniques to 

Control this Quality 

Criterion 

How this Quality 

Criterion will be 

Measured 

Goal for this 

Measurement 

Comparability High comparability 

means that the data can 

be combined for 

decision making 

purposes 

 Use standard analytical 

methods, conducted 

using standard 

procedures. 

 Use standard criteria for 

selecting sampling 

points and collecting 

samples 

Compare analytical 

methods and the 

detection limits they 

achieve 

Analytical 

methods are 

approved 

methods with 

MDLs that are 

sufficient for 

expected 

pollutant 

concentrations 

and matrix 

Sampling points 

are equivalent 

 

Completeness 

 Completeness is defined in terms of the percentage of data planned to be collected 

that are 1) collected and 2) for which the laboratory provides results that meet method QC 

specifications or are otherwise determined acceptable for use. Completeness is assessed in three 

different areas and is defined as follows: 

 Sampling completeness is the number of valid samples collected relative 

to the number of samples planned for collection; 

 Analytical completeness is the number of valid sample measurements 

relative to the number of valid samples collected; and 

 Overall completeness is the number of valid samples measurements 

relative to the number of samples planned for collection. 

ERG assesses the sampling, analytical, and overall completeness for the program. 

ERG documents sampling completeness in the SERs. 

Sensitivity 

 Sensitivity is the degree to which a measurement can be distinguished from 

background and is measured by the sample detection limit. ERG reports the sample detection 

limits, relative to method detection limits, in its SERs. 
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Precision 

 Precision is a measure of the agreement among repeated measurements. To 

evaluate precision, the laboratories calculate the relative percent difference (RPD) among the 

results from one or more types of “duplicate” analyses using the following equation. 

 

100

2 S D

1

S- D

RPD 



 

where: 

S = First sample result; and 

D = Duplicate sample result. 

 Laboratories often use matrix spike (MS)/matrix spike duplicate (MSD) samples 

to evaluate both precision and accuracy. The precision of the analytical procedure is assessed by 

calculating the RPD between the results of the MS and MSD samples. ERG evaluates the RPD 

and documents this evaluation in the data review narratives. 

 The analysis of field duplicate samples provides data to measure the precision of 

the entire sample collection, handling, preparation, and analysis process. EPA anticipates 

collecting one field duplicate sample for every 10 samples collected at a site. The results of the 

RPD analysis and the context are examined to determine the precision of the data. 

 

Representativeness 

 Representativeness is the degree to which the sample has the same properties as 

the population as a whole. Representativeness cannot be measured directly; however, ERG 

evaluates the field duplicate results to indicate if the samples are representative of the sampled 

material. If the RPD between the original sample and the duplicate are outside the methodspecified criteria, then the samples may not be representative of the wastewater samples. ERG 

evaluates the RPD and documents this evaluation in the data review narratives. ERG controlled 

the representativeness of the samples by choosing appropriate sampling points for each waste 

stream and using appropriate analytical methods. 

Sample Contamination 

 Sample contamination causes a difference between the measured value and the 

true value. Blank samples (e.g., equipment blanks and laboratory blanks) are collected and 

analyzed to estimate if there is sample contamination. For this program, the goal is that no target 

analytes are detected in blanks. The impact of any detected contamination on interpretation of 

sample measurements is determined on a sample-by-sample basis and discussed in the data 

review narratives and in ERG’s SERs. 
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Accuracy 

 Accuracy is a measure of the agreement between a measured value and a 

reference of “true” value. Because the “true” concentration of an analyte in a field sample is 

never known, spiked samples (e.g., a matrix spike (MS)) are used to evaluate accuracy. 

Laboratories prepare an MS by adding known amounts of the compounds of interest to the field 

sample. The spiked samples receive the same handling, extraction, cleanup, and analysis steps as 

the field samples. The laboratories then perform a percent recovery (%R) calculation to 

determine their accuracy: 

100

SA

(SSR SR) %R   

where: 

SSR = Spiked sample result; 

SR = Sample result; and 

SA = Spike added. 

 The successful evaluation of accuracy hinges on the choice of spiking 

concentration. To determine the appropriate spiking concentration for the MS sample, the 

laboratory must first analyze the original sample. In general, the spiking concentration must be at 

least twice the concentration of the analyte present in the original sample, and ideally, should be 

no more than 10 times that concentration. 

 The QC limits for the recovery of spiked analytes for most of the analytical 

methods used in the sampling program serves as the data quality objectives for this project. 

These limits are based primarily on method validation studies using treated effluents from 

wastewater treatment plants. If the method does not specify percent recovery, it should be 

between 50 and 150 percent. This is not intended to be a required precision, but to be a target. 

The results of the percent recovery analysis and the context are examined to determine the 

accuracy of the data. If recoveries are outside the method-specified range requirements, the 

laboratory must try to identify the interferences and notify ERG. MS failures are handled on a 

case-by-case basis. When an MS failure is due to a matrix problem, the sample is diluted and 

reanalyzed. If the MS analysis cannot meet the method-specified range requirements using 

procedures described in the method (e.g., dilutions), ERG requires the laboratory to perform a 

post digestion spike on the parent sample after digestion to verify that the MS/MSD failure is due 

to matrix interferences. 

 The percent recovery is evaluated during the laboratory data review. The results 

of this evaluation are documented in the data review narratives. 

Comparability 

 Comparability is a qualitative measure of the confidence with which data sets can 

be compared. This project achieves data comparability by following approved, standard 

analytical procedures and by reporting the results in the standard units of measure required in the 
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methods (analytes measured, procedures used, and detection limits achieved). In addition, the 

equivalence of sampling locations and operating characteristics are evaluated. 

 ERG reviews the data generated from the EPA sampling program and the data 

generated from the industry self-monitoring program to evaluate the comparability of the data for 

each sampling point over the course of the sample collection time period. 

2.5.2 Data Collected through the Questionnaire for the Steam Electric Power 

Generating Effluent Guidelines 

 This task involves the collection and use of data gathered via a questionnaire sent 

to steam electric power generating facilities. ERG is assisting EPA in the review of all submitted 

questionnaires. ERG developed the Data Review Guidelines (see Appendix E) to review 

questionnaires using several methods to improve completeness, consistency, and reasonableness 

of questionnaire responses, as described in Section 3.3.4. ERG developed the completeness 

checklist (see Appendix F) to assess the percentage of the questionnaires returned that included 

all applicable parts and attachments. ERG also assesses the accuracy and comparability of the 

survey data by conducting a question-by-question engineering review of all survey responses 

using the technical checklists (see Appendix E) that define the data acceptance criteria. ERG 

updated the checklists periodically as the questionnaire review process proceeded to reflect 

known areas where respondents had difficulty completing the questionnaire. 

 The criteria ERG uses to evaluate the quality of the data collected in the 

questionnaire are presented in Table 2-2, along with acceptable values for each criterion. ERG 

follows the procedures outlined in the data review guidelines, further discussed in Section 3.3.4, 

for any questionnaire responses that do not meet the following acceptance criteria. 

Table 2-2. Steam Electric Questionnaire Data Acceptance Criteria 

Acceptance Criterion: 

Questionnaire Data Description/Definition Specification 

Unambiguous For an individual response, can the 

response to the question be 

interpreted without confusion? 

Units of measure are identified. 

Responses to open-ended questions are clear. The 

question was interpreted consistently by multiple 

respondents. 

Internal consistency For an individual response, are the 

answers to one question consistent 

with answers to other questions? 

Responses follow questionnaire skip patterns. 

Responses to multiple questions asking for similar 

or related information are comparable. 

Completeness For a plant’s response, were all 

questions answered? For each 

question, was it answered by all 

respondents? 

A plant’s response must include answers to the 

majority of the questions. 

Each question must be answered by all respondents 

to which it applies. 
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Table 2-2. Steam Electric Questionnaire Data Acceptance Criteria 

Acceptance Criterion: 

Questionnaire Data Description/Definition Specification 

Reasonableness For an individual response, are 

reported values consistent with 

operating procedures at steam 

electric power plants? 

A plant’s response will be checked against logical 

responses provided in the data review checklist. 

ERG will follow up with any plant whose responses 

appear to be outliers. For example, ERG will follow 

up on any plant’s response for scrubber purge flow 

rate that falls outside the typical range in the data 

review checklist. 

Representativeness Did EPA receive sufficient 

response to the questionnaire to 

reflect the population of steam 

electric power plants? 

EPA’s goal is to receive at least 90% response rate 

in each sample frame. EPA’s statistical support will 

determine if the number of responses received 

represent each sample frame. 

Comparability Is the information provided in 

response to the questionnaire 

consistent with facility 

descriptions available from EIA, 

detailed study, and site visit data? 

Are unit operations reported the same as data 

collected in the study, and are questionnaire 

reported scrubber and discharge flows not more 

than 50% different to the information provided in 

EIA or other available data. 

 EPA expects 100 percent completeness of returned questionnaire responses, 

because the questionnaire is conducted under authority of section 308 of the Clean Water Act 

(Federal Water Pollution Control Act, 33 U.S.C. Section 1318) and response is mandatory. ERG 

determines completeness by tracking when, and how many, questionnaire responses are reported 

in the Steam Electric Tracking Database. In addition, ERG reports to EPA any instances of 

completeness less than 100 percent and follows up with respondents to ensure responses by all 

plants. ERG also documents any respondents who are not required to complete the questionnaire 

due to their current operating conditions. 

2.5.3 Pollution Control Technology Costs 

ERG will collect information about the costs for steam electric power plants to 

install and operate wastewater pollution control technologies, including transportation and 

disposal costs. In addition to information reported in the Questionnaire for the Steam Electric 

Power Generating Effluent Guidelines, ERG will obtain current (e.g., 2000 - 2010) cost 

information from FGD wastewater treatment and ash handling vendors. 

The criteria ERG will use to evaluate the quality of pollution control technology 

cost information are summarized in Table 2-3 along with acceptable values for each criterion. 

ERG will only use sources that meet these criteria will to develop or evaluate control options. 
Section No. 2 

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Table 2-3. Pollution Control Technology Cost Data Acceptance Criteria 

Acceptance Criterion: 

Cost Data Description/Definition Specification 

Currency (up to date) Does the information reflect 

current systems? 

Costs are current (e.g., 2000 – 2010). 

Technology Does the information reported 

reflect an area relevant to the 

study? 

Costs reflect systems that serve as the technology basis 

for steam electric regulatory options. 

Accuracy/Reliability Is the information reported 

true? 

Obtained from a vendor who does business with steam 

electric power plants. 

Comparability Are the costs comparable to 

costs provided by sources that 

meet these acceptance 

criteria? 

Comparable to other sources, such as the Steam Electric 

Questionnaire. 

2.5.4 Pollution Control Technology Cost Estimates 

ERG will use primary and secondary data to estimate costs for the affected steam 

electric power plants to manage and dispose of their wastes. The criteria that ERG will use to 

determine if the estimated costs are of the quality needed to support EPA’s rulemaking are 

summarized in Table 2-4, along with acceptable values for each criterion. 

Table 2-4. Cost Estimate Quality Specifications 

Acceptance Criterion: 

Cost Estimates Specification 

Meet requirements for 

economic analysis 

 Include one-time costs for equipment purchase and installation. 

 Include one-time costs for treatability and optimization studies, as appropriate. 

 Include on-going operating and maintenance costs (annual costs). 

 Include periodic operating and maintenance costs, as appropriate. 

Appropriate for actual plant 

locations 

 Equipment costs, including transportation and installation, reflect the costs for 

supplies and labor at steam electric power plant locations. 

 Operating costs (electricity, diesel fuel, labor, chemicals, etc.) reflect the costs at 

steam electric power plant locations. 

Unit costs are on specified, 

standard year basis 

 Input costs escalated to 2010, using RS Means Construction Index or other 

standard cost index. 

Complete  Include costs for all elements necessary to implement the waste management 

option. 

Accurate (model input)  Model inputs reflect design assumptions agreed on with project team. 

 Model inputs reflect baseline conditions at each facility. 

Accurate (calculations)  Model calculations are correct. 

 Unit conversions are correct. 

Reasonable  Order-of-magnitude of costs is comparable to costs for similar installations at 

similar plants. 

 Cost trends follow the design basis trends (i.e., costs for large plants are greater 

than the costs for small plants). 
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2.5.5 Secondary Data 

 This section presents how ERG evaluates the secondary data collected for this 

project and the criteria used to determine the acceptability of these data. Acceptance criteria and 

required quality depends on use. Secondary data may be used for the following analyses: 

 Industry profile; 

 Characterization of in-process waste; 

 Characterization of wastewater treatment system performance/efficiency; 

 Estimation of baseline pollutant discharges; 

 Estimation of cost of treatment; and 

 Environmental assessment analysis. 

2.5.5.1 Secondary Data Used for Industry Profile, Characterization of In-Process 

Waste and Wastewater Treatment System Performance; and Estimation of 

Baseline Pollutant Discharges and Treatment Costs 

Table 2-5, located at the end of this section, lists the secondary data acceptance 

criteria by type of use in relationship to the type of data. Secondary data sources reviewed 

include monitoring data, other monitoring data (e.g., 308 Letter), articles and technical papers, 

industry/vendor telephone query data, and internet information. Table 2-5 provides the specific 

circumstances that define when data meets acceptance criteria or when data are unusable. 

 When secondary data are received, ERG uses the criteria in Table 2-5 to identify 

if the data are usable. In addition to the criteria listed in Table 2-5, ERG evaluates the 

reasonableness of secondary data. For example, pollutant identities must be reasonably related to 

the process or waste stream from which they were discharged. ERG may flag data sets as 

questionable and subject to further investigation if a chemical is detected that is not expected in 

the waste stream or if an expected chemical is missing. ERG communicates to the EPA WAM 

whether reported or calculated pollutant loads, plant wastewater flows, or other secondary data 

reflect the range of expected values for specific steam electric power plants within the steam 

electric industry. In addition, if the data provided by a data source are repeatedly found to be 

unreasonable, ERG communicates these quality issues to EPA and waits for further direction 

from the EPA WAM. 

 ERG does not review the quality of existing data contained in EPA databases 

(e.g., PCS, TRI, ICIS-NPDES) or other databases provided by federal or state agencies or trade 

organizations (e.g., UWAG, EPRI) . In this case, because the data have been certified by the 

facility, EPA assumes it is of acceptable quality unless EPA has information clearly 

demonstrating the data are not of acceptable quality. In such cases, ERG will document these 

known limitations. If ERG identifies limitations in the quality of the data from published 

literature or federal/state generated databases that may impact decisions regarding the overall 

direction of further data collection efforts or the quality of deliverables, ERG communicates 

these issues to the EPA WAM. Data limitation discussions identify where data gaps exist (e.g., in 

PCS, major facilities are required to submit data, but PCS data may not represent all facilities in 

a given geographic region because minor dischargers often are not included) and a description of 

data reporting requirements (e.g., TRI does not require facilities to sample and analyze waste 
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streams to determine the quantities of toxic chemicals released, so the data included in TRI may 

be estimates of releases based on mass balance calculations, published emission factors, sitespecific emission factors, or other approaches). 

2.5.5.2 Secondary Data Used for Environmental Assessment Analysis 

 In addition to the analyses listed in Table 2-5, ERG uses secondary data to 

support qualitative and quantitative assessments (e.g., environmental modeling to predict 

receiving water concentrations and fish and wildlife tissue concentrations) of the impact of steam 

electric discharges on the environment. 

Qualitative Analyses. 

Qualitative impact analyses rely primarily on secondary data collected as part of a 

literature review to support the environmental assessment analysis. The criteria that ERG uses to 

evaluate the quality of literature sources used for qualitative analyses are 1) accuracy, 2) 

reliability, and 3) representativeness. 

Accuracy. ERG assumes that the underlying data and information contained in 

state and federal reports and peer-reviewed journal articles are accurate. ERG assumes that data 

from these sources are of sufficient quality to identify potential environmental impacts associated 

with steam electric discharges. ERG presents data that are outliers (e.g., data that are not 

consistent with the body of information collected from the literature review) to EPA for further 

direction on how to incorporate or exclude the data in the analysis. 

Reliability. During the course of the literature search, ERG may encounter sources 

that contain limited documentation of the environmental impact claim (e.g., unidentified speaker 

at a stakeholder meeting or a local resident commenting in a newspaper article). These data 

sources represent a lower level of reliability than peer-reviewed literature, but may provide 

useful information for capturing the full range of environmental impacts associated with steam 

electric discharges. If ERG identifies limitations in the quality of information taken from other 

secondary data sources (e.g., web sites, newspapers, and stakeholder meetings), ERG 

communicates these data quality issues to EPA. ERG also evaluates secondary data for use in 

qualitative analyses for reliability based on the following factors: 

 The scientific work is clearly written, so that all assumptions and 

methodologies can be identified; 

 The variability and uncertainty (quantitative and qualitative) in the 

information or in the procedures, measures, methods, or models are 

evaluated and characterized; and 

 The assumptions and methodologies are consistently applied throughout 

the analysis as reported in the source. 

Representativeness. ERG evaluates secondary data for use in qualitative analyses 

for representativeness based on whether they represent: 
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1) The types of environmental impacts caused by wastewater discharges 

from steam electric power plants. 

2) The range of concentrations observed in steam electric discharges. 

3) The environments affected by steam electric discharges. (e.g., rivers, 

lakes, and wetlands). 

Information on environmental impacts in all environments may not be readily available in the 

published literature. When a subpopulation is selected for analysis (e.g., lakes and reservoirs), 

ERG clearly describes the subpopulation and resulting limitations of the analysis to EPA. 

Quantitative Assessments. 

ERG may also use secondary data to support quantitative assessments of the 

environmental impacts of steam electric discharges through the use of environmental models. 

ERG limits national-scale modeling analyses to screening-level steady state water quality and 

wildlife assessment models. The screening-level water quality model estimates receiving water 

concentrations within the immediate vicinity of steam electric discharge points on an average 

annual basis. The wildlife assessment model estimates pollutant concentrations in fish tissue 

exposed to steam electric wastewater discharges within the immediate vicinity of the discharge 

point and downstream. This model also assesses the impacts to aquatic organisms from contact 

with sediment contaminated by the evaluated waste streams and impacts to piscivorous wildlife 

(i.e., wildlife that habitually feeds on fish) from consuming fish impacted by the evaluated waste 

streams. 

Both the water quality and wildlife models focus on simulating the movement of 

bioaccumulative metals (i.e., mercury, selenium, arsenic) through the environment. Input values 

for the environmental models include: 

 Pollutant loadings from steam electric waste streams of interest; 

 Discharge flow from steam electric power plants; 

 Average annual receiving water stream flow; 

 Partition coefficients for metals of interest; 

 Bioaccumulation factors for metals of interest for different trophic levels 

of fish; 

 Average weight for wildlife species of interest; 

 Average water ingestion rate for wildlife species of interest; and 

 Food ingestion rate of prey in each fish trophic level for wildlife species of 

interest. 

ERG obtains input values and parameterizes the environmental models based on 

data from secondary data sources including: 

 Peer-reviewed literature; 

 Government documents; 

 Academic reports; 
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 Publically available geographic information system (GIS) data sets from 

government organizations (e.g., NHD Plus); and 

 Databases provided by federal or state agencies (e.g., USGS stream 

monitoring data). 

ERG does not review the quality of existing data contained in government GIS 

systems or databases, but describes known limitations of the data in reports on which they are 

based. If ERG identifies limitations in the quality of the data from published literature or 

federal/state generated GIS or databases that may impact model predictions, ERG communicates 

these issues to the EPA WAM. In addition to the quality criteria described for the qualitative 

environmental assessment analyses, ERG also uses the following acceptance criteria to evaluate 

use of secondary data for environmental modeling analyses: 

 The data are from a peer-reviewed, government, or academic source; 

 The geographical area of which the data are collected are representative of 

the goal of the modeling analysis; 

 The exposure scenarios and concentrations are either directly from coalfired power plants or are representative of the types of waste streams 

under consideration for the steam electric effluent guideline rulemaking; 

 The data sets are representative and reflect the ecological or human 

population of interest; 

 The scientific and technical procedures, measures, methods, or models 

employed to generate the information are well documented and reasonable 

for, and consistent with, the intended application within the environmental 

model; and 

 The data are comparable to other sources. 

2.6 Element A.8: Special Training/Certification

 Confidential Business Information. Information and data collected through EPA 

site visit, sampling, and questionnaire activities may be claimed as CBI by the steam electric 

facilities. Therefore, project staff are trained in CBI handling procedures as outlined in ERG’s 

CBI security plan entitled Security Plan for Handling Confidential Business Information Under 

the Clean Water Act, dated September 25, 2008 and approved by Ahmar Siddiqui, EPA’s 

Document Control Officer for this contract, on March 12, 2009 (5a), and its successor dated 

November 9, 2012 and approved January 9, 2013 (5b). Only staff demonstrating their 

understanding of CBI handling procedures by passing a written test are permitted to access CBI 

on this project. 

 Sample Collection Training. All ERG staff supporting the steam electric sampling 

program are trained in general wastewater sample collection techniques and ERG’s standard 
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operating procedures (SOPs) for sampling (6, 7, 8). ERG staff attend internal sampling training 

to review sample preparation, collection, and packaging procedures, where staff attendance is 

documented by the ERG Program Manager. Sampling crew chiefs attend additional training in 

crew chief responsibilities. ERG also trains staff supporting the steam electric sampling program 

in the clean hands/dirty hands sample collection techniques (9) for low-level metals analyses 

(total and dissolved metals). All sampling staff receive any required on-site training by the site. 

 Health and Safety Training. ERG determines if additional health and safety 

training is required for ERG steam electric sampling staff after sites have been selected and 

sampling and safety considerations have been discussed with the site. All ERG sampling staff 

who support the steam electric sampling program receive annual health and safety training, 

documented by the ERG Chantilly office health and safety coordinator. 

2.7 Element A.9: Documents and Records

 ERG has developed and instituted document control mechanisms for the review, 

revision, and distribution of QAPPs. Each QAPP has a signed approval form, title page, table of 

contents, and EPA-approved document control format (shown below) that appears in the upper 

right-hand corner of each page: 

Section No. 

Revision No. 

Date 

 During the course of the project, any revision to the QAPP is circulated to the 

project distribution list. 

 Standard controls for project-related data, documents, and records are presented in 

Section 5 of ERG’s 2002 and 2013 QMPs (2a, 2b). ERG’s WAM is responsible for designating 

an individual to maintain all project files. S/he is also responsible for ensuring that project team 

members use ERG SOPs, including documenting all data sources used. All engineering 

information collected, generated, and analyzed on the project is handled and stored in a 

centralized record, as described in the Steam Electric Power Generating Project File 

Management Plan, dated September 25, 2009 (10). This centralized record contains all data 

collected or accessed from other sources, and documents analyses of data collected (e.g., site 

visit reports, memoranda, industry profiles). The contents of the record are indexed using a MS 

AccessTM database. 

 Management of project data is specifically described in Element B.10, Data 

Management (Sections 3.1.10, 3.3.6, and 3.4.2) of this QAPP. 
Table 2-5. Secondary Data Acceptance Criteria 

Type of Data Data Not Usable 

Data Usable 

for Profile 

Data Usable to 

Characterize InProcess Waste 

Data Usable to 

Demonstrate System 

Performance/ 

Efficiency 

Data Usable to 

Estimate Baseline 

Discharges 

Monitoring Data (e.g., NPDES permit, DMRs) 

(1) The plant has since changed operations (e.g., installed a new treatment system) since the data were collected. (2) Data collected during upset conditions. 

Waste stream identified and analytes identified. 

Waste stream identified and analytes, units, and detection limits identified. 

(1) Represent full-scale system operated at applicable steam electric power plant. (2) Influent and effluent data or percent removal identified. (3) Analytes identified and units included. 

Identified as discharge, analytes identified and units provided, approved analytical method used, represent current treatment operations. 

Other Monitoring Data (e.g., 308 Letter, Questionnaire, EPRI, In-Plant) 

(1) Data collected by an unknown method or units undefined. (2) Data collected during upset conditions. (3) Represents a process that is not of interest (e.g., sanitary wastewater). 

Waste stream identified and analytes identified. 

Waste stream identified and analytes, units, and detection limits identified. 

(1) Represents full-scale system operated at applicable steam electric power plant. (2) Influent and effluent data shows that treatment system is well-designed and operated. (3) Analytes identified and units included. 

Identified as discharge, analytes identified and units provided, approved analytical method used, represent current treatment operations. 

Articles/ Technical Papers 

Information does not address key questions 

Documented and reputable sources found through literature searches (e.g., peer-reviewed journals and government publications). 

Waste stream identified and analytes, units, and detection limits identified. 

(1) Represents full-scale system operated at applicable steam electric power plant. (2) Influent and effluent data shows that treatment system is well-designed and operated. (3) Data do not represent upset conditions. (4) Analytes identified and units and detection limits included. 

Identified as discharge, analytes identified and units provided, approved analytical method used, represent treatment operations. 
Type of Data Data Not Usable 

Data Usable 

for Profile 

Data Usable to 

Characterize InProcess Waste 

Data Usable to 

Demonstrate System 

Performance/ 

Efficiency 

Data Usable to 

Estimate Baseline 

Discharges 

Industry/ Vendor Telephone Queries 

Information does not address key questions. 

These data are generally acceptable for relevant sources. 

Data not typically used for this purpose. 

(1) Represents full-scale system operated at applicable steam electric power plant. (2) Influent and effluent data shows that treatment system is well-designed and operated. (3) Data do not represent upset conditions. (4) Analytes identified and units and detection limits included. 

Data not typically used for this purpose. 

Internet Information (not published articles or technical papers) 

Information does not address key questions. 

These data are generally acceptable for relevant sources. 

Data not typically used for this purpose. 

Data not typically used for this purpose. 

Data not typically used for this purpose. 
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3.0 DATA GENERATION AND ACQUISITION

 This section addresses how ERG plans to ensure that appropriate methods for 

data collection, generation, and acquisition are employed and documented. ERG has identified 

ten elements to be discussed in this section including: 

 B.1: Sampling process design; 

 B.2: Sampling methods; 

 B.3: Sample handling and custody; 

 B.4: Analytical methods; 

 B.5: Quality control; 

 B.6: Instrument/equipment testing, inspection and maintenance; 

 B.7: Instrument/equipment calibration and frequency; 

 B.8: Inspection/acceptance of supplies and consumables; 

 B.9: Non-direct measurements; and 

 B.10: Data management. 

 Elements B.9 and B.10 are appropriate for collection and analysis of secondary 

data and are, therefore, applicable to the updated industry profile and estimation of plant-level 

candidate option costs and pollutant reductions. All elements are appropriate for the information 

request and sampling and analysis portions of the Steam Electric Rulemaking. 

3.1 Steam Electric Site Visits and Sampling and Analysis

 This section provides detailed descriptions of the methods ERG uses to support 

EPA’s steam electric power plant visits and sampling and analysis programs. All ten data 

generation and acquisition elements apply. 

3.1.1 Element B.1 - Sampling Process Design 

 ERG is assisting EPA in conducting multiple-day sampling episodes and 

obtaining monitoring data from steam electric power plants. ERG supports EPA in selecting 

plants for site visits based on geographic variability, different coal types (i.e., bituminous, 

subbituminous, coal blends), and different operating practices (e.g., baseload vs cycling), as well 

as other of the plant’s specific operating characteristics. Other operating characteristics that are 

considered for selecting plants for sampling are operation of a wet FGD system, type and age of 

FGD wastewater treatment system type and age of FGD system, NOx controls, use of a flue gas 

mercury control system, type of boiler, and age of boiler. ERG also supports EPA in selecting 

plants for sampling based on the information collected during the site visits. 

 The generic sampling plan describes the planned sampling approach, including 

sampling point selection; analyte selection; sample fractions, bottle sets, and sample collection 

procedures; sample collection methodology; sample preservation, shipping, and analysis; field 

measurements and engineering data collection; sample labeling; traffic reports; Quality 

Assurance/Quality Control that describes techniques to reduce sample contamination; and 

sample splitting. Prior to sampling a steam electric plant, ERG prepares a site-specific sampling 

plan that will detail: plant selection, location, planned sampling points, methodology, equipment, 
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frequency of collection, total sample volume, and list of analyses. The site-specific sampling 

plan also provides a plan for protecting the health and safety of the sampling crew. 

 The site-specific sampling plans clearly identify the sampling points and the 

corresponding list of analytes for each plant sampled. EPA has identified the following potential 

sampling points and analytes: 

Selected Sampling Points: Selected Analytes:

– FGD scrubber purge (i.e., 

influent to FGD wastewater 

treatment system) 

– Intermediate point of FGD 

wastewater treatment system 

– Effluent from FGD wastewater 

treatment 

 

– Total and dissolved metals (aluminum, antimony, 

arsenic, barium, beryllium, boron, cadmium, 

calcium, chromium, cobalt, copper, hexavalent 

chromium (dissolved only), iron, lead, magnesium, 

manganese, mercury, molybdenum, nickel, 

selenium, silver, sodium, thallium, tin, titanium, 

vanadium, and zinc) 

– Classical parameters (biochemical oxygen demand, 

chemical oxygen demand, total suspended solids 

(TSS), total dissolved solids (TDS), sulfate, chloride, 

ammonia, nitrate/nitrite, total Kjeldahl nitrogen 

(TKN), total phosphorus, and total cyanide) 

 Also critical to this program is the collection of process information, including 

process wastewater flow rates, chemical additions, and routine monitoring data. Collection of 

engineering data is described in Section 2.6 of the generic sampling plan and is detailed in the 

site-specific sampling plans. 

 Modifications to Sampling Process Design. Site-specific conditions may result in 

modifications to the planned sampling methodology. For example, if samples collected from the 

influent to the FGD wastewater treatment system are still reacting (e.g., fizzing, bubbling) after 

sample collection, it may be necessary to leave the bottles uncapped until the reaction is 

complete. All deviations from the site-specific sampling plan are approved by the onsite EPA 

representative at the sampling episode and documented in both the samplers’ field notes and in 

site-specific SERs that document the information and data collected during sampling episodes. 

3.1.2 Element B.2 - Sampling Methods 

 Site-Specific Sampling Plans. The generic sampling plan describes the planned 

field sampling methodology for collecting samples from the various sample points. Prior to 

sampling a coal-fired plant, ERG prepares a site-specific sampling plan that describes the 

specific sampling methodology for each sampling point in detail. Each site-specific sampling 

plan contains the following information: 

 Name and location of site being sampled; 

 Description of the plant operations; 

 Sampling points; 

 Analytes and analytical methods; 

 Quality assurance and quality control procedures and samples; 
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 Sampling procedures; 

 Analytical laboratory contact information; and 

 Health and safety precautions. 

 Training Staff in Sample Collection Methods. Site-specific pre-sampling training 

is provided to the sampling team. The training includes: 

 Review of ERG’s site-specific health and safety requirements including 

personal protective equipment and procedures. 

 Site-specific health and safety training, as required by the plant. 

 Sampling procedures training for all crew members, including: 

— Sampling preparation; 

— Sample collection (techniques for collecting samples to be 

analyzed, including trace metals); 

— Preservation (chemicals, ice); 

— Shipping and packing, especially procedures for labeling and 

preparing bottles and packing coolers; and 

— Field tests, including temperature and pH, sulfide, aldehydes, and 

oxidants. 

 Sampling crew chief training to expand on topics discussed in general 

sampling training. 

 Methods for Identifying Upset Conditions Requiring Suspension of Sample 

Collection. This sampling program is intended to characterize FGD wastewater generation and 

treatment during normal plant operations. Thus, if electricity generation or wastewater treatment 

equipment goes down during sample collection, and the upset is considered within the plant’s 

range of normal operations, ERG continues the sample collection. If a process upset occurs 

during sampling, the sampling crew chief records the times and dates that the events occur for 

future reference during the data analysis phase. A member of the sampling crew asks plant 

personnel for information regarding the upset and records this information in the field notes. In 

the event of an extended upset (i.e., outside of the plant’s normal range of operations), the 

samplers will stop sample collection. Sample collection will not recommence until normal 

operations resume. The ERG crew chief, in consultation with the onsite EPA representative, 

considers plant personnel’s judgment as to whether a particular upset is within the plant’s normal 

range of operations. 

 Methods for Minimizing Sample Contamination. ERG conducts all sampling 

activities in a manner to minimize potential contamination and cross-contamination of samples. 

If samples are collected with a peristaltic pump, ERG installs new tubing for each sampling point 

at the beginning of the episode. ERG samplers use non-contaminating pH indicator paper or a pH 

meter during field tests and preservation. A separate one-liter glass jar is filled during collection 

of each grab sample set and used for field measurements to ensure that thermometers and test 
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kits do not contaminate the samples intended for chemical analysis. The generic sampling plan 

describes the procedures for field measurements in more detail. 

 All ERG personnel who collect samples wear new nitrile gloves at each sampling 

point to avoid exposure to pollutants and other chemical, physical, and biological hazards, and to 

prevent cross-contamination of samples. Samplers use a new pair of gloves at each sampling 

point each time they collect a grab or composite sample. Samplers use care not to touch the 

insides of bottles or lids/caps during sampling. In addition, the collection of low-level trace 

metals requires special sample collection techniques. The generic sampling plan describes 

sample collection techniques that will be used for the collection of low-level metal samples. 

 

 Sampling Equipment and Decontamination. For each sampling episode, ERG 

determines the number of sample bottles, tubing configurations, bottles of blank water, zip lock 

bags, trash bags, automatic compositors, and other miscellaneous supplies needed for the 

episode. Typical field sampling equipment that may be used for the sampling program includes: 

precleaned sample bottles for chemical analyses, pH indicator paper, pH probes, thermometers, 

chlorine test kits, and sampling collection devices such as peristaltic pumps or bottle dippers. 

ERG follows method specifications for the proper size and type of bottle to use for each sample. 

ERG determines the specific field sampling devices used on a given sampling episode based on 

the specific sampling location logistics and describes these devices in the site-specific sampling 

plans. ERG orders excess sampling equipment as a contingency against breakage, malfunction, 

or loss. 

 ERG purchases other certified clean sampling equipment that directly contacts the 

samples, such as precleaned sample bottles. Equipment is either dedicated to each sample point 

(preferable), or decontaminated before reuse. 

 ERG collects equipment blanks when necessary to verify adequate 

decontamination procedures. The generic sampling plan describes the sample collection 

techniques that will be used for the collection of required blanks. 

 

 Engineering Data: During each sampling episode, ERG/EPA collects engineering 

information with regard to design and operation of the plant being sampled. For example, this 

information may include coal usage, plant capacity, wastewater flow rates, sludge generation 

rates (if applicable), and retention times in wastewater treatment process stages. Engineering data 

collection sheets are completed for each plant sampled. This information is used to determine if 

the specific design or operational criteria of the steam electric operations affect the wastewater 

characteristics. 

3.1.3 Element B.3 - Sample Handling and Custody 

 This section describes the procedures for sample handling and sample custody. 

The generic sampling plan also contains information describing the sample handling and sample 

custody. Each site-specific sampling plan discusses proper sample handling in the field 

including: 
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 Sample collection; 

 Sample preservation and shipping; 

 Sample labeling; 

 Sample set preparation; and 

 Sample packing. 

 Sampling data EPA uses to support regulatory development programs must be 

legally defensible. Therefore, the sample must be tracked from sample collection through 

analysis. ERG creates sample labels to identify and track all samples. In addition, ERG uses field 

logs to document that samples were collected as described in the site-specific sampling plan. 

 

 ERG uses a traffic report to maintain a record of sample collection, sample 

transfer between personnel, sample shipment, and sample receipt by the laboratory. The 

sampling crew completes a traffic report for each cooler or box that is shipped to a laboratory. 

Each traffic report contains the following information: 

 Sampling episode number for each plant sampled; 

 Number of containers of each sample in shipment; 

 For each sample in the shipment: 

 Sample number; 

 Collection date and time; 

 Preservation (yes or no) and pH after preservation; 

 Sample description (environmental matrix); 

 Analyses required; 

 Shipment or airbill number; 

 Date and method of shipment; and 

 The name of the person shipping the samples. 

 The sampling crew chief or his/her designee is responsible for completing the 

traffic reports, including referencing all applicable blank and QC samples, signing the traffic 

reports, and noting the date and time of shipment. This individual also inspects the traffic reports 

for completeness and accuracy. Any person who makes changes to the form initials the changes 

made. The sampling crew chief retains one copy of the traffic report and two copies accompany 

the sample shipment. 

 ERG does not anticipate shipping samples collected during this project as 

dangerous goods. All samples collected during this project are expected to be shipped under the 

exclusion allowed for transporting laboratory samples in 40 CFR 261.4(d) and under the 

definition and exception in CFR 49 Part 173.134. For any samples that do not qualify for this 

exclusion, the field sampling crew packages and labels samples for shipment in compliance with 

current U.S. Department of Transportation and International Air Transport Association 

dangerous goods regulations. 

 When the laboratory receives the samples, the laboratory sample custodian checks 

all bottles against the Traffic Reports, records the condition of the samples, and signs, dates, and 

marks the time of receipt on the Traffic Reports. The laboratory sample custodian immediately 
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reports any discrepancies or problems to ERG. ERG verifies the receipt and condition of all 

samples. 

 The laboratory must have a SOP for sample custody within the laboratory. The 

laboratory logs all samples into a sample receipt logbook or computerized laboratory information 

system and documents the following information: 

 Date and time of sample receipt; 

 Project number and name; 

 Field sample number; 

 Laboratory sample number; 

 Sample matrix; 

 Analytical parameters; 

 Storage location; and 

 Log-in person’s initials. 

All information relevant to the samples is secured at the end of each business day. All samples 

are stored in a designated storage refrigerator with restricted access. 

 ERG uses an electronic sample tracking system to track the last date samples 

associated with each episode are received at the laboratory and the date of receipt of analytical 

data from the laboratories. 

3.1.4 Element B.4 - Analytical Methods 

 The generic sampling plan identifies the analytes that will be measured and the 

anticipated analytical methods that EPA will use for the steam electric power generating 

sampling episodes. Laboratories are allowed to identify their preferred method for analysis of 

certain analytes at the time they submit their bid response package. The site-specific sampling 

plans contain the specific list of analytical methods that will be used for that sampling episode. 

The site-specific sampling plans also identify the sample volume to be collected, the QC sample 

volume to be collected, the sample container type, and typical preservation required for each 

parameter. The additional volume collected for QC is used to perform matrix spike/matrix spike 

duplicate (MS/MSD) analyses and serial dilutions. 

 ERG uses information described above in combination with the site-specific 

sample conditions to select the proper sample volumes, bottle types, and preservation methods 

for each sample collected. Section 5.1 of this QAPP addresses the procedures for laboratory and 

data quality review. 

3.1.5 Element B.5 - Sampling Quality Control 

 The steam electric sampling program includes the collection of field quality 

control samples. Sampling QC activities are designed to measure or estimate the effect of 

sampling error such as contamination, matrix effects, and imprecision. The site-specific sampling 

plans specify the quantities and types of blank and duplicate samples to be collected during each 

episode. The analytical laboratories specify the actual quantity and types of laboratory QC 
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samples that are used; these requirements are specified “per sample set.” EPA defines a sample 

set as a group of not more than 20 samples prepared at the same time on the same day during the 

same shift by the same analyst. The following subsections describe the routine QC measures the 

laboratories conduct and the types of blank and duplicate samples the sampling crew collect 

during the project. 

 ERG verifies that the analytical laboratories’ performance is acceptable by 

comparing the QC sample results to method requirements. Based on these findings, ERG 

evaluates the usability of the data in consultation with the EPA WAM. ERG may require 

laboratories to re-analyze the wastewater samples if the analytical performance does not meet the 

method requirements. After an analytical data package has been reviewed and after all problems 

that can be corrected have been resolved, the ERG data review chemist prepares a written data 

review narrative and hard-copy and electronic data package and submits it to the EPA WAM. 

 ERG also verifies that the analytical laboratories have a comprehensive laboratory 

QA program in place and operating at all times during the performance of tasks supporting this 

study. The laboratories adhere closely to all QA/QC requirements in EPA Requirements for 

Quality Assurance Project Plans3

. The laboratories include a QA statement in the data package 

submitted to ERG, which aids ERG in determining if the laboratories meet the QC requirements. 

The laboratories may perform additional QC to assure the validity and reliability of results. 

 ERG confirms that the laboratories also have a comprehensive data management 

plan that is consistent with the principles set forth in EPA 2185 – Good Automated Laboratory 

Practices, EPA Office of Administration and Resources Management, August 10, 1995. The 

laboratories must have this data management plan in place and in use at all times. In addition, the 

laboratories must maintain internal records in an organized manner to document adherence to 

requirements, and these records must be available for review upon request. 

3.1.5.1 Field QC Measures 

 Field quality control samples for this project include bottle blanks, field blanks, 

equipment blanks, and duplicate samples. Table 3-1 presents a list of the field quality control 

samples, the analytes analyzed, the purpose, and the frequency. Note that not all analytical 

methods require all of the QC measures listed. The site-specific sampling plans discuss 

collection of these samples in greater detail. This section describes each of the field quality 

control samples that are collected for the sampling program. 

 

3

 See EPA Requirements for Quality Assurance Project Plans (March 2001), available online at 

http://www.epa.gov/QUALITY/qs-docs/r5-final.pdf. 
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Table 3-1. Field Quality Control Samples 

Field Quality 

Control Analytes Purpose Frequency 

Bottle Blank Total and dissolved 

metals, low-level total 

and dissolved metals 

To monitor the pre-cleaned bottles 

for metals contamination 

For low-level metals, one for each 

method at each sampling episode. 

For routine metals, one for each 

method for the sampling program. 

Field blank Total and dissolved 

metals, low-level total 

and dissolved metals 

To monitor potential 

contamination from sampling 

techniques (equipment used or 

ambient conditions) 

For routine total and dissolved 

metals, one blank will be collected 

for each type of sampling 

technique or special equipment 

used. At a minimum, one blank 

per episode will be collected. 

Field blanks will be collected for 

low-level total and dissolved 

metals at each sampling location 

and for each method. For 

hexavalent chromium, one blank 

will be collected for each sample 

point. For mercury, one blank will 

be collected for each sample point. 

Equipment 

blank 

Low-level total and 

dissolved metals 

To document adequate 

decontamination of sampling 

equipment before use by the 

sampling crew 

Once per lot of equipment cleaned 

(for each method). 

Field Duplicates All analytes except 

HEM/SGT-HEM 

To evaluate total measurement 

precision and assess potential 

sources of data variability, 

including sample collection, 

handling, preparation, and analysis 

One sample point per episode 

Bottle Blank 

For routine metals, the sampling crew prepares a bottle blank for one episode in 

ERG’s sample room before the start of the sampling episode. The bottle blank samples are an 

analyte-free matrix (ASTM Type 1 water) poured into the appropriate sample bottles (e.g., 250-

mL plastic bottle for total metals) and stored for several days prior to shipment to the laboratory. 

Additionally, the supplier of the cleaned sample bottles analyzes bottle blanks for each lot 

(according to EPA Method 1669) and provides a report that certifies the bottles as clean. 

Purpose: To monitor the pre-cleaned bottles for metals 

contamination. 

Recommended 

Frequency: 

One bottle blank for each sampling episode. 

Field Blanks 

 The sampling crew collects field blanks for all sampling techniques used by the 

sampling staff and for special equipment used during the sample collection, such as cooling 
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coils, tubing, etc. The field blank evaluates potential contamination of the sample from either the 

equipment used or ambient conditions. To collect field blanks, ERG pours or pumps ASTM 

Type 1 water through all equipment used for the sample collection at the sampling location and 

into sample bottles. Multiple field blanks may be required if different sampling techniques are 

used or if ambient conditions are expected to vary from sample point to sample point. ERG 

assists EPA in selecting analyses for the field blank using requirements of the analytical 

methods. The laboratories analyze the field blank for the specified analytes. The site-specific 

sampling plans list the field blanks to be collected at each site. 

Purpose: To monitor potential contamination from sampling 

techniques (equipment used or ambient conditions). 

Recommended 

Frequency: 

For all the metals samples, one field blank at each 

sampling point for one day of the sampling episode. 

Equipment Blanks 

 The analytical method being used for the analysis of mercury (EPA Method 

1631E) requires specially cleaned sample collection equipment. EPA Method 1669 details the 

cleaning method required for tubing and other equipment. The suppliers of this equipment 

perform equipment blanks and provide a report certifying the equipment as cleaned. 

Purpose: To document adequate decontamination of sampling 

equipment before the use by the sampling crew. 

Recommended 

Frequency: 

Once per lot of equipment cleaned. The equipment blank 

will be analyzed for metals. 

Field Duplicates 

 Each site-specific sampling plan specifies sample points for collection of field 

duplicates. ERG assists EPA in selecting duplicate points based on information from each site 

and the goals of the project. EPA collects one duplicate sample for every ten samples collected at 

a sampling event, excluding field blank samples. For example, EPA anticipates collecting four 

samples from each sampling point selected at a plant; therefore, if EPA collects samples from 

two sample points at a plant (total of 8 samples), only one duplicate sample will be collected. 

However, if EPA collects samples from three sample points at a plant (total of 12 samples), then 

two duplicate samples will be collected. The field blank samples associated with the sampling 

points are not included in the count of the total samples collected. Results of the duplicate 

analyses are used to evaluate precision, including variability in sample collection, handling, 

preparation, and analysis. 

Purpose: To evaluate total measurement precision and assess 

potential sources of data variability, including sample 

collection, handling, preparation, and analysis.
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Recommended 

Frequency: 

One field duplicate sample for every 10 samples collected 

at a site. 

3.1.5.2 Analytical QC Measures 

 The following are the analytical QC measures that are used for chemical analyses 

for the steam electric sampling program. Note that not all QC measures listed are required for all 

methods. 

Method Detection Limits 

 A MDL is defined as the minimum concentration of a substance that can be 

measured and reported with 99% confidence that the analyte concentration is greater than zero. 

For metals analytical methods, laboratories are required to perform MDL studies for each 

instrument on which analyses will be performed and any time a modification is made that will 

affect the MDL. Laboratories must demonstrate that they obtain a MDL value that is less than or 

equal to either (1) the MDL (if listed in the method), or (2) one-third the minimum level (ML, if 

listed in the method). Appendix B of 40 CFR Part 136 describes the EPA procedure used for 

establishing MDLs. This procedure requires the laboratory to analyze at least seven aliquots of a 

standard spiked at three to five times an estimated MDL. The laboratory processes the aliquots 

through all of the steps of the analytical method, and calculates the MDL as approximately three 

times the standard deviation of the mean for the analyses. The number of aliquots analyzed 

determines the multiplier of the standard deviation. 

Aqueous Performance Standard 

 The laboratory prepares an aqueous performance standard (ongoing precision and 

recovery (OPR)) sample by adding known amounts of the analytes of interest to a matrix with 

known characteristics. Reagent water will usually be used as the reference matrix. The standard 

is processed through all sample preparation and analysis steps. Analyte recoveries are evaluated 

against method specific limits. 

Purpose: To assess laboratory performance and to evaluate error 

sources in the laboratory. 

Recommended 

Frequency: 

Once per sample set. 

Calibration Check Standard 

 The laboratory performs a calibration check standard by adding analytes of 

interest to a laboratory reagent blank. Analyte recoveries are evaluated using limits specified in 

the applicable method. 

Purpose: To ensure that the instrument calibration remains in 

control. 
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Recommended 

Frequency: 

Every 10 analytical runs, or every 8 to 24 hours, as 

specified in the method. 

ICP Interference Check Samples (ICS) 

 The laboratory analyzes inductively coupled plasma (ICP) interference check 

samples (also known as spectral interference check samples) by analyzing a solution of selected 

method analytes at known higher concentrations. Analyte recoveries should be with 20 percent 

of the known value. 

Purpose: To evaluate the procedural routine for correcting known 

inter-element spectral interferences. 

Recommended 

Frequency: 

At the beginning and end of each analytical sequence (for 

EPA Method 200.7). At the beginning of each analytical 

sequence (for EPA Method 200.8). 

ICP Serial Dilution Analysis 

 The laboratory analyzes ICP serial dilutions, which consists of reanalyzing a 

sample after performing a five-fold dilution. 

 

Purpose: To determine whether significant physical or chemical 

interferences exist due to the sample matrix. 

Recommended 

Frequency: 

Performed on all MS/MSD samples for EPA method 

200.7 analyses. 

Laboratory Blanks 

 The laboratory analyzes a laboratory blank, which consists of reagent water or 

“clean matrix” material which does not contain the analytes of interest or interfering compounds. 

EPA requires the laboratory to analyze a laboratory blank so that any sample contamination 

originating at the laboratory can be identified. 

Purpose: To ensure that the analysis system is free from 

interferences and contamination. 

Recommended 

Frequency: 

Per method and subcontract requirements, which specify 

either a per batch preparation frequency or an 8 to 12 hour 

per analysis frequency. 

Matrix Spike/Matrix Spike Duplicates 

 The laboratory must perform the MS/MSD analysis for all samples designated by 

EPA on the accompanying traffic reports. The MS/MSD test is used to assess method 

performance in the sample matrix. The MS and MSD samples are prepared and/or analyzed 
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exactly like the field sample. The laboratory attempts to produce analytical results where the 

recoveries are within criteria, and the OPR recoveries are within criteria. The ERG sampling 

team is responsible for collecting, labeling, and shipping the laboratory QC volumes. Laboratory 

QC volumes are collected as duplicate samples collected immediately after the original sample 

aliquot. For metals analyses, EPA collects one QC sample volume (i.e., MS/MSD sample) for 

every ten samples collected at a sampling event, excluding field blank samples. For example, 

EPA anticipates collecting four samples from each sampling point selected at a plant; therefore, 

if EPA collects samples from two sample points at a plant (total of 8 samples), only one QC 

sample volume will be collected. However, if EPA collects samples from three sample points at 

a plant (total of 12 samples), then two QC sample volumes will be collected. The field blank 

samples associated with the sampling points are not included in the count of the total samples 

collected. For classicals analyses, EPA collects one QC sample volume at the FGD effluent 

sample point at each episode. 

Purpose: To assess matrix effects on analytical performance. 

Recommended 

Frequency: 

For all the metals samples, one field blank at each 

sampling point for one day of the sample episode. 

For classicals samples, one QC sample volume at the FGD 

effluent sample point each episode. 

3.1.6 Element B.6 - Instrument/Equipment Testing, Inspection, and Maintenance 

 ERG inspects all sampling and field test devices prior to use to ensure that they 

are working properly. Section 2.6 of the generic sampling plan describes the field test equipment 

ERG expects to use during the sampling program. ERG follows the manufacturer’s instructions 

in operating this equipment. 

 ERG confirms that the laboratories selected to analyze samples have a 

comprehensive laboratory QA program in place that requires the laboratories perform preventive 

maintenance on all of their analytical equipment. 

3.1.7 Element B.7 - Instrument/Equipment Calibration and Frequency 

 This section provides information on the calibration procedures and preventive 

maintenance to be conducted on all field and analytical equipment used in the steam electric 

sampling program. 

 ERG confirms that laboratories selected to analyze samples are responsible for 

performing all required instrument calibrations. Instrument calibration procedures, including 

frequency specifications and maintenance requirements, are specified in the analytical methods. 

Whenever changes are made to a system or a method, the laboratory must ensure that its 

equipment is operating properly by performing the appropriate QC tests. Analytical instruments 

requiring calibration must be uniquely identified to allow proper association of calibration 

records. To ensure that the calibration standard is met, the laboratory must analyze test samples 
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that are either certified as to purity, concentration, and authenticity, or prepared from materials of 

known purity and composition. 

3.1.7.1 Field Equipment 

 To control sampling errors, the site-specific sampling plans contain specifications 

for sampling equipment and instructions for use (e.g., peristaltic pumps, field meters, and test 

kits). Sampling crew chiefs are responsible for ensuring that all equipment is maintained in good 

working condition and that decontamination procedures are properly followed. Prior to each 

sampling episode, ERG calibrates the field test equipment following the manufacturer’s 

instructions. All variations from the manufacturer’s instructions are fully documented in field 

logs. 

 The automatic sampling machines are rented. The rental company cleans the 

automatic sampling machines between uses using a household detergent. Prior to each rental, the 

rental company runs a set of diagnostic tests on the sampling machines and installs new internal 

tubing on the sampling pump. The sampling crew installs new tubing to be used for the sample 

collection and the sampling crew collects a field blank prior to the start of sampling during one 

day of the episode. Each automatic sampling machine is dedicated to a specific sampling point 

for the duration of the sampling episode. 

3.1.7.2 Analytical Equipment 

 The laboratories selected to analyze samples are responsible for performing all 

required instrument calibrations. Instrument calibration procedures, including frequency 

specifications and maintenance requirements, are specified in the analytical methods. Whenever 

changes are made to a system or a method, the laboratory must ensure that their equipment is 

operating properly by performing the appropriate QC tests. These may include IPR or MDL 

studies. Analytical instruments requiring calibration must be uniquely identified to allow proper 

association of calibration records. 

 To ensure that the calibration standard is met, the laboratory must analyze test 

samples that are either certified as to purity, concentration, and authenticity, or prepared from 

materials of known purity and composition. ERG verifies that calibration measurements are 

performed and/or verified with calibrated systems at the specified frequencies. 

 The laboratories must perform preventive maintenance on all of their analytical 

equipment. Equipment maintenance log books must contain records of equipment usage, 

maintenance, modifications, calibrations, and repairs. 

3.1.8 Element B.8 - Inspection/Acceptance Criteria for Supplies and Consumables 

 Critical supplies and consumables are those that come in contact with samples. 

These include sample bottles, preservation chemicals, and sampling equipment. Sampling crew 

chiefs are responsible for the purchase of required materials and the inspection of materials upon 

receipt to ensure they are usable for this project (e.g., no observable breakage, evidence of 

tampering or contamination). With the exception of bottles for metals samples, discussed below, 
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ERG purchases all sample bottles from Environmental Sampling Supply (ESS). Appendix G of 

this QAPP includes relevant information from ESS on the following: 

 Sample bottle preparation/cleaning procedures; 

 Sample bottle certification/quality control; 

 Preservation chemical preparation; and 

 Blank water specifications. 

 Sample bottles for metals are cleaned by a laboratory according to EPA Method 

1669. The laboratory preparing the bottles and associated sample collection tubing provides 

bottle and equipment blanks that ERG uses to demonstrate that the supplies have not been 

contaminated. The laboratory preserves the equipment using procedures that meet the criteria of 

EPA Method 1669. 

 

3.1.9 Element B.9 - Non-Direct Measurements 

 EPA’s steam electric sampling program is augmented and complemented by the 

following types of data generated and provided by the plants: 

 Process flow diagrams; 

 Daily electricity generation data; 

 Daily wastewater flow rates through the treatment systems; 

 Coal type and rates of use (e.g., tons/day); 

 Treatment chemical rates of use (e.g., L/min); and 

 Sludge generation (tons/day). 

 ERG also obtains additional relevant information on treatment techniques specific 

to the particular waste stream being sampled, such as retention time through the system and 

design and operating characteristics. ERG develops site-specific data sheets for the engineering 

data to be collected during the sampling episode. The crew chief is responsible for using the data 

sheets and ensuring that the specified data are collected. 

3.1.10 Element B.10 - Data Management 

 Documentation, data reduction, data validation, and data reporting procedures for 

the steam electric project are followed during field data collection operations as well as during 

laboratory analyses. 

Documentation 

 Field documentation tools for this project include sample labels, field logs, traffic 

reports, and flow and process data recorded on standard data collection sheets completed by the 

samplers. The sampling crew chief reviews all field documentation and ensures that all records 

are legible and complete. During the sampling episode or shortly thereafter, EPA requests any 

needed operating data from the plant engineers. ERG confirms that all requested data are 

collected. ERG handles all documentation related to sample tracking, sample analysis, data 

reporting, and data validation. 
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Data Reduction 

 Each laboratory assigned to analyze wastewater samples on this project ensures 

accurate and contract-compliant data prior to release of the data. The laboratory cross-references 

all of its data to appropriate trip blank, field blank, equipment blank, method blank, field 

duplicate, MS, and MSD. All dates pertinent to the project (e.g., dates on which each sample is 

collected, shipped, received by the laboratory, prepared, and analyzed) are referenced to the 

appropriate analytical holding times. 

 The analytical laboratories and ERG each perform the analytical data reduction. 

The laboratories monitor data reduction using the results produced for internal standards, 

surrogates, duplicates, and spikes. 

 The laboratories perform quantitation according to protocols specified in 

laboratory subcontracts in one of the following ways: 

 By using the isotope dilution technique; 

 By using the internal standard technique; 

 By using the external standard technique; 

 By using known response factors specified in the methods; 

 By comparing the instrument response to a built-in scale; 

 By titration to a reaction-defined endpoint; 

 By comparing instrument response from a treated sample to a calibration 

curve generated from known concentration standards instrument 

responses; or 

 By using the sum of extracted ion current profile (EICP) areas relative to 

the sum of EICP areas of the nearest eluting internal standard. 

 Results are reported in micrograms per liter (μg/L) or in other units, as specified 

by the method or ERG subcontract. ERG monitors all specifications for all samples. 

 ERG controls analytical data reduction by cross checking the data received with 

the data in the final database (final database described in this section under Data Reporting). 

Each time a change is made to the computer programs used for data reduction, ERG ensures that 

the change does not alter the final results. 

 ERG will perform quality control for data reduction and database development as 

outlined in ERG’s 2002 and 2013 QMPs (2a, 2b). 

Data Validation 

 To efficiently validate the quality of analytical data received for this project, ERG 

requires the laboratories to submit a complete record of all analytical information associated with 

each sampling episode. The laboratories provide this information in a designated written and/or 
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electronic format. Written formats must include the use of specific data reporting forms, detailed 

narratives describing problems encountered during analysis, and all associated QC and raw data. 

 ERG subjects all data to a multi-stage review process to ensure that the data are 

properly formatted, complete, contract-compliant, and usable. The review process is based on the 

analytical data review checklists prepared for each analytical method used for the sampling 

program (see Section 5.1.1.1 for more details). ERG performs this review to ensure data quality, 

to note deficiencies, and, where appropriate, to initiate corrective actions with the laboratories. 

Prompt initiation of corrective actions maximizes the amount of usable data generated from each 

sampling episode. 

 After an analytical data package has been reviewed and after all problems that can 

be corrected have been resolved, ERG prepares a written data review narrative. ERG submits the 

data review narratives, along with a hard-copy summary data package, to EPA. The purpose of 

the narrative is to document the samples and analyses that were reviewed, to summarize the 

criteria by which they were reviewed, to note any deficiencies in the data, and to provide the 

EPA WAM with recommendations concerning the data usability. ERG uses standard language to 

communicate problems and recommendations. Table 3-2 lists the potential data limitations and 

associated qualifiers that may be used in this program. Any data qualifiers are fully described in 

the final laboratory packages and in the data review narratives. A listing of the specific data 

qualifiers included in the analytical database is included in Section 5.1.1. 

Data Reporting 

 Upon completion of the data reduction and validation procedures for all samples 

and analytes included in a sampling episode on this project, ERG prepares a database that 

summarizes the analytical results. ERG follows ERG’s SOPs for Databases in developing the 

database (11, 12). EPA’s WAM reviewed ERG’s SOPs and determined they are acceptable for 

meeting the objectives of this project. To increase efficiency among data users, ERG uses a 

standard database format for all industry studies. Table 3-3 shows the typical structure of the 

database files and the source of data. The structure of the database files may be reviewed and 

changed as appropriate for this program. ERG confirms the accuracy of the database by spotchecking at least 10% of results that were downloaded directly from the analytical instrument in 

the laboratories and by performing a 100% check of manually entered data. The analytical 

database is stored on ERG’s project server and shared with EPA as updated. 

 ERG retains all sample collection records in the files for this project. These 

records include site-specific sampling plans, field sampling log sheets, field data sheets, 

preservation log sheets, and traffic report forms. Copies of these records are provided to EPA as 

requested. 

 ERG prepares a final SER for each steam electric power plant sampling episode. 

The report provides descriptions of the plant sampled, wastewater sources, wastewater treatment, 

sampling points and sample collection, and deviations from the site-specific and generic 

sampling plans. The report also presents the in-field measurement data. The analytical results are 

included in the record for the Steam Electric Power Generating Effluent Guidelines Rulemaking. 
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Table 3-2. Data Quality Qualifiers for Sampling Program 

Potential Data Limitations Associated Qualifiers 

 OPR, MS/MSD, or surrogate recoveries below performance 

specifications. 

 Sample results greater than five times but less than ten times 

the blank result. 

 GGA percent recovery below method-specified criteria. 

 See correction blank recovery low. 

 Holding time exceeded (for analytes subject to loss or 

degradation). 

Data are of acceptable quality but may reflect 

minimum values. 

 OPR, MS/MSD, or surrogate recoveries above performance 

specifications. 

Data are of acceptable quality but may reflect 

maximum values. 

 Sample result greater than upper end of the calibration range. Include the value corresponding to the upper 

limit of the calibration range in the database 

with a “>” sign. 

 Sample result less than five times the blank result. 

 Sample result greater than the MDL, but less than the RL. 

Include the value in the database as not 

detected at the adjusted method detection 

limit. 

 Holding time exceeded (for analytes expected to fluctuate in 

concentration). 

 Sample pH not at method requirements. 

 Duplicate or MS/MSD relative percent difference greater than 

specified limit. 

 Instrument related QC exceeds the control limits. 

 LSC or LCSD is outside of laboratory control limits. 

 MS and/or MSD did not meet laboratory criteria, but sample 

concentration is four times greater than spike amount. 

 Method of standard addition correlation coefficient below 

specified limit. 

Data provided represent the best obtainable 

data. 

 Grossly deficient quality control data. Exclude data from the database (with EPA 

WAM concurrence). 

 As directed by EPA, ERG will develop a sampling program database to analyze 

the analytical data. ERG follow ERG’s SOPs for Databases in developing the database (11,12). 

This database includes all the analytical data from the sampling program. These data and the 

database are added to the project file according to the Steam Electric Power Generating Project 

File Management Plan (10). 

 Information collected through the sampling episodes claimed as CBI by the steam 

electric facilities are handled according to the procedures as outlined in ERG’s CBI security plan 

entitled Security Plan for Handling Confidential Business Information Under the Clean Water 

Act, dated September 25, 2008 and approved by Ahmar Siddiqui, EPA’s Document Control 

Officer for this contract, on March 12, 2009, and it’s successor plan (5a, 5b). Only staff 

demonstrating their understanding of CBI handling procedures by passing a written test are 

permitted to access CBI on this project. 
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Table 3-3. Typical Analytical Database Structure 

Field Description Field Name Field Length Source of Data 

Analyte Concentration AMOUNT 16 Laboratory 

Analyte Name ANALYTE 75 Laboratory 

CAS Registry Number CAS_NO 10 Laboratory 

Calculated Detection Limit MDL 8 Laboratory 

Calculated Reporting Limit RL 8 Laboratory 

Dilution Factor DILUTION 8 Laboratory 

Episode Number EPISODE 4 Upper right corner of traffic report 

Laboratory Name LABNAME 5 Laboratory 

Column or Extraction Type PROCEDURE 10 Laboratory 

Sample Number SAMPLE 5 Left column of traffic report 

Data Qualifier QUALIFIERS 11 Laboratory/ERG data review 

Reason for Qualification REASON 60 Laboratory 

Concentration Units UNITS 7 Laboratory 

Laboratory Method Used METHOD 12 Laboratory 

3.2 Industry Self-Monitoring Program

 This section provides detailed descriptions of the methods ERG uses to support 

EPA for the industry self-monitoring program. All ten data generation and acquisition elements 

apply. 

3.2.1 Element B.1 - Sampling Process Design 

 ERG is assisting EPA in designing and coordinating the industry self-monitoring 

program. The industry self-monitoring program includes all the plants selected for the EPA 

sampling program, as well as several plants selected for specific operating characteristics. These 

specific operating characteristics include the operation of an integrated gasification combined 

cycle system, operation of a vapor compression evaporation system, and operation of carbon 

capture technology. 

 ERG is also supporting EPA in identifying the planned sampling approach, 

including sampling point selection; analyte selection; sample fractions, bottle sets, and sample 

collection procedures; sample collection methodology; sample preservation, shipping, and 

analysis; field measurements and engineering data collection; sample labeling; traffic reports; 

and Quality Assurance/Quality Control that describes techniques to reduce sample 

contamination. ERG is supporting EPA in developing instructions for the sampling approach, 

which will be provided to the selected plants prior to the scheduled sampling event(s). 

 EPA is planning to have the plants that are selected for the EPA sampling 

program also participate in the industry self-monitoring program. These plants, referred to as 

“sampled plants,” are required to collect samples from the same sampling points that are sampled 

during the EPA sampling episodes one day per month for four months. The other plants selected 

for the industry self-monitoring program, referred to as “non-sampled plants,” are required to 

collect samples from the selected sampling points for four consecutive days, similar to the EPA 

sampling program. 
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 The instructions clearly identify the sampling points and the corresponding list of 

analytes for each plant sampled. EPA has identified the following potential sampling points and 

analytes: 

Selected Sampling Points: Selected Analytes:

– FGD scrubber purge (i.e., influent to 

FGD wastewater treatment system) 

– Intermediate point of FGD 

wastewater treatment system 

– Effluent from FGD wastewater 

treatment 

– Untreated gasification wastewater 

streams 

– Distillate from evaporation systems 

– Untreated carbon capture wastewater 

– Treated carbon capture wastewater 

– Total metals (aluminum, antimony, arsenic, 

barium, beryllium, boron, cadmium, calcium, 

chromium, cobalt, copper, iron, lead, 

magnesium, manganese, mercury, 

molybdenum, nickel, selenium, silver, sodium, 

thallium, tin, titanium, vanadium, and zinc) 

– Classical parameters (biochemical oxygen 

demand, chemical oxygen demand, total 

suspended solids (TSS), total dissolved solids 

(TDS), sulfate, chloride, ammonia, 

nitrate/nitrite, total Kjeldahl nitrogen (TKN), 

total phosphorus, and total cyanide) 

 Also critical to this program is the collection of process information, including 

process wastewater flow rates, chemical additions, and routine monitoring data. ERG is 

supporting EPA in identifying the appropriate engineering data to collect from each type of 

plant. ERG includes engineering data collection requirements in the instructions that are 

provided to the plants. 

 Modifications to Sampling Process Design. Site-specific conditions may result in 

modifications to the planned sampling methodology. For example, if samples collected from the 

influent to the FGD wastewater treatment system are still reacting (e.g., fizzing, bubbling) after 

sample collection, industry samplers may need to leave the bottles uncapped until the reaction is 

complete. Industry samplers are required to take notes of any such modifications to the planned 

sampling methodology and provide the notes to EPA/ERG after the completion of sample 

collection. 

3.2.2 Element B.2 - Sampling Methods 

 Site-Specific Sampling Instructions. Prior to the plants collecting the samples, 

ERG prepares site-specific instructions for each plant that describe the specific sampling 

methodology for each sampling point. Each set of instructions contains the following 

information: 

 Name and location of site being sampled; 

 Equipment required; 

 Sampling points; 

 Analytes and analytical methods; 

 Quality assurance and quality control samples; 

 Sampling procedures; and 
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 Sample packing and shipping procedures (including analytical laboratory 

contact information). 

 As part of the industry self-monitoring program, the individual responsible for 

directing or supervising the sample collection and the engineering data submission is required to 

complete and sign a statement certifying that the samples were collected according to the 

instructions provided by EPA. Additionally, ERG and/or EPA are auditing the sample collection 

procedures during one of the sampling sets for a majority of the plants participating in the 

program. 

 Methods for Identifying Upset Conditions Requiring Suspension of Sample 

Collection. This sampling program is intended to characterize wastewater generation and 

treatment during normal plant operations. Therefore, site-specific instructions require the plants 

to notify EPA/ERG if there are upset conditions at the plant prior to or during sample collection. 

For example, if electricity generation units or wastewater treatment equipment go down during 

sample collection, the plant is instructed to contact EPA or ERG. If the plants contact ERG to 

identify the upset condition, ERG discusses the condition with the plant personnel and then 

contacts EPA to discuss the potential options for the sample collection. ERG, in consultation 

with EPA, considers plant personnel’s judgment as to whether a particular upset is within the 

plant’s normal range of operations, or whether the sample collection should be postponed until a 

later time. 

 Methods for Minimizing Sample Contamination. As part of this industry selfmonitoring program, the plants are required to collect the wastewater samples following EPA 

Method 1669 protocols, to minimize potential contamination and cross-contamination of 

samples. As part of the EPA Method 1669 protocols, all plant sampling staff are required to wear 

gloves at each sampling point to avoid cross-contamination of samples. Samplers also use a new 

pair of gloves at each sampling point, each time they collect a grab or composite sample. 

 

 Sampling Equipment and Decontamination. Each plant selected for the industry 

self-monitoring program is responsible for obtaining the necessary supplies to collect the 

required wastewater samples. For equipment that comes in direct contact with the samples (e.g., 

sample bottles, tubing sets), the plants are required to obtain equipment that has been certified 

clean according to EPA Method 1669 standards. This equipment is dedicated to each sample 

point. 

 Other sampling equipment that the plants may use during the sample collection 

includes: pH indicator paper, pH probes, thermometers, chlorine test kits, and sampling 

collection devices such as peristaltic pumps or bottle dippers. ERG uses method specifications to 

identify for the plant the proper size and type of bottle to use for each sample. 

 ERG is supporting EPA in confirming that the proper sampling equipment and 

proper sampling techniques are used during the sample collection activities during the on-site 

audits performed at each of the plants selected to participate in the industry self-monitoring 

program. 
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 Engineering Data: Each plant is required to collect engineering information with 

regard to design and operation of the plant as part of the self-monitoring program. ERG is 

supporting EPA in identifying the specific information that each plant should collect. ERG is 

responsible for ensuring that the plants provide the information required, such as coal usage, 

plant capacity, wastewater flow rates, sludge generation rates (if applicable), and retention times 

in wastewater treatment process stages. Engineering data collection sheets are completed for 

each plant sampled. This information is used to determine if the specific design or operating 

criteria of the steam electric operations affect the wastewater characteristics. 

3.2.3 Element B.3 - Sample Handling and Custody 

 This section describes the procedures for sample handling and sample custody. 

ERG prepares site-specific instructions for each plant that will include proper sample handling in 

the field including: 

 Sample collection; 

 Sample preservation and shipping; 

 Sample labeling; 

 Sample set preparation; and 

 Sample packing. 

 Sampling data EPA uses to support regulatory development programs must be 

legally defensible. Therefore, the sample must be tracked from sample collection through 

analysis. ERG provides the plants with the information that must be included on the sample 

labels, including the appropriate sampling episode numbers and sample numbers. The plants are 

required to create the sample labels and place them on the sample bottles. In addition, the plants 

are required to document that the samples were collected as specified in the site-specific 

instructions and complete and sign a certification statement. 

 ERG provides the plants with template traffic reports to maintain a record of 

sample collection, sample transfer between personnel, sample shipment, and sample receipt by 

the laboratory. The plant sampling personnel complete the traffic report for each cooler that is 

shipped to a laboratory. Each traffic report contains the following information: 

 Sampling episode number for each plant sampled; 

 Number of containers of each sample in shipment; 

 For each sample in the shipment: 

 Sample number; 

 Collection date and time; 

 Preservation (yes or no) and pH after preservation; 

 Sample description (environmental matrix); 

 Analyses required; 

 Shipment or airbill number; 

 Date and method of shipment; and 

 The name of the person shipping the samples. 
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 The plant personnel collecting the samples completes the traffic reports, including 

referencing all applicable blank and QC samples, signing the traffic reports, and noting the date 

and time of shipment. This individual also inspects the traffic reports for completeness and 

accuracy. Any person who makes changes to the form initials the changes made. The plant 

personnel retain one copy of the traffic report, two copies accompany the sample shipment, and 

one copy is sent to ERG. 

 ERG does not anticipate that any samples collected during this program will be 

shipped as dangerous goods. All samples collected during this project are expected to be shipped 

under the exclusion allowed for transporting laboratory samples in 40 CFR 261.4(d) and under 

the definition and exception in CFR 49 Part 173.134. For any samples that do not qualify for this 

exclusion, the plant personnel package and label samples for shipment in compliance with 

current U.S. Department of Transportation and International Air Transport Association 

dangerous goods regulations. 

 When the laboratory receives the samples, the laboratory sample custodian checks 

all bottles against the Traffic Reports, records the condition of the samples, and signs, dates, and 

marks the time of receipt on the Traffic Reports. The laboratory sample custodian immediately 

reports any discrepancies or problems to ERG. ERG verifies the receipt and condition of all 

samples. 

 The laboratory must have a SOP for sample custody within the laboratory. The 

laboratory logs all samples into a sample receipt logbook or computerized laboratory information 

system and documents the following information: 

 Date and time of sample receipt; 

 Project number and name; 

 Field sample number; 

 Laboratory sample number; 

 Sample matrix; 

 Analytical parameters; 

 Storage location; and 

 Log-in person’s initials. 

All information relevant to the samples is secured at the end of each business day. All samples 

are stored in a designated storage refrigerator with restricted access. 

 ERG uses an electronic sample tracking system to track the last date samples 

associated with each episode were received at the laboratory and the date of receipt of analytical 

data from the laboratories. 

3.2.4 Element B.4 - Analytical Methods 

 Table 3-4 identifies the analytes that are measured and the analytical methods that 

EPA uses for the industry self-monitoring program. The site-specific instructions provided to the 

plants contain the specific list of analytical methods that will be used for that sampling episode. 

The site-specific instructions also identify the sample volume to be collected, the QC sample 
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volume to be collected, the sample container type, and typical preservation required for each 

parameter. The additional volume collected for QC is used to perform matrix spike/matrix spike 

duplicate (MS/MSD) analyses and serial dilutions. 

 ERG uses information described above in combination with the site-specific 

sample conditions to select the proper sample volumes, bottle types, and preservation methods 

for each sample collected. Section 5.1 of this QAPP addresses the procedures for laboratory and 

data quality review. 

Table 3-4. Analytes and Analytical Methods Included in the Industry Self-Monitoring 

Program 

Parameter Method Number 

Classicals

Biochemical oxygen demand (BOD5) SM 5210 B 

Chemical oxygen demand (COD) EPA 410.4 

Total suspended solids (TSS) SM 2540 D 

Total dissolved solids (TDS) SM 2540 C 

Sulfate EPA 300.0 

Chloride EPA 300.0 

Ammonia as nitrogen EPA 350.1 

Nitrate/nitrate as nitrogen EPA 353.2 

Total Kjeldahl nitrogen (TKN) EPA 351.2 

Total phosphorus EPA 365.1 

Total cyanide SM 4500 CN E 

Total Metals

Total mercury EPA 1631E 

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

selenium, silver, thallium, and vanadium 

EPA 200.8 with collision 

cell 

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

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

zinc 

EPA 200.7 

3.2.5 Element B.5 - Sampling Quality Control 

 The industry self-monitoring program includes the collection of field quality 

control samples. Sampling QC activities are designed to measure or estimate the effect of 

sampling error such as contamination, matrix effects, and imprecision. The site-specific 

instructions specify the quantities and types of blank and duplicate samples to be collected 

during each episode. The analytical laboratories specify the actual quantity and types of 

laboratory QC samples that will be used; these requirements are specified “per sample set.” EPA 

defines a sample set as a group of not more than 20 samples prepared at the same time on the 

same day during the same shift by the same analyst. The following subsections describe the 

routine QC measures the laboratories conduct and the types of blank and duplicate samples the 

sampling crew collect during the project. 

 For the industry self-monitoring program, ERG verifies that the laboratories have 

the appropriate QA programs and data management programs in place and verifies that the 

laboratories performance is acceptable, as discussed in Section 3.1.5 of this QAPP. 
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3.2.5.1 Field QC Measures 

 Field quality control samples for this project include field blank samples. Table 3-

1 presents a list of the field quality control samples, the analytes analyzed, the purpose, and the 

frequency. Note that not all analytical methods require all of the QC measures listed. The sitespecific instructions discuss collection of these samples in greater detail. This section describes 

the field blank samples that are collected for the sampling program. 

Field Blanks 

 The plant sampling personnel collect field blanks for all sampling techniques used 

by the sampling staff and for special equipment used during the sample collection, such as 

cooling coils, tubing, etc. The field blank evaluates potential contamination of the sample from 

either the equipment used or ambient conditions. To collect field blanks, the sampling personnel 

pour or pump ASTM Type 1 water through all equipment used for the sample collection at the 

sampling location and into sample bottles. Multiple field blanks may be required if different 

sampling techniques are used or if ambient conditions are expected to vary from sample point to 

sample point. ERG assists EPA in selecting analyses for the field blank using requirements of the 

analytical methods. The laboratories analyze the field blank for the specified analytes. The sitespecific instructions lists the field blanks to be collected at each site. 

Purpose: To monitor potential contamination from sampling 

techniques (equipment used or ambient conditions). 

Recommended 

Frequency: 

For all the metals and mercury samples, one field blank at 

each sampling point for at least one set of the sampling 

episode. 

3.2.5.2 Analytical QC Measures 

 ERG ensures that all the analytical QC measures described in Section 3.1.5.2 are 

also performed by the laboratory for the industry self-monitoring program. 

3.2.6 Element B.6 - Instrument/Equipment Testing, Inspection, and Maintenance 

 ERG confirms that the laboratories selected to analyze samples have a 

comprehensive laboratory QA program in place that requires the laboratories perform preventive 

maintenance on all of their analytical equipment. 

3.2.7 Element B.7 - Instrument/Equipment Calibration and Frequency 

 ERG confirms that laboratories selected to analyze samples perform all required 

instrument calibration requirements, as described in Section 3.1.7.2 of this QAPP. 
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3.2.8 Element B.8 - Inspection/Acceptance Criteria for Supplies and Consumables 

 The individual plants are responsible to obtaining all the required supplies and 

consumables for the sample collection, including sample bottles, preservation chemicals, and 

sampling equipment. ERG includes the specification for the equipment in the site-specific 

instructions that are provided to each plant. ERG also verifies during the on-site audits that the 

plants are using the appropriate supplies for sample collection. 

 

3.2.9 Element B.9 - Non-Direct Measurements 

 The industry self-monitoring program is augmented and complemented by the 

same types of information as the EPA sampling program, which is described in Section 3.1.9 of 

this QAPP. 

3.2.10 Element B.10 - Data Management 

 ERG uses the same documentation, data reduction, data validation, and data 

reporting procedures for the industry self-monitoring program as the EPA sampling program, 

which is described in Section 3.1.10 of this QAPP. 

3.3 Questionnaire for the Steam Electric Power Generating Effluent Guidelines

 This section describes data generation and acquisition via the Questionnaire for 

the Steam Electric Generating Effluent Guidelines, which is referred to as the “questionnaire” 

throughout the remainder of this section (see Appendix C for the final version of the 

questionnaire). This questionnaire task includes collecting and reviewing data obtained from 

electric power generating plants; therefore, this section discusses the following five elements: 

 B.1: Sampling (data collection) process design; 

 B.2: Sampling (data collection) methods; 

 B.3: Sample (data) handling and custody; 

 B.5: Quality control; 

 B.9: Non-direct measurements; and 

 B.10: Data management. 

3.3.1 Element B.1 - Questionnaire Sampling (Data Collection) Process Design 

 EPA collected data from steam electric power generating plants regulated by the 

steam electric ELGs codified at 40 CFR Part 423. The electronic questionnaire consists of nine 

parts. EPA distributed four versions of the questionnaire. EPA distributed one version of the 

questionnaire to all coal-fired power plants and distributed the remaining versions of the 

questionnaire, discussed in Section 3.3.2, to a statistical subset of coal-, nuclear-, oil-, and gasfueled steam electric power plants. ERG provided EPA with information about the entire steam 

electric population using existing data sources, including information from the DOE’s EIA 

databases. EIA collects information on existing electric generating plants and associated 

equipment to evaluate the current status and potential trends in the industry. ERG used the 

information available from the 2007 Electric Generator Report (Form EIA-860), and 
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supplemented it with information found in Form EIA-923 and a survey conducted by EPA’s 

Office of Solid Waste and Emergency Response (OSWER), to create a listing of plants that have 

steam electric power generating activities believed to be subject to the existing Steam Electric 

Power Generating Effluent Guidelines. EPA shared the initial list of recipients to industry 

stakeholders and interested environmental organizations. EPA used feedback on the list to 

correct inaccurate addresses as well as identify plants that were not included or plants that were 

no longer in operation. EPA’s statistics team used the information from the revised list to 

identify the sample population to receive the questionnaire. 

 In addition to engineering and other technical data, the questionnaire was 

designed to obtain financial and economic information that will be used by EPA’s financial 

contractor for this rulemaking. At the request of EPA, ERG transferred all financial 

questionnaire sections to the economics contractor. Any financial information designated CBI 

will be handled by ERG according to ERG’s CBI security plan entitled Security Plan for 

Handling Confidential Business Information Under the Clean Water Act, dated September 25, 

2008 and approved by Ahmar Siddiqui, EPA’s Document Control Officer for this contract, on 

March 12, 2009, or its successor plan (5a, 5b). 

 ERG supported EPA in determining the total number of plants and identifying the 

subset populations to receive the questionnaire. ERG mailed an electronic MS Excel and PDF 

version of the questionnaire via CD to the selected plants. The information collected is aiding 

EPA in developing revised ELGs. See the Steam Electric ICR Supporting Statement (EPA-HQOW-2009-0819-0044) to identify the technical information that EPA collected from steam 

electric plants. 

3.3.2 Element B.2 - Questionnaire Sampling (Data Collection) Methods 

 The questionnaire consists of nine parts and covers the following topics: general 

plant information, FGD systems, ash handling, wastewater treatment, process equipment 

cleaning wastes, landfill/pond operations, nuclear generating units, and economic/financial 

information. ERG assured the quality of the questions in these parts, except for the 

economical/financial data (to be reviewed by the economics contractor), by researching the 

industry and performing multiple reviews of the responses. ERG assisted EPA in developing the 

questions using secondary data sources and information from site visits conducted in support of 

EPA’s detailed study of the steam electric category. Several EPA offices, states, environmental 

groups, industry, and trade associations reviewed draft versions of the questionnaire, and the 

questions were made publicly available for industry comment. The Office of Management and 

Budget (OMB) also completed a thorough review of the questionnaire. EPA revised the 

questions based on all comments received to make sure they would capture the specific 

information that is required for this rulemaking. 

 

 The questionnaire (information collection) was conducted under authority of 

Section 308 of the Clean Water Act (Federal Water Pollution Control Act, 33 U.S.C. Section 

1318). All steam electric power generating plants that received the questionnaire must respond to 

it. The questionnaire was mailed to steam electric plants identified by ERG through publicly 

available information. This plant list was reviewed by the Utility Water Act Group (UWAG) and 
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made available for public comment in order to ensure all plants covered by the steam electric 

ELGs were included and that appropriate plant addresses/contacts were listed. 

 All responses must include a certification statement signed by a responsible 

corporate official or his/her authorized representative. EPA ensures compliance with the 

information request by using a variety of means, including, as necessary, follow-up phone calls 

and letters, and appropriate sanctions, as provided by law. ERG is supporting EPA with followup phone calls and letters. 

 Four versions of the questionnaire were delivered to the steam electric power 

plants in the industry. Respondents are required to answer only those parts applicable to their 

plant. EPA distributed the questionnaire versions to the following plants in each designated fuel 

classification: 

 Version 1 (Parts A through I): Coal-fired power plants included in the 

statistical subset; 

 Version 2 (Parts A through D, H, I): Coal-fired power plants not included in 

the statistical subset; 

 Version 3 (Parts A through E, H, I): Oil-fired and combination power plants; 

and 

 Version 4 (Parts A, E, H, I): Gas- and nuclear-fired power plants. 

 The four versions of the questionnaire were printed on individuals CDs at the 

EPA printing office. The CDs were clearly labeled with the title and version of the questionnaire. 

 ERG followed specific procedures to ensure each facility receives the correct 

version of the questionnaire. ERG used the Mailout Quality Assurance (QA) Checklist to 

document that the assembly of each mailout package is correct and complete. ERG also 

documented which package was sent to each plant. ERG used the Steam Electric Tracking 

Database to document questionnaire delivery. This database is also intended to aid ERG in 

keeping track of questionnaire review, discussed in Section 3.3.4. QC activities associated with 

the mailout procedures include the following: 

 Checking each printed mailing label against the finalized mailing list and 

“checking off” the appropriate column on the Mailout QA Checklist; 

 Checking 10 percent of the CDs containing the questionnaire after receipt 

from EPA to make sure that all of the files required for the version are 

present and readable; 

 Assembling the mailout package, including the questionnaire cover letter 

and enclosures, the appropriate questionnaire version, and mailing label, 

and “checking off” on the Mailout QA Checklist that all Plant IDs match 

on all mailout documents; 
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 Performing a second check that the assembled package includes the 

correct cover letter, enclosures, questionnaire, and return label; 

 Tracking all questionnaire deliveries through Federal Express tracking 

mechanisms to confirm that the questionnaire was delivered and 

electronically transferring FedEx information into the Steam Electric 

Tracking Database; 

 Tracking all returned questionnaires to identify plants that did not respond 

or that provided incomplete responses; and 

 Initial follow-up via phone and written communications with plants 

providing incomplete responses. 

 ERG coordinated with EPA on further communication for non-responsive plants. 

These communications included a series of late letters or follow-up calls/letters from EPA, 

requesting the completion and return of the survey or any further follow-up necessary for 

questionnaire review. 

 All plants have the option to identify the information or part of the information 

submitted as CBI. A “CBI” checkbox appears next to each question on the survey so that the 

plant has complete control over which questions will be handled as CBI. See Section 3.3.3, for 

handling procedures of completed questionnaires, including those marked CBI. 

3.3.3 Element B.3 - Questionnaire Sample (Data) Handling and Custody 

 Completed questionnaires were mailed to ERG, where they were logged into the 

steam electric tracking database and transferred into the steam electric questionnaire database. 

See Section 3.3.6 for a discussion of the questionnaire database. Original completed 

questionnaires were logged into ERG’s Steam Electric Project File Index and stored as CBI in 

the electronic project file. EPA requested that all plants return an electronic copy of the 

questionnaire. In order to ensure data quality, ERG did not change original responses of the 

questionnaire during review and follow-up. ERG created working copies to complete these 

changes. See Section 3.3.4 for further discussion of questionnaire receipt. Any paper copies 

received were stored and only used as a reference to the original data submitted by the plant. 

ERG’s standard controls for project-related data, documents, and records are presented in the 

Steam Electric Power Generating Project File Management Plan (10). 

3.3.4 Element B.5 - Questionnaire Quality Control 

Helpline. ERG operated a steam electric questionnaire helpline to offer assistance 

to the plants responding to the questionnaire. Plant personnel were able to call in or e-mail 

specific questions regarding the questionnaire, receive guidance on how to respond, or receive 

technical assistance in using the electronic format. Helpline contact information was provided 

with the questionnaire instructions. ERG operated the helpline to ensure quality and 

completeness of questionnaire responses. ERG developed helpline guidelines so that information 
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provided via the helpline was correct and consistent. The helpline guidelines also provided 

instructions for correctly documenting any helpline communication with a plant. The helpline 

guidelines also included: 

 Requirements for determining if a plant needs to complete a part or certain 

sections; 

 Instructions/clarification on how to complete any part, section, question, or 

table; 

 Checklists for all required information for block/water balance diagrams; 

 Acceptable units of measure for specific questions; and 

 A log of responses to all issues encountered by plants during questionnaire 

completion. 

 Both a telephone line and e-mail helpline were provided for respondents to use to 

receive help in completing the questionnaire. The helpline log contained two logs, one for the 

telephone helpline and one for the e-mail helpline. Any phone or e-mail communications with 

facilities were documented in the helpline log. Each phone or e-mail message was represented by 

one line in the helpline log. Each message was identified by Plant ID, date, time, and assisting 

helpline personnel. This helpline log assisted ERG in quickly searching past questions and 

responses while operating the helpline. The helpline log also served as a template to develop a 

frequently asked questions (FAQ) document that was placed on EPA’s website and periodically 

updated to assist plants while completing the questionnaire. The final FAQ document is located 

in the public docket for the steam electric rulemaking. 

Data Receipt. ERG used a procedure to ensure the proper handling and storage of 

questionnaire responses. This procedure helped ensure that all questionnaire responses were 

received, tracked, saved, and copied to ERG’s CBI network. The process ERG followed upon 

initial receipt of the questionnaires included: 

1. Update the Survey Tracking table in the Survey Tracking database with 

the date ERG received the returned questionnaire. 

2. Perform a completeness check according to the checklist (see Appendix F) 

to ensure that all applicable files are returned and completed. 

3. Report to EPA the number of questionnaire responses that have been 

received to date (weekly). 

4. Create a working folder for each plant that has submitted a questionnaire 

response. Save a working copy of questionnaire responses and attachments 

in the working folder for questionnaire review. 

5. Save all data review and follow-up documentation in the working folder 

for each plant. 

6. Periodically deliver batches of the economic and financial part (Part I) of 

the questionnaire to EPA’s financial contractor, as questionnaires are 

received. 
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7. For each Part I delivered, extract raw data, including identifier information 

from Part A, for EPA’s financial contractor. Perform a QA review of 10 

percent of the extracted raw data for each delivery and deliver according 

to CBI handling procedures. 

8. Store the returned CD and any paper documents in the ERG project 

archive as original files. These files will not be altered or changed, 

regardless of any issues flagged during data review. 

 Data Review. ERG uses Data Review Guidelines (see Appendix E) to ensure the 

quality and completeness of the questionnaire responses. The data review guidelines include the 

data review procedure, the technical checklists, and the documentation required for questionnaire 

review and any resulting plant follow-up. The checklist includes electronic checks, 

reasonableness checks, and checks for technical content. 

Electronic Checks 

ERG performs electronic checks on each survey response to ensure that all data 

can be successfully extracted into the Questionnaire Database. These electronic checks include 

the following: 

 Confirming that original and copied tab names are named correctly; 

 Clearing radio button responses as instructed by plants in the survey part 

comments4

; 

 Identifying true zero responses (“0”) and replacing those responses with 

the code “-555”; 

 Identifying missing data5 and replacing those fields with the code “-111”; 

and 

 Performing a check on modified files (i.e., electronic survey files that 

required modification to allow a respondent to provide information on all 

operations) to confirm that all fields and electronic mapping were correct 

after the modifications. 

Reasonableness and Technical Checks for Version 3 and 4 Survey Responses 

ERG completes reasonableness and technical content checks for different sections 

of the survey based on the plant fuel type to prioritize the review of information received. These 

reasonable and technical checks include: 

 Confirming that any plants that “kicked out” of the survey truly are kick 

outs and do not need to provide responses to the remaining survey parts; 

 

4

 The Steam Electric Survey contains several questions that have radio button response fields. Once a radio button is 

selected, the plants are unable to remove their response. In cases where the radio button was mistakenly selected, 

respondents used the comment fields to notify EPA that the radio button should be left blank. 

5

 In order to track missing data in the database, ERG uses the code “-111” to identify those responses that are left 

blank, but should have been completed based on other responses in the survey. 
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 Confirming that responses to questions in different survey parts 

correspond to the responses provided in other survey parts (for example, 

the number of ponds reported in Part A matches the number of 

impoundments reported in Part D); 

 Based on survey responses in Part A (general technical information and 

system operations), checking that the plant reported all requested data; and 

 Confirming that responses for amounts, such as BTU generated by fuel 

type, are correct given the specified units in the survey. 

For all Version 3 and 4 plants (non coal- or petroleum coke-fired plants), ERG 

performs the completeness and electronic checks described above. After these checks, all of the 

surveys are extracted into the technical database. After extraction, ERG checks reasonableness 

and completeness for the Version 3 and 4 surveys using queries on the extracted data set. The 

specific reasonableness and technical checks for the Version 3 and 4 surveys include: 

 Confirming that all kick out responses are accurate; 

 Confirming that all Version 3 and 4 plants only report steam electric 

generating units burning fuel other than coal and/or petroleum coke; and 

 Correctly identifying gas powered combined cycle units and making the 

appropriate corrections to the data to accurately represent the industry. 

Reasonableness and Technical Checks for Version 1 and 2 Survey Responses 

ERG performs the same completeness and electronic checks on the Version 1 and 

2 survey responses as were completed for the Version 3 and 4 survey responses. However, 

because EPA’s proposed rulemaking focuses on waste streams generated at coal- and petroleum 

coke-fired plants, particularly FGD wastewater, ash transport water, and combustion residual 

landfill leachate, ERG performs additional technical review checks and follow-up contacts for 

the Version 1 and 2 survey responses (i.e., coal- and petroleum coke-fired plants). 

For a maximum of 50 percent of the Version 1 and 2 survey responses, ERG 

performs a technical review focusing on wet FGD scrubber data and treatment (Part B, Sections 

1, 4, 5, and 7), wet fly ash handling (Part C, Sections 2.1 through 2.5), wet bottom ash handling 

(Part C, Sections 3.1 through 3.5), and wastewater treatment/impoundment systems (Part D, 

Sections 3.1 and 3.2). ERG identifies missing data, develops a list of follow-up questions, and 

delivers these questions to the designated plant technical contact via telephone or e-mail. As 

plant responses are received, ERG updates the plant-level survey responses located in the plant 

working folders. ERG senior personnel perform second-level reviews on a minimum of 50 

percent of these survey responses to confirm that all surveys are reviewed appropriately. These 

second-level reviews include a review of the data reported in the survey and also all of the 

proposed changes identified by the first reviewer. 

For a minimum of 50 percent of the Version 1 and 2 survey responses, ERG 

performs a more detailed review. For these survey responses, ERG reviews the entire survey for 

completeness, reasonableness, and technical content. ERG performs follow-up calls and e-mails 

to obtain missing data or confirm specific data elements. As plant responses are received, ERG 
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updates the plant-level survey responses located in the plant working folders. The Version 1 and 

2 responses that receive this more detailed review are selected based on the type of treatment 

systems operating at the plant (identified from previous site visits) or are randomly selected. 

Similar to the other Version 1 and 2 reviews, ERG senior personnel perform a second-level 

review on a minimum of 50 percent of these survey responses to confirm that surveys are 

reviewed appropriately. 

Resolution of Technical Review Issues 

 Any outstanding issues noted on the technical checklist are documented in the 

working file for each plant. Outstanding issues that require plant follow-up are documented 

according to the data review guidelines and saved in the working file for each plant. Every 

telephone call and e-mail contact with the plant is documented in the Follow-Up Questions tab in 

the technical checklist. If a plant requests follow-up conversations in writing, ERG prepares and 

documents all follow-up letters and responses. Once all issues are resolved, ERG corrects the 

working copy of the questionnaire. 

 During the review and follow-up process, ERG makes changes to the working 

copy of the questionnaire. The first reviewer documents every potential change to the 

questionnaire that results from questionnaire review and plant follow-up in the Change Form tab 

of the technical checklist. This documentation includes the question number, cell reference (in 

the MS Excel questionnaire), a comment explaining the change, the date changed, and the initials 

of the reviewer that changed the document. During the QA review, the second reviewer confirms 

these changes to ensure that they are complete and appropriate. Once the second review is 

complete, the first reviewer makes changes to the working copy of the questionnaire. ERG 

makes changes to the working copies of the questionnaire to minimize the amount of changes 

made to the data once extracted into the database. All technical checklists are saved in the 

working folders of each plant and are located in the confidential portion of the steam electric 

rulemaking record. 

3.3.5 Element B.9 – Questionnaire Non-Direct Measurements 

While preparing the questionnaire for mailout, ERG acquired, organized, and 

analyzed secondary data to characterize plants for selection of the statistical subset. ERG 

compiled this secondary information into a sample frame database that includes all plants 

potentially in the scope of this questionnaire. The sample frame database was developed using 

data reported to DOE’s EIA in 2007. ERG supplemented the EIA data with primary data 

collected by EPA through site visits. Specifically, ERG reviewed 2007 data from Form EIA-860 

to characterize plants based on the reported NAICS code, type of fuel used, and prime mover. 

ERG further reviewed data reported to Forms EIA-860 and EIA-923 to identify plant 

characteristics such as the number of units, ponds/impoundments, and landfills to the sample 

frame database. 

3.3.6 Element B.10 - Questionnaire Data Management 

Based on industry feedback during public review of the Steam Electric ICR, ERG 

concluded that respondents are familiar and comfortable with using an MS Excel electronic 
Section No. 3 

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information request tool (electronic questionnaire). The electronic questionnaire allows 

respondents to record their responses in a computer file and submit them to EPA on a CD. 

 Upon receipt of the CD, ERG follows procedures outlined in the data review 

guidelines for handling the completed questionnaire, previously discussed in Section 3.3.4. ERG 

reviews responses, completes any necessary follow-up with facilities, and finalizes outstanding 

documentation regarding plant review and follow-up. Following review and follow up, ERG 

transfers the data from the completed questionnaire to the MS AccessTM questionnaire database. 

 ERG transfers all questionnaire responses (CBI and nonCBI) received into one 

questionnaire database. The questionnaire database as a whole is handled as CBI until such later 

time as a sanitization plan is made to create a nonCBI version for the public docket. The database 

is stored electronically on ERG’s CBI server. ERG is preparing a data element dictionary to 

document the CBI and non-CBI database structure and to serve as a guide for database users. 

 In order to transfer responses into the questionnaire database, ERG uses a 

program that references mapped answer cells from the MS Excel version of the questionnaire 

and transfers them into specific locations/tables in the database. ERG maps every worksheet of 

the electronic questionnaire and thoroughly checks all mapped references in each worksheet. 

 ERG performs several small “test runs” that pull different parts of the 

questionnaire into the database. ERG performs these “test runs” until all data are entered into the 

database without error. ERG then pulls in a complete “mock-up” questionnaire to check that all 

mapping references and data correctly transfer into the database. ERG checks the resultant test 

database to ensure correct data transfer. 

 ERG also completes a 100 percent check of the transfer of data from the first 

questionnaire response received for each version of the questionnaire. ERG notifies the EPA 

WAM of the results of the transfer. If mapping errors are detected (e.g., information is populated 

in the wrong fields or incorrect tables), ERG documents the error, corrects it, and continues to 

perform 100 percent checks on additional questionnaire responses until all data are transferred 

correctly. If data transfer errors are detected (e.g., data type mismatch, incorrect file name), ERG 

documents the error, corrects it, and re-extracts the data from that file. 

 

 ERG developed the following aspects of the data transfer program to efficiently 

extract data and minimize back end work in the database. 

Survey Review Table. The survey review table is a table in the database that 

includes a listing of all plant IDs and the status of their completeness check and 

review. The table includes several fields that are utilized to document complete 

and successful data transfer. The first field, marked by the survey reviewer, flags 

the reviewed questionnaires that are ready for data extraction. After a successful 

data extraction, the program removes the flag that marks the questionnaire as 

ready and the date and time of transfer are recorded in another field. However, if 

the data transfer is not successful, the flag that marks the questionnaire as ready is 

not removed, and another flag is added indicating an error. 
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Error Log. The error log is a table in the database that automatically updates 

during data transfer. If any transfer errors occur (i.e., data type mismatch, 

incorrect file name), the error log populates the Plant ID, table name, and field 

name where the error has occurred. 

True Zero Values. Due to the nature of the questionnaire, all blank text and 

numeric fields are stored as “0”. ERG developed a process to distinguish between 

the blank data and true zero values entered by the respondent. Because both 

values are entered as zero into the database, ERG developed the transfer program 

to import “0” and “-999.” In order to avoid importing true zero values as “-999,” 

survey reviewers enter “-555” during technical review. After data extraction is 

complete, blank fields show as “-999” and zero fields show as “-555.” The 

transfer program then automatically updates all “-555” values to zero. This 

process represents the actual data entered into the questionnaire. 

Blank Tables. There are certain aspects of the questionnaire that inevitably result 

in blank responses. These aspects include skip patterns and tables where 

respondents only answer the number of rows applicable. In order to avoid a 

database full of blank data, ERG developed the program to skip these rows of 

blank data. This results in a database populated with only the information from 

plants that have responded to a specific part, section, or subset of questions 

(depending on the skip patterns throughout the questionnaire). 

 To ensure that the database accurately reflects responses, ERG performs a 100 

percent comparison of the information transferred into the database to information recorded in 

the MS Excel file, for the first 5 percent of responses. This comparison also checks that the 

survey review and error log tables accurately reflect the results in the database. This QA review 

includes checks that blank data are recorded as “-999”, true zero responses are recorded as zero 

in the database, and that blank rows/tables of information not required (e.g., due to skip patterns) 

are not transferred into the database. 

 Following technical review and follow-up of the questionnaire responses, ERG 

transfers data into the questionnaire database. ERG does not expect to key enter any data, as a 

result of the electronic data transfer. However, in the event any data do require key entry, ERG 

performs a 20 percent check to ensure it has been accurately transcribed from hard copy. 

 

 Documentation for the questionnaire includes the questionnaire responses on CD 

or DVD, revisions or edits made by the response reviewer in the working copy of the 

questionnaire, the completed questionnaire review checklist, and documentation of 

communications with steam electric plant contacts via the helpline or follow-up contacts. These 

documents, except for the original CD/DVD response, are stored in a working file specific to 

each plant on ERG’s CBI network. The original CD/DVD responses are stored in the ERG CBI 

project archive. The questionnaire review task leader or his/her designee inspects the 

questionnaire review documentation to ensure that all records are legible and complete. ERG 

logs these records into the project file and copies of these records are provided to EPA as 

requested. ERG’s standard controls for project-related data, documents, and records are 

presented in Section 5 of the 2002 and 2013 QMPs (2a, 2b). 
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 ERG uses standardized practices for database queries (12) and database 

development (11) while executing the work described in this plan. The SOPs present 

requirements for identification and control of different versions of the database and its tables. 

These requirements include: 

 Assigning a unique name and number to the revised version of any 

database tables where revisions have taken place and maintaining a log of 

database table revisions. 

 Assigning a unique name and number to versions of the database. Also, 

maintaining a log that identifies database revisions and describes the 

changes made to the different versions. 

 ERG uses data in the steam electric questionnaire database to perform specific 

analyses. ERG constructs database queries to perform these analyses, following SOP for 

database queries (12). 

 Information collected through the questionnaire claimed as CBI by the steam 

electric facilities is handled according to the procedures as outlined in ERG’s CBI security plan 

entitled Security Plan for Handling Confidential Business Information Under the Clean Water 

Act, dated September 25, 2008 and approved by Ahmar Siddiqui, EPA’s Document Control 

Officer for this contract, on March 12, 2009, and its successor plan (5a, 5b). Only staff 

demonstrating their understanding of CBI handling procedures by passing a written test are 

permitted to access CBI on this project. 

3.4 Technology Option Costs and Pollutant Reductions

This section describes how ERG ensures that appropriate methods for data 

collection, generation, and acquisition are employed and documented to support the development 

of the industry profile, option costs, and estimates of pollutant reductions and non-water quality 

impacts. In addition to collecting and reviewing sampling and questionnaire data, described 

earlier, ERG collects and reviews secondary data, such as monitoring data and literature 

information, from a number of sources. Therefore, this section discusses the remaining two 

elements: 

 B.9: Non-direct measurements; and 

 B.10: Data management. 

3.4.1 B.9: Non-Direct Measurements 

 ERG uses secondary data to supplement the primary data collected for this 

rulemaking. These data, their intended use, and the decisions they support are described in 

Section 2.4 of this QAPP. Table 2-5 describes the acceptance criteria for using industry/vendor 

telephone queries as a source for estimating cost of treatment data. Sections 2.5.4, 2.5.4, and 

2.5.5 describe the acceptance criteria for using secondary data as a source for estimating costs 

and pollutant reductions for steam electric power plants. 
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 As EPA directs ERG to collect and/or analyze secondary data, ERG identifies 

possible data sources already in the project file, through a new literature search, and/or by 

contacting vendors and other researchers. ERG evaluates the collected data using the criteria 

listed in Table 2-5 and records the findings in a format appropriate for the data collection task (a 

memo, checklist, or other format). Data sources that meet Table 2-5 quality criteria are used for 

the purposes outlined in Table 2-5. 

 A standardized telephone record form is used by ERG researchers collecting 

information by phone from other researchers, or the EPA regional or state environmental 

agencies. This form, provided as Figure 3-1, ensures each person collects and records complete 

information about the contact (e.g., person called, telephone number, date, subject, etc) in a 

documented record that can be referred to during data analysis. ERG will conduct, as a 

minimum, a 10 percent review of all telephone records to verify the completeness of the 

collected information. Telephone record forms are submitted to the docket for the rulemaking. 

 The documentation of work presented to EPA identifies the sources of data, 

documents the assumptions made, and provides the equations and methods used for calculations 

to ensure the reproducibility of the work by qualified third parties. All project deliverables must 

meet EPA’s standards of transparency, objectivity, integrity, and utility as specified in EPA’s 

Information Quality Guidelines (4). 

Project No.: DISTRIBUTION 

Page 1 of 1 

 Project Name: 

TELEPHONE CALL 

RECORD 

 Outgoing Call 

Date: Time: 

Company Name: Contact Name: 

Phone No.: 

Name: 

GENERAL SUBJECT : 

TOPICS DISCUSSED AND ACTION TAKEN 

Figure 3-1. Telephone Contact Report Form 
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3.4.2 B.10: Data Management 

 ERG’s standard controls for project-related data, documents, and records are 

presented in the Steam Electric Power Generating Project File Management Plan (10). Standard 

controls for project-related data, documents, and records are also presented in Section 5 of 

ERG’s 2002 and 2013 QMPs (2a, 2b). This QMP presents detailed procedures that are used for 

managing any data collected for estimating technology option costs and pollutant reductions. 

ERG uses a database to keep track of all information collected for determining cost estimates and 

the processes used to estimate pollutant reductions. 

 Any secondary information claimed as CBI by the steam electric facilities or 

treatment vendors will be handled according to the procedures outlined in ERG’s CBI security 

plan entitled Security Plan for Handling Confidential Business Information Under the Clean 

Water Act, dated September 25, 2008 and approved by Ahmar Siddiqui, EPA’s Document 

Control Officer for this contract, on March 12, 2009, and its successor plan (5a, 5b). Only staff 

demonstrating their understanding of CBI handling procedures by passing a written test are 

permitted to access CBI on this project. 

In support of compliance cost and pollutant reduction modeling analyses, ERG is 

developing an MS AccessTM database and writing module code and queries to develop a 

national-scale compliance modeling tool for estimating the cost to comply with proposed 

regulatory options, as well as to estimate expected pollutant reductions and non-water quality 

impacts. ERG follows ERG’s SOPs for Databases in developing the database (11, 12). ERG is 

documenting the following elements of the compliance cost and pollutant reduction modeling 

activities in a methodology report: 

 Model description; 

 Flow charts (if necessary); 

 Database description; 

 Data sources; 

 Documentation of assumptions; 

 Discussion of any boundary or limiting conditions; 

 Documentation of default parameter values and their sources; and 

 Documentation of all equations (and sources, if applicable) used by the 

model to generate output. 

ERG documents database code development and modifications for each version of the model. 

Specific documentation that is kept in the project file for each version include: 

 Any code modules or database queries created to manipulate data includes 

either inline programmer comments or is documented in a separate file 

describing the purpose and equations used in the query; 

 A table is maintained (either in the database, as a tab in the spreadsheet, or 

as a separate file) that documents/tracks significant changes made to the 

model; and 
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 Errors identified and subsequent resolution are tracked either in the 

database, as a tab in the spreadsheet, or as a separate file. 

ERG tests each version of the model prior to delivery to EPA. Test cases are 

created for each version of the model and consist of a predetermined sequence of steps to be 

executed and the expected output or results. ERG establishes the specific test case criteria and 

testing sequences in consultation with the EPA WAM. ERG executes and documents the test 

cases once the test case criteria are established. 

3.5 Environmental Assessment Analysis 

This section addresses how ERG ensures that appropriate methods for data 

collection, generation, and acquisition are employed and documented to support qualitative and 

quantitative environmental assessment analyses. Activities include collecting and reviewing 

secondary data, such as monitoring data and literature information from a number of sources. 

Therefore, this section discusses the remaining two elements: 

 B.9: Non-direct measurements; and 

 B.10: Data management. 

 Elements B.9 and B.10 are appropriate for collection and analysis of secondary 

data and are, therefore, applicable for qualitative literature review activities and quantitative 

environmental modeling analyses based on secondary data sources. 

3.5.1 B.9: Non-Direct Measurements 

 ERG uses secondary data to supplement the primary data collected for this 

rulemaking. These data, their intended use, and the decisions they support are described in 

Section 2.4.7 of this QAPP. Section 2.5.5 describes the acceptance criteria for using secondary 

data as a source for qualitative and quantitative environmental assessment analyses to predict the 

environmental impacts from steam electric power plants. 

 As discussed in Section 2.4.7, ERG conducts a literature search using publicly 

available databases to document environmental impacts from steam electric discharges and to 

parameterize models for predicting changes in environmental impacts under varying technology 

option scenarios. ERG collects full bibliographic information on all relevant publications and 

tracks the information in the steam electric environmental assessment literature search database. 

 ERG prepares reports summarizing the results of the literature search and 

modeling results in formats directed by the EPA WAM. Formats could include annotated 

spreadsheets, designed to summarize monitoring data provided in the cited references. ERG may 

also prepare technical memoranda, including tables of findings and bibliographic citations. The 

documentation of the work presented in these deliverables identifies the sources of data, 

assumptions made, and calculations used in their development with sufficient transparency to 

ensure the reproducibility of the work by qualified third parties. All project deliverables must 
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meet EPA’s standards of transparency, objectivity, integrity, and utility as specified in EPA’s 

Information Quality Guidelines (4). 

3.5.2 B.10: Data Management 

 ERG’s standard controls for project-related data, documents, and records are 

presented in the Steam Electric Power Generating Project File Management Plan (10). Standard 

controls for project-related data, documents, and records are also presented in Section 5 of 

ERG’s 2002 and 2013 QMPs (2a, 2b). This QMP presents detailed procedures that are used for 

managing any data collected for the environmental assessment analysis. ERG uses the 

environmental assessment literature review database to document, track, classify, and summarize 

the environmental impact information collected during the literature search. The steam electric 

literature review database includes parallel columns to the steam project file database to allow 

information to be easily transferred between the two tracking systems to avoid duplicating work. 

 In support of environmental modeling analyses, ERG is developing an MS 

AccessTM database and writing module code and queries to develop a national-scale screeninglevel environmental modeling tool for estimating receiving water concentrations and wildlife 

tissue values required to meet the project objectives outlined in Section 2.5. ERG follows ERG’s 

SOPs for Databases in developing the database (11, 12). ERG documents the following elements 

of the screening-level water quality and wildlife environmental models in a methodology report 

for the environmental assessment: 

 Model description; 

 Flow charts (if necessary); 

 Database description; 

 Data sources; 

 Documentation of assumptions; 

 Discussion of any boundary or limiting conditions; 

 Documentation of default parameter values and their sources; and 

 Documentation of all equations (and sources, if applicable) used by the 

model to generate output. 

ERG documents database code development and modifications to code for each version of the 

model. Specific documentation that is kept for each version includes: 

 Any code modules or database queries created to manipulate data include 

either inline programmer comments or are documented in a separate file 

describing the purpose and equations used in the query; 

 A table is maintained (either in the database, as a tab in the spreadsheet, or 

as a separate file) that documents/tracks significant changes made to the 

model; and 

 Errors identified and subsequent resolution are tracked either in the 

database, as a tab in the spreadsheet, or as a separate file. 
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ERG tests each version of the model prior to delivery to EPA. Test cases are 

created for each version of the model and consist of a predetermined sequence of steps to be 

executed and the expected output or results. ERG establishes the specific test case criteria and 

testing sequences in consultation with the EPA WAM. ERG executes and documents the test 

cases once the test case criteria are established. 
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4.0 ASSESSMENT AND OVERSIGHT ELEMENTS

 This section describes the methods ERG uses to assess the quality of the work 

conducted for the Steam Electric Rulemaking and that this QAPP is implemented as prescribed. 

4.1 Element C.1: Assessments and Response Actions

 This section describes the technical review, audits, and corrective actions that are 

performed by ERG in support of the steam electric rulemaking to ensure the QAPP is 

implemented as approved. 

4.1.1 Technical Support 

 All work conducted by ERG in support of the Steam Electric Rulemaking is 

subject to technical review. This review is conducted by Deb Bartram, ERG’s Program Manager 

for this contract, or Thomas Finseth, ERG’s Work Assignment Manager. For sampling plans and 

SERs, the review is conducted by the applicable crew chief and ERG Work Assignment 

Manager. Review of project deliverables are documented in the project file. All deliverables are 

subsequently reviewed by EPA’s Steam Electric Rulemaking staff. 

 Betsy Bicknell will serve as the Project QA Coordinator. She uses the following 

tools to assess the implementation of QA/QC procedures on this project: 

 Review of the QAPP (this document) for completeness and applicability. 

 Audit of project files to ensure project staff have developed QC 

procedures, these procedures are used, and that the deliverable review 

process is documented. 

 At any time or at the end of the project or work assignment, the Contract QA 

Manager, Mary Willett, or her designee, may inspect the project QA files. 

4.1.2 Industry Self-Monitoring On-Site Audits 

 ERG supports EPA in auditing the sample collection conducted by industry 

personnel for some of the plants selected to participate in the self-monitoring program. 

ERG/EPA conducts these on-site audits to verify that the samples are collected in accordance 

with the site-specific instructions provided to each plant. ERG/EPA is auditing the “sampled 

plants” during the second month of the sample collection because experienced industry 

representatives that participated in EPA’s sampling episodes are scheduled to help the plants 

collect the samples during the first month. ERG/EPA is auditing the “non-sampled” plants during 

the first two days of the sample collection period. Sampling procedure checklists are used to 

document the findings of the audits. Appendix H includes the sampling procedure checklists 

developed by ERG. 
Section No. 4 

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 After the completion of each on-site audit, ERG prepares a memorandum 

describing the findings from the audit. These memoranda are provided to the EPA WAM, along 

with recommendations for corrective actions. 

4.1.3 Sampling and Analysis 

 At the completion of each sampling episode, the ERG crew chief or her designee 

reviews records of field activities and evaluates the following elements: 

 Overall level of organization and professionalism; 

 Compliance of all activities with the site-specific sampling plan and the 

Health and Safety Plan; 

 Compliance with procedures outlined in this QAPP; and 

 Completeness of field documentation (i.e., field logs, traffic reports, and 

data collection sheets). 

 Any issues that are identified are communicated to the ERG Work Assignment 

Manager and the Project QA Coordinator, who discuss any deficiencies with the sampling team 

and identify any necessary corrective actions for future sampling. If any of these deficiencies 

may potentially affect the integrity of the samples being collected, the ERG Project QA 

Coordinator immediately informs the sampling team and EPA WAM, so that any corrective 

actions can be taken. The findings of this review are also summarized in the quality assurance 

updates provided to the EPA WAM (see Section 4.2). 

4.1.4 Corrective Actions 

 The site-specific sampling plans guide all field activities conducted by the 

sampling crew during each sampling episode conducted under the Steam Electric Rulemaking 

sampling program. If deviations from the planned sampling and sample preservation protocols 

are required, these deviations are first approved by the onsite EPA representative at the sampling 

episode and then described in the crew chief’s field notes. Deviations from standard sample 

preservation protocols are noted on the comment section of the traffic report. All field sampling 

deviations are also described and explained in the site-specific SER along with a discussion of 

their potential impact on the sample results. If changes to established sampling collection, 

packaging, or shipping protocols are deemed necessary, they are discussed with the plant and 

industry representatives, approved by the EPA representative, and documented in writing as part 

of the sampling plans where they are implemented. 

 The site-specific instructions prepared for each plant that is participating in the 

industry self-monitoring program guide the sampling activities conducted by the plant staff. If 

deviations from the planned sampling and sample preservation protocols are required, the plant 

notifies ERG to discuss the proposed deviations. ERG immediately notifies EPA of the proposed 

deviations to receive EPA approval prior to directing the plant personnel on how to proceed with 

sample collection. The plant personnel are required to note all deviations in the sampling notes 
Section No. 4 

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and engineering data sheets that are provided to ERG after the completion of the monitoring 

program. 

 ERG also supports EPA in conducting on-site audits at some of the plants 

participating in the industry self-monitoring program. Based on the results of the audits, 

ERG/EPA may direct the plants to deviate from standard sample collection procedures based on 

the specific layouts at the plants. All deviations are discussed with EPA and noted on the sample 

note sheets. 

 ERG reviews all laboratory data generated from sampling episodes and the 

industry self-monitoring program for accuracy and precision, completeness, and comparability to 

ensure that the quality objectives and criteria discussed in Section 2.5 of this QAPP for these 

objectives have been met. Laboratory data validation procedures are provided in the analytical 

data review checklists. The data validation process encompasses five stages of review, as 

follows: 

 Data completeness evaluation; 

 Instrument performance check; 

 Laboratory performance check; 

 Method/matrix performance check; and 

 Data quality assessment. 

 Laboratory data that fail to meet the quality objectives and criteria are subject to 

corrective actions, such as reanalysis of the samples. ERG determines the corrective action 

required based on discussions with the analytical laboratory. 

 ERG reviews data generated from sampling episodes for precision of field 

duplicate results, sampling completeness, and representativeness. These analyses are documented 

in the site-specific sampling plan and SER. 

4.2 Element C.2: Reports to Management

 ERG describes QA activities conducted for major deliverables, such as summary 

memoranda, when such documents are delivered to EPA. These descriptions may be included in 

the document or in the transmittal email, as directed by EPA. Additionally, ERG provides the 

EPA WAM with monthly reports on the status of quality assurance (QA) activities. These reports 

are incorporated into ERG’s monthly technical progress reports which are supplemented to 

include the following: 

 Quality assurance activities performed during the reporting period as part 

of the implementation of the work assignment; 

 Identification of any problems encountered; 

 Identification of any deviations from the QAPP; and 

 Identification of problem resolution and/or corrective actions taken during 

the reporting period, if any. 
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In addition, any quality deficiencies detected by technical reviewers or the Project QA 

Coordinator are communicated, in writing, to the ERG WAM. The ERG WAM is responsible for 

ensuring that appropriate corrective action is taken and reported to the Project QA Coordinator. 
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5.0 DATA VALIDATION AND USABILITY ELEMENT

 This section describes data review, verification, and validation. It also discusses 

how validated data are evaluated to determine if they adequately answer the questions posed in 

Section 2.3.2 and meet the quality objectives stated in Section 2.5. 

5.1 Elements D.1 and D.2: Data Review, Verification, and Validation; and 

Validation Methods

 This section discusses how ERG checks information collected during the site 

visit, sampling and analysis, and questionnaire portions of this project to support EPA in 

assessing how they may be used. 

5.1.1 Site Visits, Sampling, Industry Monitoring, and Analysis 

 EPA, supported by ERG, is conducting an overall engineering assessment of the 

sampling and process data. This review considers the detected and non-detected pollutants, 

pollutant concentrations, laboratory quality control issues described in the data review narratives, 

traffic reports, method-specific information, and data variability in relation to the wastewater 

samples collected. Data are also reviewed to identify any calculation errors. ERG reports these 

measures of quality to the EPA WAM. 

 

 This section discusses the following elements that pertain to ERG’s review of 

results of laboratory analysis of samples collected during the EPA/ERG sampling program and 

the industry self-monitoring program. The review covers the following elements: 

 B.3: Sample handling and custody; 

 B.4: Analytical methods; 

 B.5: Quality control; 

 B.6: Instrument/equipment testing, inspection, and maintenance; 

 B.7: Instrument/equipment calibration and frequency; and 

 B.10: Project data management. 

 Laboratory reports of analytical results include: an analytical narrative discussing 

exceptions or QC irregularities, a list of the samples, the traffic reports for the samples, and 

method-specific information such as initial method calibration, continuing quality control results, 

other quality control measures, sample results, and raw instrument data. Table 5-1 outlines the 

plans for reviewing the packages received for the steam electric rulemaking project from the 

laboratories to ensure they are of sufficient quality for use in sampling program technical 

analyses. 
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Table 5-1. Data Package Detail Expected for Project Categories 

Quality Review 

Procedure 

Category 1 

Projects 

Category 2 

Projects 

Category 3 

Projects 

Category 4 

Projects 

Screening Level Data 

Review: 

Review of traffic reports, 

sample handling, and 

proper sample preparation 

   

Level 2 Data Review: 

Screening level review 

plus a review of sample 

QA/QC results 

  

Level 3 Data Review: 

Level 2 review plus 

review of instrument 

performance 

  

Level 4 Data Review: 

Level 3 review plus 

analysis of raw data such 

as chromatograms or 

primary instrument output 

 

 ERG uses standard review procedures and detailed method-specific checklists to 

review laboratory data packages. A detailed, method-specific checklist is completed for each 

sample set and provides specific information for individual samples, as needed. For example, all 

samples analyzed by the laboratory for a single calibration in a valid sequence that includes 

calibration and sample results are reviewed. Each data review consists of the stages described in 

the following subsections. 

 

EPA plans to use the analytical data from the sampling program to the maximum 

extent possible; however, the data need to be of the quality necessary to respond to the key 

questions in Section 2.3.2, as well as support the potential development of ELGs for the industry. 

To ensure the quality of the analytical data used in support of this program is of sufficient 

quality, the following questions are answered: 

1. Did the analytical laboratory document the sample receipt and receipt 

conditions properly? 

2. Did the analytical laboratory follow the sample handling and preparation 

procedures specified in the method (e.g., holding times)? 

3. Did the laboratory follow method-specific QC requirements (e.g., 

instrument performance and calibration, method blanks, recovery of 

labeled compounds)? 

4. Should any data qualifiers be added to the analytical database prior to 

using the results in technical analyses? 
Section No. 5 

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5.1.1.1 Sample Handling and Custody 

 During the data review, ERG reviews documentation of laboratory sample 

handling to determine if all method requirements are met. ERG developed data review checklists 

that comport with the analytical methods used for the project (see Appendix D for the methodspecific checklists). The checklists include items pertaining to storage requirements and sample 

hold time requirements to verify the laboratory’s sample handling procedures and 

documentation. 

 Sections A, B, C, and D of the review checklists evaluate the common sample 

handling and custody requirements of all analytical methods. Sections A and B are fundamental 

to the identity and traceability of the sample. Additionally, Sections C and D include 

specifications for sample hold time and preparation/extraction of samples. These sections are 

described below: 

 SECTION A: Data Package Contents and Sample Identifiers. Each 

sampling episode data package needs to identify samples and include 

sufficient data for the data review to ensure the quality of the results can 

be determined. Items for this part of the check list include laboratory 

name, EPA project name, sampling episode number, sample identification 

number (SCC number), data reviewer signature, and date. The data 

reviewer performs an initial check to confirm that all the data required for 

the review are in the data package. 

 SECTION B: Traffic reports. Traffic reports are the link between the 

field sampling information and the laboratory analysis. Traffic report 

forms are generated with every set of samples sent to a laboratory for 

analysis. The traffic report is the source of the data identifiers necessary to 

track the origin of the samples. ERG reviewers determine completeness of 

the sample receipt records, receipt date, sample identification numbers, 

sample receipt temperature, and condition. 

 SECTION C: Sample Handling Information. Sample shipments 

received by a laboratory are checked for proper container material, 

preservation, and hold time. The initial hold time check determines if 

samples were not held in the field past their expiration date making the 

analysis results invalid. Hold time prior to extraction is determined from 

the day of collection to the day samples are processed by extraction. ERG 

reviewers determine if sample results are invalid due to improper 

preservation or excessive hold time prior to extraction. 

 SECTION D: Sample Preparation and Extract Handling Information. 

Data reviewers determine if laboratories reported if samples were stored at 

the appropriate temperature as specified by the method. Data reviewers 

also check the validity of the analysis hold time to method requirements. 

The analysis hold time is measured from the time of preparation/extraction 

of the samples by the laboratory to the time of sample analysis. 
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5.1.1.2 Analytical Methods 

 The sampling plans list the analytical methods that EPA is using during the steam 

electric rulemaking project. ERG determines if the laboratory followed all method-specified 

requirements and documents the findings in the method-specific checklists. 

 Method-specific QC involves reviewing the primary instrument calibration and 

performance measures. At a minimum, these reviews typically include verification of equipment 

calibration, blank preparation, spiking procedures, and assessment of field QA samples from the 

sampling episode. Classical parameters, such as total suspended solids (TSS), are measured 

following simple calibration, blank, and spike procedures, and typically require only the 

minimum review components. Reviews for higher level instrumental techniques, such as those 

used to measure toxic metals concentrations, typically involve evaluation of the response and 

recovery of unique and/or labeled analytes as a key indicator of method performance. Several 

methods also require laboratories to provide data on initial precision and accuracy to demonstrate 

their ability to perform the requested analysis on a sample in a “clean” matrix. ERG verifies that 

the laboratory followed all method-specific requirements and documents the findings in the 

method-specific checklists. 

5.1.1.3 Quality Control 

 EPA’s Office of Research and Development (ORD) specifies project categories 

based on the intended end use of the data collected6

. This categorization is used to determine the 

level of review required, as discussed in Section 5.1.1.6. The following describes typical QC 

requirements:

 Category 1: Projects defined as a study to generate data used for 

enforcement activities, litigation, or some research projects involving 

human subjects. The QAPP for category 1 projects must address all 

elements listed in EPA Requirements for Quality Assurance Project 

Plans.

7

 Category 2: Project defined as a study to generate data used in support of 

the development of environmental regulations or standards. The QAPP for 

category 2 must address all elements listed in EPA Requirements for 

Quality Assurance Project Plans8

.

 Category 3: An applied research project defined as a study to generate 

data to demonstrate the performance of accepted processes or technologies 

under defined conditions. These studies are often pilot- or field-scale. 

 

 

6

 See http://www.epa.gov/ORD/NRMRL/qa/guide/qadocsformsplanning.htm. 7

 See EPA Requirements for Quality Assurance Project Plans (March 2001), available online at 

http://www.epa.gov/QUALITY/qs-docs/r5-final.pdf. 

8

 See EPA Requirements for Quality Assurance Project Plans (March 2001), available online at 

http://www.epa.gov/QUALITY/qs-docs/r5-final.pdf. 
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 Category 4: A basic research project defined as a study to generate data 

used to evaluate unproven theories, processes, or technologies. These 

studies are often bench-scale. 

 

 QA/QC data supporting each of these categories is provided with different levels 

of detail. The steam electric power generating analytical data is classified as Category 2 data 

since EPA may use the data to develop regulations or characterize the performance of various 

treatment technologies. 

 ERG documents information and data collected during the steam electric 

rulemaking project in SERs, which are used by EPA and ERG in conducting additional technical 

analyses. Prior to using the data in the SER and technical analyses, the analytical data received 

from the laboratories must undergo a QC review to ensure the completeness, sensitivity, 

representativeness, precision, absence of sample contamination, accuracy, and comparability of 

the laboratory results. 

 For the data review, ERG reviews the laboratory data packages to ensure that 

proper laboratory quality control procedures were followed. ERG documents the results of the 

laboratory QC review in the method-specific checklists and final data review summary. The 

primary objective of this data review is to assess whether the results from chemical analyses for 

sampling episodes are of the quality necessary for use in developing effluent guidelines for this 

industry. 

5.1.1.4 Instrument/Equipment Testing, Inspection, and Maintenance 

 ERG reviews the laboratory data packages to determine if the laboratories used 

the appropriate equipment, preparation material, columns (if applicable), and detectors during the 

analysis of each sample. 

 The laboratories selected to analyze samples must perform preventive 

maintenance on all of their analytical equipment. Equipment maintenance log books must 

contain records of equipment usage, maintenance, modifications, calibrations, and repairs. 

5.1.1.5 Instrument/Equipment Calibration and Frequency 

 The laboratories selected to analyze samples are responsible for performing all 

required instrument calibrations. Instrument calibration procedures, including frequency 

specifications and maintenance requirements, are specified in the analytical methods. ERG 

verifies that calibration measurements were performed and/or verified with calibrated systems at 

the specified frequencies by reviewing the criteria listed in Section E of the method-specific 

checklists. 

5.1.1.6 Analytical Data Review Results 

 For each sampling episode and each analyte group (classicals, metals), the data 

package contains a standard electronic format including the chemical analysis results and a 

portable document format (PDF) file containing the supporting laboratory documentation (e.g., 
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traffic reports, laboratory checklists, instrument calibration information). ERG uses the 

electronic data package to conduct the analytical data review, verification, and validation. 

 ERG documents the results of the analytical data review using method-specific 

checklists and a data review summary for each sampling episode as follows: 

 Method-specific checklists – ERG provides a completed method-specific 

checklist for each sample number or range of sample numbers for each 

analyte; and 

 Data review summary – ERG provides a data review summary for each 

analyte group, which summarizes the results of the data review, 

verification, and validation. The data review summary also includes a 

discussion of any data qualifiers and the reason for the qualifier. The level 

of detail for the data review summaries is described further below. 

 The level of detail for the data quality review should also be based on a graded 

approach that varies according to the intended end use of the data. The amount and sophistication 

of data review should depend on the data available and the category of the project. In the case of 

the steam electric rulemaking project, ERG expects that all data will undergo a Level 3 data 

review. If the data qualifiers fail at any stage of the data review, the reviewer may recommend 

not proceeding with the next stage of data review. The levels of data review are summarized 

below. As shown in Table 6-1, the steam electric project is a Category 2 project and Levels 1 

through 3 are required. ERG starts with the Level 1 review and works through to Level 3. 

 Level 1 – Perform Screening Review of Sample Receipt and 

Condition. This level of review is applicable for data that are intended for 

screening purposes (e.g., determining the presence or absence of a target 

or surrogate). 

 Level 2 – Evaluate Sample Receipt and Condition Plus Basic QA/QC 

Review. This level of review is applicable to data that are used to 

characterize process performance and is used to determine if the data 

adequately represent the process. Basic QC at Level 2 includes findings 

about sample condition on receipt, storage, stabilization, preparation and 

QC spiking requirements. 

 Level 3 – Evaluate Instrument Performance and Ongoing QC. This 

level of review is applicable for data that are intended for use in regulatory 

development or compliance certification. Level 3 review includes review 

of the data for compliance with all sections of the method-specific 

checklist except raw data review. 

 The data review summaries include a narrative summary and findings of all areas 

where the QC does not meet the QAPP or method requirements. Each data review summary 
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describes QC results so EPA can determine how the data can be used for the steam electric 

rulemaking project, as described in Tables 2-1 and 2-2. 

 

 Data review findings that indicate noncompliance with method requirements (i.e., 

a check list “No” is indicated) are supported by comments regarding use of the data and the 

appropriate flag that should be entered into the corresponding data base. The following flags are 

used in the steam electric sampling program: 

 * LCS or LCSD is outside of laboratory control limits; 

 ^ ICV, CCV, ICB, CCB, ISA, ISB, CRI, CRA, DLCK or MRL 

standard: Instrument related QC exceeds the control limits; 

 4 MS and/or MSD did not meet lab criteria, but sample 

concentration is four times greater than the matrix spike 

amount, so control limits are not applicable; 

 B Compound was found in the blank and sample; 

 D Lab duplicate RPD greater than method-specified criteria; 

 E Sample analyzed outside holding time; 

 F MS and/or MSD not within laboratory control limits. 

 H Sample was prepped/analyzed beyond the specified holding 

time; 

 J Result measured above the method detection limit, but below 

the report limit; 

 L LFB (LCS) % recovery not within method-specified criteria, 

but is within laboratory-specified criteria (L) 

 ND Sample result less than 5x laboratory blank result; 

 O OPR percent recovery outside method acceptance criteria; 

 P Sample not preserved directly following collection; 

 R MS/MSD percent recovery outside method acceptance criteria; 

 s Seed correction blank recovery low; 

 T Receipt temperature above method requirements; 

 U Result below the MDL; and 

 Matrix PDS, MS/MSD failed recovery. 

EPA reviews the data collected as part of the EPA sampling program against the data 

quality review criteria in Table 2-1 to evaluate whether it is of sufficient quality for use in the 

rulemaking. Based on the review of the analytical data, EPA makes data point-specific 

determinations as to whether the data should be included in the rulemaking analysis. 

5.1.2 Questionnaire for the Steam Electric Power Generating Effluent Guidelines 

 ERG reviews the questionnaire database to ensure that data have been recorded, 

transferred, and processed correctly; for example, by checking for transcription and calculation 

errors. ERG’s questionnaire data handling, custody, and review procedures ensure the quality 

and completeness of questionnaire responses and are described in Section 3.3. 

 Section 3.3.6 describes ERG’s data management procedures developed to verify 

transcription of questionnaire data. ERG uses procedures appropriate to the data source and 
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transfer procedures to verify that data obtained from existing databases have been transcribed 

accurately. Specifically, any data transcribed from paper copies undergoes a 20 percent check to 

ensure it has been accurately entered. In order to ensure as little transcription error as possible, 

EPA requires plants to respond to the questionnaire electronically. Data are also reviewed to 

identify calculation errors. ERG resolves all transcription errors identified. 

 See Sections 2.5.2 and 3.3.4 for more information regarding checks that ERG uses 

to determine the internal consistency, completeness, and reasonableness of the questionnaire data 

as discussed in the Table 2-2 acceptance criteria, including ERG’s data review guidelines and 

technical review checklists. ERG reports these measures of quality to the EPA WAM. 

5.1.3 Technology Option Costs and Pollutant Reductions 

 See Sections 2.5.3 and 2.5.4 for more information regarding data acceptance 

criteria (Table 2-3) and quality specifications (Table 2-4) that ERG uses to assess cost data. ERG 

reports these measures of quality to the EPA WAM. 

To ensure the accuracy of secondary data transmitted either through paper copy or 

electronically, ERG follows ERG’s SOPs for Spreadsheets and Databases (11, 12, 14), including 

documenting all data sources used. ERG follows all data management procedures outlined in 

Element B.10, Data Management (Sections 3.1.10, 3.3.6, and 3.4.2 of this QAPP). To verify the 

accuracy of data entered from paper copy documents into electronic format, 10 percent of all 

paper copy data arecompared with the data in the database. If errors are detected, ERG 

documents and corrects the errors, and additional checks of paper copy data are performed. 

For modeling tools developed by ERG in MS AccessTM, ERG assigns a technical 

reviewer to review and verify module code and query code to check the correctness and accuracy 

of the governing equations and to assure that the database code is fully operational. ERG verifies 

the input files and changes to model input parameters are correct using ERG’s established 

technical review process as outlined in Section 4.1.1. Specifically, the model outputs receive 

several reviews: 

 A project engineer checks that the calculations reflect the planned 

methodologies. Where the calculations and assumptions documentation do 

not agree, ERG determines if the documentation or calculations require 

corrections and ensures the corrections are made. 

 An engineer involved in the models development checks the accuracy of 

the calculations in the models code/queries by performing hand 

calculations and comparing the results to the model outputs. Where the 

model and hand calculations result in a discrepancy, the model is corrected 

and re-checked to ensure the correct calculations are being executed by the 

model. 

 An engineer provides independent technical review of the model outputs. 

The outputs are checked to ensure the expected number of records (i.e., 

the number of known plants incurring costs/discharging). Specifically for 

the cost model, the engineer confirms that the individual cost elements 

sum to the calculated total for each category of costs presented in the 
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output (e.g., the sum of all individual capital cost elements equals the 

calculated total capital cost). The engineer also checks that the cost model 

output calculates the total annualized costs appropriately by calculating 

the plant-specific values in Excel and comparing them to annualized costs 

presented in the output. 

 After each model run, an engineer analyzes the specific model outputs for 

the expected changes based on industry profile changes or changes to the 

model equations and/or inputs. The engineer performs the following types 

of checks: 

o Confirms that plants removed from the industry profile no longer 

have compliance costs or pollutant loadings in all outputs (e.g., 

FGD biological treatment, fly ash, bottom ash); 

o Confirms that plants identified as incurring compliance 

costs/discharging wastewater are included in all applicable cost 

and loadings outputs; 

o Confirms that plants incurring compliance costs also have a 

calculated pollutant loading, where appropriate; and 

o Confirms that changes to models and/or model inputs, such as flow 

rates, factors, or equations, result in the expected change in the 

specific cost elements/loadings in the model outputs. 

 The engineer notes issues or discrepancies and the model outputs are 

corrected. The engineer re-checks the new outputs for all issues identified. 

 A senior engineer reviews the costs and loadings by comparing the 

estimates for each plant and technology, and evaluating whether the trends 

in costs/loadings reflect the amount of wastewater treated or ash handled 

and the baseline waste management strategies. 

 ERG defines model calibration as the process of adjusting model parameters 

within physically defensible ranges until the resulting predictions give the best possible or 

desired degree of fit to the observed data. ERG defines model verification as the comparison of 

predictions between a calibrated model and available data that were not used in the model 

development and calibration. ERG uses cost data for specific plants to calibrate and verify model 

estimates are reasonable. EPA sought costs for plants through the Steam Electric Survey but 

obtained only limited or incomplete information. EPA also compares summary statistics for cost 

model outputs to survey responses for total capital, purchased equipment, installation, buildings, 

and site preparation, as well as indirect costs such as engineering and construction expenses. In 

certain cases, where cost data may be unavailable from plants in operation, EPA relies on the 

cost data provided by the vendors. EPA compares the vendor data for consistency and 

reasonableness. 

5.1.4 Environmental Assessment Analysis 

 To ensure the accuracy of secondary data used in the environmental assessment 

analysis, ERG follows the same procedures outlined in Section 5.1.3. For modeling tools 

developed by ERG in MS AccessTM, ERG assigns a technical reviewer to review and verify 

module code and query code to check the correctness and accuracy of the governing equations 

and to assure that the database code is fully operational. ERG verifies the input files and changes 
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to model input parameters are correct using ERG’s established technical review process as 

outlined in Section 4.1.1. 

 ERG defines model calibration as the process of adjusting model parameters 

within physically defensible ranges until the resulting predictions give the best possible or 

desired degree of fit to the observed data. ERG defines model verification as the comparison of 

predictions between a calibrated model and available data that were not used in the model 

development and calibration. ERG uses available stream monitoring data at select sites from 

secondary sources to calibrate and verify model estimates of receiving water concentrations are 

reasonable. ERG also evaluates the fish tissue concentrations calculated by the wildlife model, 

and sets calibration factors for the mercury fish tissue concentrations and subsequent human 

exposure doses from fish consumption. 

5.2 Element D.3: Reconciliation with User Requirements

 Completed questionnaires and sampling data are primary data sources that ERG 

uses to assist EPA in answering, at least in part, each of the key questions posed in Section 2.3.2. 

Questionnaire responses provide detailed descriptions of plant characteristics, manufacturing 

operations, wastewater generation, pollutant presence, and treatment technologies in use. 

Questionnaire data, in combination with other data sources such as sampling and secondary data, 

are used in a variety of calculations and analyses throughout the rulemaking. All primary data 

calculations and analyses are thoroughly documented for the project file in spreadsheets, 

databases, calculations, database programs and queries, and technical memoranda and 

documents. Only acceptable questionnaire data are used in calculations and analyses, and any 

data limitations or assumptions are clearly described to the user. 

 The data collected during the steam electric rulemaking can be used to answer the 

questions posed in Section 2.3.2 by clearly identifying the presence (concentrations of pollutants 

above the analytical method minimum level) or non-presence (concentrations of pollutants below 

the analytical method detection level) of analytes in the sampled wastewater, and best available 

technologies to control wastewater generated in this industry. The sampling data collected under 

the steam electric rulemaking project are considered sufficient for identifying best available 

technologies, because the plants chosen for the sample collection operate the state-of-the-art 

technologies, the samples are collected under the specified procedures to minimize sample 

contamination, the analytical laboratory document the sample receipt and receipt conditions 

properly, the analytical laboratory follow the sample handling and preparation procedures 

specified in the method (e.g., sample hold times), the laboratory follows method-specific QC 

requirements (e.g., instrument performance and calibration, method blanks, recovery of labeled 

compounds), and any data qualifiers are added to the analytical database prior to using the results 

in technical analyses. 

 ERG clearly identifies the sources of secondary data collected in all project 

deliverables, as well as the limitations of the data. ERG thoroughly documents all calculations 

and analyses for the project file in spreadsheets, databases, calculations, database programs and 

queries, technical memoranda, and documents. Only reviewed and accepted data are used in 

calculations and analyses, and any data limitations or assumptions are clearly described to the 
Section No. 5 

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user. Data produced or developed under this work assignment are reconciled with project goals 

during the technical review process as described in Section 4.1. 
Section No. 6 

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6.0 REFERENCES

1. U.S. Environmental Protection Agency, EPA Requirements for Quality Assurance 

Project Plans QA/R-5, EPA/240/B-01/003, Office of Environmental Information. 

March 2001. 

2. a. Eastern Research Group, Inc. Quality Management Plan for Technical Support 

for the Strategy for National Clean Water Industrial Regulations, June 2002. 

b. Eastern Research Group, Inc. Environmental Engineering Support for Clean 

Water Regulations Quality Management Plan, January 2013. 

3. U.S. Environmental Protection Agency, EPA Requirements for Quality 

Management Plans QA/R-2, EPA/240/B-01/002, Office of Environmental 

Information. 2001. 

4. U.S. Environmental Protection Agency, Guidelines for Ensuring and Maximizing 

the Quality, Objectivity, Utility, and Integrity of Information Disseminated by the 

Environmental Protection Agency, EPA/260R-02-008, October 2002. 

5. a. Eastern Research Group, Inc. Security Plan for Handling Confidential Business 

Information Under the Clean Water Act. September 25, 2008. 

b. Eastern Research Group, Inc. Security Plan for Handling Confidential Business 

Information Under the Clean Water Act. November 9, 2012. 

6. Eastern Research Group, Inc., Standard Operating Procedure for Wastewater 

Sample Packing and Shipping, SOP No: ERG-CHA-007, 30 April 2007. 

7. Eastern Research Group, Inc., Standard Operating Procedure for Wastewater 

Sample Preservation, SOP No: ERG-CHA-011, 30 April 2007. 

8. Eastern Research Group, Inc., Draft Standard Operating Procedure for Collection 

of Samples for Analysis of Low Level Metals by EPA Method 1669, SOP No: 

ERG-CHA-016, 30 April 2007. 

9. U.S. Environmental Protection Agency, Method 1669: Sampling Ambient Water 

for Trace Metals at EPA Water Quality Criteria Levels. July 1996. 

 

10. Eastern Research Group, Inc., Steam Electric Power Generating Project File 

Management Plan. September 25, 2009. 

11. Eastern Research Group, Inc., Standard Operating Procedure for Databases: 

Developing, Documenting, and Evaluating Accuracy, SOP No.: ERG-CHA-003, 

Revision 1, 22 June 2006. 
Section No. 6 

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12. Eastern Research Group, Inc., Standard Operating Procedure for Database 

Queries: Developing, Documenting, and Evaluating Accuracy, SOP No.: ERGCHA-004, Revision 1, 22 June 2006. 

13. Eastern Research Group, Inc., Standard Operating Procedure for Deliverable 

Review Sign-Off Sheets, SOP No: ERG-CHA-001, 10 December 2002. 

14. Eastern Research Group, Inc., Standard Operating Procedure for Developing, 

Documenting, and Evaluating the Accuracy of Spreadsheet Data, SOP No: ERGCHA-002, December 10, 2002. 
Appendix A 

LIST OF SITE VISIT OBJECTIVES 
A-1

List of Site Visit Objectives

EPA is interested in observing and documenting all sources of wastewater generated 

within the steam electric process, but is particularly interested in observing the following: 

 Coal pile, wet ash handling, and air pollution controls (e.g., FGD systems) and the 

wastewaters generated by these processes. 

 Wastewater treatment systems and final outfall/discharge points from the facility. 

General

 At what points in the process does the facility collect samples for compliance or 

other monitoring? How are the samples collected (e.g., grab samples vs. 

composites)? What is the frequency of this sampling? How does the variability in 

the wastewater at these points determine when and how the sampling is 

performed? 

 What type(s) of coal is used at the facility? What is the source (i.e., from which 

mine or geographic area does it come)? Does the facility blend two or more 

different types of coal together? If so, what percentage of each type of coal is 

used? What are the characteristics of the coal (e.g., sulfur, ash, mercury, and other 

metals content)? 

Sampling Questions

The following questions apply for each of the waste streams that are potential sampling 

points: 

 Where does the facility collect samples of the waste stream? How does the 

facility collect samples of the waste stream? Are there any issues/problems with 

collecting samples of the waste stream? 

 Where is the best place to collect the sample? Consider what the waste stream 

represents at the point of collection. Is the waste stream segregated at the 

collection point? 

 Is the waste stream discharged continuously? If not, are there certain times of 

day/year that the stream is discharged? If the waste stream is discharged 

intermittently, can the facility control the time of discharge for EPA to collect 

samples? 

 What is the best way to collect the sample? Peristaltic pump and tubing, bottle 

dipper, have the facility install a temporary tap. 

 What are the characteristics of the waste stream? 

o pH 

o Temperature 

o Pressure 

o Buffered solution 

o Solids Content 
A-2

 What hazards are associated with collecting a sample from the waste stream? 

o Splash hazards 

o Confined space 

 When is a good time to sample representative operations? Are there outages 

during certain times of the year? When are SCRs operating? Are there any times 

of the year when the wastewater discharges are uncharacteristic of typical 

discharges? 

Waste Stream Specific Questions

The following general questions apply to each of the waste streams generated by the 

steam electric process: 

o What is the source of the wastewater? 

o How is the wastewater treated prior to discharge? 

o With which other process waste streams is the wastewater commingled? 

o What is the frequency of the discharge (i.e., intermittent, regular/irregular, 

or continuous). 

o What is the typical flow rate for the waste stream? 

o How is the flow rate for the waste stream monitored? 

o What is the variability of the waste stream? 

 How does the discharge frequency vary? 

 How does the flow rate vary? 

 How do the pollutant concentrations vary? 

o What are the factors that impact the variability of the wastewater? 

Source Water, Coal Pile, & Boilers

 Where does the facility collect its intake water? Are there other points where 

process system influent waters may be sampled (e.g., following pretreatment)? 

 Is there runoff generated from the coal pile (i.e., is it uncovered)? If so, where is 

the coal pile runoff collected and has the waste stream ever been sampled? 

 If the plant uses pulverized coal, is there wastewater generated from the 

pulverizers (e.g., wash water)? 

 How frequently does the facility clean the boilers? How often does the facility 

generate chemical cleaning wastewaters? 

 How frequently does the facility discharge boiler blowdown? How is the boiler 

blowdown controlled? What wastewater discharges are generated from the boiler 

feedwater treatment system? 

Air Pollution Control Wastes

 What type of fly ash handling system does the facility have? If it is a wet system, 

how frequently does the sluicing occur? How much water is used for each 

sluicing? Source of sluice water and degree of recycle? 
A-3

 What type of bottom ash handling system does the facility have? If it is a wet 

system, how frequently does the sluicing occur? How much water is used for 

each sluicing? Source of sluice water and degree of recycle? 

 What type of FGD system does the facility have? What type of sorbent is used in 

the system? Does the facility oxidize the FGD waste to produce gypsum? If so, 

what type of washing is performed on the gypsum prior to sending it off-site, and 

how are wastewaters from the washing process handled? 

 How is the FGD system operated? What parameters are used to control the 

system? How are the parameters measured? 

 Does the facility have a selective catalytic reduction (SCR) system or a selective 

non-catalytic reduction (SNCR) system? If so, what wastewater discharges are 

directly associated with the system? What wash waters are generated that may be 

contaminated with pollutants associated with the system? 

 Does the facility have an advanced mercury control system? If so, what type of 

system? What wastewater discharges are directly associated with the system? 

Cooling Water

 What type of cooling system does the facility use (i.e., once-through or 

recirculating)? What type of biocide does the facility use? How frequently does 

the facility use the biocide for biofouling control? What biocide management 

practices does the facility use? Does the facility have a dechlorination system? 

How variable are the facility’s chlorine discharges from the cooling system? Data 

recorded? Seasonal effects due to changing organic content of intake water? 

Treatment Technology Questions

 Which waste streams are treated as segregated streams (i.e., treated as generated, 

prior to commingling with other process wastewaters)? What type of treatment 

system is used to treat the waste streams? What are the pollutant removals that 

are achieved by the system?

 What type of end-of-pipe treatment system does the facility have? What waste 

streams are treated by the system? What percentage of the total system flow rate 

and mass loading is contributed by each individual waste stream? What are the 

pollutant removals that are achieved by the system?
Appendix B 

GENERIC SAMPLING PLAN FOR COAL-FIRED STEAM ELECTRIC POWER 

PLANTS [FEBRUARY 24, 2010 VERSION]
DRAFT 

Generic Sampling and Analysis Plan for 

Steam Electric Power Plants 

Prepared for:

U.S. Environmental Protection Agency

Engineering and Analysis Division 

Office of Water 

1200 Pennsylvania Avenue, NW 

Washington, D.C. 20460 

Prepared by: 

Eastern Research Group, Inc.

14555 Avion Parkway 

Suite 200 

Chantilly, VA 20151 

February 24, 2010 

EPA Contract No. 68-C-02-095 

Work Assignment 7-29
DRAFT 

i

TABLE OF CONTENTS 

Page 

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

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

1.2 Objectives and Scope ............................................................................................ 1-2 

1.3 Plant Selection ...................................................................................................... 1-3 

2.0 SAMPLING PROCEDURES .................................................................................................. 2-1 

2.1 Sampling Point Selection ...................................................................................... 2-1 

2.1.1 FGD Scrubber Purge .............................................................................. 2-1 

2.1.2 Mid-Point of FGD Wastewater Treatment ............................................. 2-3 

2.1.3 Effluent from FGD Wastewater Treatment ............................................ 2-3 

2.2 Analyte Selection .................................................................................................. 2-4 

2.3 Sample Fractions, Bottle Sets, and Sample Collection ......................................... 2-5 

2.4 Sample Collection Methodology .......................................................................... 2-5 

2.4.1 Composite Sample Collection ................................................................ 2-7 

2.4.2 Grab Sample Collection ....................................................................... 2-13 

2.4.2.1 Grab Sample Collection from Tap ....................................................... 2-13 

2.4.2.2 Grab Sample Collection from Basin (or Tank) .................................... 2-18 

2.5 Preservation, Shipping, and Analysis ................................................................. 2-21 

2.6 Field Measurements and Engineering Data Collection ...................................... 2-22 

2.7 Sample Labeling ................................................................................................. 2-23 

2.8 Traffic Reports .................................................................................................... 2-24 

2.9 Quality Assurance/Quality Control .................................................................... 2-24 

2.10 Sample Splitting .................................................................................................. 2-26 

3.0 SAMPLING ACTIVITIES ..................................................................................................... 3-1 

3.1 Sampling Team Organization ............................................................................... 3-1 

3.2 Pre-Sampling Preparation ..................................................................................... 3-1 

3.3 Field Sampling Activities ..................................................................................... 3-2 

3.4 Standard Logistics ................................................................................................. 3-3 

3.4.1 Plant Contacts ......................................................................................... 3-3 

3.4.2 EPA Contacts .......................................................................................... 3-3 

3.4.3 Analytical Laboratories .......................................................................... 3-4 

3.4.4 ERG Contacts ......................................................................................... 3-4 

3.4.5 Freight Forwarders ................................................................................. 3-4 

4.0 SAMPLE SHIPMENT .......................................................................................................... 4-1 

4.1 Sample Set Preparation ......................................................................................... 4-1 

4.2 Sample Packing ..................................................................................................... 4-2 

5.0 REFERENCES .................................................................................................................... 5-1 
DRAFT 

ii

LIST OF TABLES 

Page 

2-1 Sample Collection at Steam Electric Plants ....................................................................... 2-27 

2-3 Summary of Sample Container and Planned Preservation ................................................ 2-29 

2-4 Sampling Point Field Measurements ................................................................................. 2-30 
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iii

LIST OF FIGURES 

Page 

2-1 Sample Preservation Log Sheet ......................................................................................... 2-31 

2-2 Field Sampling Log Sheet .................................................................................................. 2-32 

2-3 Engineering Data Collection Sheet (Page 1 of 3) .............................................................. 2-33 

2-4 Engineering Data Collection Sheet (Page 2 of 2) .............................................................. 2-34 

2-5 Engineering Data Collection Sheet (Page 3 of 3) .............................................................. 2-35 

2-6 Example SCC Traffic Report ............................................................................................. 2-36 
DRAFT 

1-1

1.0 INTRODUCTION

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

Protection Agency (EPA) is planning to conduct a sampling program of up to seven steam 

electric power plants to 1) obtain wastewater characterization data and 2) obtain wastewater 

treatment technology performance data. EPA will use these data in combination with other 

industry-supplied data to evaluate wastewater discharges resulting from steam electric generating 

plants and to evaluate technology options for the handling and treatment of these wastewaters. 

This “generic” sampling plan provides general sampling procedures and methods to be followed 

when conducting sampling activities. Sampling will be performed either by EPA’s technical 

contractor, Eastern Research Group, Inc. (ERG) or by industry representatives. This document, 

in combination with plant-specific sampling plans, is intended to serve as a guide to the field 

sampling crew. The plan also provides a review mechanism for EPA personnel, and a source of 

procedural information for plant personnel. 

1.1 Background

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

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

steam electric power plants are contributing the majority of the toxic loadings for the industry. 

Additionally, EPA determined that one of the waste streams contributing the majority of these 

toxic loadings are associated with wet flue gas desulfurization (FGD) systems present at coalfired power plants. 

 This sampling and analysis plan (SAP) will focus on characterizing treatment 

system discharges from coal-fired steam electric power plants. For a description of the steam 

electric process and the wastewaters generated during the operation of a coal-fired steam electric 

power plant, see Chapters 3 and 4 of the Steam Electric Power Generating Point Source 

Category: Final Detailed Study Report [1]. 
DRAFT 

1-2

1.2 Objectives and Scope

EPA is preparing to collect and analyze samples to characterize wastewater 

streams generated at coal-fired steam electric power plants. This SAP describes the approach 

EPA will use to collect and analyze samples to characterize untreated FGD scrubber purge and 

treated FGD wastewater from the following types of FGD wastewater treatment systems: 

 Chemical precipitation: Physical/chemical precipitation for heavy metals 

removal using hydroxide or a combination of hydroxide and sulfide 

precipitation; and 

 Biological: Biological treatment specifically designed for metals removal. 

Generally, the analytical results collected during this sampling program will 

support EPA in answering the following key questions: 

 What are the characteristics (i.e., pollutants present, pollutant 

concentrations, flow rate/volume) of untreated FGD scrubber purge 

wastewater? 

 What is the performance (e.g., effluent pollutant concentrations) of 

technologies for the treatment of FGD scrubber purge wastewater? 

 What are the average effluent concentrations for pollutants present in 

treated FGD wastewater? 

 What are the pollutant loadings associated with discharges of FGD 

wastewater following treatment? 

 EPA will conduct one-day pre-sampling site visits at the plants selected for the 

sampling program; however, if EPA previously visited the plant as part of the detailed study, a 

site visit may not be necessary. The objectives of the pre-sampling site visits are to: 

 Gather general information about the plant’s operations, including 

exisiting sampling data and results; 

 Gather process-specific information; 

 Gather information on pollution prevention and wastewater 

treatment/operations; 

 Gather plant-specific information to tailor sampling plans; and 

 Select and evaluate potential sampling points. 
DRAFT 

1-3

 The sampling program will consist of four-day sampling episodes at up to seven 

selected plants. The sampling will characterize the wastewaters generated by wet FGD scrubbers 

and the treatment performance of the systems used to treat the FGD scrubber purge wastewaters. 

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

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

spike/matrix spike duplicate analyses. 

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

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

Specifically, EPA will collect information regarding system design and day-to-day operation. 

1.3 Plant Selection

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

sampling. EPA will base the plant selection on the process configurations and characteristics of 

the plants. The following primary criteria will be used to select the plants for the sampling 

program: 

 Coal-fired power plant: EPA expects that all of the plants selected for the 

sampling program will be coal-fired plants because the waste streams of 

interest for the sampling program data objectives are associated with coalfired power plants. 

 Wet FGD system: EPA will evaluate wastewaters generated from wet 

FGD systems and the treatment of these wastewaters. EPA will consider 

the following selection criteria regarding FGD systems: 

o Type of FGD wastewater treatment system: The primary factor for 

selection is the type of wastewater treatment system being operated 

for the treatment of FGD wastewater. EPA plans to select plants 

operating the following types of wastewater treatment systems: 

 Chemical precipitation – EPA will sample up to five plants 

operating chemical precipitation systems. 

 Biological – EPA will sample up to two plants operating 

biological systems that use an anaerobic/anoxic biological 

system specifically designed for the treatment of nitrates 

and selenium. 
DRAFT 

1-4

o Age of FGD wastewater treatment system: EPA does not intend to 

collect samples from a wastewater treatment system that has not 

reached steady state operation because the performance of the 

system may not be optimized. Generally, EPA plans to sample 

FGD wastewater treatment systems that have been operating for at 

least six months, or where data have shown the system to be at 

steady state. 

o Type of FGD system: EPA will consider the type of FGD system 

operated by the plant (e.g., limestone forced oxidation, lime 

inhibited oxidation) when selecting plants for sampling. Although 

EPA may sample different types of FGD systems, the plants 

operating the types of FGD wastewater treatment system of 

interest for the rulemaking are likely to operate limestone forced 

oxidation systems. The limestone forced oxidation system has the 

capability of producing wallboard-grade gypsum, but it typically 

requires a purge stream that needs to be treated prior to discharge. 

Plants operating most other types of FGD systems either reuse the 

FGD water stream or treat it in a settling pond (often commingled 

with other plant wastewaters, such as ash sluice water). 

 NOx controls: EPA will consider whether the plants operate a selective 

catalytic reduction (SCR) system or a selective non-catalytic reduction 

(SNCR) system when selecting plants for sampling. Although these NOx

control systems do not generate a specific wastewater stream, their 

operation can impact the FGD wastewater characteristics. 

 Power load cycling: EPA will consider a plant’s load cycling (i.e., 

baseload, cycling, peaking). EPA expects that most of the plants selected 

for sampling will be baseload plants; however, EPA will consider 

sampling a cycling plant. EPA does not believe that there are any coalfired peaking plants. 

 Type of Coal: EPA will consider the type of coal that the plant burns. 

EPA plans to select plants that burn different types of coal. EPA expects 

to sample at least two different types of coal. 

 EPA will consider the following characteristics as secondary factors to be 

considered in the selection of plants. Although these are not primary criteria for plant selection, 

these characteristics may be used as a determining factor where warranted. 

 Continuous versus batch operation of FGD wastewater treatment system 

(e.g., five days per week versus seven days per week); 
DRAFT 

1-5

 Use of advanced mercury control system and configuration; 

 Type of boiler; 

 Age of boiler and FGD unit (i.e., time of last upgrade); 

 Source of lime/limestone used in wet FGD system; 

 Plant location; and 

 Other plant conditions that may affect wastewater characteristics or 

sample collection, such as whether target waste streams are segregated or 

commingled. 

 
DRAFT 

2-1

2.0 SAMPLING PROCEDURES

 This section discusses the general sampling procedures to be followed during all 

sampling activities. This section also provides the necessary information to plan for the logistics 

of potential sampling activities. 

2.1 Sampling Point Selection

 In general, EPA plans to collect representative samples at the influent and effluent 

of the FGD wastewater treatment system that is operating under steady-state conditions. In 

addition, EPA may collect samples at a mid-point of the FGD treatment system (e.g., effluent 

from chemical precipitation system prior to biological treatment). EPA plans to collect 24-hour 

composite samples at the mid-point and effluent sampling points and grab samples at the influent 

sampling points of the wastewater treatment system. The proposed sampling points were selected 

by EPA to answer the questions that are the objective of the sampling program, which are 

presented in Section 1.2. The specific sampling points and locations, samples, and list of 

parameters selected for each plant will be described in the plant-specific sampling plans. 

2.1.1 FGD Scrubber Purge 

 EPA plans to collect samples of untreated FGD scrubber purge wastewater. The 

scrubber blowdown generated directly from the FGD system is expected to contain large 

amounts of solids (i.e., calcium sulfite or calcium sulfate (gypsum)); therefore, EPA will collect 

the FGD wastewater after initial solids removal, which represents the FGD scrubber purge waste 

stream. 

 Many of the FGD wastewater treatment systems that EPA has observed thus far 

contain a surge tank (or equalization tank) prior to the wastewater entering the treatment system. 

For some of these treatment systems, FGD scrubber purge is the only waste stream that enters 

the surge tank; however, for other systems, the FGD scrubber purge may be combined with 

recycle streams from the treatment system (e.g., filter backwash) within the surge tank. EPA 

will collect the FGD scrubber purge from the following locations depending on the set up of the 

influent to the FGD wastewater treatment system: 
DRAFT 

2-2

 No surge tank prior to treatment system: EPA will collect a sample of the 

FGD scrubber purge stream prior to it entering the first-stage of the 

treatment system; 

 Surge tank with only FGD scrubber purge prior to treatment system: EPA 

will collect a sample of the FGD scrubber purge either directly from the 

surge tank or from the effluent stream leaving the surge tank; and 

 Surge tank with other recycle streams prior to treatment system: EPA will 

collect a sample of the FGD scrubber purge prior to it entering the surge 

tank. 

 EPA will collect grab samples of the FGD scrubber purge. Because of the 

intermittent nature of the FGD scrubber purge waste stream, EPA anticipates working closely 

with the plants to determine the expected duration and frequency of purging the FGD wastewater 

to the treatment system. Based on this information, EPA will determine when to collect the grab 

samples. 

 EPA expects that the wastewater entering the FGD treatment system will contain 

high concentrations of certain parameters, including suspended and dissolved solids, chlorides, 

sulfates, and various cations. The high solids content of the samples may make it difficult to 

filter the samples for the dissolved metals analyses; therefore, EPA plans to allow the sample to 

settle for one hour prior to running the sample through the filter. 

 Due to the high suspended solids content (on the order of 1-5 percent) of the 

samples collected at the influent to the FGD wastewater treatment system, EPA may analyze the 

samples as bi-phasic samples. If the suspended solids content of the sample is greater than one 

percent, then the laboratory will separate the aqueous portion of the sample from the solid 

portion of the sample and analyze both for the analyte of interest. In this instance, Group I 

(chloride and sulfate only), Group II (ammonia as nitrogen, nitrate/nitrite as nitrogen, and total 

phosphorus only), and total metals (including mercury, but not hexavalent chromium because it 

is filtered in the field during sample collection) samples will be analyzed as bi-phasic samples. 

Group I (TSS and TDS only), Group II (COD only), BOD5, hexavalent chromium, and dissolved 

metals (including mercury) samples will not be analyzed as bi-phasic samples. Scrubber purge 
DRAFT 

2-3

samples with less than one percent suspended solids will not require bi-phasic separation and 

analysis. 

2.1.2 Intermediate Point of FGD Wastewater Treatment 

 EPA may collect samples at an intermediate point of the FGD wastewater 

treatment system. EPA expects to collect this sample after some initial treatment steps that could 

represent a wastewater treatment system of interest for the program. For example, some plants 

operate a chemical precipitation system followed by a biological treatment system. For this type 

of treatment system, EPA may consider collecting a sample after the chemical precipitation 

system to represent the effectiveness of the chemical precipitation portion of the system. 

 EPA expects that these samples will be collected either after a clarification step or 

after a filtration system, and will be collected from the effluent stream leaving the particular 

system before it enters the next stage of the treatment process. EPA will collect 24-hour 

composite samples of the intermediate point of the FGD wastewater treatment system, preferably 

using an automatic compositor. 

 EPA expects that the wastewater at an intermediate point in the FGD treatment 

system will contain high concentrations of certain parameters, such as chlorides, sulfates, and 

various cations. The suspended solids content of the sample is expected to be lower than at the 

influent; however, it may still be difficult to filter the samples for the dissolved metals analyses. 

2.1.3 Effluent from FGD Wastewater Treatment 

 EPA plans to collect samples of the effluent from the FGD wastewater treatment 

system. EPA expects to collect this sample from the waste stream that exits the wastewater 

treatment system; however, if EPA is unable to collect the sample from this location, then EPA 

will select a point within the system to represent the effluent. For example, if the wastewater is 

collected in an effluent tank prior to being transferred to additional treatment (e.g., an ash pond) 

and a sample cannot be collected from the wastewater piping leading to the additional treatment 

system, then it may be necessary to collect an effluent sample directly from the effluent tank. 
DRAFT 

2-4

 EPA does not expect to collect the influent and effluent samples from the FGD 

treatment system as “paired” samples because the primary objective of the sampling program is 

to collect effluent data to establish effluent limitations for the waste stream. Additionally, these 

treatment systems can have long residence times and therefore, could extend the amount of time 

required for EPA to be on site, which is a burden for the plant and unnecessary to achieve the 

sampling objectives. 

 EPA expects that the wastewater at the effluent from the FGD treatment system 

will still contain high concentrations of certain parameters, such as chlorides, sulfates, and 

various cations. The suspended solids content of the sample should be minimal (less than 0.01 

percent) and should not present any issues for filtering the sample for dissolved metals analyses. 

2.2 Analyte Selection

 Analytes that will be included in this EPA/EAD sampling program include those 

in the following classes of pollutants: 

 Classicals: 

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

— Chemical oxygen demand (COD) 

— Total suspended solids (TSS), 

— Total dissolved solids (TDS), 

— Sulfate, 

— Chloride, 

— Total Kjeldahl nitrogen (TKN), 

— Ammonia as nitrogen, 

— Nitrate/nitrite as nitrogen, 

— Total phosphorus, 

— Total cyanide; 

 Total metals: 

— Aluminum, antimony, arsenic, barium, beryllium, boron, cadmium, 

calcium, chromium, cobalt, copper, iron, lead, magnesium, 

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

sodium, thallium, tin, titanium, vanadium, and zinc. 

 Dissolved metals 

— Same parameters as listed for total metals, plus hexavalent 

chromium. 
DRAFT 

2-5

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

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

chemicals, and other sources. Table 2-1 lists the potential analytes for each sampling point and 

Table 2-2 lists the analytical methods that will be used. In addition to these analytes, the 

sampling crew will conduct field measurements at all sampling points (see Section 2.6). The 

plant-specific sampling plans will specify the list of parameters and collection frequency for each 

sampling point. 

 

2.3 Sample Fractions, Bottle Sets, and Sample Collection

 Samples are collected as a series of “fractions” or bottles designated for particular 

analyses requiring the same preservation. A typical, comprehensive sample set consists of 

sample fractions for all pollutant classes listed in Section 2.2. Note that some sample fractions 

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

and Group II (ammonia as nitrogen, COD, nitrate/nitrite, TKN, and total phosphorus). Table 2-3 

presents a summary of the parameters, bottle types, sample volume, and planned on-site 

preservation requirements. 

 Sample containers and bottles will be purchased pre-cleaned and certified and will 

not require rinsing with sample. The sample bottles for the metals analyses will be cleaned 

according to EPA Method 1669. 

 

2.4 Sample Collection Methodology

 To characterize the various waste streams expected to be sampled during the 

sampling program, the samplers may employ varying methods of sample collection depending 

on the sampling point, pollutant parameters, and the nature of the sample flow and composition 

at each sampling point. This section provides a general description of the anticipated sample 

collection techniques. Plant-specific sampling plans will contain detailed information regarding 

specific sampling points and locations, sampling methodologies, and analytes. 
DRAFT 

2-6

 In general, samplers will work in teams of at least two to ensure that proper 

sampling techniques are followed and adequate notes are taken at each sampling location. 

Samplers will wear disposable gloves, Tyvek® suits, masks (when sampling for mercury by 

EPA Method 1631E), steel-toed boots, and safety eyewear, and will observe precautions while 

collecting samples, remaining aware of his/her surroundings. Note that the use of masks is to 

prevent contamination of the mercury samples and not for respiratory protection. The plantspecific sampling plans will identify any sampling points that require additional precautions. 

 

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

sampling. Samples that require cooling to ≤6C for preservation will be cooled immediately in 

an ice-water bath to ≤6C and then placed into coolers containing bagged ice to maintain a 

sample temperature of ≤6C throughout sample storage, shipment, and receipt at the analytical 

laboratories. 

 Discharge practices vary from plant to plant and process to process. For example, 

some processes may generate wastewater continuously, while others may only generate 

wastewater when parameters reach a certain predetermined threshold and require blowdown 

from the process. Thus, the plant-specific sampling plan will outline the sample collection 

methodology that EPA plans to implement at each sampling point at a particular plant. 

 EPA will collect 24-hour composite samples at the intermediate point and effluent 

of the FGD wastewater treatment system sampling points and grab samples at the influent 

sampling point during the sampling episodes. Additionally, EPA will collect samples over four 

consecutive 24-hour periods. Each sampling point will be collected each day; therefore, EPA 

will collect four samples for each sampling point. ERG will follow protocols described in EPA 

Method 1669 to collect metal sample fractions. All sampling equipment (e.g., tubing) and 

sample bottles will be cleaned according to the procedures described in EPA Method 1669. 

Samplers will use “clean hands / dirty hands” sample collection techniques when collecting 

metal sample fractions, as described in EPA Method 1669. In addition to the differences 

between collecting grab or composite samples, ERG will also use two different techniques to 

collect samples from steam electric plants based on the location of the sampling point: collection 
DRAFT 

2-7

from a tank or basin and collection from a sample tap. Specific instructions for the potential 

sampling techniques are described below. 

2.4.1 Composite Sample Collection 

 The preferred approach for collecting the composite samples will use two 

automatic compositors which will be programmed to collect individual sample volumes into two 

large containers (e.g., two 20-liter HPDE containers). To collect sufficient sample volume, ERG 

will calculate the total volume required for ERG sample collection as well as plant split sample 

collection and also add additional volume for purging tubing and contingencies. The volume 

will then be programmed to be collected in one-hour intervals during the 24-hour composite 

period. Following the composite period, ERG will pour and/or pump-off the specific sample 

volumes into the individual sample containers. 

 ERG will use one automatic compositor to collect sample volume for the metals 

analyses and another automatic compositor to collect sample volume for all classical analytes 

(i.e., BOD5, Group I, and Group II). 

 

 ERG’s preferred approach is to collect sample volume from a basin (or tank), 

where the composite samplers will be located outside, positioned near the edge of the basin. If 

the collection point is a sample tap, the composite samplers may be outside, depending on the 

location of the tap, and will be near wastewater piping and equipment. ERG may have to 

engineer a basin that draws a slip stream from a sample tap if the collection point is located at 

pressurized piping. This basin would be level controlled and would draw volume continuously 

into the basin, with the overflow entering the plants sumps. In this case, ERG would set up the 

composite samplers to draw volume from the engineered basin. The field sampling personnel 

will use care when setting up the sample point to avoid any contamination from the 

surroundings. The sampling equipment will consist of the following: 

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

 Peristaltic pump (automatic compositor – battery powered); 

 Large composite containers (e.g., 20-liter containers); 

 Funnel; 
DRAFT 

2-8

 “Y” splitter; 

 Teflon® tubing; 

 Silicone tubing; 

 0.45 um filter; 

 Cleanbox; 

 Tyvek® suits (for metals samples); 

 Masks (for mercury samples); and 

 Sample containers. 

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

procedures described in EPA Method 1669. ERG will follow protocols described in EPA 

Method 1669 to collect metal sample fractions. Two or more ERG samplers (“clean hands” and 

“dirty hands”) will follow the protocols described in the steps below to set up the sampling point, 

collect the field blank samples, and collect wastewater samples. This section describes the set up 

of the sample point and collection of the EPA samples1. 

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

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

coolers or boxes contain the double-bagged composite containers, pre-cleaned 

tubing, blank water, and cleanbox. 

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

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

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

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

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

located inside the box. 

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

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

of pre-cleaned Teflon® tubing attached to a 4-foot length of pre-cleaned silicone 

tubing, if sampling from a basin (or a length of pre-cleaned silicone tubing if 

sampling from a sample tap). “Clean hands” takes the inner bag containing the 

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

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

Teflon® and silicone tubing. 

 

1

 For the sample collection, EPA assumes that samples will be split with the plant (or the plant’s representative) and 

therefore, the sample set-up describes equipment needed for split samples. However, EPA is not responsible for the 

collection of the split samples collected by the plant and therefore, the collection of their samples is not described. 
DRAFT 

2-9

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

the automatic compositor. 

6. Both samplers change gloves. 

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

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

the field blank water, unscrews the lid and places it in the inner bag. “Clean 

hands” then places the Teflon® end of the tubing into the blank water. “Clean 

hands” also opens the inner bag for the field blank composite container and 

loosens the lid. “Clean hands” holds the silicone tubing with the plastic bag 

covering the end out of the cleanbox and over a bucket and “dirty hands” operates 

the pump to pump blank water through the tubing. After the tubing has been 

purged with sufficient volume, “clean hands” holds the silicone tubing at the 

mouth of the field blank composite container and fills the composite container 

with enough field blank water for the collection of the total and dissolved mercury 

and metals field blank samples collected for the specific sampling point. “Dirty 

hands” stops the pump. “Clean hands” places the plastic bag over the end of the 

silicone tubing, replaces the lid on the field blank composite container, places the 

silicone tubing back in the cleanbox, and closes the inner bag on the field blank 

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

composite container. 

8. Both samplers work together to move the sampling tubing, automatic compositor, 

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

ensure that the tubing will stay in place during the 24-hour sample collection 

period. 

9. “Dirty hands” changes gloves. 

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

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

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

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

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

12. “Dirty hands” programs the automatic compositor to collect the 20 liters of 

sample over a 24-hour time period in one-hour intervals (i.e., collect 800 mL of 

sample every hour). “Dirty hands” calibrates the compositor to ensure that 800 

mL is being collected for each individual grab. 

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

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

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

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

outer bag. 
DRAFT 

2-10

14. Samplers repeat steps 1-13 to set up the automatic compositor for the 

conventional analyses (skipping step 7). Samplers will use another composite 

container. The samplers will put the classicals composite container in ice to keep 

the samples cold during compositing time period. 

15. Samplers collect a total cyanide grab sample using a bottle dipper. NOTE: if 

sample collection is from a tap, the samplers will need a third tap to allow for the 

collection of total cyanide and field measurements. The samplers will attach the 

bottle to the bottle dipper and dip the bottle directly into the tank or basin. 

16. The samplers will collect field measurements and total cyanide samples every six 

hours during the compositing time period, which will result in a total of four total 

cyanide samples for each day of sampling. The four grab samples will be 

composited by the laboratory. 

17. At the end of the sampling period, “dirty hands” stops each of the automatic 

compositors and opens the outer bag of each composite container. For each 

container, “clean hands” detaches the used tubing from the composite container 

and covers the port with a lid or small plastic bag. Then samplers transport each 

of the composite containers, including the field blank composite container, to the 

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

18. The samplers then repeat steps 1 through 17 to set up the composite containers for 

the next day of sample collection. 

After the composite samples have been collected, the sampling team then needs to 

transfer the sample into the individual sample containers. EPA will use a sample pump-off 

approach to transfer the sample volume to individual sample containers at the pump-off area. 

For this sample pump-off procedure, the dissolved metals samples will be collected before the 

total metals and classical samples to prevent cross-contamination within the tubing which could 

lead to greater concentrations in the dissolved metals fractions. 

Sample Pump–Off Procedure 

19. Samplers remove the bags containing the gloves and HDPE plastic wrap from the 

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

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

and cleanbox. 

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

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

and pre-cleaned tubing within easy access on the covered surface. 
DRAFT 

2-11

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

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

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

located inside the box. 

22. “Dirty hands” opens the opening on the peristaltic pump head so the tubing can be 

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

of pre-cleaned Teflon® tubing connected to a length of pre-cleaned silicone 

tubing, a “Y” splitter, and two additional pieces of silicone tubing. “Clean hands” 

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

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

silicone tubing. 

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

24. Both samplers change gloves. 

25. “Dirty hands” opens the outer bag of the field blank composite container and total 

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

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

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

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

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

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

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

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

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

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

metals field blank sample. “Dirty hands” stops the pump. “Clean hands” closes 

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

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

samplers repeat this procedure for the remaining total metals field blank samples 

(i.e., total metals and total mercury field blank samples). 

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

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

to the silicone tubing just before the “Y” splitter. 

27. “Dirty hands” opens the outer bag of the dissolved metals field blank sample 

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

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

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

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

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

the silicone tubing in the cleanbox, opens the inner bag of the dissolved metals 

field blank sample bottle, and removes the lid. “Dirty hands” operates the pump 
DRAFT 

2-12

to collect the dissolved metals field blank sample. “Dirty hands” stops the pump. 

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

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

the outer bag. The samplers repeat this procedure for the remaining dissolved 

metals field blank samples (i.e., dissolved metals and hexavalent chromium field 

blank samples)2. “Clean hands” closes the inner bag of the field blank composite 

container and “dirty hands” closes the outer bag. Note: 750 mL of blank water 

does not need to be purged for each sample, just at the beginning of each new 

filter. If a new filter is needed, “clean hands” removes the used filter and 

samplers follow step 25 to replace the filter. 

28. “Dirty hands” opens the outer bag of the large composite container for the metals 

samples and “clean hands” opens the inner bag. “Clean hands” transfers the 

Teflon® tubing from the field blank composite container to the metals sample 

composite container. “Clean hands” holds the end of the silicone tubing outside 

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

tubing and “dirty hands” operates the pump to pump about one liter of sample 

through the tubing and filter. “Dirty hands” stops the pump. 

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

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

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

to collect the dissolved metals sample. “Dirty hands” stops the pump. “Clean 

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

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

bag. The samplers repeat this procedure for the dissolved metals and hexavalent 

chromium samples. During one day of the sampling episode, the samplers will 

collect additional sample volume for the duplicate samples and laboratory QC 

analyses. 

30. “Clean hands” removes the capsule filter from the sample tubing configuration 

and reconnects the two pieces of tubing together. 

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

the plastic bag covering the end of the tubing. “Dirty hands” pumps about one 

liter of sample through the tubing. “Dirty hands” stops the pump. “Clean hands” 

places the end of the silicone tubing back in the cleanbox. 

32. “Dirty hands” opens the outer bag of the total mercury sample bottle. “Clean 

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

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

to collect the total mercury sample. “Dirty hands” stops the pump. “Clean 

 

2

 ERG only plans to collect field blank samples at each sampling point for one day of sampling episode. ERG will 

collect the dissolved mercury sample using the same technique as the total mercury sample, but the dissolved sample 

will be filtered at the laboratory. A dissolved mercury field blank will be performed by the laboratory to assess any 

mercury contamination from the filtering performed at the laboratory. Therefore, ERG does not need to collect a 

dissolved mercury field blank sample in the field. 
DRAFT 

2-13

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

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

bag. The samplers repeat this procedure for the dissolved mercury and total 

metals samples. During one day of the sampling episode, the samplers will collect 

additional sample volume for the duplicate samples and laboratory QC analyses. 

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

34. “Dirty hands” shakes the large composite containers for the classical analytes to 

mix the sample. “Dirty hands” opens the outer bag for the composite container. 

“Clean hands” opens the inner bag and transfers the Teflon® tubing from the 

metals composite container to the composite container for the classical analytes. 

35. “Clean hands” holds the silicone tubing outside the cleanbox over a bucket, with 

the plastic bag covering the end of the tubing. “Dirty hands” pumps about one 

liter of sample through the tubing. “Dirty hands” stops the pump. 

36. Both samplers collect the BOD5, Group I, and Group II samples. During one day 

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

the duplicate samples and laboratory QC analyses. 

2.4.2 Grab Sample Collection 

 ERG will collect the grab samples from the FGD scrubber purge, which is 

expected to contain a significant amount of suspended solids. ERG will collect samples directly 

into individual sample containers for all samples that are not required to be filtered in the field. 

For the samples that will to be filtered in the field, ERG will collect a large volume of sample 

into a large container (e.g., 10-L HDPE container) and then pump off the specific sample 

volumes into the individual sample containers. 

 The grab sample collection technique can vary significantly depending on the 

specific sampling point location (e.g., collection from a basin (or tank) compared to collection 

from a sample tap. The following two subsections describe the specific collection techniques 

that will be used to collect grab samples from the differing sampling point locations. 

2.4.2.1 Grab Sample Collection from Tap 

 For grab samples that are collected from a sample tap, ERG will set up the 

sampling equipment near the sample tap that represents the FGD scrubber purge sample. The 
DRAFT 

2-14

field sampling personnel will use care when setting up the sample point to avoid any 

contamination from the surroundings. The sampling equipment will consist of the following: 

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

 Silicone tubing with “Y” splitter; 

 10-L containers; 

 Teflon® tubing; 

 Silicone tubing; 

 0.45 um filter; 

 Funnel; 

 Peristaltic pump; 

 Small table; 

 Cleanbox; 

 Tyvek® suits (for metals samples); 

 Masks (for mercury samples); and 

 Sample containers. 

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

procedures described in EPA Method 1669. ERG will follow protocols described in EPA 

Method 1669 to collect metal sample fractions. Two or more ERG samplers (“clean hands” and 

“dirty hands”) will follow the protocols described in the steps below to set up the sampling point, 

collect the field blank samples, and collect wastewater samples. This section describes the set up 

of the sample point and collection of the EPA samples3. 

 

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

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

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

blank water, and cleanbox. Depending on the condition of the sample tap, it may 

be necessary to wipe the tap with a clean paper towel to remove any build up on 

the tap that could potentially fall in the sample bottles during sample collection. 

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

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

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

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

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

inside the box. 

 

3

 For the sample collection, EPA assumes that samples will be split with the plant (or the plant’s representative) and 

therefore, the sample set-up describes equipment needed for split samples. However, EPA is not responsible for the 

collection of the split samples collected by the plant and therefore, the collection of their samples is not described. 
DRAFT 

2-15

4. “Dirty hands” opens the outer bag containing a length of pre-cleaned silicone 

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

tubing. “Clean hands” places clean plastic bags over the ends of the silicone 

tubing. 

5. “Dirty hands” opens the outer bag of the funnel and “clean hands” opens the inner 

bag inside of the cleanbox. “Clean hands” attaches the funnel to the tubing. 

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

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

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

passes the funnel end of the tubing with a plastic bag shrouding the funnel to 

another “clean hands” person to hold outside the cleanbox. “Clean hands” 

removes the inner bag for the total mercury field blank sample bottle and places it 

in the cleanbox. “Clean hands” holds the end of the silicone tubing outside the 

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

“Dirty hands” pours field blank water through the funnel and tubing. After the 

tubing has been purged with sufficient volume, “clean hands” places the silicone 

tubing back in the cleanbox. Working inside the cleanbox, “clean hands” 

unscrews the lid of the field blank sample bottle, removes the tubing from the 

plastic bag, and prepares to fill the field blank sample bottle. “Dirty hands” pours 

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

mercury field blank sample bottle. “Clean hands” places the end of the silicone 

tubing into the plastic bag, replaces the lid on the sample bottle, and closes the 

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

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

for the total metals field blank samples4

. 

7. “Dirty hands” opens the outer bag for a pre-cleaned 10-L container. “Clean 

hands” opens the inner bag and loosens the lid. “Clean hands” holds the end of 

the silicone tubing at the mouth of the 10-L container and removes the lid. “Dirty 

hands” pours field blank water through the funnel and tubing, and “clean hands” 

fills the 10-L container with enough field blank water to collect the dissolved 

metals field blank samples. “Clean hands” places the lid back on the 10-L 

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

tubing in the cleanbox. “Clean hands” screws the lid on the 10-L container and 

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

8. After collecting the field blank samples, “clean hands” removes the funnel from 

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

tubing to the sample tap. 

 

4

 ERG only plans to collect field blank samples at each sampling point for one day of sampling episode. ERG will 

collect the dissolved mercury sample using the same technique as the total mercury sample, but the dissolved sample 

will be filtered at the laboratory. A dissolved mercury field blank will be performed by the laboratory to assess any 

mercury contamination from the filtering performed at the laboratory. Therefore, ERG does not need to collect a 

dissolved mercury field blank sample in the field. 
DRAFT 

2-16

9. “Clean hands” holds the opposite end of the silicone tubing outside the cleanbox 

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

opens the valve to the sample tap to purge the piping for a minimum of 2 minutes. 

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

10. “Dirty hands” opens the outer bag for a pre-cleaned 10-L container. “Clean 

hands” opens the inner bag and loosens the lid. “Clean hands” holds the end of the 

silicone tubing at the mouth of the 10-L container and removes the lid. “Dirty 

hands” opens the sample valve to allow sample to flow into the 10-L container. 

Samplers fill the 10-L container for the collection of dissolved metals and 

hexavalent chromium, which are all required to be filtered. The samplers will 

allow the solids to settle for one hour while collecting the remaining samples. 

“Clean hands” places the lid back on the 10-L container, places the plastic bag 

over the end of the silicone tubing, and places the tubing into the cleanbox. 

”Clean hands” screws the lid on the 10-L container and closes the inner bag. 

“Dirty hands” closes the outer bag of the 10-Liter container. Both samplers 

change their gloves. 

 

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

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

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

from the tubing and fills the sample bottle. “Clean hands” places the tubing back 

in the plastic bag, replaces the lid on the sample bottle and closes the inner bag. 

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

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

for the dissolved mercury and total metals samples. 

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

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

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

14. Both samplers collect the BOD5, Group I, Group II, and total cyanide samples 

from the sample location. 

Dissolved Metals Sample Collection 

15. Samplers allow the 10-L sample container to continue to settle if one hour has not 

elapsed since the collection of the sample. 

 

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

and places the double-bagged sample bottles within easy access on the covered 

surface. 

17. “Dirty hands” opens the outer bag of the clean box and “Clean hands” opens the 

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

2-17

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

inside the box. 

18. “Dirty hands” opens the opening on the peristaltic pump head so the tubing can be 

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

pre-cleaned Teflon® tubing attached to a 5-foot length of pre-cleaned silicone 

tubing, a “Y” splitter, and two additional pieces of pre-cleaned silicone tubing. 

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

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

Teflon® and silicone tubing. 

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

20. Both samplers change gloves. 

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

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

to the silicone tubing just before the “Y” splitter. 

22. “Dirty hands” opens the outer bag of the 10-L container that was used to collect 

the field blank water for the dissolved metals fractions. “Clean hands” opens the 

inner bag of the 10-L container. “Clean hands” removes the Teflon® tubing from 

the cleanbox, opens the lid of the 10-L plastic container, removes the plastic bag 

from the Teflon® tubing, and places the Teflon® into the 10-L container. “Dirty 

hands” opens the dissolved metals field blank sample bottle. “Clean hands” 

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

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

over a bucket, with the plastic bag still covering the end of the tubing and “dirty 

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

blank water bottle. “Clean hands” places the end of the silicone tubing in the 

cleanbox, opens the inner bag of the dissolved metals field blank sample bottle, 

and removes the lid. “Dirty hands” operates the pump to collect the dissolved 

metals field blank sample. “Dirty hands” stops the pump. The samplers repeat the 

procedure for the dissolved metals and hexavalent chromium field blank samples. 

If a new filter is needed, “clean hands” removes the used filter and samplers 

following step 22 to replace the filter. 

23. Both samplers change gloves. 

24. “Dirty hands” opens the outer bag of one of the 10-L containers. “Clean hands” 

opens the inner bag, removes the lid, and places the end of the Teflon® tubing 

into the container. “Clean hands” holds the end of the silicone tubing outside the 

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

starts the pump and passes approximately 750 mL through the tubing and filter. 

“Dirty hands” stops the pump. 
DRAFT 

2-18

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

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

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

to collect the dissolved metals sample. “Dirty hands” stops the pump. “Clean 

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

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

bag. The samplers repeat this procedure for the dissolved metals and hexavalent 

chromium samples. 

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

2.4.2.2 Grab Sample Collection from Basin (or Tank) 

 For grab samples that are collected from a basin (or tank), ERG will set up the 

sampling equipment near the basin that represents the FGD scrubber purge sample. The field 

sampling personnel will use care when setting up the sample point to avoid any contamination 

from the surroundings. The sampling equipment will consist of the following: 

 Peristalic pump; 

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

 PVC piping; 

 0.45 um filter; 

 Teflon® tubing; 

 Silicone tubing; 

 “Y” splitter; 

 Small table; 

 Cleanbox; 

 Tyvek® suits (for metals samples); 

 Masks (for mercury samples); and 

 Sample containers. 

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

procedures described in EPA Method 1669. ERG will follow protocols described in EPA 

Method 1669 to collect metal sample fractions. Two or more ERG samplers (“clean hands” and 

“dirty hands”) will follow the protocols described in the steps below to set up the sampling point, 

collect the field blank samples, and collect wastewater samples. This section describes the set up 

of the sample point and collection of the EPA samples5

. 

 

5

 For the sample collection, EPA assumes that samples will be split with the plant (or the plant’s representative) and 

therefore, the sample set-up describes equipment needed for split samples. However, EPA is not responsible for the 

collection of the split samples collected by the plant and therefore, the collection of their samples is not described. 
DRAFT 

2-19

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

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

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

and cleanbox. 

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

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

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

covered surface. 

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

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

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

inside the box. 

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

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

of pre-cleaned Teflon® tubing attached to a 5-foot length of pre-cleaned silicone 

tubing with a “Y” splitter and two separate pieces of silicone tubing attached to 

the “Y” splitter. “Clean hands” moves the tubing into the cleanbox, opens the 

inner bag, and removes the tubing. “Clean hands” places a clean plastic bag over 

the end of the Teflon® and silicone tubing and places the end of the tubing in the 

cleanbox. 

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

6. Both samplers change gloves. 

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

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

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

then places the Teflon® end of the tubing into the blank water. “Clean hands” 

moves the total mercury sample bottle into the cleanbox and opens the inner bag. 

Working inside the cleanbox, “clean hands” unscrews the lid. “Clean hands” 

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

plastic bag still covering the end of the tubing. “Dirty hands” operates the pump 

to pump blank water through the tubing. After the tubing has been purged with 

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

removes the plastic bag, and fills the total mercury field blank sample bottle. 

“Dirty hands” stops the pump. “Clean hands” places the plastic bag over the end 

of the silicone tubing, replaces the lid on the sample bottle, and closes the inner 

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

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

for the total metals field blank samples6

. 

 

6

 ERG only plans to collect field blank samples at each sampling point for one day of sampling episode. ERG will 

collect the dissolved mercury sample using the same technique as the total mercury sample, but the dissolved sample 

will be filtered at the laboratory. A dissolved mercury field blank will be performed by the laboratory to assess any 
DRAFT 

2-20

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

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

to the end of the silicone tubing, prior to the “Y” splitter. 

9. “Dirty hands” opens the outer bag of the dissolved metals field blank water and 

dissolved metals by field blank sample bottle. “Clean hands” moves the dissolved 

metals field blank sample bottle to the cleanbox. “Clean hands” opens the inner 

bag of the field blank water. “Clean hands” removes the lid from the dissolved 

metals field blank water, places it in the inner bag, and places the end of the 

Teflon® tubing in the blank water. “Clean hands” holds the end of the silicone 

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

end of the tubing and “dirty hands” operates the pump to purge about 750 mL of 

blank water from the field blank water bottle through the tubing and filter. “Clean 

hands” places the end of the silicone tubing in the cleanbox, opens the inner bag 

of the dissolved metals field blank sample bottle, and removes the lid. “Clean 

hands” holds the silicone tubing over the bottle and “dirty hands” operates the 

pump to collect the dissolved metals field blank sample. “Dirty hands” stops the 

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

“Clean hands” places the inner bag and bottle in the outer bag and “dirty hands” 

closes the outer bag. The samplers repeat this procedure for the dissolved metals 

and hexavalent chromium field blank samples. Note: 750 mL of blank water 

does not need to be purged into the waste bottle for each sample, just at the 

beginning of each new filter. If a new filter is needed, “clean hands” removes the 

used filter and samplers follow step 8 to replace the filter. 

10. Both samplers change gloves. 

11. After collecting all of the total and dissolved metals field blank samples, “clean 

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

into the sample water, taking care that the end of the tubing does not touch 

anything other than the sample water. The samplers will secure the Teflon® 

tubing to a piece of PVC piping so the samplers can easily control the position of 

the tubing in the basin/tank. 

12. “Clean hands” holds the end of the silicone tubing outside the cleanbox over a 

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

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

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

of the silicone tubing back in the cleanbox. . 

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

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

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

 mercury contamination from the filtering performed at the laboratory. Therefore, ERG does not need to collect a 

dissolved mercury field blank sample in the field. 
DRAFT 

2-21

tubing over the bottle and “dirty hands” operates the pump to collect the dissolved 

metals sample. “Clean hands” closes the lid on the sample bottle and closes the 

inner bag. “Clean hands” places the inner bag and bottle in the outer bag and 

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

dissolved metals and hexavalent chromium samples. 

14. Both samplers change gloves. 

15. “Clean hands” removes the capsule filter from the silicone tubing and reattaches 

the tubing to the “Y” splitter. 

16. “Clean hands” holds the end of the silicone tubing outside the cleanbox over a 

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

operates the pump to purge the tubing for at least 2 minutes. 

17. “Dirty hands” opens the outer bag for the total mercury sample bottle. “Clean 

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

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

from the tubing and fills the sample bottle. “Clean hands” places the tubing back 

in the plastic bag, replaces the lid on the sample bottle and closes the inner bag. 

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

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

dissolved mercury and total metals samples. 

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

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

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

20. Both samplers collect the BOD5, Group I, Group II, and total cyanide samples 

from the sample location. Samples will be pumped directly into sample bottles. 

2.5 Preservation, Shipping, and Analysis

 All samples will be maintained on ice immediately upon collection (except the 

total and dissolved metals and the total and dissolved mercury samples, which do not require 

cooling). In addition, all samples will follow the on-site preservation requirements specified in 

40 CFR 136 method-specified protocols, including hexavalent chromium. The dissolved metals 

(not including mercury) and hexavalent chromium samples will be filtered in the field. The 

dissolved mercury samples will be filtered upon receipt at the laboratory. Samplers will filter 

samples within 15 minutes of the completion of the compositing period (or as soon thereafter as 

possible). For the FGD influent, filtration of dissolved samples will occur approximately one 

hour after the compositing period (or after the large sample volume is collected during the grab 
DRAFT 

2-22

sample collection) to allow for solids settling because it has a high suspended solids content that 

would clog the filter. 

 The total cyanide samples will be preserved according to the method-specific 

protocols. The samplers will first adjust the pH of the sample to >10 S.U. using sodium 

hydroxide. The samplers will then test the sample for the presence of sulfide using lead acetate 

test strips. If sulfide is present, the samplers will dilute the sample by pouring some of the 

sample into another sample bottle containing a measured amount of blank reagent water (e.g., 

add 50 mL of sample to 200 mL of blank reagent water). The samplers will then test the diluted 

sample for the presence of sulfide. If sulfide is still present, the samplers will create a more 

diluted sample and retest for sulfide until sulfide is not present in the sample. The samplers will 

then test the sample for the presence of total chlorine using potassium-iodide starch paper. If 

total chlorine is present, the samplers will add sodium arsenite in small increments until total 

chlorine is no longer present in the sample. The samplers will then readjust the pH to >10 S.U. 

using sodium hydroxide, if necessary, and place the sample on ice. 

 Table 2-3 lists the parameters, required sample and QC volume, bottle types, and 

on-site preservation requirements for each type of analysis. The type and amount of preservation 

used will be recorded on sample preservation log sheets (Figure 2-1). Preservation will be 

discontinued and noted on the traffic report if 10 percent of the sample volume is added and the 

required pH is not achieved. The wastewater samples, except certain metals samples, will be 

packed in ice chests with a sufficient quantity of ice to maintain a temperature of ≤6C. All 

samples will be prepared for overnight shipment via Federal Express to laboratories. 

2.6 Field Measurements and Engineering Data Collection

 Temperature and pH will be measured and recorded by the sampling crew at each 

sampling point when the automatic composite samplers are set up (and every six hours after the 

composite set up) or during the grab sample collection. A 1-liter glass jar will be filled prior to 

connecting the sample tubing to the composite containers for field measurements. Temperature 

and pH will be measured immediately after the collection of the field measurement aliquot. 

Table 2-4 summarizes the field measurements, the method to be used for the measurement, and 
DRAFT 

2-23

the detection range of each field test instrument. In addition, EPA will collect flow rate data for 

all waste streams. 

 Field sampling log sheets (Figure 2-2) will be completed at each sampling point. 

This sheet will record the sampling methodology, names of the samplers, sample collection time, 

field measurements, and any notes and observations. 

 During each sampling episode, engineering information will be collected with 

regard to design and operation of the plant being sampled. For example, information such as 

coal usage, plant capacity, wastewater flow rates, sludge generation rates (if applicable), and 

retention times in wastewater treatment process stages. Engineering data collection sheets 

(Figures 2-3, 2-4, and 2-5) will be completed for each plant. This information will be used to 

determine if the specific design or operational criteria of the steam electric operations affect the 

wastewater characteristics. 

2.7 Sample Labeling

 Each sample will be coded with a unique sample number and labeled at the time 

of collection. Typically, labels are printed prior to arrival in the field, though they may also be 

completed by hand. Each self-adhesive label is completed in indelible ink and contains the 

following information: 

 Sample number; 

 Sampling episode number; 

 Sampling point/description; 

 Date of sample collection; 

 Analysis to be performed; 

 Sample bottle type; and 

 Required preservation. 

If any of the pre-printed information is incorrect, it will be revised using indelible ink. In 

particular, if a required preservation is not used, it will be marked out (additional preservation 

details will be noted on the traffic report). Once applied to the sample container, labels are 

covered with clear tape to prevent tampering, abrasion, smearing, or loss during transit. 
DRAFT 

2-24

2.8 Traffic Reports

 To maintain a record of sample collection, transfer between personnel, shipment, 

and receipt by the laboratory, a traffic report is completed for each sample set at each sampling 

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

laboratory. Traffic report forms are completed for all samples sent to all laboratories. Figure 2-6 

includes an example traffic report. At the time of sample shipment, a copy of the traffic report is 

sent to ERG, another copy is kept by sampling personnel, and two copies are transmitted with the 

samples to the analytical laboratory. 

 In addition to the transfer of custody, the traffic report provides information to the 

analytical laboratory on the sample number, type of water sample (in-line process, untreated 

wastewater, treated effluent), sample description, whether the sample is preserved, pH of the 

sample after preservation, type of sample (grab, composite), sample collection date and time, and 

the analyses requested. The comment section is used to provide special notes or instructions to 

the laboratory, such as how to composite separate samples prior to analysis. The sampling team 

will also comment if sample bottles are not completely filled (i.e., less than 75 percent full). In 

addition, the comments section will be used to note deviations from standard sampling protocols 

(for example, if a sample could not be acid-preserved because of excessive buffering). 

2.9 Quality Assurance/Quality Control

 Quality assurance/quality control (QA/QC) procedures applicable to this project 

are outlined in the Quality Assurance Project Plan for the Steam Electric Effluent Guidelines 

Rulemaking [2]. The QA/QC program for sample collection at steam electric plants will include 

the following: 

 Documentation for samples through laboratory traffic reports; 

 Collection of duplicate samples; 

 Collection of field blank(s) for total metals, dissolved metals, total 

mercury, dissolved mercury, and hexavalent chromium samples. 

 Analysis of bottle blank(s) for metals by the clean-equipment supplier; 
DRAFT 

2-25

 Analysis of equipment blank(s) for metals by the clean-equipment 

supplier; 

 Collection of laboratory QC samples for matrix spike/matrix spike 

duplicate analyses. 

 Duplicate sample sets will be collected as part of the quality assurance program 

for sampling. Duplicate samples are collected as separate aliquots in the field. EPA will collect 

one duplicate sample for every ten samples collected at a sampling event, excluding field blank 

samples. For example, EPA will collect four samples from each sampling point selected at a 

plant; therefore, if the EPA collects samples from two sample points at a plant (total of 8 

samples), only one duplicate sample will be collected, but if EPA collects samples from three 

sample points at a plant (total of 12 samples), then two duplicate samples will be collected. The 

field blank samples associated with the sampling points will not be included in the count of the 

total samples collected. Results of the duplicate analyses will be used to evaluate precision, 

including variability in sample collection, handling, preparation, and analysis. 

 Bottle blanks are used to evaluate possible contamination from the sample bottles. 

The bottle blank will consist of an analyte-free matrix (Ultra Pure Blank Water DI+TM) poured 

into the appropriate sample bottles (250-mL plastic bottle for metals by) and stored for several 

days prior to shipment to the laboratory. The supplier of the cleaned metals bottles will prepare 

and analyze the bottle blanks prior to shipping the equipment to the sampling episode. 

 Field blanks will be used to evaluate possible contamination caused by sampling 

equipment or by sampling equipment decontamination procedures. Field blanks will be 

prepared in the field prior to sample collection and analyzed for all sampling equipment, other 

than sample bottles, that come into direct contact with samples. Examples of sampling 

equipment are: 

 On-site sampling devices or piping installed for sample collection; and 

 Pumps, tubing, bottle dippers, buckets, and other equipment used to 

collect samples from less accessible sampling locations. 
DRAFT 

2-26

 For all metals samples (i.e., total mercury, total and dissolved metals, and 

hexavalent chromium), EPA will prepare a field blank at each sampling point for one day of the 

sample episode 7. 

 Equipment blanks will be used to evaluate possible contamination of metals 

caused by the sampling equipment. The supplier of the equipment used for metals sample 

collection will prepare and analyze the equipment blanks for metals. 

 As part of standard laboratory quality control, matrix effects on analytical 

performance are assessed through the analysis of matrix spikes and laboratory duplicates. 

Consequently, additional sample volume must be collected for these QC analyses. The ERG 

sampling team will be responsible for collecting, labeling, and shipping the laboratory QC 

volumes. Laboratory QC volumes will be collected as duplicate samples collected immediately 

after the original sample aliquot. For metals and classical analyses, EPA will collect one QC 

sample volume (i.e., MS/MSD sample) for every ten samples collected at a sampling event, 

excluding field blank samples. For example, EPA will collect four samples from each sampling 

point selected at a plant; therefore, if EPA collects samples from two sample points at a plant 

(total of 8 samples), only one QC sample volume will be collected, but if EPA collects samples 

from three sample points at a plant (total of 12 samples), then two QC sample volumes will be 

collected. The field blank samples associated with the sampling points will not be included in 

the count of the total samples collected. 

2.10 Sample Splitting

 The plant being sampled has the option to collect split or duplicate samples at 

each of the sampling points. If this option is exercised, the plant will supply all of the personnel, 

equipment, glassware, and reagents required to collect the samples and to coordinate the analysis 

of samples. 

 

7

 ERG will collect the dissolved mercury sample using the same technique as the total mercury sample, but the 

dissolved sample will be filtered at the laboratory. A dissolved mercury field blank will be performed by the 

laboratory to assess any mercury contamination from the filtering performed at the laboratory. Therefore, ERG does 

not need to collect a dissolved mercury field blank sample in the field. 
DRAFT 

2-27

Table 2-1. Sample Collection at Steam Electric Plants 

Analytical Parameter

Influent to FGD 

Wastewater 

Treatment

Intermediate Point 

in FGD Wastewater 

Treatment 

Effluent from FGD 

Wastewater 

Treatment

BOD5 X X X 

Total Cyanide X X X 

Group I (a) X X X 

Group II (b) X X X 

Total Metals X X X 

 

Dissolved Metals X X X 

Total Mercury X X X 

Dissolved Mercury X X X 

Hexavalent Chromium X X X 

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

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

(c) Actual sample location and specific pollutants will be defined in the plant-specific sampling plan. 
DRAFT 

2-28

Table 2-2. Analytical Methods 

Parameter Method Number 

Classicals

Biochemical Oxygen Demand (BOD5) SM 5210 B (or other 40 CFR Part 136-approved method 

Chemical Oxygen Demand (COD) EPA 410.3 (or other 40 CFR Part 136-approved method) 

Total Suspended Solids (TSS) SM 2540 D (or other 40 CFR Part 136-approved method) 

Total Dissolved Solids (TDS) SM 2540 C (or other 40 CFR Part 136-approved method) 

Sulfate ASTM D516-90 (or other 40 CFR Part 136-approved 

method) 

Chloride SM 4500–Cl–C (or other 40 CFR Part 136-approved 

method) 

Ammonia as Nitrogen SM 4500—NH3 B, F (or other 40 CFR Part 136-approved 

method) 

Nitrate/Nitrate as Nitrogen SM 4500—NO3 -H (or other 40 CFR Part 136-approved 

method) 

Total Kjeldahl Nitrogen (TKN) SM 4500—NH3 B or C, F (or other 40 CFR Part 136-

approved method) 

Total Phosphorus EPA 365.3 (or other 40 CFR Part 136-approved method) 

Total Cyanide EPA 335.4 (or other 40 CFR Part 136-approved method) 

Total and Dissolved Metals

Mercury EPA 1631E 

Hexavalent Chromium (dissolved only) EPA 218.6 (or other 40 CFR Part 136-approved method) 

 

Aluminum, antimony, arsenic, 

barium, beryllium, boron, 

cadmium, calcium, chromium, 

cobalt, copper, iron, lead, 

magnesium, manganese, 

molybdenum, nickel, selenium, 

silver, sodium, thallium, tin, 

titanium, vanadium, and zinc

EPA 200.7, EPA 200.8 (Note: EPA 200.8 may include the 

use of collision cell or dynamic reaction cell 

instrumentation for selected analytes.) 
DRAFT 

2-29

Table 2-3. Summary of Sample Container and Planned Preservation 

Parameter 

Sample 

Container and 

Volume 

QC Sample 

Container and 

Volume On-Site Preservation 

Classicals 

BOD5 One 1-L plastic 

bottle 

One 1-L plastic 

bottle 

≤6C 

Group I a Two 1-L plastic 

bottle 

Two 1-L plastic 

bottle 

≤6C 

Group II b Two 1-L plastic 

bottle 

Three 1-L 

plastic bottle 

H2SO4 to pH <2, ≤6C 

Total cyanide One 1-L plastic 

bottle 

Two 1-L plastic 

bottle 

NaOH to pH >10, dilution until 

sulfide is not present, NaAsO2 until 

total chlorine is not present, ≤6C 

Metals 

Total metals (except mercury) One 250-mL 

plastic bottle 

One 250-mL 

plastic bottle 

None 

(acid preserve at laboratory) 

 

Dissolved metals (except mercury and 

hexavalent chromium) 

One 250-mL 

plastic bottle 

One 250-mL 

plastic bottle 

0.45 μm filter (performed in field) 

(acid preserve at laboratory) 

 

Total mercury One 250-mL 

glass 

(ultraclean), 

fluoropolymer 

lined caps 

One 250-mL 

glass 

(ultraclean), 

fluoropolymer 

lined caps 

None 

(acid preserve at laboratory) 

Dissolved mercury Two 250-mL 

glass 

(ultraclean), 

fluoropolymer 

lined caps 

Two 250-mL 

glass 

(ultraclean), 

fluoropolymer 

lined caps 

None 

(filter and acid preserve at 

laboratory) 

Hexavalent chromium One 250-mL 

plastic bottle 

One 250-mL 

plastic bottle 

0.45 μm filter (performed in field) 

Ammonium sulfate buffer to 

pH 9.3 – 9.7, ≤6oC 

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

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

 
DRAFT 

2-30

Table 2-4. Sampling Point Field Measurements 

Field Measurements Method Detection Range (or Gradation of 

Scale) 

Temperature Thermometer -20 to 150 ± 1 oC 

pH (Standard Units) Four color indicator strip 

pH meter 

0 to 12 ± 1 pH S.U. 

-1.0 to 15.0 ± 0.1 pH S.U. 
DRAFT 

2-31

Sampling Episode ________ 

Preservation Chemicals - List Strength of Solution from Bottle 

H2SO4 ______________________ NH4SO4 ____________________ 

NaOH ______________________ 

Sample 

Number Analysis Date Name Chemical Initial pH Final pH

Number of 

Drops

 

Figure 2-1. Sample Preservation Log Sheet 
DRAFT 

2-32

Sampling Episode: _________________________________ 

Sampling Point: ___________________________________ 

Sample Numbers: __________________________________ 

Date: ____________________________________________ 

Manual Composite □ Grab □

Automatic Composite □

Time of Sample Collection: 

 Start Time □ AM □ PM 

 End Time □ AM □ PM 

Equipment Used: _________________________________________________ 

Samplers’ Names: ________________________________________________ 

Sample 

Point Time

Temp 

°C 

Thermometer / Meter 

pH 

(S.U.) 

Meter / Strips

Waste Stream 

Flow Rate 

(GPM)

1 

2 

3 

4 

5 

6 

7 

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

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________ 

Figure 2-2. Field Sampling Log Sheet 
2-33 

DRAFT 

Plant Name: ____________________________________________________________________________ Plant Contact: ____________________________________________________________________________ Dates of Sample Collection: ___________________________________________________________________ Data Collected by: __________________________________________________________________________ Instructions: In the tables below, fill out information on the generating units and FGD systems operating at the plant based on all four depisode. Note any changes in operation that occur during the four-day period. Provide actual data if possible. If actual data are not availfor the specific information. Some of the data requested may not be susceptible to estimation. Enter “URE” for “unable to reasonably especify whether data provided are actual or estimated by writing in “ACT” or EST” wherever appropriate. 

Generating Unit Operating Characteristics During Sample Collection 

Unit 

ID Boiler Type 

Capacity 

(MW) 

Electricity 

Production 

(or Percent 

Capacity) 

SCR 

(No, On, 

Off) 

Particulate 

Control System 

(HS/CS ESP, or 

BH) 

FGD System Operating Characteristics During Sample Collection 

Unit 

ID 

Wet FGD 

System 

(Yes/No) 

Type of 

Scrubber 

Forced 

Oxidation 

(Yes/No) Sorbent 

Additives 

(DBA, formic 

acid, etc.) 

FGD Makeup Water 

Source 

SO2

Removal 

Percentage 

Typ

So

Sepa

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

Figure 2-3. Engineering Data Collection Sheet (Page 1 of 3) 
DRAFT 

2-34

Plant Name: ____________________________________________________________________________ 

Plant Contact: ____________________________________________________________________________ 

Dates of Sample Collection: ___________________________________________________________________ 

Data Collected by: __________________________________________________________________________ 

Instructions: In the tables below, provide information on the coal burned and FGD scrubber slurry at the plant for 

each day of the sampling episode. Provide actual data if possible. If actual data are not available, provide estimates 

for the specific information. Some of the data requested may not be susceptible to estimation. Enter “URE” for 

“unable to reasonably estimate.” Otherwise, specify whether data provided are actual or estimated by writing in 

“ACT” or EST” wherever appropriate. 

Coal Information 

Day of 

Sampling Unit ID Coal Type 

Amount of 

Coal Used 

During 

Day of 

Sampling 

Source of 

Coal (Coal 

Region 

and/or 

State) 

Percent 

Sulfur in 

Coal 

Chlorine 

Content of 

Coal 

1 

 

2 

3 

4 

 

 

Note changes in operation over the past month (e.g., turned off SCRs on October 1 or burned 5% petroleum coke 

previous week) as well as conditions and changes during the sampling episode: 

Scrubber Slurry Information 

Day of 

Sampling 

FGD 

System ID 

Associated 

Unit IDs 

Scrubber Slurry 

Blowdown Flow Rate 

Scrubber 

Slurry 

Percent 

Solids 

Time of 

Dewatering 

During 

Sampling Day 

Percent 

Filtrate 

Recycled 

Back to 

Scrubber 

Flow Rate 

(gpm) Duration 

1 

 

 

2 

3 

4 

Figure 2-4. Engineering Data Collection Sheet (Page 2 of 2)
DRAFT 

2-35

Plant Name: ____________________________________________________________________________ Plant Contact: ____________________________________________________________________________ Dates of Sample Collection: ___________________________________________________________________ Data Collected by: __________________________________________________________________________ Instructions: In the table below, provide information on the FGD wastewater treatment system for each day of the sampling episode and wastewater treatment system tanks and reactors. If possible, provide the name of the acid and polymer used during the sampling episod

possible. If actual data are not available, provide estimates for the specific information. Some of the data requested may not be suscepti“URE” for “unable to reasonably estimate.” Otherwise, specify whether data provided are actual or estimated by writing in “ACT” or E

appropriate. 

FGD Wastewater Treatment System Operation Information 

Day of 

Sampling 

Scrubber Purge 

Chemical Usage 

(specify units) 

Flow Rate 

(gpm) Duration Lime 

Ferric 

Chloride 

Organo-sulfide 

_________ 

(specify type) 

Polymer: 

_________ 

(specify type) 

A

___

(spec

1 2 3 4 

Volume of equalization tank ________________ Volume of reaction tanks: 1) ________________ 2) ________________ 3) ________________ Volume of clarifiers 1) ________________ 2) ________________ Volume of first-stage bioreactors ________________ Volume of second-stage bioreactors ________________ 

Figure 2-5. Engineering Data Collection Sheet (Page 3 of 3)
DRAFT 

2-36

Figure 2-6. Example Traffic Report 

EPISODE NO:

RANGE OF SAMPLE NOS:

Return completed form to:

FOR LAB USE ONLY

NAME: SHIP TO: DATE REC'D:

CITY: ATTN: REC'D BY:

STATE: CARRIER: SAMPLE CONDITION ON RECEIPT:

INDUSTRIAL CATEGORY: AIRBILL:

DATE SHIPPED:

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

SAMPLE 

NUMBER SOURCE WATER

(city, river, well)

IN LINE PROCESS

UNREATED EFFLUENT

(raw

wastewater)

TREATED EFFLUENT

OTHER

(specify)

ADDITIONAL 

SAMPLE 

DESCRIPTION PH LEVEL

PRESERVED (Y/N)

G=GRAB / C=CO

MPOSITE

SAMPLE COLLECT OI N

TIME / DATE

Comments:

EPA Form 7500-50 (Rev 6-94) Previous editions are obselete.

Page 1: SCC Copy Page 2: Lab Copy

Copy of Page 1: Sampler Copy Copy of Page 2: Lab Copy for return to SCC

United States

EPA Environmental Protection Agency

Washington, DC 20460

TRAFFIC REPORT P.O. BOX 1407

USEPA ENGINEERING AND ANALYSIS DIVISION ALEXANDRIA, VA 22313

SAMPLE CONTROL CENTER (703) 519-1140

INDUSTRIAL FIRM SAMPLED SHIPPING & INFORMATION

SAMPLE POINT DESCRIPTION SAMPLE ANALYSES
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3-1

3.0 SAMPLING ACTIVITIES

 This section discusses the sampling team organization, site visit preparation, and 

sampling activities. 

3.1 Sampling Team Organization

 The sampling crew will consist of a crew chief from ERG, crew members from 

ERG, and EPA representative(s). The actual number of ERG crew members will be determined 

based on the number of sampling points at the plant. The crew chief will be responsible for all 

health and safety, sample collection, preservation, and shipping activities on site. After 

completion of the visit, the analytical results from each laboratory will be collated. This 

information will be summarized and transmitted in a trip report to EPA. After EPA review, the 

report will be forwarded to the plant for their review. 

3.2 Pre-Sampling Preparation

 EPA will conduct a pre-sampling site visit at each selected plant prior to 

sampling, unless EPA has already visited the plant previously. The site visits will provide EPA 

with site-specific process information such as: 

 Types of wastewater streams generated by the steam electric operations; 

 Feasibility of sampling FGD wastewater streams prior to commingling 

with other wastewater; 

 Locations of potential sampling points; 

 Conditions at potential sampling points (e.g. temperature and pH); and 

 Type of discharge at each sampling point (e.g. continuous or intermittent); 

and 

 Health and safety concerns at each potential sampling point. 
DRAFT 

3-2

 EPA will use this information to select sampling points and plan the sampling 

episode. Prior to the sampling episode, the ERG crew chief will prepare a plant-specific 

sampling plan outlining the descriptions of sampling points (including any information on flow 

rate, temperature, solids content, and pollutant concentrations provided by the facility contact), 

equipment needed (e.g., bottle clamp, dipper, and pole), anticipated health and safety 

requirements and procedures, the sample team organization, plant names and contacts, location 

of the local Federal Express office, and the names and addresses of analytical laboratories. The 

ERG Health and Safety Coordinator (HSC), Kevin Sikora, will identify the plant-specific health 

and safety requirements. 

 The ERG crew chief will distribute the plant-specific sampling plan to each team 

member and make sure they are completely familiar with the plant-specific health and safety 

requirements. Plant personnel will be given copies of the generic sampling plan, generic health 

and safety plan, and plant-specific sampling plan prior to the start of sampling. 

 The ERG crew chief will also coordinate the procurement and shipment of all 

necessary sampling and health and safety equipment. 

3.3 Field Sampling Activities

 At each site, the ERG crew chief, in conjunction with the EPA Work Assignment 

Manager (WAM), will meet with plant personnel to determine whether samples can be collected 

at each of the planned sampling points. Upon making the decision to collect samples, the ERG 

crew chief will update the descriptions of the proposed sampling points, if necessary, in 

consultation with EPA and plant personnel. If necessary, additional equipment and glassware 

will be obtained. The revised description shall include: 

 A sample point description and collection procedure for each sample 

point; 

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

 A list of potential physical hazards (such as pH, temperature, and 

potentially hazardous equipment); 
DRAFT 

3-3

 A list of potential chemical hazards associated with each sample point; 

and 

 A list of proposed health and safety procedures. 

 Prior to sampling, the ERG crew chief will also notify the ERG HSC of any 

revised sampling activity descriptions along with recommended revisions to the proposed health 

and safety procedures. Together, the crew chief and HSC will review the proposed health and 

safety procedures. The crew chief will incorporate any plant-specific changes indicated by the 

HSC, and gain approval for sampling from the HSC before proceeding with sampling activities. 

 All sample bottles will be labeled, collected, and preserved, according to method 

protocols. Sample fractions requiring ≤6C preservation will be placed on ice until desired 

temperature is reached. Sample fractions will then be sealed, and placed in coolers for shipment 

to the laboratory. The Traffic Report forms will be completed and placed in plastic sleeves 

inside the coolers. The coolers will then be taken to the nearest Federal Express office and 

shipped to the analytical laboratories. At the conclusion of the sampling episode, the sampling 

equipment will be prepared for return shipping. 

 

3.4 Standard Logistics

 This section of the sampling plan summarizes plant contacts, analytical laboratory 

contacts and addresses, and sampling team personnel and support functions. 

3.4.1 Plant Contacts 

 To be determined prior to sampling. 

3.4.2 EPA Contacts 

Ron Jordan 

 Engineering and Analysis Division 

 U.S. Environmental Protection Agency 
DRAFT 

3-4

 1200 Pennsylvania Avenue, NW (4303T) 

 Washington, D.C. 20460 

 (202) 566-1003 

Jezebele Alicea 

Engineering and Analysis Division 

U.S. Environmental Protection Agency 

1200 Pennsylvania Avenue, NW (4303T) 

Washington, D.C. 20460 

(202) 566-1755 

3.4.3 Analytical Laboratories 

To be determined prior to sampling. 

3.4.4 ERG Contacts 

Deb Bartram (ERG Work Assignment Manager) 

 Eastern Research Group, Inc. 

 14555 Avion Parkway, Suite 200 

 Chantilly, VA 20151 

 (703) 633-1669 

 TJ Finseth (Sampling Program Lead) 

 Eastern Research Group, Inc. 

 14555 Avion Parkway, Suite 200 

 Chantilly, VA 20151 

 (703) 633-1698 

3.4.5 Freight Forwarders 

 Federal Express 

 General Information (800) 463-3339 

 Specific location to be determined for each sampling trip. 
DRAFT 

4-1

4.0 SAMPLE SHIPMENT

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

samples will be tracked using Traffic Report forms. Custody will be maintained by the sampling 

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

 All samples will be packaged and shipped in accordance with DOT or IATA 

regulations. The general IATA packaging requirements for air shipment are as follows: 

 “Inner packaging must be so packed, secured or cushioned as to prevent their 

breakage or leakage and so as to control their movement within the outer 

packaging during normal conditions of transport. Cushioning material must not 

react dangerously with the contents of the inner packaging. Any leakage of the 

contents must not substantially impair the protective properties of the cushioning 

material. Unless otherwise provided in this paragraph or in the Packing 

Instructions, liquids in Classes, 3, 4, 5, 6, or 8 of Packing Groups I or II in glass or 

earthenware inner packaging, must be packaged using material capable of 

absorbing the liquid. Absorbent material must not react dangerously with the 

liquid. Absorbent material is not required...” (IATA Dangerous Goods 

Regulations, 5.0.16). 

 “When filling receptacles for liquids, sufficient ullage (outage) must be left to 

ensure that neither leakage nor permanent distortion of the receptacle will occur 

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

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

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

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

nonhazardous samples. Hazardous samples will be identified based on consultation with the 

hazardous shipments contact, and appropriate hazardous shipping procedures will be followed. 

Based on process considerations, samples collected are not expected to be classified as IATA 

dangerous goods. 

4.1 Sample Set Preparation

 Samples are collected as a series of “fractions,” or bottles designated for 

particular analyses requiring the same preservation. The comprehensive water sample set 

consists of sample fractions for all pollutants listed in Section 2.2, collected as 24-hour 

composite samples and transferred into the individual sample bottles. 
DRAFT 

4-2

4.2 Sample Packing

 All dilute samples from the plant will be packed according to the following 

guidelines (there is no limit on the amount of liquid each sample container may contain): 

1. Label each sample bottle. If a required preservation is not used, cross it off with 

indelible ink. Cover the label with clear tape to protect this information. Metals 

sample bottles will not be labeled; instead, the outer plastic bag for each bottle 

will be labeled. 

2. Tighten the lid on each filled sample bottle, being careful not to overtighten the 

lid. If bottle threads are dirty to where the lid is impeded from closing, clean the 

threads on the bottle being careful to not introduce contamination into the sample. 

Clean the sample bottle with a cloth rag or paper towel. The bottle threads will not 

be cleaned for the mercury sample bottles. 

3. Place each sample bottle requiring ≤6C preservation into an ice chest with wet 

ice prior to packaging to cool. 

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

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

place bottle in two “bubble bags”). The bubble wrap must fit snugly and 

completely cover the sample bottle. Each “bubble-wrapped” container and plastic 

container must then be enclosed in an individual sealable plastic freezer bag. 

5. Place two garbage bags inside each other in the cooler. 

6. Place sample bottles in garbage bags in the cooler with proper end up, close the 

interior garbage bag by tying, or with a twist-tie. 

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

sealed plastic freezer bags filled with wet ice on top of the sample bottles (if 

samples require ≤6C preservation). If using wet ice, place the ice inside two onegallon sealable freezer bags. Put at least 4 × 1⁄2 gallons of ice (4 × 2.5 lbs of ice) in 

each large cooler and 2 × 1⁄2 gallons of ice (2 × 2.5 lbs of ice) in each small cooler. 

More ice should be used when ambient temperatures are very high. The ice should 

be placed inside the second garbage bag. Close the second garbage bag with a 

twist-tie. 

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

Sufficient packing material should be used so that the sample containers will not 

shift during shipment. 

9. Seal the Traffic Report form in a plastic zip-lock bag and tape securely to the 

inside of the cooler lid. 
DRAFT 

4-3

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

11. Close cooler. 

12. Make several wraps with tape around the cooler perpendicular to the seal to 

ensure that the lid will remain closed if the latch is accidentally released or 

damaged. 

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

14. Place a completed address label on the lid of the cooler including name, address, 

and telephone number of the receiving laboratory and the return address and 

telephone number of the shipper. 
DRAFT 

5-1

5.0 REFERENCES

U.S. EPA. 2009. Steam Electric Power Generating Point Source Category: Final Detailed Study 

Report. EPA 821-R-09-008. Washington, DC. (October). Available online at: 

http://www.epa.gov/guide/steam/finalreport.pdf. DCN SE00003. 

Eastern Research Group, Inc. 2009. Quality Assurance Project Plan for the Steam Electric 

Effluent Guidelines Rulemaking. (September). DCN SE00058. 
Appendix C 

INFORMATION COLLECTION REQUEST FOR THE STEAM ELECTRIC 

GENERATING INDUSTRY [FINAL VERSION] 

(SEE http://water.epa.gov/scitech/wastetech/guide/steam-electric/questionnaire.cfm) 
Appendix D 

ANALYTICAL DATA REVIEW CHECKLISTS
Final Checklist July 9, 2010

Steam Study Data Review Checklist

Metals and Trace Elements Analysis in Water and Wastes 

EPA Method 200.7 (1994)

(Inductively Coupled Plasma Atomic Emission Spectrometry)

SECTION A-1. Sample Identifiers

Laboratory Name:

Sampling Episode:

Sample Numbers or 

Range:

Data Reviewer 

signature:

Date:

Instructions: Complete this checklist electronically or using a ballpoint pen.

Record reviewer comments in the Reviewer Comment section.

Record detailed information in the Comments in the “Overall Assessment” section for 

each criterion not (“N”) met.

Note: Requirements with a * are project requirements not specific to EPA Method 

200.7.

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level 

Required Present Comments

Copies of Shipping Documents (Fed-Ex 

Airbills)

1, 2, 3

Case Narrative 1, 2, 3

Table of Contents 3

Cross reference of Field Sample No., Lab 

Sample No., and Analytical Batch

1, 2, 3

Traffic Report Form (including Sample 

Receipt Checklist)

1, 2, 3

Sample Calculation (usually just a page 

copied from SOW)

3

Results Summary for Each Sample and 

Blank 

1, 2, 3

Method Detection Limit Study 3

Initial Calibration Data 3

Initial Calibration Verification 3

Initial Calibration Blank 3

Laboratory Reagent Blank (LRB) Results 2, 3

Laboratory Fortified Blank Results 2, 3

Instrument Performance Check (IPC) 

Solution Results

3
Steam Study Data Review Checklist

Metals and Trace Elements Analysis in Waters and Wastes EPA Method 200.7 (1994) 

Page 2 of 7

Final Checklist July 9, 2010

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level 

Required Present Comments

Continuing Calibration Blank 3

Quality Control Sample Results 2, 3

Spectral Interference Check (SIC) Solution 

Results

3

Laboratory Fortified Sample Matrix (LFM)/ 

Laboratory Fortified Sample Matrix 

Duplicate (LFMD) Results

2, 3

Analyte Addition Test Results 3

Dilution Test Results 3

Method of standard additions and/or Internal 

Standards Technique Results (if necessary)

3

Field Duplicate Results 2, 3

Continuing Calibration Verification Results 3

Quantitation List 3

Copies of Sample Preparation Work Sheets 3

Copies of Run Logs 3

Level 1: Review of traffic reports, sample handling, and proper sample preparation

Level 2: Level 1 review plus review of QA/QC results

Level 3: Level 2 review plus review of instrument performance

Level 4: Level 3 review plus analysis of raw data such as chromatograms or primary instrument output
Steam Study Data Review Checklist

Metals and Trace Elements Analysis in Waters and Wastes EPA Method 200.7 (1994) 

Page 3 of 7

Final Checklist July 9, 2010

EPA METHOD 200.7 REQUIREMENT Reviewer Comment

Criterion

met

Y N

SECTION B. SAMPLE RECEIPT

1. Reviewed Sample Collection Record: 

• Signatures?

• Completed?

• Sample ID numbers checked?

• Preservations? Volume?

• Any anomalies reported?

2. Reviewed Lab Sample Receipt Record:

• Date received?

• Lab ID number checked?

• Lab ID number referenced to Sample ID 

numbers?

• Preservation checked by lab? Volume?

• Sample conditions

• Sample hold time

• Any anomalies reported by lab?

SECTION C. SAMPLE PREPARATION/EXTRACT HANDLING 

INFORMATION

1. Reviewed Standard Pre logs: 

• Standard expiration date:

• Concentrations prepared?

2. Reviewed Sample Prep Logs:

• Sample extraction date:

• Sample process or run date:

3. *Field Duplicates: Was a field duplicate collected

and analyzed as part of the sampling episode? 

Indicate the relative percent difference.

SECTION D-1. QC INFORMATION 

1. Review Lab’s Instrument Run Log Report: 

Were calibrations, QC samples and samples 

included in a batch of 20 samples? 

2. Method Detection Limit Study (MDL): Were 

seven samples prepared and analyzed according to 

Section 9.2.4 of Method 200.7? Was the study 

conducted before samples were analyzed and 

annually? (200.7/9.2.4) 

What were the MDLs reported by the lab?
Steam Study Data Review Checklist

Metals and Trace Elements Analysis in Waters and Wastes EPA Method 200.7 (1994) 

Page 4 of 7

Final Checklist July 9, 2010

EPA METHOD 200.7 REQUIREMENT Reviewer Comment

Criterion

met

Y N

SECTION D-2. QC INFORMATION – Instrument Calibration

1. Initial Calibration Blank: Was a calibration 

blank analyzed following the daily calibration? 

Were the analytes less than the Reporting Limit 

(RL)? (200.7/7.10.1/9.3.4/11.4.4)

Indicate the concentration of the analyte in the 

calibration blank and the RL.

2. Mixed Calibration Standard Solutions: Were 

mixed calibration standard solutions prepared and 

analyzed after the calibration blank? 

(200.7/7.9/11.4.4)

What were the true and analyzed concentrations of 

the calibration standards used by the lab? 

Did the calibration standard solution results 

confirm that the instrument was correctly 

calibrated1?

SECTION D-3. QC INFORMATION –Blanks

1. Laboratory Reagent Blank (LRB): Was a blank 

containing all reagents prepared with each batch of 

20 or fewer samples and used to evaluate 

contaminants in reagents?

Were analyte levels in the blank less than 10% of 

the analyte level in the sample or less than 2.2 

times the analyte MDL (whichever is greater)? 

(200.7/7.10.2/9.3.1)

Note any contamination reported.

2. Laboratory Fortified Blank (LFB): Was a blank 

containing all analytes of interest prepared and 

analyzed? 

Was the percent recovery for all analytes within 

the control limits of 85-115%? (200.7/7.10.3/9.3.2)

What were the true and analyzed concentrations of 

all analytes in the LFB reported by the lab? 

What were the % recoveries of all the analytes?

 

1 Note: There is no specific requirement to confirm calibration specified in the method. The labs can use what they consider 

appropriate.
Steam Study Data Review Checklist

Metals and Trace Elements Analysis in Waters and Wastes EPA Method 200.7 (1994) 

Page 5 of 7

Final Checklist July 9, 2010

EPA METHOD 200.7 REQUIREMENT Reviewer Comment

Criterion

met

Y N

SECTION D-4. QC INFORMATION –Instrument Performance Checks

3. Instrument Performance Check (IPC) Solution: 

Was the IPC solution analyzed after calibration, 

every 10 samples, and at the end of the sample 

run?

Did the IPC solution confirm that the instrument 

was within ±5% of calibration directly after 

calibration and within ±10% of calibration for all 

other times? (200.7/7.11/9.3.4)

What were results reported for the IPC and the 

percent recovery?

4. Continuing Calibration Blank: Was a continuing 

calibration blank analyzed after every 10 samples 

and at the end of every run? Were the analytes less 

than the RL? (200.7/9.3.4)

Indicate the concentration of the analyte in the 

calibration blank and the RL.

5. Quality Control Sample (QCS) data enclosed?:

Was a secondary source QCS prepared and 

analyzed to confirm instrument performance? 

Was the average concentration from the analysis of 

three QCS samples within ±5% of the true value? 

(200.7/7.12/9.2.3)

Indicate the true value of the QCS, the QCS value 

reported by the labs, and the percent recovery.

6. Spectral Interference Check (SIC) Solutions: 

Were SIC solutions used to confirm any 

interelement corrections applied to the data? 

(200.7/7.13/9.3.5)
Steam Study Data Review Checklist

Metals and Trace Elements Analysis in Waters and Wastes EPA Method 200.7 (1994) 

Page 6 of 7

Final Checklist July 9, 2010

EPA METHOD 200.7 REQUIREMENT Reviewer Comment

Criterion

met

Y N

7. *Laboratory Fortified Sample Matrix 

(LFM)/Laboratory Fortified Sample Matrix 

Duplicate (LFMD): Was an LFM and *LFMD

analyzed at a frequency of 10% of samples? 

Was a LFM and *LFMD sample analyzed for each 

midpoint and effluent point in a sampling episode?

Was the percent recovery of the LFM/*LFMD for 

all analytes within the control limits of 70-130%? 

The RPD between LFM and LFMD is suggested to 

be less than 20%. (200.7/9.4)

What were the % recoveries for all analytes? 

What were the RPDs reported by the lab?

Note: If recoveries do not meet criteria and the 

system is otherwise in control, the problem may be 

matrix related. If an analyte recovery in the 

LFM/LFMD failed, was the associated data for 

that analyte flagged as suspect due to matrix 

effect? (200.7/9.4)

8. Analyte Addition Test: Was a standard added to 

at least one of the samples in the batch to produce 

a concentration of 20-100 times the MDL and was 

the percent recovery within 85-115% of the true 

value (or the associated data flagged as suspect due

to matrix effect)? (200.7/9.5.1)

What were the % recoveries for all analytes? 

9. Dilution Test: Was at least one of the samples in 

the batch diluted 5 fold and if the original

concentration was > 50 times the Instrument 

Detection Limit (IDL), was the percent recovery 

within ±10% of the original concentration?

(200.7/9.5.2) 

What were the % recoveries for all analytes? 

What was the original concentration in the sample?

10. Method of Standard Additions/Internal 

Standards Technique: If either the analyte 

addition test or dilution test failed as stated above, 

was the method of standard additions and/or the

internal standards technique used to correct for 

interferences? (200.7/9.5/11.5)
Steam Study Data Review Checklist

Metals and Trace Elements Analysis in Waters and Wastes EPA Method 200.7 (1994) 

Page 7 of 7

Final Checklist July 9, 2010

EPA METHOD 200.7 REQUIREMENT Reviewer Comment

Criterion

met

Y N

SECTION E. DETAILED SAMPLE RAW DATA REVIEW 

1. Sample Results Reporting: Were results reported 

in units of milligrams per liter (mg/L) for samples?

Were analyte concentrations below the IDL not 

reported? (200.7/12.1)

2. Dilution: If the analyte concentration was ≥ 90% 

of the upper limit of the LDR, was the sample 

diluted and reanalyzed? (200.7/11.4.7/12.3)
Final Notes July 9, 2010

Steam Study Data Review Notes 

Metals and Trace Elements Analysis in Water and Wastes 

EPA Method 200.7 (1994)

(Inductively Coupled Plasma Atomic Emission Spectrometry)

1. * If reported, note the total dissolved solids (TDS) concentration of the samples after 

dilution. If diluted appropriately, samples should have a TDS concentration of 0.15 -

0.2% (200.7/1.3/4.2).

2. For the determination of dissolved elements, samples should be filtered through a 0.45 

um pore membrane filter soon after collection. The filtrate should be acidified at the 

laboratory with 1 to 1 nitric acid to a pH less than 2 within two weeks of collection

(200.7/8.2).

3. Prior to the analysis of dissolved elements, samples should be acidified with nitric acid 

and if a precipitate forms samples should be digested using the procedure specified in 

Section 11.2 (200.7/11.1.1). If reported, indicate the amount of nitric acid used in the 

digestion and list any deviations noted in the lab’s digestion procedures. 

4. For the determination of total or total recoverable elements, samples should be acidified 

with 1 to 1 nitric acid to a pH less than 2 within two weeks of collection (200.7/8.3).

After acidification, the sample should be mixed and allowed to sit for 16 hours, and then 

confirmed to have a pH less than 2. If the pH was greater than or equal to 2 the sample 

should be acidified, mixed, held for 16 hours, and tested again (200.7/8.3).

5. Prior to the analysis of total or total recoverable elements, a well mixed volume of the 

sample should be digested with nitric acid and hydrochloric acid and if necessary filtered

prior to analysis (200.7/11.2). *For FGD influent samples that contain greater than 1% 

suspended solids, the laboratory should separate the solid and liquid portions of the 

sample and analyze each portion separately. If reported, indicate the amount of nitric and 

hydrochloric acids used in digestion and any deviations noted in the lab’s digestion 

procedures.

6. A rinse blank should be used to flush the system between all solution changes. If 

reported, indicate how many rinse blanks were run and note any contamination reported.

7. For aqueous samples, a field blank should be prepared and analyzed at each sample point 

during one of the four days of sample collection. If the analyte concentration was greater 

than the MDL, indicate the concentration. (200.7/8.5)

8. *If the analyte concentration in a sample was less than 5 times the analyte concentration 

in the laboratory reagent blank, the result should be reported as a nondetect. List all 

affected samples.

9. *If the analyte concentration in a sample was less than 10 times but greater than 5 times 

the analyte concentration in the laboratory reagent blank, the result should reported as an 

estimated value. List all affected samples.
Final Checklist July 9, 2010

Steam Study Data Review Checklist

Standard Operating Procedure (SOP) for Inductively Coupled Plasma 

Mass Spectrometry for Trace Element Analysis in Flue Gas 

Desulfurization Wastewaters

SECTION A-1. Sample Identifiers

Laboratory Name:

Sampling Episode:

Sample Numbers or 

Range:

Data Reviewer 

signature:

Date:

Instructions: Complete this checklist electronically or using a ballpoint pen.

Record reviewer comments in the Reviewer Comment section.

Record detailed information in the Comments in the “Overall Assessment” 

section for each criterion not (“N”) met.

Note: Requirements with a * are project requirements not specific to

The Standard Operating Procedures (SOP) for Inductively 

Coupled Plasma Mass Spectrometry for Trace Element Analysis 

in Flue Gas Desulfurization (FGD) Wastewaters (FGD SOP).

Note: The FGD SOP is based on EPA Method 200.8 and 1638, but 

optimized for FGD wastewater. Some requirements listed in 200.8 

are still required even if they are not explicitly stated in the FGD 

SOP. These requirements are indicated with a ** . 

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level

Required Present Comments

Copies of Shipping Documents (Fed-Ex Airbills) 1, 2, 3

Case Narrative 1, 2, 3

Table of Contents 3

Cross reference of Field Sample No., Lab Sample 

No., and Analytical Batch

1, 2, 3

Traffic Report Form (including Sample Receipt 

Checklist)

1, 2, 3

Sample Calculation (usually just a page copied 

from SOW)

3

Results Summary for Each Sample and Blank 1, 2, 3

Method Detection Limit Study 3
Steam Study Data Review Checklist

Standard Operating Procedures for Trace Element Analysis in Flue Gas Desulfurization Wastewaters 

Page 2 of 9

Final Checklist July 9, 2010

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level

Required Present Comments

Instrument Detection Limit Study 3

Linear Range Study Results (if reported) 3

Initial and On-going Demonstration of Capability 3

Instrument Tuning Results (including mass 

calibration and mass resolution checks)

3

Mass 75 Interference Check Results 3

Initial Calibration Results 3

Initial Calibration Verification 3

Initial Calibration Blank 3

Reporting Limit Verification Standard Results 3

Laboratory Reagent Blank (LRB) Results 2, 3

Laboratory Fortified Blank Results 2, 3

Individual Interference Check Solution Results (if 

reported)

2, 3

Synthetic FGD Interference Check Solution 2, 3

Laboratory Fortified Synthetic FGD Solution 2, 3

Matrix Spike/Matrix Spike Duplicate Results 2, 3

Internal Standardization Results 2, 3

Continuing Calibration Verification Standard

Results

3

Continuing Calibration Blank (CCB) Results 3

Field Duplicate Results 2, 3

Data for all Masses Monitored (e.g. all relevant 

isotopes) (if reported)

3

Quantitation List 3

Copies of Sample Preparation Work Sheets 3

Copies of Run Logs 3

Level 1: Review of traffic reports, sample handling, and proper sample preparation

Level 2: Level 1 review plus review of QA/QC results

Level 3: Level 2 review plus review of instrument performance

Level 4: Level 3 review plus analysis of raw data such as chromatograms or primary instrument 

output
Steam Study Data Review Checklist

Standard Operating Procedures for Trace Element Analysis in Flue Gas Desulfurization Wastewaters 

Page 3 of 9

Final Checklist July 9, 2010

FGD SOP/EPA METHOD 200.8

REQUIREMENT Reviewer Comment

Criterion

met

Y N

SECTION B. SAMPLE RECEIPT

1. Reviewed Sample Collection Record: 

• Signatures?

• Completed?

• Sample ID numbers checked?

• Preservations? pH? Volume?

• Any anomalies reported?

2. Reviewed Lab Sample Receipt Record:

• Date received?

• Lab ID number checked?

• Lab ID number referenced to Sample ID 

numbers?

• Preservation checked by lab? pH? Temp? 

Volume?

• Sample conditions

• Sample hold time

• Any anomalies reported by lab?

SECTION C. SAMPLE PREPARATION/EXTRACT HANDLING 

INFORMATION

1. Reviewed Standard Pre logs: 

• Standard expiration date:

• Concentrations prepared?

2. Reviewed Sample Prep Logs:

• Sample extraction date:

• Sample process or run date:

3. *Field Duplicates: Was a field duplicate collected 

and analyzed as part of the sampling episode? 

Indicate the relative percent difference.
Steam Study Data Review Checklist

Standard Operating Procedures for Trace Element Analysis in Flue Gas Desulfurization Wastewaters 

Page 4 of 9

Final Checklist July 9, 2010

FGD SOP/EPA METHOD 200.8

REQUIREMENT Reviewer Comment

Criterion

met

Y N

SECTION D-1. QC INFORMATION – Method Performance

1. Review Lab’s Instrument Run Log Report: Were 

calibrations, QC samples and samples included in a 

batch of 20 samples? 

2. Method Detection Limit Study (MDL): For each 

analyte of interest, were seven samples containing a 

concentration of 3-5 times the MDL prepared using 

the synthetic FGD wastewater matrix and analyzed 

according to the methods in Section 10 of the FGD 

SOP? 

Was an MDL study conducted before samples were 

analyzed, and repeated every year? (FGD SOP/12.1) 

What were the MDLs reported by the lab?

3. Instrument Detection Limit Study: For each mass 

used during the analysis, was an IDL study 

conducted quarterly? During the IDL study was the 

analysis of 10 blanks run on three non-consecutive 

days used to calculate the IDL? (FGD SOP/12.3) 

What were the IDLs reported?

4. Demonstration of Capabilities: Was an initial 

demonstration of proficiency (IDOC) performed 

prior to analysis of samples and was on-going 

proficiency demonstrated annually? (FGD 

SOP/12.5) 

What were IDOCs reported by the lab? 

Date IDOCs were done?

SECTION D-2. QC INFORMATION – Instrument Calibration

1. Instrument: Was an Inductively Coupled Plasma 

Spectrometer (ICP/MS) capable of providing the 

resolution characteristics specified in Section 6.1 of 

the FGD SOP used for analysis? 

Was the ICP/MS used in the analysis equipped with 

a collision cell, a discrete sample introduction 

system, and an autosampler? (FGD SOP/6.1)
Steam Study Data Review Checklist

Standard Operating Procedures for Trace Element Analysis in Flue Gas Desulfurization Wastewaters 

Page 5 of 9

Final Checklist July 9, 2010

FGD SOP/EPA METHOD 200.8

REQUIREMENT Reviewer Comment

Criterion

met

Y N

2. Instrument Tuning/Mass Calibration: Was the 

instrument tuned using a solution containing 

elements that represented all mass regions of 

interest?

Was the tuning solution used to run mass calibration 

and mass resolution checks at the beginning of every 

day?

Were the relative standard deviations less than 5% 

for at least four integrations of the tuning solution? 

(FGD SOP/10.3.2)

Were the mass calibration check results within 0.1 

amu of the true value? (FGD SOP/10.3.2)

Were the mass resolution check results less than 0.9 

amu full width at 10% peak height? (FGD 

SOP/10.3.2)

What were the elements and concentration of the 

tuning solution? If reported where was it purchased 

from? 

What were the reported results for instrument 

tuning?

What was the lab’s reported results for mass 

calibration check and mass resolution check?

3. Mass 75 Interference check: Were the counts per 

second for mass 75 less than 10 when the blank 

matrix was infused? (FGD SOP/10.3.3)

4. Initial Calibration: Was the ICP/MS calibrated 

daily with a calibration blank and 3 calibration 

standards? (FGD SOP/10.3.4) 

Indicate the true and analyzed concentrations of the 

3 calibration standards used by lab. 

 If reported, what type of curve fit was used? 
Steam Study Data Review Checklist

Standard Operating Procedures for Trace Element Analysis in Flue Gas Desulfurization Wastewaters 

Page 6 of 9

Final Checklist July 9, 2010

FGD SOP/EPA METHOD 200.8

REQUIREMENT Reviewer Comment

Criterion

met

Y N

5. Initial Calibration Verification (ICV): Was an 

ICV standard (i.e., a standard from a different 

vendor than the calibration standards) analyzed after 

initial calibration? 

Was the percent recovery of the ICV sample within 

90-110%? (FGD SOP/10.3.5)

Note: The ICV standard satisfies the Quality Check 

Standard (QCS) requirement in 200.8.

What was the true concentration of the ICV 

standard? 

What were the reported results and % recovery? 

If reported, indicate where the ICV was purchased 

from and the date purchased?

6. Initial Calibration Blank (ICB): After the ICV, 

was the ICB analyzed and were the results less than 

the reporting limit (RL)? (FGD SOP/10.3.6) 

Indicate the concentration in the ICB, the RL, and 

note any contamination reported by the lab.

7. Reporting Limit Verification Standard: After the 

ICB, was a RL verification standard analyzed and 

were the results within 50% of the expected value? If 

not, was the associated data qualified? (FGD 

SOP/10.3.7) 

What was the result of the RL verification standard 

analyzed? 

What was the percent recovery of the RL?

SECTION D-3. QC INFORMATION –Blanks

1. Method Blank/Laboratory Reagent Blank 

(MB/LRB): Was a MB/LRB containing reagent 

water processed in the same way as the samples and 

analyzed with each batch of 20 samples?

For all analytes of interest, was the concentration in 

the blank < RL? (FGD SOP/ 9.6) 

Indicate the concentration in the MB/LRB, the RL, 

and note any contamination reported by the lab.
Steam Study Data Review Checklist

Standard Operating Procedures for Trace Element Analysis in Flue Gas Desulfurization Wastewaters 

Page 7 of 9

Final Checklist July 9, 2010

FGD SOP/EPA METHOD 200.8

REQUIREMENT Reviewer Comment

Criterion

met

Y N

2. Laboratory Control Sample/Laboratory Fortified 

Blank (LCS/LFB): Was a LCS/LFB containing all 

analytes of interest analyzed with each batch and 

was the percent recovery for all analytes within the 

control limits of 85-115%? (FGD SOP/ 9.7) 

(200.8/7.9/9.3.2) 

What were the concentrations of all analytes in the

LCS reported by the lab? 

What were the % recoveries of all the analytes?

SECTION D-4. QC INFORMATION - Instrument Performance Checks

1. Synthetic FGD Interference Check Solution: 

Before initiating analysis and immediately after 

calibration, was the synthetic FGD matrix solution 

specified in Section 7.2.7 of the FGD SOP analyzed?

Were all results for elements of interest < the RL 

unless the presence of an element can be confirmed 

and in this case was the result < 5 times the RL? 

If dilution was required to analyze the synthetic 

FGD solution, were all samples and QC samples 

diluted by the same factor? (FGD SOP/ 9.4)

2. Laboratory Fortified Synthetic FGD Solution: 

Following the analysis of the synthetic FGD matrix, 

was a synthetic FGD solution spiked with each 

analyte of interest analyzed?

Was the percent recovery between 70 – 130% of the 

true value?

Indicate the percent recovery for all analytes.

If dilution was required to analyze the laboratory 

fortified synthetic FGD solution, were all samples 

and QC samples diluted by the same factor? (FGD 

SOP/ 9.4.1)

3. Analytical Run Sequence: Was the following 

analytical run sequence used: instrument 

initialization, warm-up, instrument tuning, mass 

calibration check, mass resolution check, tuning 

criteria validation, calibration blank, calibration 

standard, ICV, ICB, RL verification standard, CCV, 

CCB, 10 samples, CCV, and CCB. (FGD 

SOP/10.4.5)
Steam Study Data Review Checklist

Standard Operating Procedures for Trace Element Analysis in Flue Gas Desulfurization Wastewaters 

Page 8 of 9

Final Checklist July 9, 2010

FGD SOP/EPA METHOD 200.8

REQUIREMENT Reviewer Comment

Criterion

met

Y N

4. Matrix Spike/Matrix Spike Duplicate/Laboratory 

Fortified Sample Matrix /Laboratory Fortified 

Sample Matrix Duplicate 

(MS/MSD/LFM/LFMD): Was one MS/MSD pair 

analyzed for every 10 samples? (FGD SOP/ 9.8)

*Was a MS/MSD sample analyzed for each 

midpoint and effluent point in a sampling episode?

Was the percent recovery of the MS/MSD for all 

analytes within the control limits of 70-130% and 

was the RPD ≤ 20%? (FGD SOP/9.8) 

What were the % recoveries for all analytes? 

What were the RPDs reported by the lab?

5. Internal Standardization: Were responses from 

internal standards evaluated throughout each set of 

samples? (200.8/9.4.5)

Were results for all internal standards within 60-

125% of the intensity in the calibration blank and if 

not, was the calibration blank reanalyzed? If the 

results for the second calibration blank met the 

required QC criteria, was the sample diluted by a 

factor of 2 and rerun? (FGD SOP/ 9.9)

6. Continuing Calibration Verification (CCV) 

Standard: Was a 50 μg/L CCV standard tested at 

the beginning and end of each run and after the 

analysis of 10 samples and was the percent recovery 

within 85-115%? (FGD SOP/10.3.8) 

What were results reported for the CCV and the 

percent recovery?

7. Continuing Calibration Blank (CCB): Was a CCB 

analyzed after each CCV and were results less than 

the RL? (FGD SOP/10.3.6)

Indicate the result for the CCB, the RL, and any 

contamination noted by the lab.

SECTION E. DATA REVIEW – Sample Results

1. Calculations: Were all percent recoveries and 

relative percent differences for QC samples 

calculated according to the formulas presented in 

Section 11.0 in the FGD SOP.

Was the final concentration of an aqueous and 

digested solid sample calculated based on the 

formulas presented in Section 11.5 and 11.6 

respectively of the FGD SOP?
Steam Study Data Review Checklist

Standard Operating Procedures for Trace Element Analysis in Flue Gas Desulfurization Wastewaters 

Page 9 of 9

Final Checklist July 9, 2010

FGD SOP/EPA METHOD 200.8

REQUIREMENT Reviewer Comment

Criterion

met

Y N

2. Sample Results Reporting: For each field and QC 

sample analyzed, was the average of at least three 

integrations reported? (FGD SOP/10.4.1)

**Were results reported in units of micrograms per 

liter (μg/L)? 

**Were analyte concentrations below the MDL not 

reported? (200.8/12.1)

3. Dilutions: If the concentration of an analyte was 

above the linear range, was the sample diluted and 

reanalyzed? 

Was dilution not used for samples containing an 

analyte concentration < 5 times the RL? (FGD 

SOP/10.4.4)

4. Analysis of Interferences: Were interferences not 

removed by the collision cell evaluated? Were 

corrections applied to the data and if problems 

remained were they flagged? Were the 

recommended elemental equations in Attachment 1 

of the FGD SOP used and was internal 

standardization implemented to correct for both 

positive and negative interferences caused by the 

sample matrix? (FGD SOP/2.4/4.0) 
Final Notes July 9, 2010

Steam Study Data Review Notes

Standard Operating Procedure (SOP) for Inductively Coupled Plasma Mass 

Spectrometry for Trace Element Analysis in Flue Gas Desulfurization 

Wastewaters

1. For the determination of total elements, the sample should acidified at the laboratory with 

1 to 1 nitric acid to a pH less than 2 within two weeks of collection (200.8/8.3).

2. After acidification, the sample should be mixed and allowed to sit for 16 hours, and then 

confirmed to have a pH less than 2. If the pH was greater than or equal to 2 the sample 

should be acidified, mixed, held for 16 hours, and tested again (200.8/8.3).

3. An aliquot of all samples should be acidified with nitric acid and hydrochloric acid and 

digested using the closed vessel digestion techniques outlined in Section 10.2 of the FGD 

SOP. If reported, indicate the amount of nitric and hydrochloric acids used in digestion

and note any deviations reported in the lab’s digestion procedures. Note: The lab should 

use 0.5 mL of concentrated nitric acid and 0.25 mL of hydrochloric acid.

4. *For FGD influent samples that contain greater than 1% suspended solids, the laboratory 

should separate the solid and liquid portions of the sample and analyze each portion 

separately. 

5. Before initiating analysis and every year thereafter, the linear range for each analyte of 

interest should be established. If reported, note if the results of the analysis were within 

10% of the actual value (FGD SOP/9.5). If reported, indicate the LDRs reported by the 

lab and the date the LDRs were done.

6. Before initiating analysis and at least every 3 months all individual interference check 

solutions specified in Section 7.2.6 of the FGD SOP should be analyzed. If reported, were 

all results for elements of interest < the RL unless the presence of an element can be 

confirmed and in this case was the result < 5 times the RL? (FGD SOP/ 9.3) 

7. The system should be washed with a rinse blank for ≥ 30 seconds between the analysis of 

every sample and standard (FGD SOP/10.4.2). If reported, indicate how many rinse 

blanks were run and any contamination noted.

8. *For aqueous samples, a field blank should be prepared and analyzed at each sample 

point during one of the four days of sample collection. If the analyte concentration was 

greater than the MDL, indicate the concentration.

9. All masses that could influence results should be monitored for each run and this 

information should be used by the laboratory to correct data for interferences (FGD 

SOP/10.4.3).
Steam Study Data Review Notes

Standard Operating Procedures for Trace Element Analysis in Flue Gas Desulfurization Wastewaters 

Page 2 of 2

Final Notes July 9, 2010

10. *If the analyte concentration in a sample was less than 5 times the analyte concentration 

in the laboratory reagent blank, the result should be reported as a nondetect. List all 

affected samples:

11. *If the analyte concentration in a sample was less than 10 times but greater than 5 times 

the analyte concentration in the laboratory reagent blank, the result should be reported as 

an estimated value. List all affected samples:
Final Checklist July 9, 2010

Steam Study Data Review Checklist

Dissolved Hexavalent Chromium EPA Method 218.6 (1994)

Ion chromatography

SECTION A-1. Sample Identifiers

Laboratory Name:

Sampling Episode:

Sample Numbers or 

Range:

Data Reviewer 

signature:

Date:

Instructions: Complete this checklist electronically or using a ballpoint pen.

Record reviewer comments in the Reviewer Comment section.

Record detailed information in the Comments in the “Overall Assessment” 

section for each criterion not (“N”) met.

Note: Requirements with a * are project requirements not specific to 

EPA Method 218.6.

Note: Requirements with a ** are requirements specific to 200.8 and 

were added to this checklist because Frontier desires to use an 

ICP-MS detector rather than a UV detector after ion 

chromatography.

Note: Requirements with a *** are changes to method 218.6 the 

laboratory had to make because they are using an ICP-MS 

detector rather than a UV detector.

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level

Required Present Comments

Copies of Shipping Documents (Fed-Ex 

Airbills)

1, 2, 3

Case Narrative 1, 2, 3

Table of Contents 3

Cross reference of Field Sample No., Lab 

Sample No., and Analytical Batch

1, 2, 3

Traffic Report Form (including Sample 

Receipt Checklist)

1, 2, 3

Sample Calculation (usually just a page 

copied from SOW)

3

Results Summary for Each Sample and 

Blank 

1, 2, 3
Steam Study Data Review Checklist

Dissolved Hexavalent Chromium EPA Method 218.6 (1994) 

Page 2 of 6

Final Checklist July 9, 2010

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level

Required Present Comments

Quality Control Sample Results 2, 3

Calibration Curve Results 3

Initial Calibration Verification Results 3

Continuing Calibration Verification 

Results

3

Laboratory Reagent Blank Results 2, 3

Laboratory Fortified Blank Results 2, 3

Laboratory Fortified Sample 

Matrix/Laboratory Fortified Sample 

Matrix Duplicate Results

2, 3

Data for All Masses Monitored (if 

reported)

3

Field Duplicate Results 2, 3

Quantitation List 3

Copies of Sample Preparation Work 

Sheets

3

Copies of Run Logs 3

Level 1: Review of traffic reports, sample handling, and proper sample preparation

Level 2: Level 1 review plus review of QA/QC results

Level 3: Level 2 review plus review of instrument performance

Level 4: Level 3 review plus analysis of raw data such as chromatograms or primary instrument 

output
Steam Study Data Review Checklist

Dissolved Hexavalent Chromium EPA Method 218.6 (1994) 

Page 3 of 6

Final Checklist July 9, 2010

EPA METHOD 218.6 REQUIREMENT Reviewer Comment

Criterion

met

Y N

SECTION B. SAMPLE RECEIPT

1. Reviewed Sample Collection Record: 

• Signatures?

• Completed?

• Sample ID numbers checked?

• Preservations? pH? Volume?

• Any anomalies reported?

2. Reviewed Lab Sample Receipt Record:

• Date received?

• Lab ID number checked?

• Lab ID number referenced to Sample ID 

numbers?

• Preservation checked by lab? pH? Temp? 

Volume?

• Sample conditions?

• Sample hold time?

• Any anomalies reported by lab?

SECTION C. SAMPLE PREPARATION/EXTRACT HANDLING 

INFORMATION

1. Reviewed Standard Pre logs: 

• Standard expiration date:

• Concentrations prepared?

2. Reviewed Sample Prep Logs:

• Sample extraction date:

• Sample process or run date:

Note: Sample Analysis: Were samples analyzed as 

soon as possible after sample collection? 

How much time had elapsed between sample 

collection and analysis? 

Note: It is recommended that samples be analyzed 

within 24 hours of collection although it is only 

required for samples to be analyzed within 28 days. 

(218.6/8.3) (40 CFR 136 Table II)

3. *Field Duplicates: Was a field duplicate collected 

and analyzed as part of the sampling episode? 

Indicate the relative percent difference.
Steam Study Data Review Checklist

Dissolved Hexavalent Chromium EPA Method 218.6 (1994) 

Page 4 of 6

Final Checklist July 9, 2010

EPA METHOD 218.6 REQUIREMENT Reviewer Comment

Criterion

met

Y N

SECTION D-1. QC INFORMATION – Instrument Calibration 

1. Review Lab’s Instrument Run Log Report: Were 

calibrations, QC samples and samples included in a 

batch of 20 samples? 

2. ***Calibration curve: Were at least three

calibration standards used to create a calibration 

curve with a coefficient of correlation (r) ≥ 0.995? 

(218.6/11.4)

What were the concentrations of the 3 calibration 

standards used by lab? 

3. **Initial Calibration Verification: Was an 

Instrument Performance Check (IPC) solution 

(midpoint calibration standard) and an initial 

calibration blank (ICB) analyzed immediately after 

calibration? 

Did the IPC solution differ from the true value by 

more than ± 10%? 

What was the true IPC solution concentration and 

reported result?

Was the concentration of Cr(VI) in the initial

calibration blank less than the MDL? (218.6/9.3.4)

Was any contamination noted in the ICB?

SECTION D-2. QC INFORMATION –Blanks

1. Laboratory Reagent Blank: Was at least one 

laboratory reagent blank prepared and analyzed with 

each set of samples?

Did the laboratory reagent blank contain Cr(VI) at a 

concentration less than the MDL? (218.6/9.3.1)

Note any contamination reported.

2. Laboratory Fortified Blank (LFB): Was at least 

one LFB prepared and analyzed with each set of 

samples?

***Was the percent recovery of the laboratory 

reagent blank within 80-120%? (218.6/9.3.3)

What were the concentrations of all analytes in the

LFB reported by the lab? 

What were the % recoveries of all the analytes?
Steam Study Data Review Checklist

Dissolved Hexavalent Chromium EPA Method 218.6 (1994) 

Page 5 of 6

Final Checklist July 9, 2010

EPA METHOD 218.6 REQUIREMENT Reviewer Comment

Criterion

met

Y N

Section D-3. QC INFORMATION – Instrument Performance

1. Quality Control Sample (QCS) data enclosed?: 

Was a secondary source QCS analyzed and was the 

concentration within ±10% of the QCS value? 

(218.6/9.3.5)

Indicate the true and reported value of the QCS, and

the percent recovery.

2. Continuing Calibration Verification: Was an 

Instrument Performance Check (IPC) solution 

(midpoint calibration standard) and a continuing 

calibration blank (CCB) analyzed after every 10 

samples? 

***Did the values differ from the true value by more 

than ± 10%? 

What were results reported for CCV?

Was the concentration of Cr(VI) in the continuing 

calibration blank less than the MDL? (218.6/9.3.4)

Note any contamination reported.

3. ***Laboratory Fortified Sample Matrix (LFM): 

Was a known amount of analyte added to at least 

10% of samples and was the percent recovery within 

80-120%? (218.6/9.4)

What were the % recoveries for all analytes? 

4. **Laboratory Fortified Sample Matrix Duplicate 

(LFMD): Was an LFMD analyzed at a frequency of 

10% of samples? 

Was the percent recovery within 80-120%? 

What was the percent recovery?

Was the RPD less than 25%? (200.8/9.4.2-9.4.4)

What was the RPD for all analytes?

5. **Interferences: Was the mass to charge ratio of 48 

(32S160+), 81Br-, and 35Cl- monitored to identify 

possible spectral or chromatographic interferences?

To avoid spectral interferences was the appropriate 

reaction gas utilized in the dynamic reaction cell?

SECTION E. DATA REVIEW – Sample Results

1. Dilution: If the concentration of Cr(VI) in a sample 

was above the range of the calibration curve, was the 

sample diluted and reanalyzed? (218.6/11.5) 

Were samples with concentrations above or equal to 

90% of the upper limit of the LDR diluted and 

reanalyzed? (218.6/9.2.3)
Steam Study Data Review Checklist

Dissolved Hexavalent Chromium EPA Method 218.6 (1994) 

Page 6 of 6

Final Checklist July 9, 2010

EPA METHOD 218.6 REQUIREMENT Reviewer Comment

Criterion

met

Y N

2. Sample Reporting: Was the sample concentration 

calculated from the calibration curve and reported in 

μg/L? 
Final Notes July 9, 2010

Steam Study Data Review Notes

Dissolved Hexavalent Chromium EPA Method 218.6 (1994)

Ion chromatography

1. If the laboratory judges that the influent samples contained sulfate and chloride 

concentrations that were high enough to cause column overload, the affected samples 

should be diluted by the laboratory (218.6/4.1.3). If reported, note if the laboratory 

diluted samples to prevent column overload.

2. Samples should be adjusted to room temperature prior to analysis (218.6/11.1).

3. A rinse blank should be used to flush the system between all solution changes and 

suitable rinse times should be determined and used to prevent memory interferences

(200.8/4.1.5). If reported, indicate how many rinse blanks were run and state any 

contamination noted. 

4. For aqueous samples, a field blank should be prepared and analyzed at each sample point 

during one of the four days of sample collection. If the analyte concentration was greater 

than the MDL, indicate the concentration.

5. **Both masses 52 and 53 should be analyzed and mass 52 used to determine the 

concentration of Cr(VI) in the samples (200.8/11.4.4/Table 4).

6. Results should be corrected based on Cr(VI) contamination found in the LRB. Indicate 

whether the laboratory automatically made these corrections. 

7. *If the analyte concentration in a sample was less than 5 times the analyte concentration 

in the laboratory/method blank, the result should be reported as a nondetect. List all 

affected samples.

8. *If the analyte concentration in a sample was less than 10 times but greater than 5 times 

the analyte concentration in the laboratory/method blank, the result should reported as an 

estimated value. List all affected samples.
Final Checklist July 9, 2010

Steam Study Data Review Checklist

Chloride and Sulfate EPA Method 300.0

(Ion Chromatography)

SECTION A-1. Sample Identifiers

Laboratory Name:

Sampling Episode:

Sample Numbers or 

Range:

Data Reviewer 

signature:

Date:

Instructions: Complete this checklist electronically or using a ballpoint pen.

Record reviewer comments in the Reviewer Comment section.

Record detailed information in the Comments in the “Overall Assessment” 

section for each criterion not (“N”) met.

Note: Requirements with a * are project requirements not specific to 

EPA Method 300.0.

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level 

Required Present Comments

Copies of Shipping Documents (Fed-Ex 

Airbills)

1, 2, 3

Case Narrative 1, 2, 3

Table of Contents 3

Cross reference of Field Sample No., Lab 

Sample No., and Analytical Batch

1, 2, 3

Traffic Report Form (including Sample 

Receipt Checklist)

1, 2, 3

Sample Calculation (usually just a page 

copied from SOW)

3

Results Summary for Each Sample and Blank 1, 2, 3

Quality Control Sample Results 3

Laboratory Reagent Blank Results 2, 3

Laboratory Fortified Blank Results 2, 3

Instrument Performance Check Solution 

Results

3

Laboratory Fortified Matrix (LFM) Results 2, 3

Standard Curve Results 3

Continuing Calibration Data 3

Field Duplicate Results 2, 3
Steam Study Data Review Checklist

Chloride and Sulfate EPA Method 300.0 (1993)

Page 2 of 5

Final Checklist July 9, 2010

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level 

Required Present Comments

Chromatograms for Each Sample, Blank, and 

Standard

3

Quantitation List 3

Copies of Sample Preparation Work Sheets 3

Copies of Run Logs 3

Level 1: Review of traffic reports, sample handling, and proper sample preparation

Level 2: Level 1 review plus review of QA/QC results

Level 3: Level 2 review plus review of instrument performance

Level 4: Level 3 review plus analysis of raw data such as chromatograms or primary instrument

output
Steam Study Data Review Checklist

Chloride and Sulfate EPA Method 300.0 (1993)

Page 3 of 5

Final Checklist July 9, 2010

EPA METHOD 300.0 REQUIREMENT

Reviewer 

Comment

Criterion

met

Y N

SECTION B. SAMPLE RECEIPT

1. Reviewed Sample Collection Record: 

• Signatures?

• Completed?

• Sample ID numbers checked?

• Preservations? Temp? Volume?

• Any anomalies reported?

2. Reviewed Lab Sample Receipt Record:

• Date received?

• Lab ID number checked?

• Lab ID number referenced to Sample ID 

numbers?

• Preservation checked by lab? Temp? Volume?

• Sample conditions?

• Sample hold time?

• Any anomalies reported by lab?

SECTION C. SAMPLE PREPARATION

1. Reviewed Standard Pre logs: 

• Standard expiration date:

• Concentrations prepared?

2. Reviewed Sample Prep Logs:

• Sample process or run date:

3. *Field Duplicates: Was a field duplicate collected 

and analyzed as part of the sampling episode? 

Indicate the relative percent difference.

SECTION D-1. QC INFORMATION – Instrument Calibration

1. Review Lab’s Instrument Run Log Report: Were 

calibrations, QC samples, and samples included in a 

batch of 20 samples? 

2. Standard Curve: Were at least three standards 

within the standard range and one blank used to 

create a calibration curve? (300.0/10.2)

What were the concentrations of the three calibration 

standards used by lab? 
Steam Study Data Review Checklist

Chloride and Sulfate EPA Method 300.0 (1993)

Page 4 of 5

Final Checklist July 9, 2010

EPA METHOD 300.0 REQUIREMENT

Reviewer 

Comment

Criterion

met

Y N

SECTION D-2. QC INFORMATION –Blanks/Duplicates

1. Laboratory Reagent Blank: Was a laboratory 

reagent blank analyzed with each batch of samples?

Were all of the target compounds or interfering 

compounds < Reporting Limit (RL)?1

Note any contamination reported.

If no, was analysis stopped and contamination 

eliminated? (300.0/9.3.1)

2. Laboratory Fortified Blank (LFB): Was an LFB 

analyzed with every sample batch and was the 

percent recovery of all analytes within 90-110%? 

Were replicate LFBs analyzed at least quarterly to 

determine precision? (300.0/9.3.2/9.4.8)

What were the concentrations of all analytes in the 

LFB reported by the lab? 

What were the % recoveries of all the analytes?

SECTION D-3. QC INFORMATION – Instrument Performance

1. Ion Chromatographic Parameters: Were 

parameters equal to those presented in Tables 1A and 

1B of EPA Method 300.0 established for the ion 

chromatography column? (300.0/10.1)

2. Initial Demonstration of Performance, Quality 

Control Sample (QCS) data enclosed?: Was a QCS 

sample analyzed and was the percent recovery within 

± 10% of the stated values? (300.0/9.2.3)

Indicate the true and reported values of the QCS and 

the percent recovery. 

 

1 Note: EPA method 300.0 requires that the LRB be less than the Method Detection Limit (MDL). 

However, this method is written for drinking water analysis. Because chloride and sulfide levels in FGD 

wastewater will be appreciably higher than in drinking water, TestAmerica will only consider the LRB 

contaminated if analytes are higher than the reporting limit.
Steam Study Data Review Checklist

Chloride and Sulfate EPA Method 300.0 (1993)

Page 5 of 5

Final Checklist July 9, 2010

EPA METHOD 300.0 REQUIREMENT

Reviewer 

Comment

Criterion

met

Y N

3. Instrument Performance Check Solution: Was an 

instrument performance check solution (IPC) and 

calibration blank analyzed immediately after daily 

calibration, following every ten samples, and at the 

conclusion of the sample run?

Did all results for the IPC solution and calibration 

blank verify that the instrument was within ±10% of 

calibration? (300.0/9.3.4)

What were results reported for the IPC and the 

percent recovery?

4. Laboratory Fortified Sample Matrix (LFM): Was 

a known amount of analyte (≥4 times MDL) added to 

at least 10% of samples and was the percent recovery 

within 80-120% (Method A) or 75-125% (Method 

B)? (300.0/9.4)

What were the % recoveries for all analytes? 

5. Continuing Calibration Verification: Was the 

calibration curve verified at the beginning of each 

day, after every 20 samples, and whenever the anion 

eluent was changed? 

Was the retention time or response for each analyte 

within ± 10% of the expected value?

Note: If the above criteria fail, the continuing 

calibration verification analysis can be repeated using 

fresh standards and if these results are within ± 10% 

of the expected value it is not necessary to recreate 

the calibration curve. (300.0/10.4)

What were the results reported for the CCV and what 

was the percent recovery?

SECTION E. DETAILED RAW DATA REVIEW – Sample Results

1. Calculation: Was the concentration in samples 

determined using the standard curve and were values 

reported in mg/L? (300.0/12.0)

2. Dilution: If a result was greater than the highest 

standard used to calculate the calibration curve, was 

the sample diluted and reanalyzed? (300.0/12.2)

3. Sample Results Reporting: Were only results 

between the lowest and highest standards reported? 

(300.0/12.2)
Final Notes July 9, 2010

Steam Study Data Review Notes

Chloride and Sulfate EPA Method 300.0

(Ion Chromatography)

1. If residual chlorine dioxide is suspected in sample, the sample should be purged with an 

inert gas for at least five minutes (300.0/4.8).

2. Samples containing particles larger than 0.45 μm and reagents containing particles larger 

than 0.2 μm should be filtered prior to analysis (300.0/4.4).

3. *If the analyte concentration in a sample was less than 5 times the analyte concentration 

in the laboratory reagent blank, the result should be reported as a nondetect. List all 

affected samples:

4. *If the analyte concentration in a sample was less than 10 times but greater than 5 times 

the analyte concentration in the laboratory reagent blank, the result should be reported as 

an estimated value. List all affected samples:
Final Checklist July 9, 2010

Steam Study Data Review Checklist

Ammonia EPA Method 350.1 (1993)

(Semi-Automated Colorimetry)

SECTION A-1. Sample Identifiers

Laboratory Name:

Sampling Episode:

Sample Numbers or 

Range:

Data Reviewer 

signature:

Date:

Instructions: Complete this checklist electronically or using a ballpoint pen.

Record reviewer comments in the Reviewer Comment section.

Record detailed information in the Comments in the “Overall Assessment” 

section for each criterion not (“N”) met.

Note: Requirements with a * are project requirements not specific to 

EPA Method 350.1.

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level

Required Present Comments

Copies of Shipping Documents (Fed-Ex 

Airbills)

1, 2, 3

Case Narrative 1, 2, 3

Table of Contents 3

Cross reference of Field Sample No., Lab 

Sample No., and Analytical Batch

1, 2, 3

Traffic Report Form (including Sample 

Receipt Checklist)

1, 2, 3

Sample Calculation (usually just a page 

copied from SOW)

3

Results Summary for Each Sample and 

Blank

1, 2, 3

Laboratory Reagent Blank Results 2, 3

Laboratory Fortified Blank Results 2, 3

Standard Curve and Quality Control 

Sample Results

3

Instrument Performance Check Solution 

Results

3
Steam Study Data Review Checklist

Ammonia EPA Method 350.1 (1993)

Page 2 of 5

Final Checklist July 9, 2010

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level

Required Present Comments

Laboratory Fortified Sample Matrix 

Results

3

Field Duplicate Results 2, 3

Quantitation List 3

Copies of Sample Preparation Work 

Sheets

3

Copies of Run Logs 3

Level 1: Review of traffic reports, sample handling, and proper sample preparation

Level 2: Level 1 review plus review of QA/QC results

Level 3: Level 2 review plus review of instrument performance

Level 4: Level 3 review plus analysis of raw data such as chromatograms or primary instrument 

output
Steam Study Data Review Checklist

Ammonia EPA Method 350.1 (1993)

Page 3 of 5

Final Checklist July 9, 2010

EPA Method 350.1 Requirement Reviewer Comment

Criterion

met

Y N

SECTION B. SAMPLE RECEIPT

1. Reviewed Sample Collection Record: 

• Signatures?

• Completed?

• Sample ID numbers checked?

• Preservations? pH? Temp? Volume

• Any anomalies reported?

2. Reviewed Lab Sample Receipt Record:

• Date received?

• Lab ID number checked?

• Lab ID number referenced to Sample ID 

numbers?

• Preservation checked by lab? pH? Temp? 

Volume?

• Sample conditions?

• Sample hold time?

• Any anomalies reported by lab?

SECTION C. SAMPLE PREPARATION

1. Reviewed Standard Pre logs:

• Standard expiration date:

• Concentrations prepared?

2. Reviewed Sample Prep Logs:

• Sample extraction date:

• Sample process or run date:

3. *Field Duplicates: Was a field duplicate collected 

and analyzed as part of the sampling episode? 

Indicate the relative percent difference.

SECTION D-1. QC INFORMATION – Calibration 

1. Review Lab’s Instrument Run Log Report: Were 

calibrations, QC samples and samples included in a 

batch of 20 samples? 

2. Standard Curve: Were at least three standards 

within the standard range and one blank used to 

create a calibration curve? (350.1/10.1)

What were the concentrations of the three calibration 

standards used by lab? 
Steam Study Data Review Checklist

Ammonia EPA Method 350.1 (1993)

Page 4 of 5

Final Checklist July 9, 2010

EPA Method 350.1 Requirement Reviewer Comment

Criterion

met

Y N

3. Quality Control Sample (QCS) data enclosed?: 

Was a QCS used to verify the calibration (i.e., were

results within ±10% of QCS true value)?

(350.1/9.2.3/10.7)

What was the true value of the QCS? 

What was the QCS value reported by the labs?

What was the percent recovery?

SECTION D-2. QC INFORMATION – Blanks/Duplicates

1. Laboratory Reagent Blank: Was a laboratory 

reagent blank analyzed with each batch of samples 

and were the results always less than the Method 

Detection Limit (MDL)? (350.1/9.3.1)

Note any contamination reported.

2. Laboratory Fortified Blank (LFB): Was a LFB

analyzed with each batch of samples and was the 

percent recovery of all analytes within 90-110%? 

(350.1/9.3.2)

What were the concentrations of all analytes in the

LFB reported by the lab? 

What were the % recoveries of all the analytes?

SECTION D-3. QC INFORMATION – Instrument Performance Checks

1. Instrument Performance Check Solution (IPC): 

Was an IPC and calibration blank analyzed 

immediately after daily calibration, following every 

ten samples, and at the conclusion of the sample 

run? Did all results for the IPC solution and 

calibration blank verify that the instrument was 

within ±10% of calibration? (350.1/9.3.4)

What were results reported for the IPC and 

calibration blank and what were the percent 

recoveries?

2. Laboratory Fortified Sample Matrix (LFM): Was 

a known amount of analyte (≥4 times MDL) added 

to at least 10% of samples and was the percent 

recovery within 90-110%? (350.1/9.4)

What were the % recoveries for all analytes? 

SECTION F. DATA REVIEW – Sample Results

1. Calculation: Was the concentration in samples 

determined using the standard curve and were values 

reported in mg NH3-N/L? (350.1/12.0)
Steam Study Data Review Checklist

Ammonia EPA Method 350.1 (1993)

Page 5 of 5

Final Checklist July 9, 2010

EPA Method 350.1 Requirement Reviewer Comment

Criterion

met

Y N

2. Dilution: If a result was greater than the highest 

standard used to calculate the calibration curve, was 

the sample diluted and reanalyzed? (350.1/12.2)

3. Sample Results Reporting: Were only results 

between the lowest and highest standards reported? 

(350.1/12.2)
Final Notes July 9, 2010

Steam Study Data Review Notes

Ammonia EPA Method 350.1 (1993)

(Semi-Automated Colorimetry)

1. Prior to analysis, the distillation apparatus should be steamed out until ammonia is 

no longer detected in the distillate (350.1/11.1).

2. The samples should be checked for residual chlorine and if necessary sodium 

thiosulfate or sodium sulfite should be added to dechlorinate the samples 

(350.1/4.2/7.5).

3. The pH of the sample should be adjusted to 9.5 prior to distillation 

(350.1/4.1/11.2). The pH of the wash water and standard ammonia solutions 

should be adjusted to match the pH in the samples (350.1/11.4).

4. Automated continuous flow analysis equipment should be used to analyze 

samples (350.1/6.4).

5. *If the analyte concentration in a sample was less than 5 times the analyte 

concentration in the laboratory reagent blank, the result should be reported as a 

nondetect. List all affected samples:

6. *If the analyte concentration in a sample was less than 10 times but greater than 5 

times the analyte concentration in the laboratory reagent blank, the result should 

be reported as an estimated value. List all affected samples:
Final Checklist July 9, 2010

Steam Study Data Review Checklist

Total Kjeldahl Nitrogen EPA Method 351.2 (1993)

(Semi-Automated Colorimetry)

SECTION A-1. Sample Identifiers

Laboratory Name:

Sampling Episode:

Sample Numbers or 

Range:

Data Reviewer 

signature:

Date:

Instructions: Complete this checklist electronically or using a ballpoint pen.

Record reviewer comments in the Reviewer Comment section.

Record detailed information in the Comments in the “Overall Assessment” 

section for each criterion not (“N”) met.

Note: Requirements with a * are project requirements not specific to 

EPA Method 351.2.

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level

Required Present Comments

Copies of Shipping Documents (Fed-Ex 

Airbills)

1, 2, 3

Case Narrative 1, 2, 3

Table of Contents 3

Cross reference of Field Sample No., Lab 

Sample No., and Analytical Batch

1, 2, 3

Traffic Report Form (including Sample 

Receipt Checklist)

1, 2, 3

Sample Calculation (usually just a page 

copied from SOW)

3

Results Summary for Each Sample and 

Blank

1, 2, 3

Laboratory Reagent Blank Results 2, 3

Laboratory Fortified Blank Results 2, 3

Standard Curve and Quality Control 

Sample Results

3

Instrument Performance Check Solution 

Results

3
Steam Study Data Review Checklist

Total Kjeldahl Nitrogen EPA Method 351.2

Page 2 of 5

Final Checklist July 9, 2010

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level

Required Present Comments

Laboratory Fortified Sample Matrix 

Results

3

Field Duplicate Results 2, 3

Quantitation List 3

Copies of Sample Preparation Work 

Sheets

3

Copies of Run Logs 3

Level 1: Review of traffic reports, sample handling, and proper sample preparation

Level 2: Level 1 review plus review of QA/QC results

Level 3: Level 2 review plus review of instrument performance

Level 4: Level 3 review plus analysis of raw data such as chromatograms or primary instrument 

output
Steam Study Data Review Checklist

Total Kjeldahl Nitrogen EPA Method 351.2

Page 3 of 5

Final Checklist July 9, 2010

EPA Method 351.2 REQUIREMENT Reviewer Comment

Criterion

met

Y N

SECTION B. SAMPLE RECEIPT

1. Reviewed Sample Collection Record: 

• Signatures?

• Completed?

• Sample ID numbers checked?

• Preservations? pH? Temp? Volume?

• Any anomalies reported?

2. Reviewed Lab Sample Receipt Record:

• Date received?

• Lab ID number checked?

• Lab ID number referenced to Sample ID 

numbers?

• Preservation checked by lab? pH? Temp? 

Volume?

• Sample conditions?

• Sample hold time?

• Any anomalies reported by lab?

SECTION D. SAMPLE PREPARATION – Digestion/Distillation

1. Reviewed Standard Pre logs: 

• Standard expiration date:

• Concentrations prepared?

2. Reviewed Sample Prep Logs:

• Sample extraction date:

• Sample process or run date:

3. *Field Duplicates: Was a field duplicate collected 

and analyzed as part of the sampling episode? 

Indicate the relative percent difference.
Steam Study Data Review Checklist

Total Kjeldahl Nitrogen EPA Method 351.2

Page 4 of 5

Final Checklist July 9, 2010

EPA Method 351.2 REQUIREMENT Reviewer Comment

Criterion

met

Y N

SECTION E-1. QC INFORMATION – Calibration 

1. Review Lab’s Instrument Run Log Report: Were 

calibrations, QC samples and samples included in a 

batch of 20 samples? 

2. Standard Curve: Were at least three standards 

within the standard range and one blank used to 

create a calibration curve? (351.2/10.1)

What were the concentrations of the three calibration 

standards used by lab? 

3. Quality Control Sample (QCS) data enclosed?: 

Was a QCS used to verify the calibration (i.e., were 

results within ±10% of QCS true value)?

(351.2/9.2.3/10.7)

What was the true value of the QCS? 

What was the QCS value reported by the labs?

What was the percent recovery?

SECTION E-2. QC INFORMATION – Blanks/Duplicates

1. Laboratory Reagent Blank: Was a laboratory 

reagent blank analyzed with each batch of samples 

and were the results always less than the Method 

Detection Limit (MDL)? (351.2/9.3.1)

Note any contamination reported.

2. Laboratory Fortified Blank (LFB): Was a LFB

analyzed with each batch of samples and was the 

percent recovery of all analytes within 90-110%? 

(351.2/9.3.2)

What were the concentrations of all analytes in the

LFB reported by the lab? 

What were the % recoveries of all the analytes?
Steam Study Data Review Checklist

Total Kjeldahl Nitrogen EPA Method 351.2

Page 5 of 5

Final Checklist July 9, 2010

EPA Method 351.2 REQUIREMENT Reviewer Comment

Criterion

met

Y N

SECTION E-3. QC INFORMATION – Instrument Performance Checks

1. Instrument Performance Check Solution (IPC): 

Was an IPC and calibration blank analyzed 

immediately after daily calibration, following every 

ten samples, and at the conclusion of the sample 

run?

Did all results for the IPC solution and calibration 

blank verify that the instrument was within ±10% of 

calibration? (351.2/9.3.4)

What were results reported for the IPC and 

calibration blank and what were the percent 

recoveries?

2. Laboratory Fortified Sample Matrix (LFM): Was 

a known amount of analyte (≥4 times MDL) added 

to at least 10% of samples and was the percent 

recovery within 90-110%? (351.2/9.4)

What were the % recoveries for all analytes? 

SECTION F. DATA REVIEW – Sample Results

1. Calculation: Was the concentration in samples 

determined using the standard curve and were values 

reported in mg N/L? (351.2/12.0)

2. Dilution: If a result was greater than the highest 

standard used to calculate the calibration curve, was 

the sample diluted and reanalyzed? (351.2/12.2)

3. Sample Results Reporting: 

Were only results between the lowest and highest 

standards reported? (351.2/12.2)
Final Notes July 9, 2010

Steam Study Data Review Notes

Total Kjeldahl Nitrogen EPA Method 351.2 (1993)

(Semi-Automated Colorimetry)

1. If the sample was suspected to have nitrate concentrations greater than or equal to 10 

times the TKN concentration, the sample should be diluted and reanalyzed.

2. Samples should be placed in a digestor at 140°C for at least one hour, the temperature

should be reset to 380°C to heat for 1.5 hours, and 380°C should be maintained for 30 

minutes (351.2/11.5).

1

3. Automated continuous flow analysis equipment should be used to analyze samples

(351.2/6.4).

 Indicate any deviations noted in the lab’s digestion procedures.

4. *If the analyte concentration in a sample was less than 5 times the analyte concentration 

in the laboratory reagent blank, report the result as a nondetect. List all affected samples:

5. *If the analyte concentration in a sample was less than 10 times but greater than 5 times 

the analyte concentration in the laboratory reagent blank, report the result as an 

estimated value. List all affected samples:

 1 Note: TestAmerica found that digesting initially at 140°C rather than 160°C as EPA method 351.2 requires 

produced better results by reducing splattering and overheating. The time increment was increased to ensure 

complete evaporation of water before increasing the temperature to 380°C.
Final Checklist July 9, 2010

Steam Study Data Review Checklist

Nitrate/Nitrite EPA Method 353.2 (1993)

(Automated Colorimetry)

SECTION A-1. Sample Identifiers

Laboratory Name:

Sampling Episode:

Sample Numbers or 

Range:

Data Reviewer 

signature:

Date:

Instructions: Complete this checklist electronically or using a ballpoint pen.

Record reviewer comments in the Reviewer Comment section.

Record detailed information in the Comments in the “Overall Assessment” 

section for each criterion not (“N”) met.

Note: Requirements with a * are project requirements not specific to 

EPA Method 353.2

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level

Required Present Comments

Copies of Shipping Documents (Fed-Ex 

Airbills)

1, 2, 3

Case Narrative 1, 2, 3

Table of Contents 3

Cross reference of Field Sample No., Lab 

Sample No., and Analytical Batch

1, 2, 3

Traffic Report Form (including Sample 

Receipt Checklist)

1, 2, 3

Sample Calculation (usually just a page

copied from SOW)

3

Results Summary for Each Sample and Blank 1, 2, 3

Standard Curve and Quality Control Sample 

Results

3

Laboratory Reagent Blank Results 2,3

Laboratory Fortified Blank Results 2,3

Instrument Performance Check Solution 

Results

3
Steam Study Data Review Checklist

Nitrate/Nitrite EPA Method 353.2 (1993)

Page 2 of 5

Final Checklist July 9, 2010

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level

Required Present Comments

Laboratory Fortified Sample Matrix Results 3

Field Duplicate Results 2, 3

Quantitation List 3

Copies of Sample Preparation Work Sheets 3

Copies of Run Logs 3

Level 1: Review of traffic reports, sample handling, and proper sample preparation

Level 2: Level 1 review plus review of QA/QC results

Level 3: Level 2 review plus review of instrument performance

Level 4: Level 3 review plus analysis of raw data such as chromatograms or primary instrument 

output
Steam Study Data Review Checklist

Nitrate/Nitrite EPA Method 353.2 (1993)

Page 3 of 5

Final Checklist July 9, 2010

EPA Method 353.2 REQUIREMENT Reviewer Comment

Criterion

met

Y N

SECTION B. SAMPLE RECEIPT

1. Reviewed Sample Collection Record: 

• Signatures?

• Completed?

• Sample ID numbers checked?

• Preservations? pH? Temp? Volume?

• Any anomalies reported?

2. Reviewed Lab Sample Receipt Record:

• Date received?

• Lab ID number checked?

• Lab ID number referenced to Sample ID 

numbers?

• Preservation checked by lab? pH? Temp? 

Volume?

• Sample conditions?

• Sample hold time?

• Any anomalies reported by lab?

SECTION C. SAMPLE PREPARATION

1. Reviewed Standard Pre logs: 

• Standard expiration date:

• Concentrations prepared?

2. Reviewed Sample Prep Logs:

• Sample process or run date:

3. *Field Duplicates: Was a field duplicate collected 

and analyzed as part of the sampling episode? 

Indicate the relative percent difference.

SECTION D-1. QC INFORMATION – Calibration 

1. Review Lab’s Instrument Run Log Report: Were 

calibrations, QC samples and samples included in a 

batch of 20 samples? 

2. Standard Curve: Were at least three nitrate 

standards and one blank used to create a calibration 

curve? 

Was at least one nitrite standard analyzed to verify 

the reduction capability of the copper-cadmium 

column? (353.2/10.1)

What were the concentrations of the calibration 

standards used by lab? 

Section D-2. QC INFORMATION – Blanks/Duplicates
Steam Study Data Review Checklist

Nitrate/Nitrite EPA Method 353.2 (1993)

Page 4 of 5

Final Checklist July 9, 2010

EPA Method 353.2 REQUIREMENT Reviewer Comment

Criterion

met

Y N

1. Laboratory Reagent Blank: Was a laboratory 

reagent blank analyzed with each batch of samples 

and were the results always less than the Method 

Detection Limit (MDL)? (353.2/9.3.1)

Note any contamination reported by the lab.

2. Laboratory Fortified Blank (LFB): Was a LFB

analyzed with each batch of samples and was the 

percent recovery of all analytes within 90-110%? 

(353.2/9.3.2)

What were the concentrations of all analytes in the

LFB reported by the lab? 

What were the % recoveries of all the analytes?

Section D-3. QC INFORMATION – Instrument Performance Results

1. Quality Control Sample (QCS) data enclosed?: 

Was a QCS used to verify the calibration (i.e., were

results within ±10% of QCS true value)?

(353.2/9.2.3/10.7)

What was the true value of the QCS? 

What was the QCS value reported by the labs?

What was the percent recovery?

2. Instrument Performance Check Solution: Was an 

instrument performance check solution (IPC) and 

calibration blank analyzed immediately after daily 

calibration, following every ten samples, and at the 

conclusion of the sample run?

Did all results for the IPC solution and calibration 

blank verify that the instrument was within ±10% of 

calibration? (353.2/9.3.4)

What were results reported for the IPC and 

calibration blank and what were the percent 

recoveries?

3. Laboratory Fortified Sample Matrix (LFM): Was 

a known amount of analyte (≥4 times MDL) added 

to at least 10% of samples and was the percent 

recovery within 90-110%? (353.2/9.4)

What were the % recoveries for all analytes? 

SECTION E. DATA REVIEW – Sample Results

1. Calculation: Was the standard curve used to 

calculate the concentration of nitrate/nitrite in the 

sample? (353.2/12.1)
Steam Study Data Review Checklist

Nitrate/Nitrite EPA Method 353.2 (1993)

Page 5 of 5

Final Checklist July 9, 2010

EPA Method 353.2 REQUIREMENT Reviewer Comment

Criterion

met

Y N

2. Dilution: If a result was greater than the highest 

standard used to calculate the calibration curve, was 

the sample diluted and reanalyzed? (353.2/12.2)

3. Sample Results Reporting: 

Were only results between the lowest and highest 

standards reported? (353.2/12.2)

Were results reported in mg/L as nitrogen? 

(353.2/12.3)
Final Notes July 9, 2010

Steam Study Data Review Notes

Nitrate/Nitrite EPA Method 353.2 (1993)

(Automated Colorimetry)

1. Samples that contain a high concentration of suspended solids should be filtered

(353.2/4.1).

2. EDTA should be added to samples that contained high concentrations of iron, copper, 

and/or other metals (353.2/4.2).

3. If reported, indicate whether samples were checked for residual chlorine and if samples 

contained chlorine, indicate if sodium thiosulfate or another chemical was added to 

dechlorinate the samples (353.2/4.3).

4. Prior to analysis, the pH of the sample should be adjusted to between 5 and 9 using HCl 

or NH4OH. If reported, state the pH of the samples prior to analysis.

5. Automated continuous flow analysis equipment should be used to analyze the samples

(353.2/6.3).

6. *If the analyte concentration in a sample was less than 5 times the analyte concentration 

in the laboratory reagent blank, report the result as a nondetect. List all affected samples:

7. *If the analyte concentration in a sample was less than 10 times but greater than 5 times 

the analyte concentration in the laboratory reagent blank, report the result as an estimated 

value. List all affected samples:
Final Checklist July 9, 2010

Steam Study Data Review Checklist

Total Phosphorus EPA Method 365.1 (1993)

(Semi-Automated Colorimetry)

SECTION A-1. Sample Identifiers

Laboratory Name:

Sampling Episode:

Sample Numbers or 

Range:

Data Reviewer 

signature:

Date:

Instructions: Complete this checklist electronically or using a ballpoint pen.

Record reviewer comments in the Reviewer Comment section.

Record detailed information in the Comments in the “Overall Assessment” 

section for each criterion not (“N”) met.

Note: Requirements with a * are project requirements not specific to 

EPA Method 365.1.

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level

Required Present Comments

Copies of Shipping Documents (Fed-Ex

Airbills)

1, 2, 3

Case Narrative 1, 2, 3

Table of Contents 3

Cross reference of Field Sample No., Lab 

Sample No., and Analytical Batch

1, 2, 3

Traffic Report Form (including Sample 

Receipt Checklist)

1, 2, 3

Sample Calculation (usually just a page 

copied from SOW)

3

Results Summary for Each Sample and 

Blank

1, 2, 3

Laboratory Reagent Blank Results 2, 3

Laboratory Fortified Blank Results 2, 3

Standard Curve and Quality Control 

Sample Results

3
Steam Study Data Review Checklist

Total Phosphorus EPA Method 365.1 (1993)

Page 2 of 5

Final Checklist July 9, 2010

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level

Required Present Comments

Instrument Performance Check Solution 

Results

3

Laboratory Fortified Sample Matrix 

Results

2, 3

Field Duplicate Results 2, 3

Standard Curve Results 3

Quantitation List 3

Copies of Sample Preparation Work 

Sheets

3

Copies of Run Logs 3

Level 1: Review of traffic reports, sample handling, and proper sample preparation

Level 2: Level 1 review plus review of QA/QC results

Level 3: Level 2 review plus review of instrument performance

Level 4: Level 3 review plus analysis of raw data such as chromatograms or primary instrument

output
Steam Study Data Review Checklist

Total Phosphorus EPA Method 365.1 (1993)

Page 3 of 5

Final Checklist July 9, 2010

EPA METHOD 365.1 REQUIREMENT Reviewer Comment

Criterion

met

Y N

SECTION B. SAMPLE RECEIPT

1. Reviewed Sample Collection Record: 

• Signatures?

• Completed?

• Sample ID numbers checked?

• Preservations? pH? Temp? Volume?

• Any anomalies reported?

2. Reviewed Lab Sample Receipt Record:

• Date received?

• Lab ID number checked?

• Lab ID number referenced to Sample ID 

numbers?

• Preservation checked by lab? pH? Temp? 

Volume?

• Sample conditions?

• Sample hold time?

• Any anomalies reported by lab?

SECTION C. SAMPLE PREPARATION/EXTRACT HANDLING 

INFORMATION

1. Reviewed Standard Pre logs: 

• Standard expiration date:

• Concentrations prepared?

2. Reviewed Sample Prep Logs:

• Sample extraction date:

• Sample process or run date:

3. *Field Duplicates: Was a field duplicate collected 

and analyzed as part of the sampling episode? 

Indicate the relative percent difference.

SECTION D-1. QC INFORMATION - Calibration

1. Review Lab’s Instrument Run Log Report: Were 

calibrations, QC samples and samples included in a 

batch of 20 samples? 

2. Standard Curve: Were at least three standards and 

one blank used to create a calibration curve? 

(Suggested ranges 0-0.10 mg/L or 0.2-1.0 mg/L) 

(365.1/10.0)

What were the concentrations of the three calibration

standards used by lab? 
Steam Study Data Review Checklist

Total Phosphorus EPA Method 365.1 (1993)

Page 4 of 5

Final Checklist July 9, 2010

EPA METHOD 365.1 REQUIREMENT Reviewer Comment

Criterion

met

Y N

3. Quality Control Sample (QCS) data enclosed?: 

Was a QCS used to verify the calibration (i.e., were 

results within ±10% of QCS true value)?

(365.1/9.2.3/10.7)

What was the true value of the QCS? 

What was the QCS value reported by the labs?

What was the percent recovery?

SECTION D-2. QC INFORMATION – Blanks/Duplicates

1. Laboratory Reagent Blank: Was a laboratory 

reagent blank analyzed with each batch of samples 

and were the results always less than the Method 

Detection Limit (MDL)? (365.1/9.3.1)

Note any contamination reported by the lab.

2. Laboratory Fortified Blank (LFB): Was a LFB

analyzed with each batch of samples and was the 

percent recovery of all analytes within 90-110%? 

(365.1/9.3.2)

What were the concentrations of all analytes in the

LFB reported by the lab? 

What were the % recoveries of all the analytes?

SECTION D-3. QC INFORMATION – Instrument Performance Checks

1. Instrument Performance Check Solution: Was an 

instrument performance check solution (IPC) and 

calibration blank analyzed immediately after daily 

calibration, following every ten samples, and at the 

conclusion of the sample run?

Did all results for the IPC solution and calibration 

blank verify that the instrument was within ±10% of 

calibration? (365.1/9.3.4)

What were results reported for the IPC and 

calibration blank and what were the percent 

recoveries?

2. Laboratory Fortified Sample Matrix (LFM): Was 

a known amount of analyte (≥4 times MDL) added 

to at least 10% of samples and was the percent 

recovery within 90-110%? (365.1/9.4)

What were the % recoveries for all analytes? 

SECTION E. DATA REVIEW – Sample Results

1. Calculation: Was the total phosphorus calculated 

from the standard curve? (365.1/12.1)
Steam Study Data Review Checklist

Total Phosphorus EPA Method 365.1 (1993)

Page 5 of 5

Final Checklist July 9, 2010

EPA METHOD 365.1 REQUIREMENT Reviewer Comment

Criterion

met

Y N

2. Dilution: If a result was greater than the highest 

standard used to calculate the calibration curve, was 

the sample diluted and reanalyzed? (365.1/12.2)

3. Sample Results Reporting: Was total phosphorus 

reported in milligrams per litter (mg/L)? 

(365.1/12.3)

Were only results between the lowest and highest 

standards reported? (365.1/12.2)
Final Notes July 9, 2010

Steam Study Data Review Notes

Total Phosphorus EPA Method 365.1 (1993)

(Semi-Automated Colorimetry)

1. High iron concentrations can cause phosphorus to precipitate (365.1/4.1).

2. Arsenate can interfere when it is present at concentrations higher than phosphorus.

(365.1/4.3)

3. If sample color was reported indicate if the color absorbs in the photometric range used 

during analysis. If so, designate the affected samples, the color, and the magnitude of the 

color.

4. Sample should be digested using persulfate (365.1/11.1.2). If reported, indicate the 

amount of persulfate used in the digestion and state any deviations noted in the lab’s 

digestion procedures.

5. If the sample was not clear after digestion, the sample should be filtered (365.1/11.1.4). 

Note: Samples intended for total or total hydrolyzable phosphorus analysis should only 

be filtered after digestion (365.1/4.4).

6. Automated continuous flow analysis equipment should be used to analyze the samples 

(365.1/6.4).

7. *If the analyte concentration in a sample was less than 5 times the analyte concentration 

in the laboratory reagent blank, report the result as a nondetect. List all affected samples:

8. *If the analyte concentration in a sample was less than 10 times but greater than 5 times 

the analyte concentration in the laboratory reagent blank, report the result as an estimated 

value. List all affected samples:
Final Checklist July 9, 2010

Steam Study Data Review Checklist

Chemical Oxygen Demand (COD) EPA Method 410.4 (1993)

(Semi-Automated Colorimetry)

SECTION A-1. Sample Identifiers

Laboratory Name:

Sampling Episode:

Sample Numbers or 

Range:

Data Reviewer 

signature:

Date:

Instructions: Complete this checklist electronically or using a ballpoint pen.

Record reviewer comments in the Reviewer Comment section.

Record detailed information in the Comments in the “Overall Assessment” 

section for each criterion not (“N”) met.

Note: Requirements with a * are project requirements not specific to

EPA Method 410.4.

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level

Required Present Comments

Copies of Shipping Documents (Fed-Ex 

Airbills)

1, 2, 3

Case Narrative 1, 2, 3

Table of Contents 3

Cross reference of Field Sample No., Lab 

Sample No., and Analytical Batch

1, 2, 3

Traffic Report Form (including Sample 

Receipt Checklist)

1, 2, 3

Sample Calculation (usually just a page 

copied from SOW)

3

Results Summary for Each Sample and 

Blank

1, 2, 3

Results for Laboratory Reagent Blank 2, 3

Results for Laboratory Fortified Blank 2, 3

Standard Curve and Quality Control 

Sample Results

3
Steam Study Data Review Checklist

Chemical Oxygen Demand (COD) EPA Method 410.4 (1993)

Page 2 of 5

Final Checklist July 9, 2010

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level

Required Present Comments

Instrument Performance Check Solution 

Results

3

Laboratory Fortified Sample Matrix 

Results

3

Field Duplicate Results 2, 3

Quantitation List 3

Copies of Sample Preparation Work 

Sheets

3

Copies of Run Logs 3

Level 1: Review of traffic reports, sample handling, and proper sample preparation

Level 2: Level 1 review plus review of QA/QC results

Level 3: Level 2 review plus review of instrument performance

Level 4: Level 3 review plus analysis of raw data such as chromatograms or primary instrument 

output
Steam Study Data Review Checklist

Chemical Oxygen Demand (COD) EPA Method 410.4 (1993)

Page 3 of 5

Final Checklist July 9, 2010

EPA METHOD 410.4 REQUIREMENT Reviewer Comment

Criterion

met

Y N

SECTION B. SAMPLE RECEIPT

1. Reviewed Sample Collection Record: 

• Signatures?

• Completed?

• Sample ID numbers checked?

• Preservations? pH? Temp? Volume?

• Any anomalies reported?

2. Reviewed Lab Sample Receipt Record:

• Date received?

• Lab ID number checked?

• Lab ID number referenced to Sample ID 

numbers?

• Preservation checked by lab? pH? Temp? 

Volume?

• Sample conditions?

• Sample hold time?

• Any anomalies reported by lab?

SECTION C. SAMPLE PREPARATION

1. Reviewed Standard Pre logs: 

• Standard expiration date:

• Concentrations prepared?

2. Reviewed Sample Prep Logs:

• Sample extraction date:

• Sample process or run date:

3. *Field Duplicates: Was a field duplicate collected 

and analyzed as part of the sampling episode? 

Indicate the relative percent difference.

SECTION D-1. QC INFORMATION – Calibration 

1. Review Lab’s Instrument Run Log Report: Were 

calibrations, QC samples and samples included in a 

batch of 20 samples? 

2. Standard Curve: Were at least three standards and 

one blank used to create a calibration curve?

(410.4/10.0)

What were the concentrations of the three calibration 

standards used by lab? 
Steam Study Data Review Checklist

Chemical Oxygen Demand (COD) EPA Method 410.4 (1993)

Page 4 of 5

Final Checklist July 9, 2010

EPA METHOD 410.4 REQUIREMENT Reviewer Comment

Criterion

met

Y N

3. Quality Control Sample (QCS) data enclosed?: 

Was QCS used to verify the calibration (i.e., were 

results within ±10% of QCS true value)? 

(410.4/9.2.3/10.7)

What was the true value of the QCS? 

What was the QCS value reported by the labs?

What was the percent recovery?

SECTION D-2. QC INFORMATION – Blanks/Duplicates

1. Laboratory Reagent Blank: Was a laboratory 

reagent blank analyzed with each batch of samples 

and were the results always less than the Method 

Detection Limit (MDL)? (410.4/9.3.1)

Note any contamination reported by the laboratory.

2. Laboratory Fortified Blank (LFB): Was a 

laboratory fortified blank analyzed with each batch 

of samples and was the percent recovery of all 

analytes within 90-110%? (410.4/9.3.2)

What were the concentrations of all analytes in the

LFB reported by the lab? 

What were the % recoveries of all the analytes?

SECTION D-3. QC INFORMATION – Instrument Performance Checks

1. Instrument Performance Check Solution: Was an 

instrument performance check solution (IPC) and 

calibration blank analyzed immediately after daily 

calibration, following every ten samples, and at the 

conclusion of the sample run?

Did all results for the IPC solution and calibration 

blank verify that the instrument was within ±10% of 

calibration? (410.4/9.3.4) 

What were results reported for the IPC and 

calibration blank and what were the percent 

recoveries?

2. Laboratory Fortified Sample Matrix (LFM): Was 

a known amount of analyte (≥4 times MDL) added 

to at least 10% of samples and was the percent 

recovery within 90-110%? (410.4/9.4)

What were the % recoveries for all analytes? 

SECTION E. DATA REVIEW – Sample Results

1. Calculation: Was the standard curve used to 

calculate the concentration of COD in the sample?

(410.4/12.1)
Steam Study Data Review Checklist

Chemical Oxygen Demand (COD) EPA Method 410.4 (1993)

Page 5 of 5

Final Checklist July 9, 2010

EPA METHOD 410.4 REQUIREMENT Reviewer Comment

Criterion

met

Y N

2. Dilution: If a result was greater than the highest 

standard used to calculate the calibration curve, was 

the sample diluted and reanalyzed? (410.4/12.2)

3. Sample Results Reporting:

Were only results between the lowest and highest 

standards reported? (410.4/12.2)

Were results reported in mg/L? (410.4/12.3)
Final Notes July 9, 2010

Steam Study Data Review Notes

Chemical Oxygen Demand (COD) EPA Method 410.4 (1993)

(Semi-Automated Colorimetry)

1. If chlorides were present, mercuric sulfate should be added to the digestion tubes

(410.4/4.1).

2. Samples should be digested at 150°C for two hours. (410.4/11.0) Indicate any deviations 

noted in the lab’s digestion procedures.

3. Automated continuous flow analysis equipment should be used to analyze samples

(410.4/6.6).

4. *If the analyte concentration in a sample was less than 5 times the analyte concentration 

in the laboratory reagent blank, report the result as a nondetect. List all affected samples:

5. *If the analyte concentration in a sample was less than 10 times but greater than 5 times 

the analyte concentration in the laboratory reagent blank, report the result as an estimated 

value. List all affected samples:
Final Checklist July 9, 2010

Steam Study Data Review Checklist

Mercury in Water Method 1631 Revision E (2002)

(Oxidation, Purge and Trap, and Cold Vapor Atomic Fluorescence 

Spectrometry)

SECTION A-1. Sample Identifiers

Laboratory Name:

Sampling Episode:

Sample Numbers or 

Range:

Data Reviewer 

signature:

Date:

Instructions: Complete this checklist electronically or using a ballpoint pen.

Record reviewer comments in the Reviewer Comment section.

Record detailed information in the Comments in the “Overall Assessment” 

section for each criterion not (“N”) met.

Note: Requirements with a * are project requirements not specific to 

EPA Method 1631E.

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level

Required Present Comments

Copies of Shipping Documents (Fed-Ex 

Airbills)

1, 2, 3

Case Narrative 1, 2, 3

Table of Contents 3

Cross reference of Field Sample No., Lab 

Sample No., and Analytical Batch

1, 2, 3

Traffic Report Form (including Sample 

Receipt Checklist)

1, 2, 3

Sample Calculation (usually just a page 

copied from SOW)

3

Results Summary for Each Sample and 

Blank 

1, 2, 3

Initial Precision and Recovery (IPR) 

Results

3

Quality Control Sample 1, 2, 3
Steam Study Data Review Checklist

Mercury in Water Method 1631 Revision E (2002)

Page 2 of 6

Final Checklist July 9, 2010

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level

Required Present Comments

Initial Calibration Data (blanks and 

calibration points)

3

Reagent, Method, Field, Equipment, 

Bottle, and Filter Blank Results

2, 3

Matrix Spike (MS)/Matrix Spike 

Duplicate (MSD) Results

1, 2, 3

Ongoing Precision and Recovery (OPR) 3

Field Duplicate Results 1, 2, 3

Quantitation List 3

Copies of Sample Preparation Work 

Sheets

3

Copies of Run Logs 3

Level 1: Review of traffic reports, sample handling, and proper sample preparation

Level 2: Level 1 review plus review of QA/QC results

Level 3: Level 2 review plus review of instrument performance

Level 4: Level 3 review plus analysis of raw data such as chromatograms or primary instrument 

output
Steam Study Data Review Checklist

Mercury in Water Method 1631 Revision E (2002)

Page 3 of 6

Final Checklist July 9, 2010

EPA 1631 REVISION E REQUIREMENT Reviewer Comment

Criterion

met

Y N

SECTION B. SAMPLE RECEIPT

1. Reviewed Sample Collection Record: 

• Signatures?

• Completed?

• Sample ID numbers checked?

• Preservations? pH? Temp? Volume?

• Any anomalies reported?

2. Reviewed Lab Sample Receipt Record:

• Date received?

• Lab ID number checked?

• Lab ID number referenced to Sample ID 

numbers?

• Preservation checked by lab? pH? Temp?

Volume?

• Sample conditions?

• Sample hold time?

• Any anomalies reported by lab?

SECTION C. SAMPLE PREPARATION/EXTRACT HANDLING 

INFORMATION

1. Reviewed Standard Pre logs: 

• Standard expiration date:

• Concentrations prepared?

2. Reviewed Sample Prep Logs:

• Sample extraction date:

• Sample process or run date:

3. *Field Duplicates: Was a field duplicate collected 

and analyzed as part of the sampling episode? 

Indicate the relative percent difference. (1631E/9.7)
Steam Study Data Review Checklist

Mercury in Water Method 1631 Revision E (2002)

Page 4 of 6

Final Checklist July 9, 2010

EPA 1631 REVISION E REQUIREMENT Reviewer Comment

Criterion

met

Y N

Section D-1. QC INFORMATION

1. Review Lab’s Instrument Run Log Report: Were 

calibrations, QC samples and samples included in a 

batch of 20 samples? 

2. Method Detection Limit data enclosed?: Does the 

laboratory have the capability to detect Hg less than 

or equal to either the MDL for this method (0.2 

ng/L) or 1/3 the regulatory compliance limit?

(1631E/9.2.1) 

What was the MDL reported by the lab?

3. Initial Precision and Recovery (IPR) data 

enclosed?: Were four replicates of the IPR solution 

analyzed? 

Was the average percent recovery within 79-121% 

and was the Relative Standard Deviation (RSD) less 

than or equal to 21%? (1631E/9.2.2)

What was the IRP spiked at?

What was the % recovery of the IPR?

What was the RSD of the IPR?

4. Quality Control Sample (QCS) data enclosed?: 

Was a secondary source calibration sample prepared 

with a known amount of mercury and analyzed to 

determine the system performance? 

What was the true value of the QCS? 

What was the QCS value reported by the labs?

What was the percent recovery?

SECTION D-2. QC INFORMATION – Instrument Calibration 

1. Bubbler blank: Were at minimum three bubbler 

blanks analyzed at calibration and during each 

batch? Did all bubbler blanks contain less than 50 pg 

of Hg? 

Was the mean for all bubbler blanks less than 25 pg 

Hg and the standard deviation less than 10 pg Hg? 

(1631E/9.4.1)

2. System Blank: Were at minimum three system 

blanks analyzed at calibration and during each batch 

and did all system blanks contain less than 0.50 ng/L 

Hg?

Was the mean for all system blanks less than 0.5 

ng/L Hg and the standard deviation less than 0.1 

ng/L Hg? (1631E/9.4.2)
Steam Study Data Review Checklist

Mercury in Water Method 1631 Revision E (2002)

Page 5 of 6

Final Checklist July 9, 2010

EPA 1631 REVISION E REQUIREMENT Reviewer Comment

Criterion

met

Y N

3. Calibration Points: Were a minimum of five nonzero calibration points tested and was the lowest 

calibration point at the ML (0.5 ng/L)?

What were the concentrations of the 5 calibration

points?

Was the RSD of the calibration factor (CFm) less 

than or equal to 15% and was the percent recovery 

of the CFm within 75-125% for both the bubbler and 

flow-injection systems? (1631E/10.2/10.3)

What was the RSD and percent recovery of the CFm?

SECTION D-3. QC INFORMATION –Blanks

1. Reagent Blank: Were reagent blanks prepared and 

used to confirm that each new batch of reagents had 

less than 0.2 ng/L Hg? (1631E/9.4.3) 

Note any contamination reported by the laboratory.

2. Method Blank: Were at least three method blanks 

prepared and analyzed with each batch for the 

bubbler and flow-injection systems? 

Did all method blanks contain less than 0.5 ng/L 

Hg? (1631E/9.4.4)

Note any contamination reported by the laboratory.

3. Additional Method Blanks: If a sample required 

additional reagent (e.g. BrCl), was a corresponding 

method blank containing an identical amount of 

reagent analyzed? (1631/12.4.2)

4. Field Blank: Was a field blank analyzed for each set 

of samples (i.e. up to 10 samples collected and 

shipped at the same time and place)?

*Was a field blank analyzed for every point in a 

sampling episode?

Was the concentration of Hg in all field blanks less 

than the ML (0.5 ng/L) or less than 1/5 the level in 

the related sample? (1631E/9.4.5)

Note any contamination reported by the laboratory.

5. Filter Blank: Was a filter blank prepared and 

analyzed under the same conditions as the sample? 

(1631E/8.4)

Note any contamination reported by the laboratory.
Steam Study Data Review Checklist

Mercury in Water Method 1631 Revision E (2002)

Page 6 of 6

Final Checklist July 9, 2010

EPA 1631 REVISION E REQUIREMENT Reviewer Comment

Criterion

met

Y N

SECTION E. INSTRUMENT PERFORMANCE CHECKS

1. Matrix Spike (MS)/Matrix Spike Duplicate 

(MSD): Was a known amount of Hg added, in 

duplicate, to whichever is greater one sample or at 

least 10% of the samples from each site? 

Was the percent recovery for Hg in all MS and MSD 

samples within 71-125% and was the Relative 

Percent Difference (RPD) between duplicate 

concentrations ≤ to 24%? (1631E/9.3) 

What was the % recovery of MS/MSD?

Calculation of % recovery checked?

What was the RPD calculated and reported for 

MS/MSD?

Calculation of RPD checked?

2. Ongoing Precision and Recovery (OPR): Was an 

OPR solution containing 5 ng/L Hg analyzed before 

each batch and at the end of a batch/at the end of 

each 12-hour shift?

Was the percent recovery within 77-123% 

(1631E/7.11/9.5)

What was the % recovery of the OPR?

SECTION F. DATA REVIEW – Sample Results

1. Sample Reporting: Were results above or at the ML 

reported in units of nanograms per liter (ng/L) with 

three significant figures and were results below the 

ML reported as <0.5 ng/L? (1631E/12.5.1)

2. Reagent/Method/Field Blank Reporting: Were all 

reagent and field blanks with concentrations greater 

than or equal to the ML reported with three 

significant figures in ng/L?
Final Notes July 9, 2010

Steam Study Data Review Notes

Mercury in Water Method 1631 Revision E (2002)

(Oxidation, Purge and Trap, and Cold Vapor Atomic Fluorescence 

Spectrometry)

1. For the determination of total Hg, the samples should be preserved by adding 5 ml/L of 

BrCl solution in a mercury-free clean area in the laboratory within 48 hours of collection.

(1631E/8.5). If reported, indicate the elapsed time between sample collection and 

preservation and list any samples that were not preserved in time. 

2. For dissolved Hg, the samples should be filtered before preservation using a 0.45 μm 

capsule filter in a mercury-free clean area in the laboratory within 48 hours of collection. 

Immediately after filtration, the samples should be preserved with 5 ml/L of BrCl 

solution (1631E/6.1.3/8.4). If reported indicate the elapsed time between sample 

collection, filtration, and preservation and list any samples that were not filtered or 

preserved in time.

3. Sample bottles should be stored in new polyethylene bags until analysis is completed.

4. Because of the presence of sulfides and organic matter, sample may require the addition 

of more BrCl. Enough BrCl should be added to the samples to maintain a yellow color 

for 12 hours (1631E/11.1.1).

5. To prevent carryover samples should be run in the following order: FGD effluent and 

FGD influent.

6. All samples should be analyzed consistently with one system either the bubbler system or 

the flow injection system.

7. MS/MSD samples should be analyzed for each midpoint and effluent point in a sampling 

episode. The concentration of Hg added to the MS/MSD samples should be either 1-5 

times the ML (0.5 ng/L) or 1-5 times the background concentration whichever is greater.

8. The concentration of Hg in the bubbler blank or system blank should be used to calculate 

Hg concentration as designated in the formulas in Method 1631E. Note whether the lab 

has automatically incorporated the bubbler blank or system blank into the data results 

(1631E/12.2.2/12.3.2).

9. *If the analyte concentration in a sample was less than 5 times the analyte concentration 

in the method blank, report the result as a nondetect. List all affected samples:

10. *If the analyte concentration in a sample was less than 10 times but greater than 5 times 

the analyte concentration in the method blank, report the result as an estimated value. List 

all affected samples:
Steam Study Data Review Notes

Mercury in Water Method 1631 Revision E (2002)

Page 2 of 2

Final Notes July 9, 2010

11. Reagent, method, and field blanks with concentrations below the ML, but above or at the 

MDL should be reported in ng/L with two significant figures. Note whether the lab 

automatically reported the data in this way.

12. Reagent, method, and field blanks with concentrations below the MDL should be 

reported as <0.2 ng/L (1631E/12.5). Note whether the lab automatically reported the data 

in this way.

13. If reported, note if positive hits were checked for contamination and/or carryover?
Final Checklist July 9, 2010

Steam Study Data Review Checklist

Total Dissolved Solids Standard Method 2540C (1991)

(Dried at 180°C)

SECTION A-1. Sample Identifiers

Laboratory Name:

Sampling Episode:

Sample Numbers or 

Range:

Data Reviewer 

signature:

Date:

Instructions: Complete this checklist electronically or using a ballpoint pen.

Record reviewer comments in the Reviewer Comment section.

Record detailed information in the Comments in the “Overall Assessment” 

section for each criterion not (“N”) met.

Note: Requirements with a * are project requirements not specific to SM 

2540C.

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level

Required Present Comments

Copies of Shipping Documents (Fed-Ex Airbills) 1, 2, 3

Case Narrative 1, 2, 3

Table of Contents 3

Cross reference of Field Sample No., Lab Sample No., 

and Analytical Batch

1, 2, 3

Traffic Report Form (including Sample Receipt 

Checklist)

1, 2, 3

Sample Calculation (usually just a page copied from 

SOW)

3

Results Summary for Each Sample and Blank 1, 2, 3

Field Duplicate Results 2, 3

Quantitation List 3

Copies of Sample Preparation Work Sheets 3

Copies of Run Logs 3

Level 1: Review of traffic reports, sample handling, and proper sample preparation

Level 2: Level 1 review plus review of QA/QC results

Level 3: Level 2 review plus review of instrument performance

Level 4: Level 3 review plus analysis of raw data such as chromatograms or primary instrument output
Steam Study Data Review Checklist

Total Dissolved Solids Standard Method 2540C (1991)

Page 2 of 2

Final Checklist July 9, 2010

SM 2540C REQUIREMENT Reviewer Comment

Criterion

met

Y N

SECTION B. SAMPLE RECEIPT

1. Reviewed Sample Collection Record: 

• Signatures?

• Completed?

• Sample ID numbers checked?

• Preservations? Temp? Volume?

• Any anomalies reported?

2. Reviewed Lab Sample Receipt Record:

• Date received?

• Lab ID number checked?

• Lab ID number referenced to Sample ID 

numbers?

• Preservation checked by lab? Temp? 

Volume?

• Sample conditions?

• Sample hold time?

• Any anomalies reported by lab?

SECTION C. SAMPLE PREPARATION-Filtration and Drying Information

1. Reviewed Standard Pre logs: 

• Standard expiration date:

• Concentrations prepared?

2. Reviewed Sample Prep Logs:

• Sample process or run date:

3. *Field Duplicates: Was a field duplicate collected 

and analyzed as part of the sampling episode? 

Indicate the relative percent difference.

SECTION D. QC INFORMATION

1. Was the tare weight of the evaporating dish 

reported?

2. Was the sample volume recorded in milliliters (mL)?

3. Were the oven-drying times reported? 

SECTION E. DATA REVIEW – Sample Results

1. Calculation: Was the total dissolved solids 

calculated by the formula in Section 4 of SM 

2540C?
Final Notes July 9, 2010

Steam Study Data Review Notes

Total Dissolved Solids Standard Method 2540C (1991)

(Dried at 180°C)

1. The sample should be brought to room temperature before analysis.

2. Sample volumes should be selected so that 10-200 mg of dry residue would be acquired. 

If the filtration took longer than 10 minutes, the filter size should be increased or the 

sample volume decreased (2540C/3c). The sample size should be decreased if 

evaporation of the filtrate resulted in more than 200 mg of residue (2540C/1b).

3. After filtration, at least three aliquots of 10 ml of reagent-grade water should be added to 

the sample/filter and suction continued for 3 minutes after washing (2540C/3d).

4. The filtrate and all washings should be transferred to the evaporating dish and dried with 

a steam bath or drying oven? The evaporated sample should be further dried in an oven 

for 1 hour at 180 ± 2°C, cooled in a desiccator, and weighed. The above process should 

be repeated until the weight change is less than 4% of the previous weight or 0.5 mg 

(whichever is less).

5. If laboratory duplicates were run, duplicate weights should be within 5% of their average. 

If applicable, indicate whether this criteria was met and specify the average and percent 

recovery from the average for each of the samples.

6. Samples may contain calcium, magnesium, chloride and/or sulfate. Such species may 

make the sample hygroscopic. The following procedures should be done in order to 

prevent errors: drying time increased, proper dessication procedures used, and samples 

weighed rapidly (2540C/ 1b).

7. The oven thermometer should be immersed in a sand bath or other suitable thermal mass. 

8. The desiccator should have a good seal (vacuum or grease).

9. Desiccant should be kept inside the balance to maintain humidity control in the balance.

10. The oven temperature should be checked for proper setting and stability and the 

temperature recorded. If reported, indicate the oven temperature.

11. The balance should be checked with “S” class weights (100 mg, 1 g, and 100 g).

12. The analytical balance should have been serviced and calibrated within the last year. If 

provided, indicate the last date of service.
Final Checklist July 9, 2010

Steam Study Data Review Checklist

Total Suspended Solids Standard Method 2540D (1991)

(Dried at 103-105°C)

SECTION A-1. Sample Identifiers

Laboratory Name:

Sampling Episode:

Sample Numbers or 

Range:

Data Reviewer 

signature:

Date:

Instructions: Complete this checklist electronically or using a ballpoint pen.

Record reviewer comments in the Reviewer Comment section.

Record detailed information in the Comments in the “Overall Assessment” 

section for each criterion not (“N”) met.

Note: Requirements with a * are project requirements not specific to SM 

2540D.

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level

Required Present Comments

Copies of Shipping Documents (Fed-Ex 

Airbills)

1, 2, 3

Case Narrative 1, 2, 3

Table of Contents 3

Cross reference of Field Sample No., Lab 

Sample No., and Analytical Batch

1, 2, 3

Traffic Report Form (including Sample 

Receipt Checklist)

1, 2, 3

Sample Calculation (usually just a page copied 

from SOW)

3

Results Summary for Each Sample and Blank 1, 2, 3

Field Duplicate Results 2, 3

Quantitation List 3

Copies of Sample Preparation Work Sheets 3

Copies of Run Logs 3

Level 1: Review of traffic reports, sample handling, and proper sample preparation

Level 2: Level 1 review plus review of QA/QC results

Level 3: Level 2 review plus review of instrument performance

Level 4: Level 3 review plus analysis of raw data such as chromatograms or primary instrument 

output
Steam Study Data Review Checklist

Total Suspended Solids Standard Method 2540D (1991)

Page 2 of 2

Final Checklist July 9, 2010

SM 2540D REQUIREMENT Reviewer Comment

Criterion

met

Y N

SECTION B. SAMPLE RECEIPT

1. Reviewed Sample Collection Record: 

• Signatures?

• Completed?

• Sample ID numbers checked?

• Preservations? Temp? Volume?

• Any anomalies reported?

2. Reviewed Lab Sample Receipt Record:

• Date received?

• Lab ID number checked?

• Lab ID number referenced to Sample ID 

numbers?

• Preservation checked by lab? Temp? 

Volume?

• Sample conditions?

• Sample hold time?

• Any anomalies reported by lab?

SECTION C. SAMPLE PREPARATION-Filtration and Drying Information

1. Reviewed Standard Pre logs: 

• Standard expiration date:

• Concentrations prepared?

2. Reviewed Sample Prep Logs:

• Sample process or run date:

3. *Field Duplicates: Was a field duplicate collected 

and analyzed as part of the sampling episode? 

Indicate the relative percent difference.

SECTION D. QC INFORMATION 

1. Was the tare weight of the drying dish reported?

2. Was the sample volume recorded in milliliters (mL)?

3. Were the oven-drying times reported? 

SECTION E. DATA REVIEW – Sample Results

1. Calculation: Was the total suspended solids 

calculated by the formula in Section 4 of SM 

2540D?
Final Notes July 9, 2010

Steam Study Data Review Notes

Total Dissolved Solids Standard Method 2540C (1991)

(Dried at 180°C)

1. The sample should be brought to room temperature before analysis.

2. Sample volumes should be selected so that 10-200 mg of dry residue would be acquired. 

If the filtration took longer than 10 minutes, the filter size should be increased or the 

sample volume decreased (2540C/3c). The sample size should be decreased if 

evaporation of the filtrate resulted in more than 200 mg of residue (2540C/1b).

3. After filtration, at least three aliquots of 10 ml of reagent-grade water should be added to 

the sample/filter and suction continued for 3 minutes after washing (2540C/3d).

4. The filtrate and all washings should be transferred to the evaporating dish and dried with 

a steam bath or drying oven? The evaporated sample should be further dried in an oven 

for 1 hour at 180 ± 2°C, cooled in a desiccator, and weighed. The above process should 

be repeated until the weight change is less than 4% of the previous weight or 0.5 mg 

(whichever is less).

5. If laboratory duplicates were run, duplicate weights should be within 5% of their average. 

If applicable, indicate whether this criteria was met and specify the average and percent 

recovery from the average for each of the samples.

6. Samples may contain calcium, magnesium, chloride and/or sulfate. Such species may 

make the sample hygroscopic. The following procedures should be done in order to 

prevent errors: drying time increased, proper dessication procedures used, and samples 

weighed rapidly (2540C/ 1b).

7. The oven thermometer should be immersed in a sand bath or other suitable thermal mass. 

8. The desiccator should have a good seal (vacuum or grease).

9. Desiccant should be kept inside the balance to maintain humidity control in the balance.

10. The oven temperature should be checked for proper setting and stability and the 

temperature recorded. If reported, indicate the oven temperature.

11. The balance should be checked with “S” class weights (100 mg, 1 g, and 100 g).

12. The analytical balance should have been serviced and calibrated within the last year. If 

provided, indicate the last date of service.
Final Checklist July 9, 2010

Steam Study Data Review Checklist

Cyanide Standard Method 4500 CN- E (1990)

(Colorimetric Method)

SECTION A-1. Sample Identifiers

Laboratory Name:

Sampling Episode:

Sample Numbers or 

Range:

Data Reviewer 

signature:

Date:

Instructions: Complete this checklist electronically or using a ballpoint pen.

Record reviewer comments in the Reviewer Comment section.

Record detailed information in the Comments in the “Overall Assessment” section for 

each criterion not (“N”) met.

Note: Requirements with a * are project requirements not specific to SM 

4500 CN- E.

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level 

Required Present Comments

Copies of Shipping Documents (FedEx Airbills)1, 2, 3

Case Narrative 1, 2, 3

Table of Contents 3

Cross reference of Field Sample No., 

Lab Sample No., and Analytical 

Batch

1, 2, 3

Traffic Report Form (including 

Sample Receipt Checklist)

1, 2, 3

Sample Calculation (usually just a 

page copied from SOW)

3

Results Summary for Each Sample 

and Blank 

1, 2, 3

Calibration Curve Results 3

Calibration Curve Verification 3

Laboratory Blank Results 2, 3

Field Duplicate Results 2, 3
Steam Study Data Review Checklist

Cyanide SM 4500 CN- E

Page 2 of 4

Final Checklist July 9, 2010

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level 

Required Present Comments

Quantitation List 3

Copies of Sample Preparation Work 

Sheets

3

Copies of Run Logs 3

Level 1: Review of traffic reports, sample handling, and proper sample preparation

Level 2: Level 1 review plus review of QA/QC results

Level 3: Level 2 review plus review of instrument performance

Level 4: Level 3 review plus analysis of raw data such as chromatograms or primary 

instrument output
Steam Study Data Review Checklist

Cyanide SM 4500 CN- E

Page 3 of 4

Final Checklist July 9, 2010

SM 4500 CN- E REQUIREMENT

Reviewer 

Comment

Criterion

met

Y N

SECTION B. SAMPLE RECEIPT

1. Reviewed Sample Collection Record: 

• Signatures?

• Completed?

• Sample ID numbers checked?

• Preservations? Temp? pH? Volume?

• Any anomalies reported?

2. Reviewed Lab Sample Receipt Record:

• Date received?

• Lab ID number checked?

• Lab ID number referenced to Sample ID 

numbers?

• Preservation checked by lab? pH? Temp? 

Volume?

• Sample conditions?

• Sample hold time?

• Any anomalies reported by lab?

SECTION C. SAMPLE PREPARATION/EXTRACT HANDLING 

INFORMATION

1. Reviewed Standard Pre logs: 

• Standard expiration date:

• Concentrations prepared?

2. Reviewed Sample Prep Logs:

• Sample extraction date:

• Sample process or run date:

3. *Field Duplicates: Was a field duplicate collected 

and analyzed as part of the sampling episode? 

Indicate the relative percent difference.
Steam Study Data Review Checklist

Cyanide SM 4500 CN- E

Page 4 of 4

Final Checklist July 9, 2010

SM 4500 CN- E REQUIREMENT

Reviewer 

Comment

Criterion

met

Y N

SECTION D-1. QC INFORMATION – Instrument Calibration

1. Calibration Curve: Were a series of standards 

within the standard range and one blank used to 

create a calibration curve? (4500 CN E/4a)

What were the concentrations of the calibration 

standards used by lab? 

2. Calibration Curve Verification (CCV): Was the 

calibration curve checked periodically including 

every time the lab prepared a new reagent? (4500 

CN E/4a)

If provided, what were results reported for the 

CCV?

SECTION D-2. QC INFORMATION –Blanks/Duplicates

1. Laboratory Blank: Was a blank (0.0 mg CN-/L) 

prepared and analyzed containing NaOH dilution 

solution and all solutions added to the samples? 

Note any contamination reported by the 

laboratory.

SECTION E. DETAILED RAW DATA REVIEW – Sample Results

1. Calculation: Was the concentration in samples 

determined using the standard curve and were 

values reported in mg/L? (4500 CN E/5)

2. Dilution: Were only results between 5 and 20 

ug/L reported and if a result was ≥ 20 ug/L, was 

the sample diluted and reanalyzed? (4500 CN A 

3a)
Final Notes July 9, 2010

Steam Study Data Review Notes

Cyanide Standard Method 4500 CN- E (1990)

(Colorimetric Method)

1. The sample should be diluted if necessary so that the aliquot used in the distillation step 

contains ≤ 10 mg CN- /L.

2. If S2- was detected, it should be removed to undetected levels prior to distillation. If 

reported, indicate whether S2- was detected and note the removal method (4500 CN 

C/4a).

3. The sample should be acidified prior to distillation. The sample should be refluxed for ≥

1 hour and after refluxing the heat should be discontinued, but air flow continued for ≥ 15 

minutes (4500 CN C/4d).

4. After the addition of chloramine-T solution and acetate buffer, the sample should be 

allowed to stand for exactly 2 minutes. After the addition of pyridine-barbituric acid

reagent, the color should be allowed to develop for 8 minutes (4500 CN E/4b).

5. A spectrophotometer with the capability of taking measurements at 578 nm or a filter 

photometer having a maximum transmittance from 570 to 580 nm should be used in the 

analysis (4500 CN E/2).

6. Distillation standards should be periodically used to verify the accuracy of the apparatus, 

reagents, and/or other variables. (For example, it is recommended that a standard 

containing 1mg CN- /L should have a percent recovery of 96 -104%) (4500 CN C/4g). If 

provided, what were the concentrations and percent recoveries of these standards?

7. *If the analyte concentration in a sample was less than 5 times the analyte concentration 

in the laboratory reagent blank (if reported1), report the result as a nondetect. List all 

affected samples:

8. *If the analyte concentration in a sample was less than 10 times but greater than 5 times 

the analyte concentration in the laboratory reagent blank (if reported1), was the result 

reported as an estimated value? List all affected samples. 

 

1 Note: It is optional for the laboratory to analyze a separate blank other than the blank used to create the calibration 

curve.
Final Checklist July 9, 2010

Steam Study Data Review Checklist

BOD Standard Method 5210B (1992)

(5-day Test)

SECTION A-1. Sample Identifiers

Laboratory Name:

Sampling Episode:

Sample Number or 

Range:

Data Reviewer 

signature:

Date:

Instructions: Complete this checklist electronically or using a ballpoint pen.

Record reviewer comments in the Reviewer Comment section.

Record detailed information in the Comments in the “Overall Assessment” 

section for each criterion not (“N”) met.

Note: Requirements denoted with a * are project requirements that are not 

specific to SM 5210B.

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level

Required Present Comments

Copies of Shipping Documents (Fed-Ex 

Airbills)

1, 2, 3

Case Narrative 1, 2, 3

Table of Contents 3

Cross reference of Field Sample No., 

Lab Sample No., and Analytical Batch

1, 2, 3

Traffic Report Form (including Sample 

Receipt Checklist)

1, 2, 3

Sample Calculation (usually just a page 

copied from SOW)

3

Results Summary for Each Sample and 

Blank 

1, 2, 3

Field and Laboratory Duplicate Results 2, 3

Water Blank Results 2, 3

Glucose-Glutamic Acid Standard

Results

2, 3

Calibration Check Data 3
Steam Study Data Review Checklist

BOD Standard Method 5210B (1992)

Page 2 of 5

Final Checklist July 9, 2010

SECTION A-2. OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

General Comment Checklist

Deliverable Requirement

Review 

Level

Required Present Comments

Copies of Sample Preparation Work 

Sheets

3

Copies of Run Logs 3

Level 1: Review of traffic reports, sample handling, and proper sample preparation

Level 2: Level 1 review plus review of QA/QC results

Level 3: Level 2 review plus review of instrument performance

Level 4: Level 3 review plus analysis of raw data such as chromatograms or primary instrument output
Steam Study Data Review Checklist

BOD Standard Method 5210B (1992)

Page 3 of 5

Final Checklist July 9, 2010

STANDARD METHOD 5210 B Reviewer Comment

Criterion

met

Y N

SECTION B. SAMPLE RECEIPT

1. Reviewed Sample Collection Record: 

• Signatures?

• Completed?

• Sample ID numbers checked?

• Preservations? Temp? Volume?

• Any anomalies reported?

2. Reviewed Lab Sample Receipt Record:

• Date received?

• Lab ID number checked?

• Lab ID number referenced to Sample ID 

numbers?

• Preservation checked by lab? Temp? 

Volume?

• Sample conditions

• Sample hold time

• Any anomalies reported by lab?

SECTION C. SAMPLE PREPARATION/EXTRACT HANDLING 

INFORMATION

1. Reviewed Standard Pre logs: 

• Standard expiration date:

• Concentrations prepared?

2. Reviewed Sample Prep Logs:

• Sample process or run date:

• # of hours between collection and start of 

analysis:

Note: Samples should be analyzed within 24 hours of 

collection. (5210B/1b)

3. *Field Duplicates: Was a field duplicate collected 

and analyzed as part of the sampling episode? 

Indicate the relative percent difference.

SECTION D-1. QC INFORMATION – Method Performance

1. Nitrification Inhibitor: For CBOD5 analysis, was 

nitrification inhibitor added to all samples and 

controls?

If applicable, what nitrification inhibitor was used?

2. Seeding: Were all samples, seed controls, and

glucose-glutamic acid (GGA) for CBOD seeded?
Steam Study Data Review Checklist

BOD Standard Method 5210B (1992)

Page 4 of 5

Final Checklist July 9, 2010

STANDARD METHOD 5210 B Reviewer Comment

Criterion

met

Y N

3. Initial Dissolved Oxygen: Was initial DO 

measured (within 30 min) of sample dilution 

preparation? (5210B/4g)

If reported, what was the initial DO measurement?

4. Dilution: If necessary, were enough dilutions 

prepared so that the final result had a residual DO 

≥ 1 mg/L and a DO uptake ≥ 2 mg/L after 5 days 

of incubation? (5210B/4f) 

Note: If there are multiple dilutions that fit the 

above criteria, the average should be used as the 

final result (5210B/5).

5. Are any final DO measurements below 1.0 mg/L?

If so, specify the final DO measurement:

6. Have all samples shown a DO depletion of at least 

2.0 mg/L?

If not, specify the DO depletion:

7. Incubation: Are samples incubated for 5 days ± 6 

hours?

If reported, indicate the incubation time?

8. Seed Correction: Were seed corrections properly 

subtracted from seeded samples?

SECTION D-2. QC INFORMATION – Instrument Calibration

1. Calibration Checks: Was the calibration of the 

probe checked prior to analysis, after every 9 

samples, and at the end of the run?

Was the result within 2% of the true value? If not, 

was the probe recalibrated?

What were the results of the probe checks and the 

percent recovery?

SECTION D-3. QC INFORMATION –Reagent Blanks

1. Water Quality: Was water type or quality 

documented? Is water aged before use, if so how 

long?

2. Was water allowed to come to room temperature 

before usage?

3. Were nutrient and phosphate buffer prepared or 

purchased? 

4. Was reagent quality verified and documented?

5. Phosphate Buffer pH: Was this buffer pH= 7.2?

If not, specify the buffer pH:
Steam Study Data Review Checklist

BOD Standard Method 5210B (1992)

Page 5 of 5

Final Checklist July 9, 2010

STANDARD METHOD 5210 B Reviewer Comment

Criterion

met

Y N

6. Water Blank: Was a water blank analyzed in 

each analysis batch? Was it ≤ 0.20 mg/L?

(5210B/4h)

Indicate the water blank reading and any 

contamination noted by the laboratory.

7. Glucose-Glutamic Acid Standards: Was a 

glucose-glutamic acid standard analyzed with each 

analysis batch?

Were results within 198 ± 30.5 mg/L (85-115%)?

What was the percent recovery?

SECTION E. Method QC

1. Laboratory Duplicates: Were duplicates run at 

every 20 samples? (5%) Was the relative percent 

difference less than 20%?

Indicate the results of the sample and the sample 

duplicate and the relative percent difference?

SECTION F. DATA REVIEW

1. Calculations: Was BOD5 calculated using the 

appropriate formula below and reported in 

milligrams per liter (mg/L)? 

For non-seeded samples: P

D1− D2

 

For seeded samples: P

(D1− D2) − (B1− B2) f

Where: D1 = Initial diluted sample DO (mg/L)

D2 = Final diluted sample DO (mg/L)

P = Volumetric fraction of sample used

B1 = Initial seed control DO (mg/L)

B2 = Final seed control DO (mg/L)

f = Ratio of seed in diluted sample to seed 

in seed control
Final Notes July 9, 2010

Steam Study Data Review Notes

BOD Standard Method 5210B (1992)

(5-day Test)

1. If reported, indicate how samples are checked and treated for chlorine (5210B/4e).

2. If reported, indicate if the pH was adjusted prior to analysis. It is suggested that the pH of 

samples be between 6.5 – 7.5 S.U. (5210B/4e).

3. If reported, indicate if hydrogen peroxide is present in the samples and if relevant 

indicate how the lab treated the samples for hydrogen peroxide.

4. If reported, indicate the temperature that samples were equilibrated to prior to analysis. It 

is suggested samples be equilibrated to 20°C.

5. If reported, indicate the incubator or water bath temperature. It is suggested that the 

temperature be maintained between 19 and 21°C during the entire analysis. (5210B/2b)

6. If reported, indicate if it was necessary for samples to be seeded and state the material 

used to seed the samples. Note: the seed correction should be calculated based on average 

seed control sample results (5210B/4d).

7. The DO uptake of seeded dilution water should be between 0.6 - 1.0 mg/L (5210B/4d). If 

reported, indicate if the above criteria were met.

8. *If the analyte concentration in a sample was less than 5 times the analyte concentration 

in the laboratory reagent blank (if reported1

9. *If the analyte concentration in a sample was less than 10 times but greater than 5 times 

the analyte concentration in the laboratory reagent blank (if reported

), report the result as a nondetect. List any 

affected samples:

1

), report the result as 

an estimated value. List any affected samples:

 

1 Note: It is optional for the laboratory to analyze a laboratory reagent blank.
Appendix E 

DATA REVIEW GUIDELINES 
U.S. Environmental Protection Agency 

Office of Water 

QUESTIONNAIRE FOR THE STEAM ELECTRIC POWER GENERATING EFFLUENT 

GUIDELINES

CODING AND REVIEW GUIDE FOR 

TECHNICAL QUESTIONS

August 27, 2010 
TABLE OF CONTENTS 

Page 

1.0 BACKGROUND ....................................................................................................... 1-1 

1.1 Goals of the Project .................................................................................. 1-1 

1.2 Description of Recipients ......................................................................... 1-1 

1.3 Description of the Questionnaire ............................................................. 1-1 

2.0 QUESTIONNAIRE REVIEW AND CODING PROCEDURES ........................................... 2-1 

2.1 Receipt of Questionnaires ........................................................................ 2-1 

2.2 Overview of Technical Review Procedure .............................................. 2-2 

2.3 General Survey Checks ............................................................................ 2-3 

2.4 Conducting Follow-Up Activities ............................................................ 2-5 

2.5 Review QA Procedures ............................................................................ 2-6 

Attachment A TECHNICAL QUESTIONNAIRE CHECKLIST 

Attachment B FOLLOW-UP PHONE CALL AND EMAIL INSTRUCTIONS 
1-1

1.0 BACKGROUND

1.1 Goals of the Project

EPA’s Office of Water (OW) will use the information gathered from the steam 

electric questionnaire (survey) and EPA sampling data to review and revise effluent limitations 

guidelines and standards (ELGs) for the Steam Electric Power Generating Industry (40 CFR Part 

423). 

EPA will use the technical data collected in the questionnaire to gain knowledge 

on the processes and wastewaters generated from those processes at steam electric facilities. EPA 

will review wastewaters associated with flue gas desulfurization (FGD) and ash handling 

systems, as well as other wastewaters generated at the facility. To assess economic impacts and 

benefits associated with any revised limitations considered, EPA will use the technical data 

together with financial data collected in the economic sections of the questionnaire. 

1.2 Description of Recipients

EPA distributed the questionnaire to 733 fossil- and nuclear-fueled steam electric 

power plants that are potentially regulated by the steam electric effluent guidelines. 

1.3 Description of the Questionnaire

The questionnaire is divided into the following parts: 

PART A: STEAM ELECTRIC POWER PLANT OPERATIONS; 

PART B: FLUE GAS DESULFURIZATION (FGD) SYSTEMS; 

PART C: ASH HANDLING; 

PART D: POND/IMPOUNDMENT SYSTEMS AND OTHER 

 WASTEWATER TREATMENT OPERATIONS; 

PART E: WASTES FROM CLEANING METAL PROCESS 

 EQUIPMENT; 

PART F: MANAGEMENT PRACTICES FOR PONDS/IMPOUNDMENTS 

 AND LANDFILLS; 

PART G: LEACHATE SAMPLING DATA FOR PONDS/ 

 IMPOUNDMENTS AND LANDFILLS; 

PART H: NUCLEAR POWER GENERATION; AND 

PART I: ECONOMIC AND FINANCIAL DATA. 

The questionnaire consists of multiple parts which have been tailored to address 

specific processes, specific data needs, or types of power plants. Part A of the questionnaire 

collects general plant information and selected technical information about the plant processes 

and the electric generating units. Additional parts of the questionnaire are designed to collect 

economic data and to collect technical information on flue gas desulfurization (FGD) 

wastewater, ash handling, metal cleaning operations, wastewater treatment, surface 

impoundment and landfill operations, and nuclear operations. One part of the questionnaire 
1-2

requires certain power plants to collect and analyze samples of leachate from surface 

impoundments and landfills containing coal combustion residues. 

Parts A, H, and I of the questionnaire were provided to all questionnaire 

recipients; the remaining parts were sent to discrete subpopulations of questionnaire recipients: 

coal-fired, petroleum coke-fired, oil-fired, gas-fired, and nuclear plants, as shown in Table 1. 

Table 1. Distribution of Questionnaire Parts 

Questionnaire 

Part 

Type of Plant 

Coal Subset 

(Version 1) 

Other Coal 

(Version 2) 

Oil/Combination 

(Version 3) 

Gas/Nuclear 

(Version 4) 

A X X X X 

B X X X 

C X X X 

D X X X 

E X X X 

F X 

G X 

H X X X X 

I X X X X 
2-1

2.0 QUESTIONNAIRE REVIEW AND CODING PROCEDURES

This section presents the review and coding procedures to be used for the steam 

electric questionnaires responses. All responses are expected to be received electronically, as 

directed by the survey instructions. Upon receipt, ERG will make an electronic working copy of 

each survey and store this working copy on the Steam Electric CBI project area on ERG’s CBI 

server (P:\Steam Electric\Rulemaking\Survey\Survey Working Copies\). ERG will manage all 

survey responses on the CBI server in the expectation that some CBI will be claimed by 

respondents. In this way, all materials related to survey review and resolution will reside in the 

same network area. 

Each questionnaire response will undergo an initial review for completeness, 

followed by a technical review of the responses, using an electronic technical review checklist. 

The checklist templates are located in the CBI survey project area, and are also found in 

Attachments 1 and 2 to these guidelines. There is a template for Version 1 and 2 surveys, and a 

separate template for Version 3 and 4 surveys. The initial reviewer will create and save in the 

specific plant/questionnaire electronic folder a blank copy of the checklist template workbook. 

The Excel workbook containing the checklist template also contains a blank contact form. All 

contacts to the plant must be documented in a contact form. Reviewers will create a worksheet 

in the review checklist workbook for each contact completed, and name the worksheet with the 

Plant ID and date (e.g., 12345_Contact_082510). A more detailed description of the review 

process is described in this section. 

2.1 Receipt of Questionnaires

Upon receipt of a questionnaire response, Marla will transfer questionnaire 

packages to Teresa, who will note the date received on the package. Teresa or her designee will 

conduct the initial completeness checklist, following the checklist form titled “Completeness.” 

This completeness review includes the following steps: 

• Enter name of the person completing the checklist, along with the plant ID and 

questionnaire version number. 

• Check to ensure returned packages contain a CD/DVD and certification 

statement. If an electronic copy of the questionnaire or the certification statement 

is missing, contact the plant to request a copy. 

• Immediately log the date of receipt of the questionnaire response into the Survey 

Tracking database “Survey Tracking” table (located on the CBI server at P:\Steam 

Electric\Rulemaking\Survey\), along with any pertinent notes on status. 

• Enter survey information and completeness checks into the “Survey Review” 

table. 

• Place a pre-populated label on the CD. Enter the date uploaded, your initials, and 

the Plant ID on the label. 

• Check CD for content. Check that all required parts are returned and all files can 

be opened and read electronically. (See Table 1 for a list of parts required for each 

version of the questionnaire) 

• Upload the files to the CBI server (P:\Steam Electric\Rulemaking\Survey\Survey 

Working Copies\ ). 
2-2

 Create an electronic folder for each plant ID (e.g., 12345). 

 Upload the questionnaire response files from the CD to the working copy 

folder and rename the questionnaire part files with the Plant ID and Part 

designated (e.g., 12345_PartA.xls). 

 Create a subfolder called “Supporting Documentation” if needed and 

upload supporting files to this folder. 

 Create a log of all hard copy documents submitted by the respondent and 

where they are stored. Name the log with the Plant ID (e.g., 

12345_HardcopyLog.doc) 

 For Hardcopies submitted, scan documents into PDF and save on the CBI 

network wherever feasible. 

 Save a copy of the Survey Review checklist to the plant folder and update 

as completeness checks are finished. 

• Create a physical file folder and place a pre-populated label on the folder – Plant 

ID, Version, and Plant Name. Place the CD and any hardcopy documents 

received in the folder and store the folder in the CBI archive room by Plant ID 

order. 

• Conduct initial check of the questionnaire response: 

 Determine if the plant kicked out of the questionnaire in Part A through 

evaluation of Q A1-6, 1-7, 1-8, and 1-11.1

 Determine if the plant kicked out of any remaining questionnaire parts. 

 Determine if all necessary parts are present and the survey is ready for 

technical review. 

• Once the initial checks are complete and the questionnaire is ready for technical 

review, move the Part I questionnaire file to the “Part I Deliveries” folder. 

• Complete the information on the checklist and in the “Survey Review” table to 

note that the survey is ready for technical review. 

2.2 Overview of Technical Review Procedure

Once a questionnaire is ready for technical review, Deb or her designee will 

assign it to a project team member for technical review and any corrections to the electronic 

responses. In general, reviewers will follow this 8-step process: 

1. Enter your name and review start date to the Survey Tracking database 

(Survey Review table), located at P:\Steam Electric\Rulemaking\Survey\. 

2. Access the working copy of the questionnaire on the CBI server at 

P:\Steam Electric\Rulemaking\Survey\Survey Working Copies\. 

3. Complete the technical review following the technical review checklist for 

your version of the questionnaire (hide any unnecessary tabs), and if 

necessary prepare a list of follow-up questions/issues to discuss with the 

respondent. (An electronic copy of the checklist should already be located 

in the working copy folder). 

4. Contact respondent and resolve follow-up questions/issues. 

 

1

 Please note that if the plant answers Questions A8-2 and A8-3 “No” for all steam electric generating units at the 

plant, they do not need to complete the remainder of the questionnaire. However, these responses will still require 

technical review. 
2-3

5. Make necessary changes to the electronic responses in the working copy 

files and document changes on the change form in the electronic checklist 

file. 

6. Notify Deb or her designee that the survey is ready for 2nd review, and 

update information in the Survey Tracking database (Survey Review 

table). 

7. Following 2nd review, finish resolution of any remaining issues. 

8. Move reviewed survey files to the P:\Steam 

Electric\Rulemaking\Survey\Extraction folder and update the Survey 

Tracking database (Survey Review table). 

2.3 General Survey Checks

Be sure to incorporate into your review the following general survey checks for 

each respondent:

 Before reviewing/coding, skim through the survey files to become familiar with 

the inserts and attachments provided. If you are reviewing a Version 1 or 2 

survey, you may find it helpful to review any helpline entries related to this 

respondent (P:\Steam\Survey\Helpline\Helpline Log.xls).

 Note if a required attachment is not included in the survey files or hard copy 

folder. 

 For multiple copies of the same question or section, check that copy numbering of 

the workbook tabs is correct. 

 Check the comments as you review a section to see if there are explanations for 

missing or incomplete information. 

 If any question is marked as CBI, ensure that the survey is noted as “CBI” in the 

Survey Tracking database. 

 Calculations – 

- If you need to calculate a value, document the calculation on a calculation 

sheet (P:\Steam\Survey\Review and Followup\Blank Calc Sheet.doc). 

- Show each calculation step with explanation and have each calculation 

checked and signed by another team member. 

- Save all calculations for one plant in one file in the Survey Working 

Copies plant folder with the plant ID and “calc” (e.g., 12345_calc). 
2-4

 Missing/Incomplete – 

- If a required response is missing or incomplete, check the Comments page 

to see if there is an explanation. Note: Be aware of skipping patterns. For 

questions allowed to be blank with no skipping patterns, leave blank. 

- Note any missing, incomplete, inconsistent, etc. information on your list of 

Follow-Up Questions so that all required information can be obtained 

and/or clarified during the follow-up call. 

- It may be necessary to send blank/additional tables or pages to the contact 

for completion. Please coordinate these activities with Liz Sabol. 

 Follow the general coding guidelines in Table 2. 
2-5

Table 2. GENERAL CODING GUIDELINES

Category Coding Guidelines 

General Document all changes to the electronic files in the Change Form worksheet in the electronic checklist. 

Any changes made by someone other than the initial reviewer must be initialed in the Change Form. 

Grey out any portions of the review checklist that are not applicable to the respondent (i.e., they 

appropriately skipped). 

Comments should only be on the comments page and every comment should have a question number 

associated with it. 

Electronic 

Checks/ 

Copies/ 

Copy 

Buttons 

If a question should not have a response (i.e., skipped question), but the respondent accidently hit a 

radio button response which could not be cleared, check the comments for the question and clear the 

response from the file. 

Ensure that no tabs were deleted from each questionnaire response. 

Check that tab names were not changed (including copied tabs). Rename them to the original 

nomenclature if they were changed. 

If the plant created new tabs where no copy button existed (e.g., Part A, Section 7), check the file to see 

if they reported multiple units/systems with the same IDs (that is, was the same ID used for more than 

one unit/system). 

Coordinate with Liz Sabol or her designee to ensure that new copies are correctly mapped before 

finishing review. 

Units When unit dropdown boxes are presented, only the units in the dropdown box may be used. Similarly, 

if units are specified in the questions (e.g., in the column headings of tables), only the units specified 

may be used. If the company/plant reported other units, do a calculation to convert the value and enter 

the new value on the form.

Numeric 

Fields

Leave numbers as shown; do not round. 

Numeric field can contain only numbers. 

- If the field contains a text entry in addition to a number (such as average, estimate, unknown, per 

year, <, or >), remove the text entry. Do not remove the number. Add a comment to the comments 

page describing the text (e.g., “The value was an average/estimate/per year/less than/greater 

than...”). 

- If the numeric field contains a unit, remove the unit and reenter the number. For example, if the 

company/plant reports “10K”, reenter it as “10,000”; If the company reports “7.5 million”, reenter it 

as “7,500,000”.) 

- If the field contains a number as text, remove the text and reenter the number. For example, if the 

company/plant reports “ten”, remove “ten”, and enter “10”). 

- If a field that should be completed is missing a value, enter “-111” into the data field. Add a 

comment (with question number) describing the entry. Follow up with plant to try and resolve 

missing data. 

2.4 Conducting Follow-Up Activities

Once a questionnaire has been reviewed, resolve outstanding issues through 

contacts to the respondent: 

 Using the Follow Up Questions document, have all questions ready to be asked. 

 Coordinate with the Task Leader, Deb or her designee, prior to communicating 

with the contact. 
2-6

 If you plan to send the Follow Up Questions to the contact beforehand, telephone 

the contact and email or fax the questions, and set a schedule to discuss the 

questions in another call. 

 See Attachment 3 for a phone script and email template. 

 At the end of the phone call, ask if any of the discussion is CBI. Note: Survey 

questions checked as CBI are assumed as such, and the CBI status of the 

discussion and the data request question must match. 

 Using your notes from the phone call, complete the Follow Up Question

document, describing and summarizing what was discussed and the final 

resolution of the flagged item(s). The Follow Up Question document will also 

serve as the contact record. 

 If you exchanged email with the company/plant, create a Word document with the 

email and save it in the Survey Working Copies plant folder in a subfolder named 

“Email Contacts.” Name the document: Plant ID_Email_date (e.g., 

12345_Email_083107). 

 All correspondence (Follow Up Questions and email) should be stored to the 

Survey Working Copies plant folder. 

 When follow-up is completed, enter the date follow up is completed in the Survey 

Tracking database (Survey Review table). 

2.5 Review QA Procedures

Once the first technical review is completed, a second team member will conduct 

a QA review of the response. 

 The purpose of review QA is to ensure that review and coding procedures were 

performed following the review guidelines. The QA reviewer will check that: 

- Data were inserted or corrected where appropriate; 

- Calculations are correct; 

- Missing/inconsistent information is appropriately flagged; and 

- The basis of assumptions is appropriate. 

 The QA reviewer will mark revisions in the questionnaire checklist. If changes to 

the questionnaire response files are necessary, the reviewer will document any 

further changes in the Change Form. The QA reviewer will discuss any changes 

or comments with the data request reviewer first. 
Attachment 1 

TECHNICAL QUESTIONNAIRE CHECKLIST – VERSION 1/2 
Part A Name Date(s) Reviewed

Reviewer No. 1Reviewer No. 2Status of Review

Questionnaire 

Part/Section/ 

Question 

Number

Copy Number Related Section Type of Information Coding and Review Activity First Reviewer Comments Second Reviewer 

Part A Steam Electric Plant Operations

TOC Ensure that plant name and ID have been populated in the TOC page 

Section 1 Plant Contact Information

A1.1- A1.5 Information for Primary and Secondary 

Technical and Economical Contacts

Make sure all data is provided for Primary and Seconday Contacts for both Technical and Economical Contacts 

Section 1.2 General Plant Operating Characteristics

A1-6 Plant retired If YES, respondent should not have completed questionnaire; check comments.

[Ensure no other answers are completed in Part A; technical review is complete.] 

A1-7 Generation of electricity via steam electric 

generating unit.

If NO, respondent should not have completed questionnaire; check comments.[Ensure no other answers are completed in Part A; technical review is complete.] 

A1-8 Table A-11 Type of fossil fuel used If NONE, respondent should not have completed questionnaire; check comments.

[Ensure no other answers are completed in Part A; technical review is complete.]If a positive reply, confirm Question A1-8 and Table A-11 are consistent.

A1-9 Electricity uses/handling Ensure answers = 100% 

A1-10 NAICS Code Ensure at least a primary NAICS code is identified A1-11 Primary Purpose If NO, check to be sure reason given is reasonable. If so, respondent should not have 

finished questionnaire; check comments.[Ensure no other answers are completed in Part A; technical review is complete.]

A1-12 Steam Usage Ensure answers = 100% 

Table A-1 Net and Gross Electrical Generation 2007-

2009

Ensure net generation is less than gross generation. 

Section 2.1 Plant Identification, Permits, Studies

A2-1 - A2-2 Indentification code Ensure fields are complete (EIA IDs can be 1 to 5 digits long 

A2-3 Table A-2 EA or EIS If NO skip to A2-4 and Table A2 

Table A-2 Permit Information Check comments carefully to be sure stormwater permits are properly classified 

(individual permits listed under NPDES, general permits listed under Stormwater) 

Section 2.2 Outfall Information May have multiple copies to account for multiple outfalls

Latitude/Longitude Ensure lat/long coordinates are provided in degrees . If not, calculate the lat/long in 

these units. 

Di h Fl E d l If h l d fl i l i l l b h

A2-5

Discharge Flow Ensure data are complete. If the plant reported flow in multiple columns, be sure the

data are consistent. 

A2-6 Section 3 Internal or Final Outfall If INTERNAL outfall, skip to Section 3 for specific outfall information (remember there

may be multiple outfalls) 

A2-7 Discharge canal Answer YES or NO A2-8 Receiving water Ensure all data are completed A2-9 Mixing zone Answer YES or NO 

A2-10/Table A-3 Percent contribution of wasterwater Answers should = 100%. Note if emergency outfall box is checked. 

Section 3 Ponds or Impoundments

Entire Section Part D, F, & G (if 

required) Ensure ponds reported in Parts D, F, & G are reported consistently with Table A-4 

A3-1 Section 4 Ponds or Impoundments If NO, skip to Section 4 

Pond identification Ensure all data are complete Latitude/Longitude Ensure lat/long coordinates are provided in degrees . If not, calculate the lat/long in 

these units. 

A3-3 and Table A5 Table A-4 Pond wastewater identification Ensure data are provided for each pond identified in Table A-4 

Section 4 Landfills

Entire Section Parts F & G (if 

required) Ensure landfills reported in Parts F & G are reported consistently with Table A-6 

A4-1 Section 5 Landfills If NO, skip to Section 5 

Landfill identification Ensure all data are complete Latitude/Longitude Ensure lat/long coordinates are provided in degrees . If not, calculate the lat/long in 

these units. 

A4-3 and Table A7 Table A-6 Landfill wastestream identification Ensure data are provided for each landfill identified in Table A-6 

Section 5 Plant Property and Water Balance

A4-2 and Table A6

Table A-5Table A-7

A3-2 and Table A4
Entire Section Section 4 Ensure that all ponds/impoundments and landfills entered in Tables A-4 and A-6 are 

referenced here 

Location of plant If a nuclear unit is present, ensure box is checked and coordinates are not provided. Latitude/Longitude Ensure lat/long coordinates are provided in degrees . If not, calculate the lat/long in 

these units. Ensure map has been provided and covers buildings, ponds/impoundments, landfills and any significant features. NOTE: if one or more nuclear units are on-site, no map is required.

Check that map file has plant ID in name If a hard copy map is provided, ensure plant ID is on every page in upper right corner. Ensure diagram has been provided and covers water balance diagram number, plant id info, all SEGUs designated in Table A-8, all wastewater treatment systems and discharge pts, and flow ratesCheck that map file has plant ID in name If a hard copy diagram is provided, ensure plant ID is on every page in upper right corner.

Section 6 Steam Electric Generating Unit Information

A6-1 and Table A8 Table A-1 SEGU information Ensure all data are complete including OTHER information if appropriate. Check that the sum of Total Unit Electric Generation for all rows in Table A-8 is less than or equal 

to the Gross Electrical Generation in Table A-1 for 2009

A6-2 and Table A9 Question A1-13 SEGU information Ensure all data are complete including OTHER information if appropriate. 

Section 7 Condenser Cooling Water Systems

Ensure all data are complete including OTHER information if appropriate 

Ensure that a cooling water system is reported for all SEUs listed in Tables A-8 and A 

A7-2 Demonstrate compliance Ensure all data are complete including OTHER information if appropriate. A7-3 POTW Effluent Ensure question is answered. 

Section 8 Fuel Usage May have multiple copies to account for multiple SEGUs

Ensure all data are complete including OTHER information if appropriate Check that a copy of Table A-11 exists for each SEGU listed in Table A-8 Check that the total BTUs generated equals the total fossil/nuclear BTUs + total "other" BTUs.Check that the BTU Generated by Gas is approximately nine orders of magnitude 

greater than the sum of the Amount (Million ft3) of Gas values 

Check that the BTU Generated by Coal and/or Petroleum Coke is approximately seven orders of magnitude greater than the sum of the Amount (tons) of Coal and Petroleum Coke values.Check that the BTU Generated by Oil is approximately six orders of magnitude greater Ensure that units are specified for other fuels.

A8-1 and Table A- Types and amounts of fuel used

11

Table A-8

A5-2 Aerial Map

Condenser cooling water systems

A5-3 Table A-8, D-1, 

D-2

Water balance diagram

A7-1 and Table 7-

10

Tables A-8/A-9

A5-1

Check that the value for Amount (Million ft3) for gas is approximately three orders of magnitude less than the order of magnitude of the Quantity of Fuel Burned in Table I-22 for the FY 2009 row that lists the same gas as the Primary Energy Source for the given SE Unit ID. Note that Part I is located on the CBI network in the "Part I Deliveries" folder. Do not make any changes to Part I for discrepancies; instead, flag for follow up with the plant.Following contact with the plant, if the Part I information is determined to be incorrect, add the correction to the "Abt Part I Corrections.xls" file, located in the Part I Deliveries folder

Determine if SEGU is an "Other EGU" If ALL SEGUs in Table A-8 are classified as 'Other EGUs,' respondent does not need to

complete remainder of questionnaire.[Ensure no other answers are completed in Part A; technical review is complete.]

Section 9 NOx Control Systems

A9-1 NOx Control Systems If NO, skip to Section 10 

Table A-12 Table A-8 and A9 Ensure all data are complete including OTHER information if appropriate. Confirm SE Unit IDs reported here are also reported in Tables A-8 or A-9 

A9-2 Table A-12 Offsite Regeneration If offsite SCR catalyst regeneration reported in Table A-12, Table A-13 should be 

completed; otherwise, checkbox above Table A-13 should be checked 

A9-3 Onsite Catalyst Regeneration If NO or NA, skip to Question A9-7 A9-4 Regeneration wastewater Ensure all data are complete and in proper units A9-5 Regeneration wastewater commingling Ensure all data are complete including OTHER information if appropriate A9-6 Section 2.2 Regeneration wastewater destination Ensure all data are complete including OTHER information if appropriate. Confirm 

NPDES outfall number(s) in Section 2.2 

A8-2 and A8-3 BTU by percent fossil/nuclear fuels 

Predominance of fossil/nuclear fuels
A9-7 Catalyst wash If NO, skip to Section 10 

A9-8 Catalyst wash wastewater If NO, skip to Section 10 A9-9 Catalyst wash wastewater volume Ensure all data are complete and in proper units 

A9-10 Catalyst wash wastewater commingling Ensure all data are complete including OTHER information if appropriate A9-11 Catalyst wash wastewater destination Ensure all data are complete including OTHER information if appropriate. Confirm 

NPDES outfall number(s) in Section 2.2 

Section 10 Flue Gas Mercury Control Systems

Entire Section Section 8, Table 

A-8, Table A-9

Flue gas mercury control systems This section should only report on fossil-fueled EGU; see Section A-8 for classification. 

A10-1 Flue gas mercury control systems If NO, skip to Question A10-3 

Table A-14 Table A-8, Table 

A-9

Flue gas mercury control systems Ensure all data are complete. Confirm SE Unit IDs reported here are also reported in 

Tables A-8 or A-9. 

A10-3 Pilot-scale systems If NO, skip to Section 11 

A10-4 Wastewater If NO, skip to Section 11 A10-5 Technology Ensure all data are complete, if DID NOT ATTACH confirm there is a reason why not. 

Section 11 Carbon Capture Systems

Entire Section Section 8, Table 

A-8, Table A-9

Carbon capture systems This section should only report on fossil-fueled EGU; see Section A-8 for classification. 

A11-1 Carbon capture systems If NO, skip to Section 12 

Table A-15 Table A-8, Table 

A-9

Carbon capture systems Ensure all data are complete. Confirm SE Unit IDs reported here are also reported in 

Tables A-8 or A-9. 

A11-3 Pilot-scale systems If NO, skip to Section 12 

A11-4 Technology Ensure all data are complete, if DID NOT ATTACH confirm there is a reason why not. A11-5 Wastewater Ensure all data are complete A11-6 Wastewater If NO, skip to Section 12; if YES, ensure analytical results are attached or a reason 

given why not. 

Section 12 Wet Electrostatic Precipitator Systems

Entire Section Section 8, Table 

A-8, Table A-9

Wet electrostatic precipitator systems This section should only report on fossil-fueled EGU; see Section A-8 for classification. 

A12-1 Wet electrostatic precipitator systems If NO, skip to Section 13 

Table A-15 Table A-8, Table 

A-9

Wet electrostatic precipitator systems Ensure all data are complete. Confirm SE Unit IDs reported here are also reported in 

Tables A-8 or A-9. 

A12-2 Flow rate, duration, and frequency Ensure all data are complete 

A12-3 Water source Ensure all data are complete including OTHER information if appropriate A12-4 Water criteria Ensure all data are complete including OTHER information if appropriate A12-5 Section 2.2 Wastewater destinations Ensure all data are complete including OTHER information if appropriate. If wastewate

is discharged to surface water, confirm NPDES outfall number(s) in Section 2.2. 

A12-6 Pilot-scale systems If NO, skip to Section 13. 

A12-7 Technology Ensure all data are complete, if DID NOT ATTACH confirm there is a reason why not. 

A12-8 Characterization samples If NO, skip to Section 13; if YES ensure analytical results are attached or a reason given 

why not. 

Section 13 Coal Storage and Processing

A13-1 Coal storage and processing If NO, skip to Question A13-16. 

A13-2 Discharge Ensure number of days is <= 365 days 

If NO, skip to Question A13-4; if YES ensure all data are complete 

Ensure pH values are between zero and 14 

A13-4 Table A-4 Pond/Impoundment If YES, confirm that IDs were reported in Table A-4 

A13-5 Wastewater destinations Ensure all data are complete including OTHER information if appropriate. If wastewate

is discharged to surface water, confirm NPDES outfall number(s) in Section 2.2. Confirm that pond IDs are reported in Table A-4

A13-6 Coal washing If NO, skip to Question A13-8; if YES, ensure all data are complete 

A13-7 Coal wash water destinations Ensure all data are complete including OTHER information if appropriate. If wastewate

is discharged to surface water, confirm NPDES outfall number(s) in Section 2.2. Confirm that pond IDs are reported in Table A-4

A13-8 Coal blending If NO, skip to Question A13-10 

A13-9 Coal blending process wastewater If YES, ensure all data are complete. Check that number of days is <=365 days 

A13-10 Coal pulverizing If NO, skip to Question A13-16 A13-11 Coal pulverizing process wastewater If NO, skip to Question A13-12; if YES, ensure all data are complete. Check that 

number of days is <=365 days. 

A13-12 Coal pulverizing process wastewater If NO, skip to Question A13-14; if YES, ensure all data are complete. Check that 

number of days is <=365 days. 

A13-13 and 14 Sluicing and pyritics Ensure data are complete 

A13-15 Disposal of mill rejects Ensure all data are complete including OTHER information if appropriate. Confirm that 

pond IDs are reported in Table A-4 and landfill IDs are reported in Table A-6. 

A13-3 pH
A13-16 and 17 IGCC generating unit Ensure data are complete 

Comments

Entire Section Check that all comments have a question number identified and the comment is 

understandable. 

Entire Section Resolve comments that indicate a change must be made to any electronic response. 
Part B Name Date(s) Reviewed

Reviewer No. 1Reviewer No. 2Status of Review

Questionnaire 

Part/Section/ 

Question 

Number

Copy Number Related Section Type of Information Coding and Review Activity First Reviewer Comments Second Reviewer 

Part B FGD Systems

TOC Ensure that plant name and ID have been populated in the TOC page 

Section 1 General FGD System Information

B1-1. If NO was selected check that the plant did not complete the remainder of Part B. 

Tables A-8 and A9 FGD System ID For FGD that range from FGD 1-6 (FGD systems currently operating), check against date system brought online, and the SE Unit selected (SE 1-10 would be selected). 

Tables A-8 and A9 FGD System ID For FGD that range from FGD A-C (FGD systems planned to operate), check against date system brought online, and the SE Unit selected (SE A-D would be selected). 

FGD System ID Confirm that the plant selected a unique FGD system ID for each completed row in 

Table B-1. 

Steam Electric Units Check that the plant has provided information in Tables A-8 and A-9 for all steam 

electric units checked. 

Type of Oxidation... AND Does (or Will) the System Generate a FGD Slurry Blowdown

Check that if the plant selected “Not Applicable” in the “Type of Oxidation...” column that the plant also selected “No” in the “Does (or Will) the System Generate a FGD Slurry Blowdown” column

 Type of FGD System AND/OR Type of Sorbent

Confirm that if the plant selected "Other," it is specified in the appropriate cell. 

Sulfur Dioxide Removal Efficiency Check that the value is reasonable. Typically, these SO2 removal efficiencies are 95% 

or greater.

Section 2 Planned FGD System Information

B2-1 FGD System ID Confirm that the plant included a row for all FGD systems in Table B-1 whose planned 

online date was after 12/31/2020 (Table B-1, column 2) and who answered yes the system generates FGD slurry blowdown (Table B-1, column 4).

Planned Solids Handling... AND Type of Wastewater Treatment System...

In the “Planned Solids Handling...” and “Type of Wastewater Treatment System...” columns: Check that the codes provided match with codes provided in the Code Tables Tab and that multiple entries are separated by commas

Design Flow Rate If the plant provided responses in units other than those specified in the table, perform a 

calculation to convert the value into the specified units (see the General Coding Guidelines)

Estimated Date Check that the date is in the appropriate form (i.e., mm/yyyy) 

Table B-1 FGD System ID Confirm that the plant has selected each of the FGD systems designated FGD A-C 

ONLY listed in Table B-1 in at least one of the rows 

Section 3 FGD Additive

FGD System ID Confirm that the plant has provided information in Table B-1 for the FGD Systems 

checked. 

Purpose of Additive Confirm that if the plant selected "Other," it is specified in the appropriate cell. 

Section 4 Wet FGD System Information May have multiple copies to account for multiple wet FGD systems.

B4-1 Table B-1 If NO is selected in question B4-1, check that the plant did not complete the remainder 

of Section 4. 

All Copied 

Section 4 Tabs

Confirm that the plant completed Section 4 for all wet FGD systems reported in Table B

1 (i.e., the plant checked yes in the “Does (or Will) the System Generate a FGD Slurry Blowdown...” column). Confirm that the plant wrote the appropriate FGD System ID in the proper form (i.e., FGD-#) at the top of each copied Section 4 tab. 

B4-2 Operating concentration of chlorides The chloride operating concentration range should be 2,000 - 40,000 ppm 

FGD system max. design chlorides conc The chloride operating concentration should be no larger than ____ ppm FGD equipment that determines max. design conc.

Confirm that if the plant selected "Other," it is specified in the appropriate cell. For each box that was selected, check that the plant provided the appropriate information. 

If the plant provided responses in units other than those specified, perform a calculation to convert the value into the specified units (see the General Coding Guidelines) Confirm that if the plant selected "Other," it is explained in the appropriate cell For each box that was selected, check that the plant provided the appropriate information. 

B4-5 Water sources

B1-2./Table B-1

B4-4 FGD system parameters

B2-1/Table B-2

B4-3

B3-1/Table B-3 Table B-1
If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines) Confirm that if the plant selected "Other," it is explained in the appropriate cell 

B4-6 Flow rate/duration/frequency If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines). 

B4-7 Flow rate/duration/frequency If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines). 

B4-8 Flow rate/duration/frequency If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines). 

B4-9 Flow rate/duration/frequency If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines). 

B4-10 Mist eliminator If "Other" is selected in the "Process Wastewater" dropdown box or if the “Other, 

explain” checkbox was selected confirm that a description was provided in the appropriate cell.

B4-11 FGD reagent prepartation water If "Other" is selected in the "Process Wastewater" dropdown box or if the “Other, 

explain” checkbox was selected confirm that a description was provided in the appropriate cell.

B4-12 Absorber make-up water If "Other" is selected in the "Process Wastewater" dropdown box or if the “Other, 

explain” checkbox was selected confirm that a description was provided in the appropriate cell.

% FGD Solids Check that the percentage of FGD solids generated is provided for all checkboxes 

selected and that this percentage sums to 100% 

Other Confirm that if the plant selected "Other," it is explained in the appropriate cell 

B4-14 If NO is selected, check that the plant skipped to Question B4-16 B4-16 Other Confirm that if the plant selected "Other," it is explained in the appropriate cell B4-17 Other Confirm that if the plant selected "Other," it is explained in the appropriate cell B4-18 Concentrations If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines) For each box that was selected, check that the plant provided the appropriate information. Confirm that if the plant selected "Other," it is explained in the appropriate cell If the plant provided responses in units other than those specified, perform a calculation to convert the value into the specified units (see the General Coding Guidelines) 

Section 4, Tables Wet FGD System Information -- TABLES May have multiple copies to account for multiple wet FGD systems.

Amount Disposed (tons) If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines) 

All Except for the “Other, explain” rows if there is no description provided, all rows should 

be fully completed. Where appropriate, fill all empty cells in these rows with a zero. 

Tons/Gross Revenue Generated ($) If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines) 

All All rows the plant selected a destination for should be fully completed. Where 

appropriate, all empty cells in these rows should be filled in with a zero 

Total Confirm that the sum of the partial costs add up to the total cost for 2005, 2007, and 

2009. 

Other Confirm that if the plant selected "Other," it is explained in the appropriate cell. 

Section 5 FGD Wastewater Generation

FGD System ID Information provided only for operational wet FGD systems (FGD 1-10 that also 

selected "Yes" in the “Does (or Will) the System Generate a FGD Slurry Blowdown...” cells in table B-1).

Percent and Flow Rate If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines) 

Percent For each FGD system confirm that the percentages sum to 100% FGD System ID Information provided only for operational wet FGD systems (FGD 1-10 that also 

selected "Yes" in the “Does (or Will) the System Generate a FGD Slurry Blowdown...” cells in table B-1).

All If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines) 

B5-2/Table B-8 Table B-1B5-1/Table B-7 Table B-1

B4-21/Table B-5B4-22/Table B-6

Parameters

B4-20/Table B-4 Table A-4

B4-13B4-19
Chlorides and TSS concentrations For pollutants checked, confirm that the ppm was provided 

ppm If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines) 

Section 6 FGD Monitoring Data Instructions May have multiple copies to account for multiple FGD scrubber purge streams.

B6-1 If NO is checked, question Section 6 should be skipped 

Any information provided should be for (some/all/none) wet FGD systems reported in Table B-1 (i.e., the plant checked yes in the “Does (or Will) the System Generate a FGD Slurry Blowdown...” column).

Check that the plant has provided information in Table B-1 (FGD 1-10) or in Table A-8 for all checked FGD systems and all checked steam electric units 

Measured Value, Method Detection, Reporting Limit, Flow Rate

If the plant provided responses in units other than those specified, perform a calculation to convert the value into the specified units (see the General Coding Guidelines) 

CAS Number Check that the CAS number has no more than 10 digits and is seperated into 3 parts by 

hypens. 

Measured Value including Units AND Method Detection Limit

Check that the measured value entered is a number greater than or equal to the method detection limit. If the measured value is less than the method detection limit, the method detection limit value preceded by a less than (<) symbol (i.e., <#) should be entered into 

the “Measured Value Including Units” column.

Date Sample Collected Check that the date is provided in the appropriate form (i.e., mm/dd/yyyy) Flow Rate of... Check to see that this flow rate is reasonable by comparing it to the flow rate provided 

in Table B-8 for the appropriate FGD systems. 

Analyzed as Total... Check to make sure one is selected only if a metal analyte is listed. 

Section 7 FGD Wastewater Treatment

B7-1 Table B-1 If NO is checked, the next question answered should be B7-4 

B7-2 Other Confirm that if the plant selected "Other," it is explained in the appropriate cell B7-3 Other Confirm that if the plant selected "Other," it is explained in the appropriate cell B7-4 Other Confirm that if the plant selected "Other," it is explained in the appropriate cell 

Recycled back Description provided on how it is reused. Discharged NPDES permitted outfall number 

Confirm that if the plant selected "Other," it is explained in the appropriate cell If NO is checked, the remainder of Section 7 should be skipped If YES is checked, the volume and frequencey should be entered 

Reused in other processes Description provided on how it is reused. Transferred Checked all that apply and if "Other, explain" is selected, there is an explinatio 

Discharged NPDES permitted outfall number 

Other Confirm that if the plant selected "Other," it is explained in the appropriate cell. 

Section 8 Dry FGD System May have multiple copies to account for multiple dry FGD systems.

B8-1 Table B-1 If NO is checked, the remainder of Part B should not be completed 

All Copied 

Section 8 Tabs

Confirm that the plant completed Section 8 for all dry FGD systems reported in Table B1 (i.e., the plant checked no in the “Does (or Will) the System Generate a FGD Slurry Blowdown...” column). Confirm that the plant wrote the appropriate FGD System ID in the proper form (i.e., FGD-#) at the top of each copied Section 8 tab.

B8-2 Other Confirm that if the plant selected "Other," it is explained in the appropriate cell 

Chlorides conc. and solids % For each box that was selected, check that the plant provided the appropriate 

information. 

ppm or % If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines) 

Other Confirm that if the plant selected "Other," it is explained in the appropriate cell 

B8-5 gpm/hpd/dpy If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines) 

B8-6 Other If "Other" is selected in the "Process Wastewater" dropdown box or if the “Other, 

explain” checkbox was selected confirm that a description was provided in the appropriate cell.

B8-7 If NO is checked, the next question answered should be B8-9 

Reused in other processes Description provided on how it is reused. Transferred Checked all that apply and if "Other, explain" is selected, there is an explinatio 

Discharged NPDES permitted outfall number Other Confirm that if the plant selected "Other," it is explained in the appropriate cell 

If NO is selected, the next question answered should be B8-11 

If YES is checked, the volume and frequencey should be entered 

B8-8 Part A, Section 

2.2

B8-9B7-7 Part A, Section 

2.2

B8-4B7-6

B6-2, Table B-9 Tables A-8 and B1

B7-5 Part A, Section 

2.2

B5-3
Reused in other processes Description provided on how it is reused. 

Transferred Checked all that apply and if "Other, explain" is selected, there is an explinatio 

Discharged NPDES permitted outfall number Other Confirm that if the plant selected "Other," it is explained in the appropriate cell 

Parameters For parameters checked, confirm that the ppm was provided Other Confirm that if the plant selected "Other," it is explained in the appropriate cell Amount Disposed (tons) If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines) 

All All rows the plant selected a destination for should be fully completed. Where 

appropriate, all empty cells in these rows should be filled in with a zero 

Other Checked all that apply and if "Other, explain" is selected, there is an explination Total Confirm that the sum of the partial costs add up to the total cost for 2005, 2007, and 

2009. 

Other Confirm that if the plant selected "Other," it is explained in the appropriate cell. Total Confirm that the sum of the partial costs add up to the total cost for 2005, 2007, and 

2009. 

Other Confirm that if the plant selected "Other," it is explained in the appropriate cell. 

Comments

Entire Section Check that all comments have a question number identified and the comment is 

understandable. 

Entire Section Resolve comments that indicate a change must be made to any electronic response. 

B8-13/Table B11B8-14/Table B12

B8-11

B8-12/Table B10

B8-10 Part A, Section 

2.2
Part C Name Date(s) Reviewed

Reviewer No. 1Reviewer No. 2Status of Review

Questionnaire 

Part/Section/ 

Question 

Number

Copy Number Related Section Type of Information Coding and Review Activity First Reviewer Comments Second Reviewer 

Part C Ash Handling Systems

TOC Ensure that plant name and ID have been populated in the TOC page 

Section 1 Ash Generation 

If NO, check that the plant did not check “Fly ash” or “Bottom ash” for any ponds in Table A-5 If NO, check that the plant did not check “Fly ash” or “Bottom ash” for any landfills in Table A-7 If NO, the remainder of Part C should not be completed; check comments

[Ensure no other answers are completed in Part C 

C1-2 Plant acreage Make sure the Total Plant Area acreage is equal to the sum of all the other acreages 

provided in Table C-1. If NO, check that the plant did not check “Fly ash” for any ponds in Table A-5 If NO, check that the plant did not check “Fly ash” for any landfills in Table A-7 If NO is checked for question C1-3, the remainder of Part C, Section 2 should not be completed.

[Ensure no other answers are completed in Part C, Section 2

Section 2.1 Fly Ash Handling – System Level 

Information

May have multiple copies to account for multiple steam electric generating units.

General Table A-8 Number of Copies Check that there is a copy of section 2.1 for each steam electric generating unit operated 

at any time in 2009 as reported in Table A-8. For each copy of section 2.1 that the respondent creates, copy and paste all the checklist questions for section 2.1 and label the Copy Number appropriately.Note that section 2.1 will not need to be completed for gas or nuclear units and only for a portion of the oil units. If a unit listed in Table A-8 doesn't have an associated worksheet for Section 2.1, check the fuel usage from Table A-11 to make sure that it is agas nuclear or oil fired unit

Only applicable rows need to be completed for the Type of Fly Ash Collection and Type of Fly Ash Handling (i.e., there may be empty rows in these columns). Ensure all other data are complete including OTHER information if appropriate

C1-1 C1-3

Table C-2 Fly ash handling systems operated in 2009.

Generation of ash in any fossil-fueled steam electric generations units located at the plant. Generation of fly ash in any fossil-fueled steam electric generations units located at the

plant.

Table A-5Table A-7Table A-5Table A-7

data are complete including OTHER information if appropriateIf “Wet scrubber(s) (only) is selected, the remainder of Part C, Section 2 should not be completed.[Ensure no other answers are completed in Part C, Section 2

Check that the “typical amount of fly ash produced in 2009” is less than or equal to the “design ash handling rate” (both tpd and dpy). 

C2-2 Wet fly ash handling C2-3 through C2-5 should only be answered if C2-2 is answered "Yes". If "Yes is 

marked, all fields should be populated 

Ensure all data are complete including OTHER information if appropriate Check that "Percent Contribution of Source to Sluice Water Flow" values sum to 100% 

C2-3 Maximum Chloride Concentration and 

Maximum Solids Percentage

Check that corresponding fields are completed for each box checked. 

C2-4 POTW Check that if "Yes" is selected, a description is provided. C2-5 POTW Ensure an answer is selected. C2-6 Wet Vacuum System (pneumatic) Check that if "Yes" is selected, questions C2-7 and C2-8 are answered, otherwise ensure

respondent skipped to C2-9. 

Check that corresponding fields are completed for each box checked If respondent checks "Discharged to surface water", check that NPDES permitted outfal

number provided matches one of the copies of Part A section 2.2 Check that corresponding fields are completed for each Storage Destination selected. Check that "Percent of Dry Conveyed Fly Ash to this Destination" values sum to 100% Check that "Percent of Wet Conveyed Fly Ash to this Destination" values sum to 100% 

Process Wastewater Generated from Wet Fly Ash Handling in 2009

Table C-4 Storage Destinations that Receive Fly Ash

C2-8 Wet Vacuum System (pneumatic)

Table C-3
C2-10 Fly ash handled by both wet and dry fly ash 

handling systems.

Check that if "Yes" is selected, questions C2-11 and C2-12 are answered. Otherwise respondent should skip to C2-13. 

For each reason that is checked, make sure the number of days is provided Check that the sum of the "days" fields do not sum to greater than 365 If “Design/develop new infrastructure...” is selected, make sure that the respondent specifies the new infrastructure needed If “other” is selected, make sure that the respondent provides an explanation If “Decreased use...” is selected, make sure that the respondent provides the expected operating days. If “End use...” is selected, make sure that the respondent provides the expected end date. If “other” is selected, make sure that the respondent provides an explanation If either "NA" or "No" is selected, make sure that the respondent skips to question C2-17. If "Yes" is selected, make sure that the respondent has answered the remainder of 

question C2-14 and C2-15. If “The retrofit was made to an existing dry system” is checked for question C2-15, respondent should continue answering questions starting with C2-23 

If “A dry fly ash handling system was installed (for operation in addition to the wet fly ash handling system)” or “The retrofit was a complete conversion from a wet to dry fly ash handling system” is checked for question C2-15, question C2-16 should be 

completed.

C2-16 Changes required for installed retrofit Check that corresponding fields, where applicable, are completed for each checkbox tha

is selected. 

If "Yes" is selected, make sure that the respondent has entered a value for "Estimated shutdown time (days) required to bring dry fly ash handling system online" and skipped to Question C2-19.

If "No" is selected, make sure that the respondent continued to Question C2-18 

If "Yes" is selected, make sure that the respondent has entered a value for "Estimated shutdown time (days) required to bring dry fly ash handling system online" and continued to Question C2-19.If "No" is selected, make sure that the respondent skipped to Question C2-22 If YES is checked and “I have attached...” are checked, make sure the documentation/costs are provided 

If YES is checked and “I did not attach...” are checked, make sure that the respondent 

provides an explanation. 

If NO is checked, the remainder of Question C2-19 should be blank and the respondent should skip to Question C2-22 

C2-20 Changes that will be required for planned 

retrofit

Check that corresponding fields, where applicable, are completed for each checkbox thais selected. 

If “Marketed, sold...” and “If other, specify” are selected, make sure treatment system iidentified. Make sure that the “% of the dry fly ash” is provided for each dropdown completed and 

hb l d 

C2-15 Fly ash handling installed as retrofit.C2-17 In the process of installing dry fly ash 

handling

C2-18 Plan to install dry fly ash handling by 

December 31, 2020.

C2-19 Provide cost estimates for 

conversion/installation

C2-21 Expected destinations for dry fly ash

Changes in fly ash handling expected.

C2-14 Fly ash handling installed as retrofit.C2-13

Reason fly ash was handled wet and dry.

C2-12 Modifications required to handle all ash dry.C2-11

each box selected. If “Other” is selected, make sure that the respondent provides an explanation 

If YES is checked and “I have attached...” are checked, make sure the documentation/costs are provided 

Make sure that if YES is checked and “I did not attach...” are checked, make sure that the respondent provides an explanation 

If NO is checked, the remainder of Question C2-22 should be blank 

If NO is checked for question C2-23, Table C-5 should be blank. Respondent should continue answering questions starting with C2-25 

If YES is checked for question C2-29, Table C-5 should be complete. 

C2-24 Unscheduled generating unit outages due to 

the wet fly ash handling systems in the last 5 

years.

Check that any row that has a value listed for the "Total Days of Outage" has explanations for the "Reason(s) for outage(s)" and "Method(s) Used to Resolve Outage(s)" fields.

Section 2.2 Fly Ash Handling – Storage and Use Data

Check that Table C-6 has destination information for each storage destination listed in Table C-4. Check all copies of Table C-4. If Table C-4 contains only destinations marked “intermediate” and Table C-6 does not contain any other destinations, follow up is required. If Table C-6 does not contain “final” destinations (i.e., ponds, landfills in Table A-6, landfills not in Table A-6, marketed, or other with description of a final destination) follow up is required.

Only applicable rows need to be completed (i.e., Storage Destination 2 row may be empty). 

Unscheduled generating unit outages due to the wet fly ash handling systems in the last 5 

years.

C2-22 Consideration of dry fly ash system.C2-23 Table C-5

Table C-6 Table C-4 Dry fly ash storage destination information.
Check that the sum of Wet & Dry Conveyed tpd multiplied by the dpy, from all the 

copies of Table C-2, is generally less than or equal to the sum of the Tons of Fly Ash Transported to Destination in 2009 in Table C-6.

If “other” is selected in any of the dropdowns in the “Type of destination” column, mak

sure that the respondent provides an explanation for each “other” option selected. If NO is checked for question C2-26, Table C-7 should be blank. Respondent should continue answering questions starting with C2-28 

If YES is checked for question C2-26, Table C-7 should be complete. 

Confirm that Table C-7 contains all destinations required in Table C-4. Check that if the box next to either of the process wastewaters dropdowns is checked, the appropriate dropdown is completed. If “Other” is selected in either dropdown, make sure that the respondent provides an explanation in the appropriate free response box. If chlorides concentration is selected, makes sure a ppm value is provided.If Solids percentage is selected, makes sure a percentage is provided. If “Other” is selected, make sure that the respondent provides an explanation.

C2-27 Criteria for water used to moisten ash Check that the respondent properly defined the criteria used to determine if a water

source is unacceptable for use to moisten ash 

If NO is checked for question C2-28, Table C-8 should be blank. Respondent should continue answering questions starting with C2-29 

If YES is checked for question C2-28, Table C-8 should be complete. 

Table C-8 Marketing of fly ash from dry ash handling 

system

Only applicable rows need to be completed (i.e., some rows may be empty). Ensure that if C2-27 is YES, respondent has provided at least one row of data 

If NO is checked for question C2-29, Table C-9 should be blank. Respondent should skip to Section 2.3. If YES is checked for question C2-29, Table C-9 should be complete. 

Table C-9 Marketing of fly ash from wet ash handling 

system

Only applicable rows need to be completed (i.e., some rows may be empty). Ensure that if C2-29 is YES, respondent has provided at least one row of data 

Section 2.3 Fly Ash Cost Information – Conveyance May have multiple copies to account for multiple fly ash handling systems. 

Despite no specific kickout question, this section will be blank for the majority of plants because their conveyance system did not "begin operating or was converted 

after January 1, 2000."

General C2-17

C2-18

Installing or planning to install dry fly ash handling system

For each copy of questions C2-17 or C2-18 that are answered "Yes", check that one of the copies of section 2.3 has the checkbox associated with "Planned" marked and the 

appropriate fields populated

C2-29 Marketing of fly ash from wet ash handling 

system

C2-26 Table C-4 Is water used to moisten the fly ash?

Marketing of fly ash from dry ash handling system

Table C-7 Table C-4 Fly ash handling systems operated in 2009.

C2-28

appropriate fields populated.

General Comments Multiple units using the same fly ash 

handling system

Check the comments section related to section 2.3 to see if the plant has multiple units utilizing the same ash handling system. If that is the case, flag for follow-up to ensure that the situation is properly represented in our database for modeling purposes. Additionally, ensure that the respondent only listed the shared components on one copy 

of Section 2.3

If “Other” is selected for Type of Component, make sure that the respondent provides an explanation. If “Other” is selected for the units for Total System Capacity of Component, make sure that the respondent provides an explanation. Check that there is a value for Number of Components in the System and Total System Capacity of Component for each Type of Component specified. 

C2-31 Fly ash handling 

diagram 

attachment

Fly ash handling diagram attachment If YES is checked and “I have attached...” are checked, make sure the 

documentation/costs are provided. Check that all fields have a value (some may be $0) and make sure that all values make logical sense (i.e. the year on which the modification cost is based is >= 2000) Check that if components are listed in C2-32 or C2-33 that "Other Contractor's Fees" or "Engineering Costs" have values greater than $0 

C2-35 Major conveyance components If "No" is checked, make sure the respondent provided explanations of what system 

components are and are not included 

Table C-12 O&M Cost for Conveyance of Fly Ash 

Handling for 2009

Check that all fields have a value (some may be $0) and make sure that all values make logical sense 

Table C-10 Table C-4 Fly ash system components - conveyance

Capital cost for conveyance of fly ash handling

Table C-11 C2-32

C2-33
Section 2.4 Fly Ash Cost Information – Intermediate 

Storage

May have multiple copies to account for intermediate fly ash storage systems.Despite no specific kickout question, this section will be blank for the majority of plants because their intermediate fly ash storage systems did not "begin operating 

or was modified after January 1, 2000."

General C2-17

C2-18

Installing or planning to install dry fly ash handling system

Check that if questions C2-17 or C2-18 are answered "Yes", check that one of the copies of section 2.4 has the checkbox associated with "Planned" marked and the appropriate fields populated.

C2-37 Bottom and fly ash shared storage If "Yes" is checked, verify the unit IDs are populated and consistent with Table A-8 

If YES is checked for question C2-38, Table C-13 should be blank. Respondent should skip to Section 2.5. If “Yes”, confirm that the storage ID is for a pond/impoundment listed in Table A-4. If NO is checked for question C2-38, Table C-13 should be complete. If “Other” is selected for Type of Component, make sure that the respondent provides an explanation. If “Other” is selected for the units for Total System Capacity of Component, make sure that the respondent provides an explanation. Check that there is a value for Number of Components in the System and Total System Capacity of Component for each Type of Component specified. Check that all fields have a value (some may be $0) and make sure that all values make logical sense (i.e. the year on which the modification cost is based is >= 2000) Check that if components are listed in C2-40 or C2-41 that "Other Contractor's Fees" or "Engineering Costs" have values greater than $0 

C2-43 Major intermediate storage components If "No" is checked, make sure the respondent provided explanations of what system 

components are and are not included 

Table C-15 O&M Cost for Intermediate Storage of Fly 

Ash Handling for 2009

Check that all fields have a value (some may be $0) and make sure that all values make logical sense 

Section 2.5 Fly Ash Cost Information – Transport 

and Disposal

Despite no specific kickout question, this section will be blank for the majority of plants because their transport/disposal systems did not "begin operating or was modified after January 1, 2000."

C2-45 Bottom and fly ash shared transport and 

disposal

If "Yes" is checked, verify the unit IDs are populated and consistent with Table A-8 If YES is checked for question C2-46, confirm that a pond/impoundment is included in Table C-6. The remainder of section 2.5 should be blank. Respondent should skip to Section 3.1.If NO is checked for question C2-46, respondent should proceed to C2-47. 

Check that the respondent has identified at least one method of transportation Check that the respondent has identified the number of units for each method of transportation selected. 

C2-47 Method of transportation to final destinationC2-38 Table A-4 Storage destination pond/impoundment?

Table C-13 Fly ash system components - intermediate 

storage

Table C-14 C2-40

C2-41

Capital cost for intermediate storage of fly ash handling

C2-46 Table C-6 Is a pond/impoundment the final destination?

transportation selected.Check that the respondent has identified whether the units are bought, leased, or contracted out for each method of transportation selected 

Check that all fields have a value (some may be $0) and make sure that all values make logical sense (i.e. the year on which the modification cost is based is >= 2000) Check that if components are listed in C2-48 or C2-49 that "Other Contractor's Fees" or "Engineering Costs" have values greater than $0 

C2-51 Major transportation components If "No" is checked, make sure the respondent provided explanations of what system 

components are and are not included 

Table C-17 O&M Cost for Transportation of Fly Ash 

collection for 2009

Check that all fields have a value (some may be $0) and make sure that all values make logical sense 

Section 3.1 Bottom Ash Handling – Generating Unit 

Level Information

May have multiple copies to account for multiple steam electric generating units.

General Table A-8 Number of Copies Check that there is a copy of section 3.1 for each steam electric generating unit operated 

at any time in 2009 as reported in Table A-8. For each copy of section 3.1 that the respondent creates, copy and paste all the checklist questions for section 3.1 and label the Copy Number appropriately

If NO is checked for question C3-1, check that the plant did not check “Bottom ash” foany ponds in Table A-5 If NO is checked for question C3-1, check that the plant did not check “Bottom ash” foany landfills in Table A-7 If NO is checked for question C3-1, the remainder of Part C, Section 3 should not be completed.

[Ensure no other answers are completed in Part C, Section 3

C3-1 Table A-5

Table A-7

Generation of bottom ash in any fossil-fueled

steam electric generations units located at theplant.

C2-48C2-49

Capital cost for transportation of fly ash collection

Table C-16
Only applicable rows need to be completed for the Type of Fly Ash Collection and Type 

of Fly Ash Handling (i.e., there may be empty rows in these columns). Ensure that the respondent has selected at least one "Type of Bottom Ash Handling System" and all other data are complete including OTHER information if appropriate.Check that the “typical amount of fly ash produced in 2009” is less than or equal to the “design ash handling rate” (both tpd and dpy). If NO is checked for question C3-3, confirm that “wet sluicing” was not selected in Table C-18. If NO is checked for question C3-3, the respondent should skip to C3-11. If YES is checked for question C3-3, the respondent should complete Table C-19. Check that the respondent entered values for the "Average Sluice Water Flow Rate" and "Typical Duration AND Frequency of Sluicing" 

Each "Source of Sluice Water" selected should have an associated value in the "Percent Contribution of Source to Sluice Water Flow" column Check that "Percent Contribution of Source to Sluice Water Flow" values sum to 100% 

C3-4 Maximum Chloride Concentration and 

Maximum Solids Percentage

Check that corresponding fields are completed for each box checked. 

C3-5 Wet bottom ash sluice immediately recycled?If YES is checked for question C3-5, the respondent should enter a description of how 

the wet bottom ash sluice is used 

C3-6 POTW Check that the respondent selected YES or NO 

If NO is checked for question C3-7, the respondent should skip to C3-11. If YES is checked for question C3-7, the respondent should complete Table C-20. Check that the respondent checked at least one box for the "Solids Removal" and "Bottom Ash Disposal". Check that a description is provided if the respondent checks "other" for the "Solids Removal" and "Bottom Ash Disposal" 

Check that "Amount of Solids Disposed" and "Typical Percent Moisture of Bottom Ash Disposed" values have been entered for each "Bottom Ash Disposal" destination selected. 

C3-9 Amount of water overflow from solid 

removal

Check that value is entered by respondent 

C3-10 Destination of waste water overflow from 

solid removal

If respondent checks "Discharged to surface water", check that NPDES permitted outfalnumber provided matches one of the copies of Part A section 2.2 If NO is checked for question C3-11, the respondent should skip to C3-15. If YES is checked for question C3 11 check that the respondent provided a description

Table C-18 Bottom ash handling systems operated in 

2009 by generating unit.

C3-3 Wet sluicing used to collect bottom ash?

Table C-19 Process Wastewater Generated from Wet Fly 

Ash Handling in 2009

C3-7 Solid removal occur at the plant?

Table C-20 Wet ash sluice systems

C3-11 Mechanical drag system?

If YES is checked for question C3-11, check that the respondent provided a descriptionof the process. 

C3-12 Mechanical drag system? If NO is checked for question C3-12, the respondent should skip to C3-15. C3-13 Amount of water overflow from mechanical 

drag system

Check that value is entered by respondent 

C3-14 Destination of waste water overflow from 

mechanical drag system

If respondent checks "Discharged to surface water", check that NPDES permitted outfalnumber provided matches one of the copies of Part A section 2.2 Check that corresponding fields are completed for each Storage Destination selected. Check that "Percent of Dry Conveyed FlyAsh to this Destination" values sum to 100% 

Check that "Percent of Wet Conveyed FlyAsh to this Destination" values sum to 100% 

C3-16 Bottom ash handled by both wet and dry fly 

ash handling systems.

Check that if "Yes" is selected, questions C3-17 and C3-18 are answered. For each reason that is checked, make sure the number of days is provided 

Check that the sum of the "days" fields do not sum to greater than 365 If “Design/develop new infrastructure...” is selected, make sure that the respondent specifies the new infrastructure needed If “other” is selected, make sure that the respondent provides an explanation If “Decreased use...” is selected, make sure that the respondent provides the expected operating days. If “End use...” is selected, make sure that the respondent provides the expected end date. If “other” is selected, make sure that the respondent provides an explanation 

Table C-21 Storage Destinations that Receive Fly Ash

C3-17 Reason bottom ash was handled wet and dry.C3-18 Modifications required to handle all bottom 

ash dry.

C3-19 Changes in bottom ash handling expected.
If either "NA" or "No" is selected, make sure that the respondent skips to question C3-

24. If "Yes" is selected, make sure that the respondent has answered the remainder of question C3-20 and continues to C3-21. 

If “The retrofit was made to an existing dry system” is checked for question C3-29, respondent should continue answering questions starting with C2-23 If “A dry fly ash handling system was installed (for operation in addition to the wet fly ash handling system)” or “The retrofit was a complete conversion from a wet to dry fly ash handling system” is checked for question C3-21, respondent should continue to C3-

22.

C3-22 Changes required for installed retrofit Check that corresponding fields, where applicable, are completed for each checkbox tha

is selected. 

C3-23 Dry bottom ash 

handling retrofit diagram attachment

Dry bottom ash handling retrofit diagram attachment

If “Diagram attached” is checked, make sure the documentation/costs are provided.If "Yes" is selected, make sure that the respondent has entered a value for "Estimated shutdown time (days) required to bring dry fly ash handling system online" and skipped to Question C3-26.

If “Yes” to C3-24 confirm that Section 3.3 and 3.4 are completed for the SE Unit. 

If "No" is selected, make sure that the respondent continued to Question C3-25 If "Yes" is selected, make sure that the respondent has entered a value for "Estimated shutdown time (days) required to bring dry bottom ash handling system online" and continued to Question C3-26.If “Yes” to C3-25 confirm that Section 3.3 and 3.4 are completed for the SE Unit. If "No" is selected, make sure that the respondent skipped to Question C3-29 If YES is checked and “I have attached...” are checked, make sure the documentation/costs are provided 

If YES is checked and “I did not attach...” are checked, make sure that the respondent 

provides an explanation. 

If NO is checked, the remainder of Question C3-26 should be blank and the respondent should skip to Question C3-29. 

C3-27 Changes required for installed retrofit Check that corresponding fields, where applicable, are completed for each checkbox tha

is selected. 

If “Marketed, sold...” and “If other, specify” are selected, make sure treatment system iidentified. Make sure that the “% of the dry bottom ash” is provided for each dropdown completed and each box selected. If “Other” is selected, make sure that the respondent provides an explanation If YES is checked and “I have attached...” are checked, make sure the 

documentation/costs are provided 

C3-20 Bottom ash handling installed as retrofit.C3-21 Bottom ash handling installed as retrofit.C3-24 In the process of installing dry bottom ash 

handling

C3-25 Plan to install dry bottom ash handling.C3-28 Expected destinations for dry bottom ashC3-26 Provide cost estimates for 

conversion/installation

C3-29 Consideration of dry bottom ash system.

documentation/costs are providedMake sure that if YES is checked and “I did not attach...” are checked, make sure that the respondent provides an explanation 

If NO is checked, the remainder of Question C3-29 should be blank 

If NO is checked for question C3-30, Table C-22 should be blank. Respondent should skip to section 3.2. 

If YES is checked for question C3-30, Table C-22 should be complete. 

Table C-22 Unscheduled generating unit outages due to 

the wet bottom ash handling systems in the last 5 years.

Check that any row that has a value listed for the "Total Days of Outage" has explanations for the "Reason(s) for outage(s)" and "Method(s) Used to Resolve Outage(s)" fields.

Section 3.2 Bottom Ash Handling - Storing and Use 

Data

Confirm that Table C-23 contains ALL storage destinations and not just the initial storage destinations listed in Table C-21. Check all copies of Table C-21. If Table C-21 contains only destinations marked “intermediate” and Table C-23 does not contain any other destinations, follow up is required. If Table C-23 does not contain “final” destinations (i.e., ponds, landfills in Table A-6, landfills not in Table A-6, marketed, or other with description of a final destination) follow up is required.

Only applicable rows need to be completed (i.e., Storage Destination 2 row may be empty). Check that the sum of Wet & Dry Conveyed tpd multiplied by the dpy, from all the copies of Table C-18, is less than or equal to the sum of the Tons of Bottom Ash Transported to Destination in 2009 in Table C-23.If “other” is selected in any of the dropdowns in the “Type of destination” column, mak

sure that the respondent provides an explanation for each “other” option selected. 

C3-30 Table C-5 Unscheduled generating unit outages due to 

the wet bottom ash handling systems in the last 5 years.

Table C-23 Table C-18

Table C-21

Bottom ash storage destination information.
If NO is checked for question C3-33, Table C-24 should be blank. Respondent should 

continue answering questions starting with C3-34 

If YES is checked for question C3-33, Table C-24 should be complete. 

Table C-24 Marketing of bottom ash from dry ash Only applicable rows need to be completed (i.e., some rows may be empty 

If NO is checked for question C3-34, Table C-25 should be blank. Respondent should skip to section 3.3. 

If YES is checked for question C3-34, Table C-25 should be complete. 

Table C-25 Marketing of bottom ash from wet ash 

handling system

Only applicable rows need to be completed (i.e., some rows may be empty). Ensure that if C3-34 is YES, respondent has provided at least one row of data 

Section 3.3 Bottom Ash Handling - Conveyance May have multiple copies to account for multiple bottom ash handling systems. 

Despite no specific kickout question, this section will be blank for the majority of plants because their conveyance system did not "begin operating or was converted 

after January 1, 2000."

General C3-24

C2-25

Installing or planning to install dry bottom ash handling system

For each copy of questions C3-24 or C3-25 that are answered "Yes", check that one of the copies of section 3.3 has the checkbox associated with "Planned" marked and the appropriate fields populated.

General Comments Multiple units using the same bottom ash 

handling system

Check the comments section related to section 3.3 to see if the plant has multiple units utilizing the same bottom ash handling system. If that is the case, flag for follow-up to ensure that the situation is properly represented in our database for modeling purposes. Additionally, ensure that the respondent only listed the shared components on one copy 

of Section 3.3

If “Other” is selected for Type of Component, make sure that the respondent provides an explanation. If “Other” is selected for the units for Total System Capacity of Component, make sure that the respondent provides an explanation. Check that there is a value for Number of Components in the System and Total System Capacity of Component for each Type of Component specified. 

C3-36 Bottom ash 

handling diagram 

attachment

Bottom ash handling diagram attachment If “Diagram attached” is checked, make sure the document is provided. 

Check that all fields have a value (some may be $0) and make sure that all values make logical sense (i.e. the year on which the modification cost is based is >= 2000) Check that if components are listed in C3-37 or C3-38 that "Other Contractor's Fees" or "Engineering Costs" have values greater than $0 

C3-40 Major conveyance components If "No" is checked, make sure the respondent provided explanations of what system 

components are and are not included 

Table C-28 O&M Cost for Conveyance of Bottom Ash 

Handling for 2009

Check that all fields have a value (some may be $0) and make sure that all values make logical sense 

Section 3.4 Bottom Ash Handling - Intermediate May have multiple copies to account for intermediate bottom ash storage systems.

C3-33 Marketing of bottom ash from dry ash 

handling system

C3-34 Marketing of bottom ash from wet ash 

handling system

Table C-26 Table C-4 Bottom ash system components - conveyanceTable C-27 C3-37

C3-38

Capital cost for conveyance of bottom ash handling

Section 3.4 Bottom Ash Handling Intermediate

Storage

May have multiple copies to account for intermediate bottom ash storage systems.Despite no specific kickout question, this section will be blank for the majority of plants because their intermediate fly ash storage systems did not "begin operating or was modified after January 1, 2000."

General C3-24

C2-25

Installing or planning to install dry bottom ash handling system

For each copy of questions C3-24 or C3-25 that are answered "Yes", check that one of the copies of section 3.4 has the checkbox associated with "Planned" marked and the appropriate fields populated.

C3-42 Table A-8

Part C, Section 

2.4

Bottom and fly ash shared storage If “Yes” to C3-42, verify the unit IDs are populated and consistent with Table A-8 and 

confirm that Section 2.4 was completed for the same Storage ID. The respondent should

then skip to section 3.5.

If YES is checked for question C3-43, Table C-29 should be blank. Respondent should skip to Section 4. If “Yes”, confirm that the storage ID is for a pond/impoundment listed in Table A-4. If NO is checked for question C3-43, Table C-29 should be complete. If “Other” is selected for Type of Component, make sure that the respondent provides an explanation. If “Other” is selected for the units for Total System Capacity of Component, make sure that the respondent provides an explanation. Check that there is a value for Number of Components in the System and Total System Capacity of Component for each Type of Component specified. Check that all fields have a value (some may be $0) and make sure that all values make logical sense (i.e. the year on which the modification cost is based is >= 2000) 

C3-43 Table A-4 Storage destination pond/impoundment?

Table C-29 Bottom ash system components - 

intermediate storage

Table C-30 C3-45

C3-46

Capital cost for intermediate storage of bottom ash handling
Check that if components are listed in C3-45 or C3-46 that "Other Contractor's Fees" or 

"Engineering Costs" have values greater than $0 

C3-48 Major intermediate storage components If "No" is checked, make sure the respondent provided explanations of what system 

components are and are not included 

Table C-31 O&M Cost for Intermediate Storage of 

Bottom Ash Handling for 2009

Check that all fields have a value (some may be $0) and make sure that all values make logical sense 

Section 3.5 Bottom Ash Handling - 

Transport/Disposal

Despite no specific kickout question, this section will be blank for the majority of plants because their transport/disposal systems did not "begin operating or was modified after January 1, 2000."

C3-50 Bottom and fly ash shared transport and 

disposal

If "Yes" is checked, verify the unit IDs are populated and consistent with Table A-8. Also check that the respondent checked "Yes" for question C2-45 

If YES, confirm that a pond/impoundment is included in Table C-23. The remainder of section 3.5 should be blank. Respondent should skip to Section 4 If NO, respondent should proceed to C3-52. 

Check that the respondent has identified at least one method of transportation 

Check that the respondent has identified the number of units for each method of transportation selected. Check that the respondent has identified whether the units are bought, leased, or contracted out for each method of transportation selected Check that all fields have a value (some may be $0) and make sure that all values make logical sense (i.e. the year on which the modification cost is based is >= 2000) Check that if components are listed in C3-53 or C3-54 that "Other Contractor's Fees" or "Engineering Costs" have values greater than $0 

C3-56 Major transportation components If "No" is checked, make sure the respondent provided explanations of what system 

components are and are not included 

Table C-33 O&M Cost for Transportation of Bottom 

Ash collection for 2009

Check that all fields have a value (some may be $0) and make sure that all values make logical sense 

Section 4 Economizer Ash Handling

General Table A-8 Verify the unit IDs are populated and consistent with Table A-8 for each copy of section 

4. 

C4-1 Part C, Section 5 Economizer has collected with air heater 

ash?

If “No” to C4-1, confirm that Section 5 is completed. If not, review comments to determine if follow up is required 

C4-2 Method of handling economizer ash If "Segregated from fly and bottom ash" is selected, check that description is provided 

and C4-3 is blank. 

C4-3 Method of combining economizer ash with 

fly and bottom ash

Check that "Combined with fly and bottom ash" is selected in C4-2 and that a description is provided if "other" is selected 

C4-4 Amount of economizer ash produced Check that respondent has entered reasonable values C4-5 Process wastewater generated from 

economizer ash handling

If “No” to C4-5, confirm that question C4-6 was completed. If not, follow up may be required. 

Check that a percent value is entered for each final destination selected Check that "% of economizer ash" values sum to 100% 

Section 5 Economizer Ash Handling

Final destination of economizer ash

C3-51 Table C-23 Is a pond/impoundment the final destination?C3-52 Method of transportation to final destination

Table C-32 C3-53

C3-54

Capital cost for transportation of bottom ash collection

C4-6

g

General Table A-8 Verify the unit IDs are populated and consistent with Table A-8 for each copy of section 

5. 

C5-1 Method of handling air heater ash If "Segregated from fly and bottom ash" is selected, check that description is provided 

and C5-2 is blank. 

C5-2 Method of combining air heater ash with fly 

and bottom ash

Check that "Combined with fly and bottom ash" is selected in C5-1 and that a description is provided if "other" is selected 

C5-3 Amount of air heater ash produced Check that respondent has entered reasonable values C5-4 Process wastewater generated from air heater

ash handling

If “No” to C5-4, confirm that question C5-5 was not completed. If not, follow up may be required. 

Check that a percent value is entered for each final destination selected Check that "% of air heater ash" values sum to 100% 

Comments

Entire Section Check that all comments have a question number identified and the comment is 

understandable. 

Entire Section Resolve comments that indicate a change must be made to any electronic response. 

C5-5 Final destination of air heater ash
Part D Name Date(s) Reviewed

Reviewer No. 1Reviewer No. 2Status of Review

Questionnaire 

Part/Section/ 

Question 

Number

Copy Number Related Section Type of Information Coding and Review Activity First Reviewer Comments Second Reviewer Comme

Part D Steam Electric Plant Operations

TOC Ensure that plant name and ID have been populated in the TOC page 

Section 1 Plant Pond/Impoundment Systems and Wastewater Treatment Systems 

D1-1 and D1-2 Pond/impoundment systems and wastewater 

treatment systems located at the plant. 

If YES to at least one question, respondent should have completed the remainder of Part D.If NO for both questions, respondent should not have completed Part D of the questionnaire. Ensure no other answers are completed in Part D; technical review is 

complete.If NO to D1-1, confirm that respondent answered "No" to A3-1.

Section 2 Pond/Impoundment System and 

Wastewater Treatment System Identification

D2-1 Plant involvement with ash or FGD 

wastewater treatment full- or pilot-scale studies.

If NO, questions D2-2 and D2-3 should be skipped. Question D2-4 should be answered. 

D2-3 Plant involvement with ash or FGD 

wastewater treatment full- or pilot-scale studies.

If YES, make sure a copy of the summary/report is attached. Make sure that descriptions cover ash or FGD wastewater treatment technologies.Flag any potentially interesting studies.If NO, make sure an explanation of the study is provided in the free response cell. Make sure that descriptions only cover ash or FGD wastewater treatment technologies.

D2-4 Plant involvement with ash or FGD 

wastewater treatment studies, including 

bench-scale.

Make sure that the response to question D2-4 only covers studies not accounted for in previous questions and that the technologies listed are for ash or FGD wastewater treatment. If YES, both or one of Tables D-1 and D-2 should be completed. Respondent should also complete Section 3.If NO, the remainder of Section 2 and all of Section 3 should not be completed. The respondent should skip to Section 4.1. Ensure no answers are provided in Part D Sections 2 and 3. Confirm that D1-2 is "NO".If there are ponds/impoundments listed in Table A-4 that contain coal combustion byproducts, respondents should answer "YES" to this question 

If the respondent indicates that the FGD scrubber purge or gypsum wastewater is sent to a settling pond in Part B Section 7 or Question B4-16, respondents should answer "YES" to this question and include those ponds in Table D-1

D2-6 Table A-4 Plant Pond/Impoundment System 

Identification

If YES, Table D-1 should be complete. Check that the “Individual Ponds/Impoundments” column matches the information provided in Table A-4.If NO, Table D-1 should be blank.[Table D-1. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-1).]

D2-5 Table A-4; Part B 

Question 4-16; 

Part B Section 7 

(QB7-1 through 

B7-3)

Plant operation of any systems for the treatment of process wastewaters from ash handling or FGD operations.
If YES, Table D-2 should be complete. Check that the information provided matches 

any footprints or diagrams the plant provides along with the questionnaire.If NO, Table D-2 should be blank and Table D-1 should be complete. Confirm that D1-2 is "NO".[Table D-2. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-2).]If the respondent indicates that the FGD scrubber purge or gypsum wastewater is sent to a wastewater treatment system in Part B Section 7 or Question B4-16, respondents should answer "YES" to this question and include those systems in Table D-2. 

Section 3.1

Wastewater Treatment Diagram

May have multiple copies to account for multiple pond/impoundment system or wastewater treatment system IDs.

Check that the plant attached a block diagram(s). Note that there may be multiple diagrams. If not, check comments tab for explanation 

Check that the diagram(s) includes all information identified in the “Block Diagram Checklist” on pages D-7 through D-10 

Tables D-1/D-2 Check that the diagram(s) includes all pond/impoundment systems and wastewater 

treatment systems identified in Table D-1 and/or Table D-2 

Tables A-4/B-1/B2 Check that the diagram(s) use EPA-assigned numbers from Part A or B (e.g., FGD-1) and that they are used correctly, if applicable. 

Tables D-3/D-4 Check that the flow rates provided in the diagram(s) match those provided in Tables D3 and D-4 within a reasonable amount. 

Table D-11 Check that the diagram(s) includes all wastewater treatment units identified in Table D11. 

Codes Tables Check that the diagram(s) identifies process operations and wastewater treatment 

systems using appropriate codes. 

Tables A-5/C-3/C19/B-8 Check that the flow rates provided in the diagram(s) are balanced and generally make sense. Bottom ash, fly ash, and scrubber purge influent flow rates can be checked in 

Tables C-3, C-19, and B-8. Also check against Table A-5 for process wastewaters entering the pond/impoundment

Section 3.2 Wastewater Treatment Wastewater 

Flows

May have multiple copies to account for multiple pond/impoundment system or wastewater treatment system IDs.

Check that all influents in Table D-3 correspond to block diagram(s) with the same System ID submitted by the plant 

Check that only influents are included in Table D-3 

Table D-4 Check that the influents correspond to the same System ID effluents in Table D-4. 

Check that the influent flow rates provided generally make sense. For example, corresponding gpm, hpd, and dpy values match the information provided in the diagram(s). Bottom ash, fly ash, and scrubber purge influent flow rates can be checkein Tables C-3, C-19, and B-8.Check that the plants properly identify the process or treated wastewater and that influents correspond to diagram attached in D3-1 Table D-3. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-3). 

Check that all effluents in Table D-4 correspond to block diagram(s) with the same System ID submitted by the plant 

Check that only effluents are included in Table D-4 

Table D-3 Check that the effluents correspond to the same System ID influents in Table D-3. 

Check that units are selected for the amount of solids/sludge, if applicabl Check that the effluent flow rates provided generally make sense. For example, corresponding gpm, hpd, and dpy values match the information provided in the diagram(s) submitted by the plantCheck that the plants properly identified the treated wastewater and final destination and that effluents correspond to diagram attached in D3-1 Table D-4. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-4). 

Section 4.1 Active/Inactive/Open and Planned Pond/Impoundment Unit Information May have multiple copies to account for multiple pond(s)/impoundment(s) reported in Table A-4.

Diagram RequestPond/impoundment system or wastewater treatment system influent flows 

D3-2

Pond/impoundment system or wastewater treatment system effluent flows

D3-3D3-1D2-7 Plant Wastewater Treatment System 

Identification

Question B4-16; 

Part B Section 7
D4-1 Table A-4 The use or planned use of any 

active/inactive/open ponds/impoundments for the storage, treatment, and/or disposal of process wastewater, residues or by-products from the combustion of coal, pet-coke, or oil.

Question D4-1 should be answered regardless of the response to question D2-5. If YES, Section 4.1 should be completed for every active/inactive/open pond/impoundment unit identified in Table A-4. If NO, Section 4.1 should be skipped. Check to make sure no ponds are listed in Table A-4. Ensure no answers are provided for Part D Section 4.2.

D4-2 Residence time, life, and number of cells of 

the pond/impoundment uni

Make sure that the number of cells for the pond/impoundment unit matches the block diagram(s) submitted by the plant, if applicable. 

D4-3 Volume, surface area, bottom and top 

elevation, freeboard height, maximum heigh

of the berms/dams, total amount of solids placed, and expected year of closure/retirement of the pond/impoundment unit when it was originally built, at its current status, and at its expected end of life.

Make sure that responses logically make sense. For example, all height and elevation responses should correspond to one another; total solids placed in the pond should increase from current to end of life status.Reminder: Operating capacity = Free water + Added solids

D4-4 Does the pond/impoundment unit have a 

liner?

If YES, Table D-6 should be complete.If NO, skip to question D4-5. Table D-6 should not be completed.If NA, skip to question D4-10. [Table D-6. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-6).]

D4-5 Has the pond/impoundment unit ever been 

dredged?

If YES, the following fill in the blanks should be complete. If NO, skip to question D4-7.If NA, skip to question D4-10. Make sure that answers logically make sense. For example, if the last year of dredging was 2000, no answers should be provided for the responses required for the last 5 years. 

D4-6 Transfer location of dredged solids If “other” is checked, make sure that the respondent provides an explanation 

D4-7 Pond/Impoundment unit expansion. If YES, questions D4-8 and D4-9 should be completed. 

If NO, skip to question D4-10.If NA, skip to question D4-10.

D4-9 Description of pond/impoundment 

expansions.

Make sure that plant provides starting/ending dimensions and total cost associated with the expansion. 

D4-10D4-11

If YES, Table D-7 should be completed.If NO, skip to Section 4.2. Ensure that no answers are provided for Part D Section 4.1.If NA, Table D-7 should be completed to the extent possible.Make sure that units are selected for in the “Average Addition Rate” column and make sure that the units selected make logical sense for the chemical liquid/solid addition. 

Section 4.2 Closed Pond/Impoundment Unit 

Information

May have multiple copies to account for multiple pond(s)/impoundment(s) reported in Table A-4.

Pollutants targeted for removal other than “solely settling”.

If “other” is checked, make sure that the respondent provides an answer.Based on pollutants listed in D4-11, make sure the appropriate pollutant categories are selected in D4-10.Make sure any limitations provided have corresponding units selected.

D4-12 Chemical addition to pond/impoundment 

unit in 2009.
D4-13 Table A-4 Closed pond/impoundments. If YES, Section 4.2 should be completed.

If NO, skip to Section 5.1. Check to make sure there are no closed ponds listed in Tabl

A-4. Ensure no answers are provided for Part D Section 4.2.This section should only contain ponds closed on or after January 1, 2000 identified in Table A-4.

D4-14 Date closed, life, and number of cells in the 

close pond/impoundment

Make sure that the number of cells in the pond match the block diagram(s) submitted by the facility, if applicable 

D4-15 Volume, surface area, bottom and top 

elevation, freeboard height, max height of dams/berms, and total solids in the closed 

pond/impoundment

Make sure that responses logically make sense. For example, all height and elevation responses should correspond to one another; total solids placed in the pond should increase from current to end of life status.

D4-16 Does the pond/impoundment unit have a 

liner?

If YES is checked, Table D-9 should be complete.If NO is checked, skip to question D4-17. Table D-9 should not be completed.Make sure that the thickness and permeability entries are in the correct units.[Table D-9. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-9).]

D4-17 Does the pond/impoundment unit have a 

cap/cover?

If YES is checked, Table D-10 should be complete.If NO is checked, skip to question D4-18. Table D-10 should not be completed.Make sure that the thickness and permeability entries are in the correct units.[Table D-10. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-10).]If YES, all questions should be completed.If NO, skip to question D4-21

Make sure that plant provides starting/ending dimensions and total cost associated with the expansion. 

D4-21 and D4-22 Closure plan/process for the 

pond/impoundment unit.

If YES, make sure that a copy of the closure plan is attached.Check to make sure that closure plan is attached and contains all necessary information if there is not answer provided for question D4-22. 

D4-23 Has the plant built any structures on top of 

the closed pond/impoundment unit?

If YES, make sure that a description of the structures is provided.If NO, skip to question D4-24. 

D4-24 Long-term groundwater, soil, or overflow 

monitoring of the closed pond/impoundment unit.

If YES, make sure that a description of the monitoring plan is provided.

Section 5.1 Wastewater Treatment Unit Information 

– System Level

May have multiple copies to account for multiple wastewater treatment IDs reported in Table D-5.

D5-1 Table D-2 Identification of wastewater treatment 

systems in Table D-2.

If YES, Section 5.1 should be completed for each wastewater treatment system identified in Table D-2.If NO, skip to Section 6.1. Make sure no wastewater treatment systems were identified in Table D-2. Ensure that no answers are provided in Part D Sections 5.1 and 5.2.

Check to make sure the wastewater treatment IDs match the block diagram(s) submitted by the facility.[Table D-11. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-11).]

Table A-4 If a pond/impoundment is selected, check to make sure that the ID listed matches Table 

A-4 and block diagram(s) submitted by the facility. 

D5-2 Wastewater Treatment Units

D4-18 through 

D4-20

Expansions of pond/impoundment unit
Check that the respondents identify wastewater treatment units using appropriate code

Request new codes if necessary. 

Table D-2 Check to make sure that the surface area of the WWT Unit makes sense/corresponds to 

the surface area submitted for the entire treatment system (Table D-2). 

D5-3 Flow rates, duration, and frequency for the 

wastewater treatment system.

Check to make sure the flow rates, duration, and frequency logically make sense and match block flow diagram attached in D3-1. 

D5-4 and D5-5 Pollutants targeted for removal other than 

“solely settling”.Note D5-6 through D5-9 only need completeness checks.

If “other”, make sure that the respondent provides an answer.Based on pollutants listed in D5-5, make sure the appropriate pollutant categories are selected in D5-4.Make sure any limitations provided have corresponding units selected.

D5-10 Planned improvements to existing 

wastewater treatment systems

Make sure that bid proposals are attached or that an explanation is provided. 

D5-11 Planned improvements to existing 

wastewater treatment systems.

Make sure that all wastewater treatment unit IDs correspond to units entered in Table D-11.[Table D-12. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-12).]

D5-12 Table D-11 Planned improvements based on potential 

limit changes in the future.

If YES, no explanation is necessary.If NO, make sure that the respondent provides an explanation

Section 5.2 Wastewater Treatment System Chemical 

Addition

May have multiple copies to account for multiple wastewater treatment IDs reported in Table D-5.

If YES, Table D-13 should be completed for every wastewater treatment system identified in Table D-2.If NO is checked, skip to Section 6.1. Make sure there are no wastewater treatment systems identified in Table D-2. Ensure that no answers are provided for Part D Section 2.If NA is checked, Table D-13 should be completed until the extent possible.[Table D-13. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-13).]Make sure that units are selected for in the “Average Addition Rate” column. Make sure that the units selected make logical sense for the chemical liquid/solid addition. 

Section 6.1 Pond/Impoundment System and 

Wastewater Treatment System Costs

May have multiple copies to account for multiple pond/impoundment system or wastewater treatment system IDs that began operating on or after January 1, 2000.If YES, Sections 6.1 and 6.2 should be completed for each pond/impoundment system or wastewater treatment system identified in Tables D-1/D-2.If NO, respondents are instructed to skip to the next Part. Make sure there are no pond/impoundment or wastewater treatment systems identified in Tables D-1/D-2. Ensure no answers are provided in Part D Sections 6.1 and 6.2.Check to make sure that all pond/impoundment or wastewater treatment systems identified in Tables D-1 and D-2 as being installed on or after January 1, 2000, have a completed copy of Sections 6.1 and 6.2Make sure that Table D-14 is complete. If not, follow-up with the plant may be necessary.Information may not be provided in Table D-14 if the pond/poundment or wastewater treatment system was not operated in 2009.Make sure that the individual O&M costs match the total provided at the end of the table. 

D6-2 O&M costs for the pond/impoundment 

system or the wastewater treatment system operated in 2009.

D5-13 Chemical addition to wastewater treatment 

units.

6.1 Tables D-1/D-2 Pond/impoundment systems and/or 

wastewater treatment systems identified in Tables D-1 or D-2 installed after January 1, 2000.
D6-3 Capital costs for the pond/impoundment 

system or the wastewater treatment system.

Make sure that Table D-15 is complete. If not, follow-up with the plant may be necessary.Make sure that there are no discrepancies between the individual indirect/direct costs, the indirect/direct totals, and the total capital cost provided at the end of the table.Information may not be provided in Table D-15 if the pond/poundment or wastewater treatment system was not operated in 2009.

D6-4 Capital costs for the pond/impoundment 

system or the wastewater treatment system.D6-5 and D6-6 – only need to be checked for completeness.

If NO, make sure that a list of key components not included is included in the explanation.

D6-7 Tables D-1/D-2 Ancillary equipment of the 

pond/impoundment system or wastewater treatment system.

Check to make sure that all systems identified in Tables D-1 and D-2 as being installed on or after January 1, 2000, have a completed copy of Section 6.2.[Table D-16. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-16).]

Comments

Entire Section Check that all comments have a question number identified and the comment is 

understandable. 

Entire Section Resolve comments that indicate a change must be made to any electronic response. 
Part E Name Date(s) Reviewed

Reviewer No. 1Reviewer No. 2Status of Review

Questionnaire 

Part/Section/ 

Question 

Number

Copy Number Related Section Type of Information Coding and Review Activity First Reviewer Comments Second Reviewer 

Part E WASTES FROM CLEANING METAL 

PROCESS EQUIPMENT

TOC Ensure that plant name and ID have been populated in the TOC page 

Universal All questions are answered except for those that can be skipped. 

Section 1 Metal Cleaning Operations

E1-1 N/A If "No" is selected for either Question, Part E should not have been completed. 

Section 2 Generating Unit Cleaning Data May have multiple copies to account for multiple SEGUs

Each SEGU Id reported should match an ID in Table A-8 

If "yes" to specific cleaning method are all necessary data fields complete including 'Other' specific data. Check comments to be sure dose concentration and chemical added are in proper units. If not, calculate the proper value. Check frequency reported to determine if understandable Each SEGU Id reported should match an ID in Table A-8 If "yes" to specific cleaning method are all necessary data fields complete including 'Other' specific data. If plant reports no metal cleaning waste generated, check comments to determine why 

(typically, they have used steam and there is no residual waste) 

Check frequency reported to determine if understandable. 

Section 3 Cleaning Operation Data May have multiple copies to account for multiple SEGUs

E3 Table E-1/E-2 All For each type of cleaning for each unit identified in Tables E-1/E-2, there should be a 

completed Section 3. 

E3 Table E-1/E-2 All If the cleaning operating is selected as "Other" in Table E-1/E-2: make sure that the 

Metal Cleaning Operation ID is as follows:Table E-1, First Other Option is selected: Chem_Other1Table E-1, Second Other Option is selected: Chem_Other2Table E-2, First Other Option is selected: No_Chem_Other 1

Table E 2 Second Other Option is selected: No Chem Other 2 E3-1 Cleaning Operation Data Description must include: Type of Equipment, Type of Metal Cleaned, Chemical 

Preparation Steps, Short Description 

E3-2 Cleaning Operation Data Answer "yes" or "no" E3-3 Cleaning Operation Data Ensure all data are complete. Check that reported NPDES outfall number(s) match Part 

A, Section 2.2. 

E3-4 Cleaning Operation Data Answer "yes" continue on. "No" Skip ou E3-5 Cleaning Operation Data Answer ALWAYS or SOMETIME HAZARDOUS continue on. Answer ALWAYS 

NON-HAZARDOUS OR UNKNOWN jump to E3-7 

E3-6 Cleaning Operation Data Answered only if ALWAYS or SOMETIME HAZARDOUS in E3-5 E3-7 Cleaning Operation Data Ensure all data is complete including "expanded info 

E3-8 Cleaning Operation Data If 'yes" ensure all data is complete including "expanded info" 

Comments

Entire Section Check that all comments have a question number identified and the comment is 

understandable. 

Entire Section Resolve comments that indicate a change must be made to any electronic response. 

E2-2./Table E-2

E2-1/Table E-1

Non-Chemical Method/Water Source Used

Table A-8 Specific Chemical/Water Source UsedTable A-8
Part F Name Date(s) Reviewed

Reviewer No. 1Reviewer No. 2Status of Review

Questionnaire 

Part/Section/ 

Question 

Number

Copy Number Related Section Type of Information Coding and Review Activity First Reviewer Comments Second Reviewer 

Part F Management Practices For 

Ponds/Impoundments And Landfills

TOC Ensure that plant name and ID have been populated in the TOC page 

Section 1 Pond/Impoundment and Landfill Use

If NO, confirm that the plant did not included any ponds in Table A-4/Table A-5 or landfills in Table A-6/Table A-7 that contain process wastewaters, residues, or byproducts from the combustion of coal or petroleum coke (e.g., bottom ash sluice, fly ash sluice, FGD scrubber purge, gypsum wash water, bottom ash, fly ash, gypsum, and/or calcium sulfite). Review of the water balance diagram in Part A may be helpful.[Ensure no other answers are completed in Part F; technical review is complete.]If YES is checked for question F1-1, the remainder of Part F should be completed. 

Section 2 Pond/Impoundment Management 

Practices

May have multiple copies to account for multiple pond/impoundments

General Table A-4

Table A-5

Number of Copies Check that there is a copy of section 2 for each active/inactive/open or retired/closed 

pond/impoundment unit in Table A-4/Table A-5 that contains process wastewaters, residues, or by-products from the combustion of coal or petroleum coke (e.g., bottom ash sluice, fly ash sluice, FGD scrubber purge, gypsum wash water, bottom ash, fly ash, gypsum, and/or calcium sulfite). This section should include leachate ponds and all ponds reported in Part D. It should not include coal pile runoff ponds. Confirm that the Pond ID provided is reported in Table A-4.

F2-1 Hydrologic design criteria of the 

pond/impoundment unit

Ensure all data are complete including OTHER information if appropriate. If NO, skip to Question F2-4 

If YES, check that the respondent provided when the overflow occurred and the cause for the overflow. If NO, skip to question F2-9. If YES, ensure all data are complete including OTHER information if appropriate. Confirm at least one box is checked 

F2-5 Volume of leachate collected in 2009 (gpd 

and gpy) and the frequency of wastewater 

generation(days).

Ensure all data are complete and in the correct units. Compare data to the water balance diagram in Part A. 

F2-7 Table A-4 

Table D-2

Table F-5

Part A Section 2.2 

All intermediate and final destinations of the leachate.

Ensure all data are complete including OTHER information if appropriate. If transferred to pond/impoundment(s), confirm that pond IDs are reported in Table A-4. If transferredto onsite treatment system, verify that this system was reported in Table D-2 or section 4 of Part F was completed for this treatment system. If wastewater is discharged to surface water, confirm NPDES outfall number(s) in Part A Section 2.2. If NO, skip to Section 3. 

If YES, continue. 

F2-10 Monitoring measures or inspections 

performed on the impoundment unit by the 

plant.

Check that corresponding fields are completed for each box checked. Ensure all data are complete including OTHER information if appropriate. 

Section 3.1 Landfill Management Practices May have multiple copies to account for multiple landfills

General Table A-6 Number of Copies Check that there is a copy of section 3 for each active/inactive/open or retired/closed 

landfill in Table A-6/Table A-7 that contains process wastewaters, residues, or byproducts from the combustion of coal or petroleum coke (e.g., bottom ash sluice, fly ash sluice, FGD scrubber purge, gypsum wash water, bottom ash, fly ash, gypsum, and/or calcium sulfite). Confirm that the Landfill ID provided is reported in Table A-6.

F2-9 Regular Monitoring of the structural integrity

of the pond/impoundment unit

F2-8 Chemicals used to treat leachate which is 

sent to a pond or storage tank

If YES, ensure all data are complete including OTHER information if appropriate. Note: At least one box should be checkedIf YES, ensure all data are complete including OTHER information if appropriate. Note: At least one box should be checked

F2-4 System to collect leachate for 

pond/impoundment units

F2-6F2-2 Overflow or other type of release,excluding 

routine permitted discharges, since January 1,1995 from the pond/impoundment unit

Collection and Identification of stormwater, rainfall, or process wastewaters and their 

F2-3 Non-permitted pond/impoundment overflow 

or other type of release to a receving water

F1-1 A3-1 through

A4-3

Use of one or more active/inactive/open or retired/closed pond/impoundment units or landfill used for the storage, treatment, and/or disposal of process wastewater, residues, or by-products from the combustion of coal or petroleum coke,including, but not limited to fly ash, bottom ash, boiler slag, or flue gas emission 

control residues

If YES, check that the name of the receiving water is specified.
F3-1 Landfill's surface area, approved/licensed 

volume capacity and height when it was built and the date on which it was built

Ensure all fields are complete and data is provided in the correct units.

F3-2 Landfill's current surface area, volume and 

height above the original elevation of the stored materials

Ensure all fields are complete and data is provided in the correct units.If NO, confirm expected end date, surface area, volume, and height are provided. Confirm data is provided in the correct units 

If YES , confirm date closed is specified 

If NO, skip to Question F3-8 If YES, continue. 

F3-5 Type of expansion of the landfill Ensure plant selected only one answer F3-6 Description of the landfill expansion since 

January 1, 2000

Check that the starting and ending dimensions (surface area, volume of stored materials and height) and the date(s) of expansion are provided. Confirm plant specified units for all numbers provided. The end dimension should be larger than the starting dimension. It's possible for this question to be blank if no expansions occurred since January 1, 2000. If completed, Q F3-7 should be completed.

F3-7 Total Cost of expansion(s) since January 

1,2000

Make sure a value is entered for the total cost. It's possible for this question to be blank if no expansions occurred since January 1, 2000. Should be completed if F3-

6 is answered.

If NO, skip to question F3-9. 

If YES, ensure that corresponding fields are completed for each box checked in Table F1. Note: There may be empty rows in Table F-1, but at least one row should be completed.

If NO, skip to question F3-10. 

If YES, ensure that corresponding fields are completed for each box checked in Table F2. Note: There may be empty rows in Table F-2, but at least one row should be completed.

If NO or NA, skip to question F3-11. If YES, make sure that a description of the structure(s) and/or challenges the plant faced while building on top of the landfill are provided If NO, skips to question F3-16. 

If YES, ensure all data are complete including OTHER information if appropriate 

F3-12 F2-5 Volume of leachate collected in 2009 (gpd 

and gpy) and the frequency of process wastewater generation(days)

Ensure all fields are complete and data is provided in the correct units. Make sure that a description of the estimation method is provided. Using the water balance diagram, and answers to F2-5, ensure that all leachate is accounted for

F3-14 Table A-4

Table D-2

Table F-5

Part A Section 2.2

All intermediate and final destinations of the leachate.

Ensure all data are complete including OTHER information if appropriate. If transferred to pond/impoundment(s), confirm that pond IDs are reported in Table A-4. If transferred

to onsite treatment system, verify that this system was reported in Table D-2 or section 4 of Part F was completed for this treatment system. If wastewater is discharged to surface water, confirm NPDES outfall number(s) in Part A Section 2.2. 

F3-15 Chemicals used to treat leachate which is 

sent to a pond or storage tank

If YES, ensure all data are complete including OTHER information if appropriate. Confirm at least one box is checked 

F3-16 Combining the conveyed stormwater runoff 

that has contacted uncapped portion of the landfill with leachate

Answer YES or NO

F13-17 Table A-4

Table D-2

Part A Section 2.2 

All intermediate and final destinations of the conveyed stormwater runoff that has contacted uncapped portion of the landfill.

Ensure all data are complete including OTHER information if appropriate. If transferred to pond/impoundment(s), confirm that pond IDs are reported in Table A-4. If transferredto onsite treatment system, verify that this system was reported in Table D-2 or the planentered NA and indicated the type. If wastewater is discharged to surface water, confirm NPDES outfall number(s) in Part A Section 2.2. 

F3-18 Combining the conveyed stormwater runoff 

that has contacted capped portion of the landfill with leachate

Answer YES or NO

F3-19 Table A-4

Table D-2

Part A Section 2.2 

All intermediate and final destinations of the conveyed stormwater runoff that has contacted capped portion of the landfill.

Ensure all data are complete including OTHER information if appropriate. If transferred to pond/impoundment(s), confirm that pond IDs are reported in Table A-4. If transferred

to onsite treatment system, verify that this system was reported in Table D-2 or the planentered NA and indicated the type. If wastewater is discharged to surface water, confirm NPDES outfall number(s) in Part A Section 2.2. 

Section 3.2 Landfill Costs May have multiple copies to account for multiple landfills. Please be aware that 

this section may be blank if their landfill did not "begin operating on or after January 1, 2000."

If YES, ensure that corresponding fields are completed for each box checked and that at least one box is checked. If OTHER is selected, make sure that the type of process

F3-13 Collection and Identification of stormwater, 

rainfall, or process wastewaters and their 

F3-3 Is landfill closed? 

F3-10 Structures on top of landfillF3-11 System to collect leachate for landfill

F3-9 Cap/Cover for the landfillF3-8 Liner for the landfillF3-4 Expansion of the landfill
General Number of Copies Check that there is a copy of section 3.2 for each landfill provided in section 3.1 that 

began operating on or after January 1, 2000 based on F3-1. Ensure that the landfill IDs for the same landfill are written identically in section 3.1 and 3.2. Note: Even an extra space will disrupt linking in Access, so make sure these fields are truly identical.

F3-20

Table F-3

2009 O&M cost data for landfills Check the comments section to see whether actual data or an estimate is used. If an 

estimate is provided, make sure that the methods used are listed in the comments section. Ensure all fields are complete including OTHER information if appropriate. Confirm the data is provided in the correct units and units are specified if requested. Ensure that the Total O&M cost is the sum of all the subcosts. 

F3-21

Table F-4

Capital cost data for landfills Check the comments section to see whether actual data or an estimate is used. If an 

estimate is provided, make sure that the methods used are listed in the comments section. Ensure all fields are complete. Ensure that the total direct cost, total indirect cost, and total cost were correctly reported (i.e., sum of respective subcosts). Follow up with the respondent to check that the capital costs for the planned LTSs are not included in Table F-3.

Section 4.1 Leachate Treatment System(LTS) Design Only one copy at the plant level.

General Table D-2 Leachate treatment system design Confirm that Section 4.1 is completed for all leachate treatment systems specified in F2-

7 and F3-14. Make sure that treatment systems listed in Table D-2 are not included. Ensure all data are complete and provided in the correct units. Only applicable rows need to be completed (i.e., some rows may be completely empty, but no rows should be partially completed). Confirm NPDES outfall number(s) are in Part A Section 2.2. Check that an estimate of the expected average annual flow rate of the effluent is provided for the planned leachate treatment systems (LTSs). Please note that we ask for this in the directions, but not in the table. Because we ask for influent flow in Section 4.2, we do not need to capture the average annual flow in this question. Therefore, ensure that the flow is reported for planned systems in Table F-6. If the

plant entered it only as a comment, add it to Table F-6. Confirm that F4-2 is checked and that the documentation is provided. If not, review the comments to determine whether follow up is required 

Check that the block diagrams are numbered and the plant name, plant ID, and LTS ID are provided in the upper corner of the diagram Check that all the influent and effluent streams from the units and LTSs are labeled using the Code table. Make sure that a description of the source or destination and the block diagram number are provided when the source or destinations are not shown the diagram. Check that the point of chemical addition is identified. Make sure that the chemicals indicated correspond to the chemicals listed in Table F-9 Check that the final destination of the treated leachate is identified and make sure that when appropriate, details of reuse or recycling of leachate within the plant are provided. Check that the average annual (2009) flow rates for influent and effluent are included and make sure that these are the same flow rates entered into Table F-6. Check the comments to see if the flow rate is arrived at by dividing the annual flow by 365 days.Check that NPDES permit outfall numbers are included when applicable and are also reported in Part A section 2.2 

Section 4.2 Leachate Treatment System Flows May have multiple copies to account for multiple leachate treatment systems

General Table F-5 Number of Copies Check that there is a copy of section 4.2 for each leachate treatment system identified in 

Table F-5. Make sure that LTS ID assigned in Table F-5 is entered correctly for each copy.

Table F-6 Table A-4 Table 

A-6

LTS Flows in 2009 Confirm that the pond and landfill IDs are reported in Table A-4 or Table A-6 

respectively. Ensure all data are complete including OTHER information if appropriate. Check data are provided in correct units. Only applicable rows need to be completed (i.e., some rows may be completely empty, but no rows should be partially completed). Note: Plant can provide gpm, hpd, and dpy OR gpd and dpy. If plant provides both, make sure gpm x hpd x 60 = gpd and that dpy = dpy. 

Section 4.3 Leachate Treatment System Units May have multiple copies to account for multiple leachate treatment systems

General Table F-5 Number of Copies Check that there is a copy of section 4.3 for each LTS identified in Table F-5. Make sur

that the LTS ID assigned in Table F-5 is entered correctly for each copy. 

Table F-5 Table D-2

Part A Section 2.2

Plant Leachate Treatment systems

F4-2 F4-1

Table F-9

Part A Section 2.2

Block Diagram for Leachate Treatment System
Table F-7 Table A-4 Leachate Treatment units Ensure all data are complete including OTHER and POND ID information if 

appropriate. Only applicable rows need to be completed (i.e., some rows may be completely empty). If a pond/impoundment unit is included as part of the leachate treatment system, check that the pond ID is reported in Table A-4. Please note that we ask for the date added to the WWT system in the instructions but they did not need to provide that (it was deleted from the table). If the information is provided 

in comments you can leave them

Table F-8 Table A-4 Planned Improvements to the LTSs. Ensure all data are complete including OTHER and POND ID information if

appropriate. Only applicable rows need to be completed (i.e., some rows may be completely empty). If a pond/impoundment unit is included as part of the leachate 

treatment system, check that the pond ID is reported in Table A-4.

If NO, skip to question F4-7. If YES, make sure that the targeted pollutants and/or limits are specified 

F4-7 Flow rate data for LTS in 2009 Make sure that all the fields are populated and that data is provided in the correct units. 

For planned LTS, check that the design flow rate is provided and N/A is entered in all other the fields

Section 4.4 Leachate Treatment Unit (LTU) 

Information

May have multiple copies to account for multiple leachate treatment systems and multiple leachate treatment system units

General Table F-5 Table 

F-7

Number of Copies Check that there is a copy of section 4.4 for each LTU in Table F-7. Remember that 

there is a Table F-7 for each LTS identified in Table F-5. Thus, if you had 2 LTSs each with 3 LTUs you should have 6 copies of section 4.4. Make sure that the LTS ID assigned in Table F-5 and LTU ID assigned in Table F-7 are entered correctly for each 

copy.

F4-8 Volume of the LTU Ensure that the volume field is always completed and in the case of a wetland cell that 

water depth (ft) is also provided. 

F4-9 Footprint/Surface area of the LTU Data is provided and in correct units 

F4-10 Residence time(hours) of leachate within the 

LTU

Data is provided and in correct units. 

 F4-11 Types of Materials of construction of the 

LTU

Ensure all data are complete including OTHER information if appropriate. At least one box should be selected. If selected "Stainless steel" make sure that plant also provided the type of stainless steel. 

F4-12 Pollutants targeted for removal by LTU 

using technologies other than settling

Ensure all data are complete including OTHER and METALS information if appropriate. At least one box should be selected 

F4-13 F4-12 Pollutants and effluent Limitations 

controlling the LTU operation

Make sure that limitations and units are provided for each listed pollutant. Ensure that no polutants are provided that were not previously provided in question F4-12. 

If YES, make sure that Table F-9 is completed. Check that corresponding fields are completed for all the chemicals listed. Confirm plant provided answers in correct units. Only applicable rows need to be completed (i.e., some rows may be completely empty, 

but no rows should be partially completed)

If NO, skip to F4-15 

If NA, make sure that Table F-8 is completed for this LTU and skip to F4-15 

If YES, make sure that Table F-10 is complete. Check that corresponding fields are completed for all the plant species listed. Only applicable rows need to be completed (i.e., some rows may be completely empty, but no rows should be partially completed).If NO, skip to Section 4.5 

If NA, make sure that Table F-8 is completed for this LTU and skip to section 4.5. 

Section 4.5 Leachate Treatment System (LTS) Costs May have multiple copies to account for multiple leachate treatment systems. 

Please be aware that this section may be blank if their LTS did not "begin operating on or after January 1, 2000."

General Table F-5 Number of Copies Check that there is a copy of section 4.5 for each leachate treatment system identified in 

Table F-5 that began operating on or after January 1, 2000. Make sure that LTS ID assigned in Table F-5 is entered correctly for each copy

F4-16

Table F-11

2009 O&M cost data for leachate treatment systems

Check the comments section to see whether actual data or an estimate is used. If an estimate is provided, make sure that the methods used are listed in the comments section. Ensure all fields are complete including OTHER information if appropriate. Confirm the data is provided in the correct units and units are specified if requested. Ensure that the Total O&M cost is the sum of all the subcosts. If this table was not completed, check the comments page and make sure plant provided an explanation for why records were not available 

Check the comments section to see whether actual data or an estimate is used. If an estimate is provided, make sure that the methods used are listed in the comments section. Ensure all fields are complete. Ensure that the total direct cost, total indirect cost, and total cost were correctly reported (i.e., sum of respective subcosts). 

F4-17

Table F-12

Capital cost data for leachate treatment systems

F4-6 Planned improvements in preparation for 

potential limit changes

 F4-15 Table F-8 Plant species in LTU  F4-14 Table F-8 Chemicals added to LTU unit in 2009
Section 4.6 Leachate Treatment System Equipment May have multiple copies to account for multiple leachate treatment systems. 

Please be aware that this section may be blank if their LTS did not "begin operating on or after January 1, 2000."

General Table F-5 Table 

F-7

Number of copies Check that there is a copy of section 4.6 for each leachate treatment system provided in 

section 4.5. Ensure that the leachate treatment system IDs for the same landfill are written identically in section 4.5 and 4.6.

F4-18

Table F-13

Leachate treatment system equipment Confirm all data are complete. Only applicable rows need to be completed (i.e., some 

rows may be completely empty, but no rows should be partially completed). 

Section 5 Groundwater Monitoring Practices May have multiple copies to account for multiple pond/impoundments and 

landfills

General Number of copies Check that there is a copy of section 5 for each pond/impoundment provided in section 2

and a copy of section 5 for each landfill provided in section 3.1. Ensure that the pond IDs and landfill IDs for the same pond/impoundment or landfill are written identically between the sections.

If NO, respondent should skip to next questionnaire part.

[Ensure no other answers are completed in Part F; technical review is complete 

If Yes, ensure all data are complete and in correct units If YES, continue. If NO, skip to question F5-4. 

F5-3 Pollutants that exceeded primary or 

secondary MCL or state criteria

Ensure that the plant provided a list of pollutants. If YES, continue. 

If NO, skip to question F5-6. 

F5-5 Pollutants that exceeded background 

concentrations

Ensure that the plant provided a list of pollutants. Confirm that box is checked and that the diagram is provided. Ensure that the locations of the monitoring wells are labeled on the diagram using the same IDs provided in Table F-14.Check that corresponding fields are completed for all monitoring wells listed. Confirm plant provided answers in correct units. Only applicable rows need to be completed (i.e., some rows may be completely empty, but no rows should be partially completed).

Comments

Entire Section Check that all comments have a question number identified and the comment is 

understandable. 

Entire Section Resolve comments that indicate a change must be made to any electronic response. 

F5-6

Table F-14

Monitoring well informationPlant measured pollutant concentrations in 

groundwater that exceed a primary or

F5-4 Measured pollutant concentrations in ground 

water that do not exceed a primary or

F5-2F5-1 Preform groundwater monitoring
Part G Name Date(s) Reviewed

Reviewer No. 1Reviewer No. 2Status of Review

Questionnaire 

Part/Section/ 

Question 

Number

Copy Number Related Section Type of Information Coding and Review Activity First Reviewer Comments Second Reviewer 

Part G Leachate Sampling Data for 

Ponds/Impoundments and Landfills

TOC Ensure that plant name and ID have been populated in the TOC page 

Section 1 Leachate Collection

If "no" is checked for question G1-1, the remainder of Part G should not be completed. Check for consistency in answer to G1-1 and whether leachate was reported to be collected for any ponds/landfills listed in Tables A-4 and A-6 

If "yes," confirm respondant completed appropriate questions in Part F (F2-4, F3-11, Table F-5). 

Section 2 Leachate Generated from Pond/Impoundments and Landfills May have mutiple copies for each pond/landfill where leachate is collected.

Each pond/landfill ID should match an ID in Tables A-4 or A-6 

If "no" is checked for question G2-1, skip to Section 5. 

If "no" is checked for question G2-1, confirm respondant answered “No” to question F2-4 and/or F3-11 for the same pond/landfill ID. 

If "yes" skip to Section 3, and ensure reported data is ONLY untreated leachate. 

See Figure G-1 for sampling requirements

If "yes" confirm questions F2-7 and/or F3-14 are answered consistently 

If "no" skip to Section 3, and ensure reported data is ONLY untreated leachate. 

If "yes" confirm questions F2-7 and/or F3-14 are answered consistently 

If "yes" confirm that Part F Section 4 was completed Confirm that questions F2-6, F3-13, F3-16, and F3-18 are answered consistently If "yes" to 'only runoff or other stormwater' ensure reported data is for both treated effluent and untreated leachate.If "yes" to 'with process wasterwater other than runoff/stormwater' ensure reported data is for untreated leachate.

If "no" ensure reported data is for both treated effluent and untreated leachate. 

Section 3 Leachate Sample Collection

G3-1 G2-1 - G2-4; 

Table G-4 for 

results

Sampling Check comments regarding any possible EPA plant sample exemption (as of 9/17/10, 

EPA had not granted any exemptions). 

G3-2 Confirm that aerial map is provided 

G3-3 F4-2 and G3-1 Confirm sampling locations are marked in the diagram from question F4-2. Confirm 

that sampling locations are appropriate (untreated is within the leachate collection system and the treated sample is from effluent of the leachate treatment system).

Section 4 Sample Collection Information

Confirm each pond/impoundment and/or landfill identified in Section 2 are listed in Table G-1. Pond/impoundment and/or landfill IDs are found in Tables A-4 and A-6. Using questions G2-1 through G2-4, determine if the correct type of samples (untreated and/or treated) were reported in Table G-1. There should be FOUR SAMPLE DATES or SETS OF ANALYSIS per type of leachate (untreated and/or treated) for EACH pond or landfill identified in Section 2

Sample dates should be once a week (minimum of 5 days between samples, prefer 7 days) for 4 weeks. For low flows, sample as soon as collectable but with a minimum of 5 days between samples.If leachate is treated ensure the treatment system is identified in Part F Table F-5 and there is a Section 4.2 completed in Part F 

G4-2 Rain event Confirm plant provided rainfall data starting two weeks prior to the collection of the 

first leachate sample through the last day of sample collection 

Section 5 Waste Information

Confirm each pond/impoundment and/or landfill identified in Section 2 are listed in Table G-3. Pond/impoundment and/or landfill IDs are found in Tables A-4 and A-6. Compare reported wastes with those listed in Table A-7 for consistency. 

G1-1 Part A Tables A-4 

and A- 6; Part F 

Sections 2, 3, and 

4

Collection of leachate

G2-1 Part F Section 2 

& 3

Leachate generated from pond/impoundments and landfills

G2-2 Part F Section 2 

& 3

Leachate destination

G2-3 Part F Section 2, 

3 & 4

Leachate treatment

G2-4 Part F Section 2, 

3 & 4 See Figure 

G-1 for sampling 

req'ments

Combined waste streamsSampling locations

G4-1 Table A-4 and A6; Part F Section 

4 Table F-5

Sample collection information

G5-1 Table A-4 and A6; G2, Table G-1 Waste information
Lab Results Laboratory Analytical Data Form Will have mutiple copies for each pond/landfill and leachate collection location.

Ensure the plant reported results for each entry in Table G-1. There should be FOUR COPIES OF TABLE G-4 per type of leachate (untreated and/or treated) for EACH 

pond or landfill identified in Section 2

Ensure a laboratory and a sample description is provided for each copy Confirm analytical methods are specified for each reported result Confirm that the MDL is <= to the Reporing Limit Confirm analytical results are complete and that the non-detect indicator is selected if the result is < the numerial value for the MDL or comments are provided. If the analytical result is < Reporting Limit, ensure that a qualifier is provided Ensure a data review summary is attached Do a spot check to confirm concentrations are reported correctly from the data review summary and are in μg/L. 

Table G-4 Table A-4 and A6; G2, Table G-1; 

Part F Question 4-

2

Laboratory analytical data
Part H Name Date(s) Reviewed

Reviewer No. 1Reviewer No. 2Status of Review

Questionnaire 

Part/Section/ 

Question 

Number

Copy Number Related Section Type of Information Coding and Review Activity First Reviewer Comments Second Reviewer 

Part H NUCLEAR POWER GENERATION

TOC Ensure that plant name and ID have been populated in the TOC page 

Universal All questions are answered except for those that can be skipped. 

Section 1 Nuclear Generating Unit Data

H1-1 and H1-2 If "No" is selected for either Question, Part H should not have been completed 

Ensure data are complete. If "Other" is selected, ensure "Other" is specified. Ensure there is a Section 2 for each wastewater reported. 

H1-3/Table H-1 Part H, Section 3 Nonradioactive/Radioactive Is selected, check to ensure that QH3-1 in Section 3 for systems that treat this 

wastewater are marked as radioactive. 

H1-3/Table H-1 Table A-8 Nuclear Unit(s) If "Other" is selected, ensure "Other" is specified. Confirm that SE Unit IDs match those

reported in Table A-8. 

N/A Part H, Section 1, 

Table H-1

Process wastewater code Code identified needs to match the process wastewater code indicated in H1-3/Table H1. 

N/A N/A Process wastewater code Different wastewater code name for each new Tab created by user.

Section 2 Process Wastewater Generation May have multiple copies to account for multiple wastewaters

Check that typcial duration does not exceed 24 hrs/day or 365 days/y Ensure that typical frequency is understandable 

Recycled process wastewater If "Immediately recycled back..." is selected, ensure a process description is selected. If 

"Other" is selected, ensure that "Other" is specified 

Discharged to surface water and treated If "Discharged to surface water following on-site treatment..." is selected, ensure the 

NPDES permit outfall number is provided and is reported in Part A, Section 2.2. 

Discharged to surface water untreated If "Discharged to surface water untreated..." is selected, ensure the NPDES outfall 

number is provided and is reported in Part A, Section 2.2 

Other If "Other" is selected, ensure "Other" is explained. 

Section 3 Wastewater Treatment Systems May have multiple copies to account for multiple treatment systems

Entire Section Wastewater Treatment System Name Ensure the plant used a different Treatment System Name for each new copy created by 

user.

H3-1 Table H-1 Nonradioactive/Radioactive Check if radioactive process wastewaters reported in table H-1 are treated in this 

system, that "Radioactive" is selected 

H3-2 Table H-1 All Ensure that all process wastewater codes identified for each wastewater treatment 

system is also reported in H1-3/Table H-1. 

Check that maximum flow rate is >= typical flow rate Check that days/yr is <=365 days and hrs/day is <=24 hrs/day 

Wastewater Treatment Technology If "Other" is selected, ensure "Other" is specified. 

If "Metals" is selected, ensure "Metals" are specified If "Other" is selected, ensure "Other" is specified 

Unit Selected and matches value Wastewater Treatment Technology If "Other" is selected, ensure "Other" is specified 

If "Metals" is selected, ensure "Metals" are specified If "Other" is selected, ensure "Other" is specified 

H3-7 Recycled process wastewater If "Immediately recycled back..." is selected, ensure a process description is selected. If 

"Other" is selected, ensure that "Other" is specified 

Discharged to surface water and treated If "Discharged to surface water following on-site treatment..." is selected, ensure the 

NPDES permit outfall number is provided and is reported in Part A, Section 2.2. 

Discharged to surface water untreated If "Discharged to surface water untreated..." is selected, ensure the NPDES outfall 

number is provided and is reported in Part A, Section 2.2 

N/A Other If "Other" is selected, ensure "Other" is explained 

If "Recycled back..." is selected in H3-6, make sure question is answered Check that maximum flow rate is >= typical flow rate Check that days/yr is <=365 days and hrs/day is <=24 hrs/day. 

H1-3/Table H-1 Part H, Section 2 Process WastewaterH2-1/Table H-2 Process Wastewater Flows

H2-2

Part A, Section 

2.2

H3-3 All

H3-4/Table H-3

Pollutants Targeted for Removal...

H3-5/Table H-4

Pollutants Targeted for Removal...All

H3-6

Part A, Section 

2.2

H3-7 H3-6
Comments

Entire Section Check that all comments have a question number identified and the comment is 

understandable. 

Entire Section Resolve comments that indicate a change must be made to any electronic response. 
Project Name: Steam Electric Project No: 0172.07.029.022 (non-coal)

0172.07.029.025 (coal)

CBI = Yes (Y)

Questionnaire 

Part

Question 

Number Copy # Question/Answer

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Type of Contact (Email/Tele):

Company Name:

Plant Name:

Point of Contact:

Contact Phone Number:

Date:

Contact Email Address:

ERG Staff (or ERG Rep) Name:

Company Affiliation: 

This document contains CBI:

General Subject: Steam Electric Questionnaire Assistance / Follow-Up 

Steam Electric Questionnaire Follow-Up Questions

yes/no
Project No.: 0172.07.029.022 (non-coal)

Project No.: 0172.07.029.025 (coal)

Contact Phone No.: 

Contact Email Address: 

Date: 

Time: __ AM ___ PM

Type of Contact (Email/Telephone):

CBI = Question

Yes (Y) No.

Project Name: Steam Electric

Plant ID: 

Plant Name: 

Contact Name:

ERG Staff Name: 

This document contains CBI (yes/no):

General Subject: 

QUESTIONNAIRE ASSISTANCE / FOLLOW-UP: 

Topics Discussed

Steam Questionnaire Contact Record
Reviewer: Date Completed:

Questionnaire 

Part

Section & 

Question #

Copy # (if 

necessary) Description of Change

Source for Change 

(list telecon or other 

source)

Approved/ 

Rejected D

Steam Electric Questionnaire - Change Form

Instructions:1) Include as much identifying information as possible in the "Description of Change" column to document the change made (e.g., if the information is about a spboiler/unit ID).2) Include a source/reference for the change, such as a specific telecon where the change was discussed with the point of contact.

ER
Part A Name Date(s) Reviewed

Reviewer No. 1Reviewer No. 2Status of Review

Questionnaire 

Part/Section/ 

Question Number

Type of Information Coding and Review Activity Notes for Copy Buttons First Reviewer Comments Second 

All General Instructions

Unlocking Tabs Must unlock each tab separately. 

Password: FinalSteamLocked0510Note that the password for Part A Sections 2.2 and 8 is different. Password: steam

Select Tools > Protection > Unprotect Sheet > Copy and past password

Clear Radio Buttons Clear if respondent accidentally selected a 

radio button.

Unlock tabRight click on the radio button > Format Control > Select "Control" Tab > Unchecked

Check Modified Files All Check to make sure that the plant is not on the 

"modified files" list (See Modified Files tab). If Yes - Thoroughly check the mapping for the changed

tabs. Note that some of the infromation will not be automatically uploaded and will have to hand enter that data. Highlight additional rows in green that are not programmed to bring to our attention.Also note that in some cases there may be tabs that are copied that did not originally have a copy button. That is OK for these files.

Steps to Thoroughly Check Mapping

1. Unlock tab2. Unhide mapping rows at the bottom (Row 300)3. Check to make sure that the answers in the map match the answers selected above on the copied tab and that no linking is present between the original tab and the copied tab.4. Check the offset functions (mostly the drop downs) to see if they reference the previous tab.5. If they do reference the original tab; do a find and replace on the previous tab name for a space (“ “). 

All General Instructions

Check for True Zeroes All number fields Review each questionnaire part for answers where the 

respondent entered "0". If the answer is truly zero, delete the "0" and enter "-555" into the field. 

Check for Missing Data All fields Review each section for missing data. If there are 

questions in tab that don't have answers, but should be answered, enter "-111". All "-111" entries should be removed after plant follow-up, but incase they are not, this will designate missing data in the database.

Part A Tab Name

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part A Section 2.2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per outfall ID.

Check to make sure that tab name is not changed or that tab is deleted. 

Part A Section 1.1Part A Section 1.2Part A Section 2.1Part A Section 2.2Part A Section 3

Check Tab Names
Check to make sure that there are no copies of the tab. 

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part A Section 8 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per SE Unit ID.

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. 

Part B Tab Name

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab copies in tandem with "Part B Section 4 Tables". Make sure that there is a "Part B Section 4 Tables" copy for every copy of Part B Section 4. If copied, confirm that tab names follow the format: Part B Section 4 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Copy button for multiple wet FGD systems. Make sure that the same FGD System ID is on the corresponding Part B Section 4 Tables copy. Make sure there are not two or more sets of copies with the same ID. 

Check to make sure that tab name is not changed or that tab is deleted. Tab copies in tandem with "Part B Section 4". Make sure that there is a "Part B Section 4" copy for every copy of Part B Section 4 Tables. If copied, confirm that tab names follow the format: Part B Section 4 Tables Cop (#). Note that original tab name should NOT change or contain the word "copy" and that the word "Copy" may cut off. 

Copy button for multiple wet FGD systems. Make sure that the same FGD System ID is on the corresponding Part B Section 4 copy. Make sure there are not two or more sets of copies with the same ID. 

Part A Section 4Part A Section 5Part A Section 6Part A Section 7Part A Section 8Part A Section 9Part A Section 10Part A Section 11Part A Section 12Part A Section 13Part A Comments

Check Tab Names

Part B Section 4Part B Section 3Part B Section 2Part B Section 1Part B Section 4 Tables
Check to make sure that tab name is not changed or 

that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab copy button is actually on tab Part B Section 6. If copied, confirm that tab names follow the format: Part B Section 6 Table Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Copy button for provided incase respondent needs more space. In this case, copies can refer to the same data set. 

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab copies in tandem with "Part B Section 8 Tables". Make sure that there is a "Part B Section 8 Tables" copy for every copy of Part B Section 8. If copied, confirm that tab names follow the format: Part B Section 8 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Copy button for multiple dry FGD systems. Make sure that the same FGD System ID is on the corresponding Part B Section 8 Tables copy. Make sure there are not two or more sets of copies with the same ID. 

Check to make sure that tab name is not changed or that tab is deleted. Tab copies in tandem with "Part B Section 8". Make sure that there is a "Part B Section 8" copy for every copy of Part B Section 8 Tables. If copied, confirm that tab names follow the format: Part B Section 8 Tables Cop (#). Note that original tab name should NOT change or contain the word "copy" and that the word "Copy" may cut off. 

Copy button for multiple dry FGD systems. Make sure that the same FGD System ID is on the corresponding Part B Section 8 copy. Make sure there are not two or more sets of copies with the same ID. 

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. 

Part C Tab Name

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part C Section 2.1 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per SE Unit ID.

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part C Section 2.3 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per SE Unit ID.

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part C Section 2.4 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Storage ID.

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part C Section 3.1 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per SE Unit ID.

Check to make sure that tab name is not changed or that tab is deleted. 

Part C Section 2.1Part C Section 2.4Part C Section 2.3Part C Section 2.2

Check Tab Names Part C Section 1

Part C Section 2.5Part C Section 3.2Part C Section 3.1Part B CommentsPart B Section 8 TablesPart B Section 8Part B Section 7Part B Section 6 TablePart B Section 6Part B Section 5
Check to make sure that there are no copies of the tab. 

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part C Section3.3 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per SE Unit ID.

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part C Section 3.4 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Storage ID.

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part C Section 4 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per SE Unit ID.

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part C Section 5 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per SE Unit ID.

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. 

Part D Tab Name

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part D Section 3.1 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Pond/Impoundment System or Wastewater Treatment System ID. 

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part D Section 3.2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Pond/Impoundment System or Wastewater Treatment System ID. 

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part D Section 4.1 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Pond/Impoundment Unit ID. 

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part D Section 4.2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Pond/Impoundment Unit ID. 

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part D Section 5.1 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Wastewater Treatment System ID. 

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part D Section 5.2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Wastewater Treatment System ID. 

Check to make sure that tab name is not changed or that tab is deleted. 

Part D Section 5.1Part D Section 5.2Part D Section 6.1Part C Section 3.4Part D Section 1Part D Section 2Part D Section 3.1Part D Section 3.2Part D Section 4.1Part D Section 4.2Part C CommentsPart C Section 5Part C Section 4Part C Section 3.5Part C Section 3.3
Tab copies in tandem with "Part D Section 6.2". Make 

sure that there is a "Part D Section 6.2" copy for every copy of Part D Section 6.1. If copied, confirm that tab names follow the format: Part D Section 6.1 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Pond/Impoundment System or Wastewater Treatment System ID. Make sure that the same ID is on the corresponding Part D Section 6.1 copy. 

Check to make sure that tab name is not changed or that tab is deleted. Tab copies in tandem with "Part D Section 6.1". Make sure that there is a "Part D Section 6.1" copy for every copy of Part D Section 6.2 Tables. If copied, confirm that tab names follow the format: Part D Section 6.2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Pond/Impoundment System or Wastewater Treatment System ID. Make sure that the same ID is on the corresponding Part D Section 6.2 copy. 

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. 

Part E Tab Name

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part E Section 2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per SE Unit ID.

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part E Section 3 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Metal Cleaning Operatoin ID, note that there may be multiple copies with the same SE Unit ID. 

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. 

Part F Tab Name

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part F Section 2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Pond/Impoundment Unit ID. 

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part F Section 3.1 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Landfill ID.

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part F Section 3.2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Landfill ID.

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part F Section 4.2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Leachate Treatment System ID. 

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part F Section 4.3 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Leachate Treatment System ID. 

Part D CommentsPart D Section 6.2

Check Tab Names Part F Section 1

Part F Section 2Part F Section 3.1Part F Section 3.2Part F Section 4.1Part F Section 4.2Part F Section 4.3

Check Tab Names Part E Section 1

Part E Section 2Part E Section 3Part E Comments
Check to make sure that tab name is not changed or 

that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part F Section 4.4 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Leachate Treatment Unit ID. Note that there may be multpile copies with the same Leachate Treatment System ID. 

Check to make sure that tab name is not changed or that tab is deleted. Tab copies in tandem with "Part F Section 4.6". Make sure that there is a "Part F Section 4.6" copy for every copy of Part F Section 4.5. If copied, confirm that tab names follow the format: Part F Section 4.5 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Leachate Treatment System ID. Make sure that the same ID is on the corresponding Part F Section 4.5 copy. 

Check to make sure that tab name is not changed or that tab is deleted. Tab copies in tandem with "Part F Section 4.5". Make sure that there is a "Part F Section 4.5" copy for every copy of Part F Section 4.6. If copied, confirm that tab names follow the format: Part F Section 4.6 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Leachate Treatment System ID. Make sure that the same ID is on the corresponding Part F Section 4.6 copy. 

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part F Section 5 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Pond/Impoundment ID or Landfill ID. 

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. 

Part G Tab Name

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part G Section 2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Pond/Impoundment ID or Landfill ID. 

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part G Section 5 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Copy button for provided incase respondent needs more space. In this case, copies can refer to the same data set. 

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part G Sampling Results Cop (#). Note that original tab name should NOT change or contain the word "copy" and that the word "Copy" may cut off. 

Make sure that there is only one copy per Pond/Impoundment ID or Landfill ID.

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. 

Part H Tab Name

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. 

Check Tab Names Part H Section 1

Part H Section 2Part F Section 4.6Part F Section 5Part F CommentsPart F Section 4.4Part F Section 4.5

Check Tab Names Part G Section 1

Part G Section 2Part G Section 3Part G Section 4Part G Section 5Part G Sampling ResultsPart G Comments
Tab has a copy button. If copied, confirm that tab 

names follow the format: Part H Section 2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Process Wastewater Code. 

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part H Section 3 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per wastewater treatment system name. 

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. 

Part H Section 3Part H Comments
Attachment 2 

TECHNICAL QUESTIONNAIRE CHECKLIST – VERSION 3/4
Part A Name Date(s) Reviewed

Reviewer No. 1Reviewer No. 2Status of Review

Questionnaire 

Part/Section/ 

Question 

Number

Copy Number Related Section/Part Type of Information Coding and Review Activity First Reviewer Comments Second Reviewer 

Part A Steam Electric Plant Operations

TOC Ensure that plant name and ID have been populated in the TOC page 

Section 1 Plant Contact Information

A1.1- A1.5 Information for Primary and Secondary 

Technical and Economical Contacts

Make sure all data is provided for Primary and Seconday Contacts for both Technical and Economical Contacts 

Section 1.2 General Plant Operating Characteristics

A1-6 Plant retired If YES, respondent should not have completed questionnaire; check comments.

[Ensure no other answers are completed in Part A; technical review is complete.] 

A1-7 Generation of electricity via steam electric 

generating unit.

If NO, respondent should not have completed questionnaire; check comments.[Ensure no other answers are completed in Part A; technical review is complete.] 

A1-8 Table A-11 Type of fossil fuel used If NONE, respondent should not have completed questionnaire; check comments.

[Ensure no other answers are completed in Part A; technical review is complete.]If a positive reply, confirm Question A1-8 and Table A-11 are consistent.

A1-9 Electricity uses/handling Ensure answers = 100% 

A1-10 NAICS Code Ensure at least a primary NAICS code is identified A1-11 Primary Purpose If NO, check to be sure reason given is reasonable. If so, respondent should not have 

finished questionnaire; check comments.[Ensure no other answers are completed in Part A; technical review is complete.]

A1-12 Steam Usage Ensure answers = 100% 

Table A-1 Net and Gross Electrical Generation 2007-

2009

Ensure net generation is less than gross generation. 

Section 2.1 Plant Identification, Permits, Studies

A2-1 - A2-2 Indentification code Ensure fields are complete (EIA IDs can be 1 to 5 digits long 

A2-3 Table A-2 EA or EIS If NO skip to A2-4 and Table A2 

Table A-2 Permit Information Check comments carefully to be sure stormwater permits are properly classified 

(individual permits listed under NPDES, general permits listed under Stormwater) 

Section 2.2 Outfall Information May have multiple copies to account for multiple outfalls

A2-5 Latitude/Longitude Ensure lat/long coordinates are provided in degrees . If not, calculate the lat/long in 

these units. 

A2 5- Discharge Flo Di h Fl w E d l If h l d fl i l i l l b h Ensure data are complete. If the plant reported flow in multiple columns, be sure the

data are consistent. 

A2-6 Section 3 Internal or Final Outfall If INTERNAL outfall, skip to Section 3 for specific outfall information (remember there

may be multiple outfalls) 

A2-7 Discharge canal Answer YES or NO A2-8 Receiving water Ensure all data are completed A2-9 Mixing zone Answer YES or NO 

A2-10/Table A-3 Percent contribution of wasterwater Answers should = 100%. Note if emergency outfall box is checked. 

Section 3 Ponds or Impoundments

Entire Section Part D, F, & G (if 

required) Ensure ponds reported in Parts D, F, & G are reported consistently with Table A-4 

A3-1 Section 4 Ponds or Impoundments If NO, skip to Section 4 

Pond identification Ensure all data are complete Latitude/Longitude Ensure lat/long coordinates are provided in degrees . If not, calculate the lat/long in 

these units. 

A3-3 and Table A5 Table A-4 Pond wastewater identification Ensure data are provided for each pond identified in Table A-4 

Section 4 Landfills

Entire Section Parts F & G (if 

required) Ensure landfills reported in Parts F & G are reported consistently with Table A-6 

A4-1 Section 5 Landfills If NO, skip to Section 5 

Landfill identification Ensure all data are complete Latitude/Longitude Ensure lat/long coordinates are provided in degrees . If not, calculate the lat/long in 

these units. 

A4-3 and Table A7 Table A-6 Landfill wastestream identification Ensure data are provided for each landfill identified in Table A-6 

Section 5 Plant Property and Water Balance

A3-2 and Table A4 Table A-5

A4-2 and Table A- Table A-7

6
Entire Section Section 4 Ensure that all ponds/impoundments and landfills entered in Tables A-4 and A-6 are 

referenced here 

Location of plant If a nuclear unit is present, ensure box is checked and coordinates are not provided. Latitude/Longitude Ensure lat/long coordinates are provided in degrees . If not, calculate the lat/long in 

these units. Ensure map has been provided and covers buildings, ponds/impoundments, landfills and any significant features. NOTE: if one or more nuclear units are on-site, no map is required.

Check that map file has plant ID in name If a hard copy map is provided, ensure plant ID is on every page in upper right corner. Ensure diagram has been provided and covers water balance diagram number, plant id info, all SEGUs designated in Table A-8, all wastewater treatment systems and discharge pts, and flow ratesCheck that map file has plant ID in name If a hard copy diagram is provided, ensure plant ID is on every page in upper right corner.

Section 6 Steam Electric Generating Unit Information

A6-1 and Table A8 Table A-1 SEGU information Ensure all data are complete including OTHER information if appropriate. Check that the sum of Total Unit Electric Generation for all rows in Table A-8 is less than or equal 

to the Gross Electrical Generation in Table A-1 for 2009

A6-2 and Table A9 Question A1-13 SEGU information Ensure all data are complete including OTHER information if appropriate. 

Section 7 Condenser Cooling Water Systems

Ensure all data are complete including OTHER information if appropriate 

Ensure that a cooling water system is reported for all SEUs listed in Tables A-8 and A9. 

A7-2 Demonstrate compliance Ensure all data are complete including OTHER information if appropriate. A7-3 POTW Effluent Ensure question is answered. 

Section 8 Fuel Usage May have multiple copies to account for multiple SEGUs

Ensure all data are complete including OTHER information if appropriate Check that a copy of Table A-11 exists for each SEGU listed in Table A-8 Check that the total BTUs generated equals the total fossil/nuclear BTUs + total "other" BTUs.Check that the BTU Generated by Gas is approximately nine orders of magnitude 

greater than the sum of the Amount (Million ft3) of Gas values 

Check that the BTU Generated by Coal and/or Petroleum Coke is approximately seven orders of magnitude greater than the sum of the Amount (tons) of Coal and Petroleum Coke values.Check that the BTU Generated by Oil is approximately six orders of magnitude greater than the sum of the Amount (barrels) of Oil values 

Types and amounts of fuel used

Table A-8, D-1, 

D-2

Water balance diagram

A8-1 and Table A11 Table A-8

A5-2 Aerial Map

A7-1 and Table 7- Tables A-8/A-9 Condenser cooling water systems

10

A5-3A5-1

( )

Ensure that units are specified for other fuels 

Check that the value for Amount (Million ft3) for gas is approximately three orders of magnitude less than the order of magnitude of the Quantity of Fuel Burned in Table I-22 for the FY 2009 row that lists the same gas as the Primary Energy Source for the given SE Unit ID. Note that Part I is located on the CBI network in the "Part I Deliveries" folder. Do not make any changes to Part I for discrepancies; instead, flag for follow up with the plant.Following contact with the plant, if the Part I information is determined to be incorrect, add the correction to the "Abt Part I Corrections.xls" file, located in the Part I Deliveries 

folder

Determine if SEGU is an "Other EGU" If ALL SEGUs in Table A-8 are classified as 'Other EGUs,' respondent does not need to

complete remainder of questionnaire.[Ensure no other answers are completed in Part A; technical review is complete.]

Section 9 NOx Control Systems

A9-1 NOx Control Systems If NO, skip to Section 10 

Table A-12 Table A-8 and A9 Ensure all data are complete including OTHER information if appropriate. Confirm SE Unit IDs reported here are also reported in Tables A-8 or A-9 

A9-2 Table A-12 Offsite Regeneration If offsite SCR catalyst regeneration reported in Table A-12, Table A-13 should be 

completed; otherwise, checkbox above Table A-13 should be checked 

A9-3 Onsite Catalyst Regeneration If NO or NA, skip to Question A9-7 A9-4 Regeneration wastewater Ensure all data are complete and in proper units A9-5 Regeneration wastewater commingling Ensure all data are complete including OTHER information if appropriate A9-6 Section 2.2 Regeneration wastewater destination Ensure all data are complete including OTHER information if appropriate. Confirm 

NPDES outfall number(s) in Section 2.2 

A9-7 Catalyst wash If NO, skip to Section 10 

A8-2 and A8-3 BTU by percent fossil/nuclear fuels 

Predominance of fossil/nuclear fuels
A9-8 Catalyst wash wastewater If NO, skip to Section 10 

A9-9 Catalyst wash wastewater volume Ensure all data are complete and in proper units 

A9-10 Catalyst wash wastewater commingling Ensure all data are complete including OTHER information if appropriate A9-11 Catalyst wash wastewater destination Ensure all data are complete including OTHER information if appropriate. Confirm 

NPDES outfall number(s) in Section 2.2 

Section 10 Flue Gas Mercury Control Systems

Entire Section Section 8, Table 

A-8, Table A-9

Flue gas mercury control systems This section should only report on fossil-fueled EGU; see Section A-8 for classification. 

A10-1 Flue gas mercury control systems If NO, skip to Question A10-3 

Table A-14 Table A-8, Table 

A-9

Flue gas mercury control systems Ensure all data are complete. Confirm SE Unit IDs reported here are also reported in 

Tables A-8 or A-9. 

A10-3 Pilot-scale systems If NO, skip to Section 11 

A10-4 Wastewater If NO, skip to Section 11 A10-5 Technology Ensure all data are complete, if DID NOT ATTACH confirm there is a reason why not. 

Section 11 Carbon Capture Systems

Entire Section Section 8, Table 

A-8, Table A-9

Carbon capture systems This section should only report on fossil-fueled EGU; see Section A-8 for classification. 

A11-1 Carbon capture systems If NO, skip to Section 12 

Table A-15 Table A-8, Table 

A-9

Carbon capture systems Ensure all data are complete. Confirm SE Unit IDs reported here are also reported in 

Tables A-8 or A-9. 

A11-3 Pilot-scale systems If NO, skip to Section 12 

A11-4 Technology Ensure all data are complete, if DID NOT ATTACH confirm there is a reason why not. A11-5 Wastewater Ensure all data are complete A11-6 Wastewater If NO, skip to Section 12; if YES, ensure analytical results are attached or a reason 

given why not. 

Section 12 Wet Electrostatic Precipitator Systems

Entire Section Section 8, Table 

A-8, Table A-9

Wet electrostatic precipitator systems This section should only report on fossil-fueled EGU; see Section A-8 for classification. 

A12-1 Wet electrostatic precipitator systems If NO, skip to Section 13 

Table A-15 Table A-8, Table 

A-9

Wet electrostatic precipitator systems Ensure all data are complete. Confirm SE Unit IDs reported here are also reported in 

Tables A-8 or A-9. 

A12-2 Flow rate, duration, and frequency Ensure all data are complete 

A12-3 Water source Ensure all data are complete including OTHER information if appropriate A12-4 Water criteria Ensure all data are complete including OTHER information if appropriate A12-5 Section 2.2 Wastewater destinations Ensure all data are complete including OTHER information if appropriate. If wastewate

is discharged to surface water, confirm NPDES outfall number(s) in Section 2.2. 

A12-6 Pilot-scale systems If NO, skip to Section 13. 

A12-7 Technology Ensure all data are complete, if DID NOT ATTACH confirm there is a reason why not. A12-8 Characterization samples If NO, skip to Section 13; if YES ensure analytical results are attached or a reason given 

p ,p ; y g why not. 

Section 13 Coal Storage and Processing

A13-1 Coal storage and processing If NO, skip to Question A13-16. 

A13-2 Discharge Ensure number of days is <= 365 days 

If NO, skip to Question A13-4; if YES ensure all data are complete 

Ensure pH values are between zero and 14 

A13-4 Table A-4 Pond/Impoundment If YES, confirm that IDs were reported in Table A-4 

A13-5 Wastewater destinations Ensure all data are complete including OTHER information if appropriate. If wastewate

is discharged to surface water, confirm NPDES outfall number(s) in Section 2.2. Confirm that pond IDs are reported in Table A-4

A13-6 Coal washing If NO, skip to Question A13-8; if YES, ensure all data are complete 

A13-7 Coal wash water destinations Ensure all data are complete including OTHER information if appropriate. If wastewate

is discharged to surface water, confirm NPDES outfall number(s) in Section 2.2. Confirm that pond IDs are reported in Table A-4

A13-8 Coal blending If NO, skip to Question A13-10 

A13-9 Coal blending process wastewater If YES, ensure all data are complete. Check that number of days is <=365 days 

A13-10 Coal pulverizing If NO, skip to Question A13-16 A13-11 Coal pulverizing process wastewater If NO, skip to Question A13-12; if YES, ensure all data are complete. Check that 

number of days is <=365 days. 

A13-12 Coal pulverizing process wastewater If NO, skip to Question A13-14; if YES, ensure all data are complete. Check that 

number of days is <=365 days. 

A13-13 and 14 Sluicing and pyritics Ensure data are complete 

A13-15 Disposal of mill rejects Ensure all data are complete including OTHER information if appropriate. Confirm that 

pond IDs are reported in Table A-4 and landfill IDs are reported in Table A-6. 

A13-16 and 17 IGCC generating unit Ensure data are complete 

Comments

A13-3 pH
Entire Section Check that all comments have a question number identified and the comment is 

understandable. 

Entire Section Resolve comments that indicate a change must be made to any electronic response. 
Part B Name Date(s) Reviewed

Reviewer No. 1Reviewer No. 2Status of Review

Questionnaire 

Part/Section/ 

Question 

Number

Copy Number Related Section Type of Information Coding and Review Activity First Reviewer Comments Second Reviewer 

Part B FGD Systems

TOC Ensure that plant name and ID have been populated in the TOC page 

Section 1 General FGD System Information

B1-1. If NO was selected check that the plant did not complete the remainder of Part B. 

Tables A-8 and A9 FGD System ID For FGD that range from FGD 1-6 (FGD systems currently operating), check against date system brought online, and the SE Unit selected (SE 1-10 would be selected). 

Tables A-8 and A9 FGD System ID For FGD that range from FGD A-C (FGD systems planned to operate), check against date system brought online, and the SE Unit selected (SE A-D would be selected). 

FGD System ID Confirm that the plant selected a unique FGD system ID for each completed row in 

Table B-1. 

Steam Electric Units Check that the plant has provided information in Tables A-8 and A-9 for all steam 

electric units checked. 

Type of Oxidation... AND Does (or Will) the System Generate a FGD Slurry Blowdown

Check that if the plant selected “Not Applicable” in the “Type of Oxidation...” column that the plant also selected “No” in the “Does (or Will) the System Generate a FGD Slurry Blowdown” column

 Type of FGD System AND/OR Type of Sorbent

Confirm that if the plant selected "Other," it is specified in the appropriate cell. 

Sulfur Dioxide Removal Efficiency Check that the value is reasonable. Typically, these SO2 removal efficiencies are 95% 

or greater.

Section 2 Planned FGD System Information

B2-1 FGD System ID Confirm that the plant included a row for all FGD systems in Table B-1 whose planned 

online date was after 12/31/2020 (Table B-1, column 2) and who answered yes the system generates FGD slurry blowdown (Table B-1, column 4).

Planned Solids Handling... AND Type of Wastewater Treatment System...

In the “Planned Solids Handling...” and “Type of Wastewater Treatment System...” columns: Check that the codes provided match with codes provided in the Code Tables Tab and that multiple entries are separated by commas

Design Flow Rate If the plant provided responses in units other than those specified in the table, perform a 

calculation to convert the value into the specified units (see the General Coding Guidelines)

Estimated Date Check that the date is in the appropriate form (i.e., mm/yyyy) 

Table B-1 FGD System ID Confirm that the plant has selected each of the FGD systems designated FGD A-C 

ONLY listed in Table B-1 in at least one of the rows 

Section 3 FGD Additive

FGD System ID Confirm that the plant has provided information in Table B-1 for the FGD Systems 

checked. 

Purpose of Additive Confirm that if the plant selected "Other," it is specified in the appropriate cell. 

Section 4 Wet FGD System Information May have multiple copies to account for multiple wet FGD systems.

B4-1 Table B-1 If NO is selected in question B4-1, check that the plant did not complete the remainder 

of Section 4. 

All Copied 

Section 4 Tabs

Confirm that the plant completed Section 4 for all wet FGD systems reported in Table B

1 (i.e., the plant checked yes in the “Does (or Will) the System Generate a FGD Slurry Blowdown...” column). Confirm that the plant wrote the appropriate FGD System ID in the proper form (i.e., FGD-#) at the top of each copied Section 4 tab. 

B4-2 Operating concentration of chlorides The chloride operating concentration range should be 2,000 - 40,000 ppm 

FGD system max. design chlorides conc The chloride operating concentration should be no larger than ____ ppm FGD equipment that determines max. design conc.

Confirm that if the plant selected "Other," it is specified in the appropriate cell. For each box that was selected, check that the plant provided the appropriate information. 

If the plant provided responses in units other than those specified, perform a calculation to convert the value into the specified units (see the General Coding Guidelines) Confirm that if the plant selected "Other," it is explained in the appropriate cell For each box that was selected, check that the plant provided the appropriate information. 

B4-5 Water sources

B1-2./Table B-1

B4-4 FGD system parameters

B2-1/Table B-2

B4-3

B3-1/Table B-3 Table B-1
If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines) Confirm that if the plant selected "Other," it is explained in the appropriate cell 

B4-6 Flow rate/duration/frequency If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines). 

B4-7 Flow rate/duration/frequency If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines). 

B4-8 Flow rate/duration/frequency If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines). 

B4-9 Flow rate/duration/frequency If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines). 

B4-10 Mist eliminator If "Other" is selected in the "Process Wastewater" dropdown box or if the “Other, 

explain” checkbox was selected confirm that a description was provided in the appropriate cell.

B4-11 FGD reagent prepartation water If "Other" is selected in the "Process Wastewater" dropdown box or if the “Other, 

explain” checkbox was selected confirm that a description was provided in the appropriate cell.

B4-12 Absorber make-up water If "Other" is selected in the "Process Wastewater" dropdown box or if the “Other, 

explain” checkbox was selected confirm that a description was provided in the appropriate cell.

% FGD Solids Check that the percentage of FGD solids generated is provided for all checkboxes 

selected and that this percentage sums to 100% 

Other Confirm that if the plant selected "Other," it is explained in the appropriate cell 

B4-14 If NO is selected, check that the plant skipped to Question B4-16 B4-16 Other Confirm that if the plant selected "Other," it is explained in the appropriate cell B4-17 Other Confirm that if the plant selected "Other," it is explained in the appropriate cell B4-18 Concentrations If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines) For each box that was selected, check that the plant provided the appropriate information. Confirm that if the plant selected "Other," it is explained in the appropriate cell If the plant provided responses in units other than those specified, perform a calculation to convert the value into the specified units (see the General Coding Guidelines) 

Section 4, Tables Wet FGD System Information -- TABLES May have multiple copies to account for multiple wet FGD systems.

Amount Disposed (tons) If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines) 

All Except for the “Other, explain” rows if there is no description provided, all rows should 

be fully completed. Where appropriate, fill all empty cells in these rows with a zero. 

Tons/Gross Revenue Generated ($) If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines) 

All All rows the plant selected a destination for should be fully completed. Where 

appropriate, all empty cells in these rows should be filled in with a zero 

Total Confirm that the sum of the partial costs add up to the total cost for 2005, 2007, and 

2009. 

Other Confirm that if the plant selected "Other," it is explained in the appropriate cell. 

Section 5 FGD Wastewater Generation

FGD System ID Information provided only for operational wet FGD systems (FGD 1-10 that also 

selected "Yes" in the “Does (or Will) the System Generate a FGD Slurry Blowdown...” cells in table B-1).

Percent and Flow Rate If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines) 

Percent For each FGD system confirm that the percentages sum to 100% FGD System ID Information provided only for operational wet FGD systems (FGD 1-10 that also 

selected "Yes" in the “Does (or Will) the System Generate a FGD Slurry Blowdown...” cells in table B-1).

All If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines) 

B5-2/Table B-8 Table B-1B5-1/Table B-7 Table B-1

B4-21/Table B-5B4-22/Table B-6

Parameters

B4-20/Table B-4 Table A-4

B4-13B4-19
Chlorides and TSS concentrations For pollutants checked, confirm that the ppm was provided 

ppm If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines) 

Section 6 FGD Monitoring Data Instructions May have multiple copies to account for multiple FGD scrubber purge streams.

B6-1 If NO is checked, question Section 6 should be skipped 

Any information provided should be for (some/all/none) wet FGD systems reported in Table B-1 (i.e., the plant checked yes in the “Does (or Will) the System Generate a FGD Slurry Blowdown...” column).

Check that the plant has provided information in Table B-1 (FGD 1-10) or in Table A-8 for all checked FGD systems and all checked steam electric units 

Measured Value, Method Detection, Reporting Limit, Flow Rate

If the plant provided responses in units other than those specified, perform a calculation to convert the value into the specified units (see the General Coding Guidelines) 

CAS Number Check that the CAS number has no more than 10 digits and is seperated into 3 parts by 

hypens. 

Measured Value including Units AND Method Detection Limit

Check that the measured value entered is a number greater than or equal to the method detection limit. If the measured value is less than the method detection limit, the method detection limit value preceded by a less than (<) symbol (i.e., <#) should be entered into 

the “Measured Value Including Units” column.

Date Sample Collected Check that the date is provided in the appropriate form (i.e., mm/dd/yyyy) Flow Rate of... Check to see that this flow rate is reasonable by comparing it to the flow rate provided 

in Table B-8 for the appropriate FGD systems. 

Analyzed as Total... Check to make sure one is selected only if a metal analyte is listed. 

Section 7 FGD Wastewater Treatment

B7-1 Table B-1 If NO is checked, the next question answered should be B7-4 

B7-2 Other Confirm that if the plant selected "Other," it is explained in the appropriate cell B7-3 Other Confirm that if the plant selected "Other," it is explained in the appropriate cell B7-4 Other Confirm that if the plant selected "Other," it is explained in the appropriate cell 

Recycled back Description provided on how it is reused. Discharged NPDES permitted outfall number 

Confirm that if the plant selected "Other," it is explained in the appropriate cell If NO is checked, the remainder of Section 7 should be skipped If YES is checked, the volume and frequencey should be entered 

Reused in other processes Description provided on how it is reused. Transferred Checked all that apply and if "Other, explain" is selected, there is an explinatio 

Discharged NPDES permitted outfall number 

Other Confirm that if the plant selected "Other," it is explained in the appropriate cell. 

Section 8 Dry FGD System May have multiple copies to account for multiple dry FGD systems.

B8-1 Table B-1 If NO is checked, the remainder of Part B should not be completed 

All Copied 

Section 8 Tabs

Confirm that the plant completed Section 8 for all dry FGD systems reported in Table B1 (i.e., the plant checked no in the “Does (or Will) the System Generate a FGD Slurry Blowdown...” column). Confirm that the plant wrote the appropriate FGD System ID in the proper form (i.e., FGD-#) at the top of each copied Section 8 tab.

B8-2 Other Confirm that if the plant selected "Other," it is explained in the appropriate cell 

Chlorides conc. and solids % For each box that was selected, check that the plant provided the appropriate 

information. 

ppm or % If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines) 

Other Confirm that if the plant selected "Other," it is explained in the appropriate cell 

B8-5 gpm/hpd/dpy If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines) 

B8-6 Other If "Other" is selected in the "Process Wastewater" dropdown box or if the “Other, 

explain” checkbox was selected confirm that a description was provided in the appropriate cell.

B8-7 If NO is checked, the next question answered should be B8-9 

Reused in other processes Description provided on how it is reused. Transferred Checked all that apply and if "Other, explain" is selected, there is an explinatio 

Discharged NPDES permitted outfall number Other Confirm that if the plant selected "Other," it is explained in the appropriate cell 

If NO is selected, the next question answered should be B8-11 

If YES is checked, the volume and frequencey should be entered 

B8-8 Part A, Section 

2.2

B8-9B7-7 Part A, Section 

2.2

B8-4B7-6

B6-2, Table B-9 Tables A-8 and B1

B7-5 Part A, Section 

2.2

B5-3
Reused in other processes Description provided on how it is reused. 

Transferred Checked all that apply and if "Other, explain" is selected, there is an explinatio 

Discharged NPDES permitted outfall number Other Confirm that if the plant selected "Other," it is explained in the appropriate cell 

Parameters For parameters checked, confirm that the ppm was provided Other Confirm that if the plant selected "Other," it is explained in the appropriate cell Amount Disposed (tons) If the plant provided responses in units other than those specified, perform a calculation 

to convert the value into the specified units (see the General Coding Guidelines) 

All All rows the plant selected a destination for should be fully completed. Where 

appropriate, all empty cells in these rows should be filled in with a zero 

Other Checked all that apply and if "Other, explain" is selected, there is an explination Total Confirm that the sum of the partial costs add up to the total cost for 2005, 2007, and 

2009. 

Other Confirm that if the plant selected "Other," it is explained in the appropriate cell. Total Confirm that the sum of the partial costs add up to the total cost for 2005, 2007, and 

2009. 

Other Confirm that if the plant selected "Other," it is explained in the appropriate cell. 

Comments

Entire Section Check that all comments have a question number identified and the comment is 

understandable. 

Entire Section Resolve comments that indicate a change must be made to any electronic response. 

B8-13/Table B11B8-14/Table B12

B8-11

B8-12/Table B10

B8-10 Part A, Section 

2.2
Section C Name

Date(s) Reviewed

Reviewer No. 1Reviewer No. 2Status of Review

Questionnaire 

Part/Section/ 

Question 

Number

Copy Number Related Section Type of Information Coding and Review Activity First Reviewer Comments Second Reviewe

Part C Ash Handling Systems

TOC Ensure that plant name and ID have been populated in the TOC page 

Section 1 Ash Generation 

If NO, check that the plant did not check “Fly ash” or “Bottom ash” for any ponds in Table A-5 If NO, check that the plant did not check “Fly ash” or “Bottom ash” for any landfills in Table A-7 If NO, the remainder of Part C should not be completed; check comments[Ensure no other answers are completed in Part C] 

C1-2 Plant acreage Make sure the Total Plant Area acreage is equal to the sum of all the other acreages 

provided in Table C-1. If NO, check that the plant did not check “Fly ash” for any ponds in Table A-5 If NO, check that the plant did not check “Fly ash” for any landfills in Table A-7 If NO is checked for question C1-3, the remainder of Part C, Section 2 should not be completed.[Ensure no other answers are completed in Part C, Section 2]

Section 2.1 Fly Ash Handling – System Level 

Information

May have multiple copies to account for multiple steam electric generating units.

General Table A-8 Number of Copies Check that there is a copy of section 2.1 for each steam electric generating unit 

operated at any time in 2009 as reported in Table A-8. For each copy of section 2.1 that the respondent creates, copy and paste all the checklist questions for section 2.1 and label the Copy Number appropriately.Note that section 2.1 will not need to be completed for gas or nuclear units and only for a portion of the oil units. If a unit listed in Table A-8 doesn't have an associated 

Generation of ash in any fossil-fueled steam electric generations units located at the plant. Generation of fly ash in any fossil-fueled steam electric generations units located at the plant.

Table A-5Table A-7Table A-5Table A-7

C1-1 C1-3

worksheet for Section 2.1, check the fuel usage from Table A-11 to make sure that it is a gas, nuclear, or oil fired unit.Only applicable rows need to be completed for the Type of Fly Ash Collection and Type of Fly Ash Handling (i.e., there may be empty rows in these columns). Ensure all other data are complete including OTHER information if appropriate.If “Wet scrubber(s) (only) is selected, the remainder of Part C, Section 2 should not be completed.[Ensure no other answers are completed in Part C, Section 2]Check that the “typical amount of fly ash produced in 2009” is less than or equal to the “design ash handling rate” (both tpd and dpy). 

C2-2 Wet fly ash handling C2-3 through C2-5 should only be answered if C2-2 is answered "Yes". If "Yes is 

marked, all fields should be populated. Ensure all data are complete including OTHER information if appropriate. Check that "Percent Contribution of Source to Sluice Water Flow" values sum to 100% 

C2-3 Maximum Chloride Concentration and 

Maximum Solids Percentage.

Check that corresponding fields are completed for each box checked. 

C2-4 POTW Check that if "Yes" is selected, a description is provided. C2-5 POTW Ensure an answer is selected. C2-6 Wet Vacuum System (pneumatic) Check that if "Yes" is selected, questions C2-7 and C2-8 are answered, otherwise 

ensure respondent skipped to C2-9. Check that corresponding fields are completed for each box checked. 

Fly ash handling systems operated in 2009.Process Wastewater Generated from Wet Fly Ash Handling in 2009

C2-8 Wet Vacuum System (pneumatic)

Table C-3Table C-2
If respondent checks "Discharged to surface water", check that NPDES permitted 

outfall number provided matches one of the copies of Part A section 2.2 Check that corresponding fields are completed for each Storage Destination selected. Check that "Percent of Dry Conveyed Fly Ash to this Destination" values sum to 100% Check that "Percent of Wet Conveyed Fly Ash to this Destination" values sum to 100% 

C2-10 Fly ash handled by both wet and dry fly ash 

handling systems.

Check that if "Yes" is selected, questions C2-11 and C2-12 are answered. Otherwise respondent should skip to C2-13. For each reason that is checked, make sure the number of days is provided. Check that the sum of the "days" fields do not sum to greater than 365. If “Design/develop new infrastructure...” is selected, make sure that the respondent specifies the new infrastructure needed. If “other” is selected, make sure that the respondent provides an explanation. If “Decreased use...” is selected, make sure that the respondent provides the expected operating days. If “End use...” is selected, make sure that the respondent provides the expected end date. If “other” is selected, make sure that the respondent provides an explanation. If either "NA" or "No" is selected, make sure that the respondent skips to question C2-17. If "Yes" is selected, make sure that the respondent has answered the remainder of question C2-14 and C2-15. If “The retrofit was made to an existing dry system” is checked for question C2-15, respondent should continue answering questions starting with C2-23. If “A dry fly ash handling system was installed (for operation in addition to the wet fly ash handling system)” or “The retrofit was a complete conversion from a wet to dry fly ash handling system” is checked for question C2-15, question C2-16 should be completed.

C2-16 Changes required for installed retrofit Check that corresponding fields, where applicable, are completed for each checkbox 

that is selected. If "Yes" is selected, make sure that the respondent has entered a value for "Estimated shutdown time (days) required to bring dry fly ash handling system online" and skipped to Question C2-19.If "No" is selected, make sure that the respondent continued to Question C2-18. If "Yes" is selected, make sure that the respondent has entered a value for "Estimated 

shutdown time (days) required to bring dry fly ash handling system online" and 

Table C-4 Storage Destinations that Receive Fly Ash

Reason fly ash was handled wet and dry.

C2-12 Modifications required to handle all ash 

dry.

C2-11

Changes in fly ash handling expected.

C2-14 Fly ash handling installed as retrofit.C2-13

Plan to install dry fly ash handling by 

December 31 2020

C2-17 In the process of installing dry fly ash 

handling

C2-15 Fly ash handling installed as retrofit.C2-18

shutdown time (days) required to bring dry fly ash handling system online" and

continued to Question C2-19.

If "No" is selected, make sure that the respondent skipped to Question C2-22. If YES is checked and “I have attached...” are checked, make sure the documentation/costs are provided. If YES is checked and “I did not attach...” are checked, make sure that the respondent provides an explanation. If NO is checked, the remainder of Question C2-19 should be blank and the respondent should skip to Question C2-22 

C2-20 Changes that will be required for planned 

retrofit

Check that corresponding fields, where applicable, are completed for each checkbox that is selected. If “Marketed, sold...” and “If other, specify” are selected, make sure treatment system is identified. Make sure that the “% of the dry fly ash” is provided for each dropdown completed and each box selected. If “Other” is selected, make sure that the respondent provides an explanation. If YES is checked and “I have attached...” are checked, make sure the documentation/costs are provided. Make sure that if YES is checked and “I did not attach...” are checked, make sure that the respondent provides an explanation. If NO is checked, the remainder of Question C2-22 should be blank. If NO is checked for question C2-23, Table C-5 should be blank. Respondent should continue answering questions starting with C2-25. If YES is checked for question C2-29, Table C-5 should be complete. 

Unscheduled generating unit outages due to the wet fly ash handling systems in the last 5 years.

C2-22 Consideration of dry fly ash system.C2-23 Table C-5C2-21 Expected destinations for dry fly ashC2-19 Provide cost estimates for 

conversion/installation

December 31, 2020.
C2-24 Unscheduled generating unit outages due to 

the wet fly ash handling systems in the last 5 years.

Check that any row that has a value listed for the "Total Days of Outage" has explanations for the "Reason(s) for outage(s)" and "Method(s) Used to Resolve Outage(s)" fields.

Section 2.2 Fly Ash Handling – Storage and Use Data

Check that Table C-6 has destination information for each storage destination listed in Table C-4. Check all copies of Table C-4. If Table C-4 contains only destinations marked “intermediate” and Table C-6 does not contain any other destinations, follow up is required. If Table C-6 does not contain “final” destinations (i.e., ponds, landfills in Table A-6, landfills not in Table A-6, marketed, or other with description of a final destination) follow up is required.Only applicable rows need to be completed (i.e., Storage Destination 2 row may be empty). Check that the sum of Wet & Dry Conveyed tpd multiplied by the dpy, from all the copies of Table C-2, is generally less than or equal to the sum of the Tons of Fly Ash Transported to Destination in 2009 in Table C-6.If “other” is selected in any of the dropdowns in the “Type of destination” column, make sure that the respondent provides an explanation for each “other” option selected.If NO is checked for question C2-26, Table C-7 should be blank. Respondent should continue answering questions starting with C2-28. If YES is checked for question C2-26, Table C-7 should be complete. Confirm that Table C-7 contains all destinations required in Table C-4. Check that if the box next to either of the process wastewaters dropdowns is checked, the appropriate dropdown is completed. If “Other” is selected in either dropdown, make sure that the respondent provides an explanation in the appropriate free response box. If chlorides concentration is selected, makes sure a ppm value is provided.If Solids percentage is selected, makes sure a percentage is provided. If “Other” is selected, make sure that the respondent provides an explanation.

Table C-7 Table C-4 Fly ash handling systems operated in 2009.

Is water used to moisten the fly ash?

Table C-6 Table C-4 Dry fly ash storage destination information.

C2-26 Table C-4

C2-27 Criteria for water used to moisten ash Check that the respondent properly defined the criteria used to determine if a water

source is unacceptable for use to moisten ash. If NO is checked for question C2-28, Table C-8 should be blank. Respondent should continue answering questions starting with C2-29. If YES is checked for question C2-28, Table C-8 should be complete. 

Table C-8 Marketing of fly ash from dry ash handling 

system

Only applicable rows need to be completed (i.e., some rows may be empty). Ensure that if C2-27 is YES, respondent has provided at least one row of data. If NO is checked for question C2-29, Table C-9 should be blank. Respondent should skip to Section 2.3. If YES is checked for question C2-29, Table C-9 should be complete. 

Table C-9 Marketing of fly ash from wet ash handling 

system

Only applicable rows need to be completed (i.e., some rows may be empty). Ensure that if C2-29 is YES, respondent has provided at least one row of data. 

Section 2.3 Fly Ash Cost Information – Conveyance May have multiple copies to account for multiple fly ash handling systems. 

Despite no specific kickout question, this section will be blank for the majority of plants because their conveyance system did not "begin operating or was converted after January 1, 2000."

General C2-17

C2-18

Installing or planning to install dry fly ash handling system

For each copy of questions C2-17 or C2-18 that are answered "Yes", check that one of the copies of section 2.3 has the checkbox associated with "Planned" marked and the appropriate fields populated.

Marketing of fly ash from dry ash handling system

C2-28C2-29 Marketing of fly ash from wet ash handling 

system
General Comments Multiple units using the same fly ash 

handling system

Check the comments section related to section 2.3 to see if the plant has multiple units utilizing the same ash handling system. If that is the case, flag for follow-up to ensure that the situation is properly represented in our database for modeling purposes. Additionally, ensure that the respondent only listed the shared components on one copy of Section 2.3If “Other” is selected for Type of Component, make sure that the respondent provides an explanation. If “Other” is selected for the units for Total System Capacity of Component, make sure that the respondent provides an explanation. Check that there is a value for Number of Components in the System and Total System Capacity of Component for each Type of Component specified. 

C2-31 Fly ash 

handling 

diagram 

attachment

Fly ash handling diagram attachment If YES is checked and “I have attached...” are checked, make sure the 

documentation/costs are provided.Check that all fields have a value (some may be $0) and make sure that all values make logical sense (i.e. the year on which the modification cost is based is >= 2000) Check that if components are listed in C2-32 or C2-33 that "Other Contractor's Fees" or "Engineering Costs" have values greater than $0. 

C2-35 Major conveyance components If "No" is checked, make sure the respondent provided explanations of what system 

components are and are not included. 

Table C-12 O&M Cost for Conveyance of Fly Ash 

Handling for 2009

Check that all fields have a value (some may be $0) and make sure that all values make logical sense 

Section 2.4 Fly Ash Cost Information – Intermediate 

Storage

May have multiple copies to account for intermediate fly ash storage systems.Despite no specific kickout question, this section will be blank for the majority of plants because their intermediate fly ash storage systems did not "begin operating or was modified after January 1, 2000."

General C2-17

C2-18

Installing or planning to install dry fly ash handling system

Check that if questions C2-17 or C2-18 are answered "Yes", check that one of the copies of section 2.4 has the checkbox associated with "Planned" marked and the appropriate fields populated.

C2-37 Bottom and fly ash shared storage If "Yes" is checked, verify the unit IDs are populated and consistent with Table A-8 

If YES is checked for question C2-38, Table C-13 should be blank. Respondent should skip to Section 2.5. 

Capital cost for conveyance of fly ash handling

C2-38 Table A-4 Storage destination pond/impoundment?

Table C-11Table C-10 Table C-4 Fly ash system components - conveyance

C2-32C2-33

If “Yes”, confirm that the storage ID is for a pond/impoundment listed in Table A-4. If NO is checked for question C2-38, Table C-13 should be complete. If “Other” is selected for Type of Component, make sure that the respondent provides an explanation. If “Other” is selected for the units for Total System Capacity of Component, make sure that the respondent provides an explanation. Check that there is a value for Number of Components in the System and Total System Capacity of Component for each Type of Component specified. Check that all fields have a value (some may be $0) and make sure that all values make logical sense (i.e. the year on which the modification cost is based is >= 2000) Check that if components are listed in C2-40 or C2-41 that "Other Contractor's Fees" or "Engineering Costs" have values greater than $0. 

C2-43 Major intermediate storage components If "No" is checked, make sure the respondent provided explanations of what system 

components are and are not included. 

Table C-15 O&M Cost for Intermediate Storage of Fly 

Ash Handling for 2009

Check that all fields have a value (some may be $0) and make sure that all values make logical sense 

Section 2.5 Fly Ash Cost Information – Transport 

and Disposal

Despite no specific kickout question, this section will be blank for the majority of plants because their transport/disposal systems did not "begin operating or was modified after January 1, 2000."

C2-45 Bottom and fly ash shared transport and 

disposal

If "Yes" is checked, verify the unit IDs are populated and consistent with Table A-8 

Table C-14 C2-40

C2-41

Capital cost for intermediate storage of fly ash handling

Table C-13 Fly ash system components - intermediate 

storage
If YES is checked for question C2-46, confirm that a pond/impoundment is included 

in Table C-6. The remainder of section 2.5 should be blank. Respondent should skip to Section 3.1.If NO is checked for question C2-46, respondent should proceed to C2-47. Check that the respondent has identified at least one method of transportation. Check that the respondent has identified the number of units for each method of transportation selected. Check that the respondent has identified whether the units are bought, leased, or contracted out for each method of transportation selected. Check that all fields have a value (some may be $0) and make sure that all values make logical sense (i.e. the year on which the modification cost is based is >= 2000) Check that if components are listed in C2-48 or C2-49 that "Other Contractor's Fees" or "Engineering Costs" have values greater than $0. 

C2-51 Major transportation components If "No" is checked, make sure the respondent provided explanations of what system 

components are and are not included. 

Table C-17 O&M Cost for Transportation of Fly Ash 

collection for 2009

Check that all fields have a value (some may be $0) and make sure that all values make logical sense 

Section 3.1 Bottom Ash Handling – Generating Unit 

Level Information

May have multiple copies to account for multiple steam electric generating units.

General Table A-8 Number of Copies Check that there is a copy of section 3.1 for each steam electric generating unit 

operated at any time in 2009 as reported in Table A-8. For each copy of section 3.1 that the respondent creates, copy and paste all the checklist questions for section 3.1 and label the Copy Number appropriately

If NO is checked for question C3-1, check that the plant did not check “Bottom ash” for any ponds in Table A-5 If NO is checked for question C3-1, check that the plant did not check “Bottom ash” for any landfills in Table A-7 If NO is checked for question C3-1, the remainder of Part C, Section 3 should not be completed.[Ensure no other answers are completed in Part C, Section 3]Only applicable rows need to be completed for the Type of Fly Ash Collection and Type of Fly Ash Handling (i.e., there may be empty rows in these columns). Ensure that the respondent has selected at least one "Type of Bottom Ash Handling System" and all other data are complete including OTHER information if appropriate.Check that the “typical amount of fly ash produced in 2009” is less than or equal to the “design ash handling rate” (both tpd and dpy). 

C2-46 Table C-6 Is a pond/impoundment the final 

destination?

C2-47 Method of transportation to final 

destination

Table C-16 C2-48

C2-49

Capital cost for transportation of fly ash collectionBottom ash handling systems operated in 2009 by generating unit.

C3-1 Table A-5

Table A-7

Generation of bottom ash in any fossilfueled steam electric generations units located at the plant.

Table C-18

If NO is checked for question C3-3, confirm that “wet sluicing” was not selected in Table C-18. If NO is checked for question C3-3, the respondent should skip to C3-11. If YES is checked for question C3-3, the respondent should complete Table C-19. Check that the respondent entered values for the "Average Sluice Water Flow Rate" and "Typical Duration AND Frequency of Sluicing". Each "Source of Sluice Water" selected should have an associated value in the "Percent Contribution of Source to Sluice Water Flow" column. Check that "Percent Contribution of Source to Sluice Water Flow" values sum to 100% 

C3-4 Maximum Chloride Concentration and 

Maximum Solids Percentage.

Check that corresponding fields are completed for each box checked. 

C3-5 Wet bottom ash sluice immediately 

recycled?

If YES is checked for question C3-5, the respondent should enter a description of how the wet bottom ash sluice is used. 

C3-6 POTW Check that the respondent selected YES or NO. 

If NO is checked for question C3-7, the respondent should skip to C3-11. If YES is checked for question C3-7, the respondent should complete Table C-20. Check that the respondent checked at least one box for the "Solids Removal" and "Bottom Ash Disposal". 

Table C-20 Wet ash sluice systems

C3-7 Solid removal occur at the plant?

Table C-19 Process Wastewater Generated from Wet 

Fly Ash Handling in 2009

C3-3 Wet sluicing used to collect bottom ash?
Check that a description is provided if the respondent checks "other" for the "Solids 

Removal" and "Bottom Ash Disposal". Check that "Amount of Solids Disposed" and "Typical Percent Moisture of Bottom Ash Disposed" values have been entered for each "Bottom Ash Disposal" destination selected. 

C3-9 Amount of water overflow from solid 

removal

Check that value is entered by respondent 

C3-10 Destination of waste water overflow from 

solid removal

If respondent checks "Discharged to surface water", check that NPDES permitted outfall number provided matches one of the copies of Part A section 2.2 If NO is checked for question C3-11, the respondent should skip to C3-15. If YES is checked for question C3-11, check that the respondent provided a description of the process. 

C3-12 Mechanical drag system? If NO is checked for question C3-12, the respondent should skip to C3-15. C3-13 Amount of water overflow from mechanical 

drag system

Check that value is entered by respondent 

C3-14 Destination of waste water overflow from 

mechanical drag system

If respondent checks "Discharged to surface water", check that NPDES permitted outfall number provided matches one of the copies of Part A section 2.2 Check that corresponding fields are completed for each Storage Destination selected. Check that "Percent of Dry Conveyed FlyAsh to this Destination" values sum to 100% Check that "Percent of Wet Conveyed FlyAsh to this Destination" values sum to 100% 

C3-16 Bottom ash handled by both wet and dry fly 

ash handling systems.

Check that if "Yes" is selected, questions C3-17 and C3-18 are answered. For each reason that is checked, make sure the number of days is provided. Check that the sum of the "days" fields do not sum to greater than 365. If “Design/develop new infrastructure...” is selected, make sure that the respondent specifies the new infrastructure needed. If “other” is selected, make sure that the respondent provides an explanation. If “Decreased use...” is selected, make sure that the respondent provides the expected operating days. If “End use...” is selected, make sure that the respondent provides the expected end date. 

If “other” is selected make sure that the respondent provides an explanation 

C3-19 Changes in bottom ash handling expected.C3-18 Modifications required to handle all bottom 

ash dry.

C3-17 Reason bottom ash was handled wet and 

dry.

Table C-21 Storage Destinations that Receive Fly Ash

C3-11 Mechanical drag system?

If “other” is selected, make sure that the respondent provides an explanation. 

If either "NA" or "No" is selected, make sure that the respondent skips to question C3-24. If "Yes" is selected, make sure that the respondent has answered the remainder of question C3-20 and continues to C3-21. If “The retrofit was made to an existing dry system” is checked for question C3-29, respondent should continue answering questions starting with C2-23. If “A dry fly ash handling system was installed (for operation in addition to the wet fly ash handling system)” or “The retrofit was a complete conversion from a wet to dry fly ash handling system” is checked for question C3-21, respondent should continue to C3-22.

C3-22 Changes required for installed retrofit Check that corresponding fields, where applicable, are completed for each checkbox 

that is selected. 

C3-23 Dry bottom 

ash handling retrofit diagram attachment

Dry bottom ash handling retrofit diagram attachment

If “Diagram attached” is checked, make sure the documentation/costs are provided.If "Yes" is selected, make sure that the respondent has entered a value for "Estimated shutdown time (days) required to bring dry fly ash handling system online" and skipped to Question C3-26.If “Yes” to C3-24 confirm that Section 3.3 and 3.4 are completed for the SE Unit. If "No" is selected, make sure that the respondent continued to Question C3-25. 

C3-24 In the process of installing dry bottom ash 

handling

C3-21 Bottom ash handling installed as retrofit.C3-20 Bottom ash handling installed as retrofit.
If "Yes" is selected, make sure that the respondent has entered a value for "Estimated 

shutdown time (days) required to bring dry bottom ash handling system online" and continued to Question C3-26.If “Yes” to C3-25 confirm that Section 3.3 and 3.4 are completed for the SE Unit. If "No" is selected, make sure that the respondent skipped to Question C3-29. If YES is checked and “I have attached...” are checked, make sure the documentation/costs are provided. If YES is checked and “I did not attach...” are checked, make sure that the respondent provides an explanation. If NO is checked, the remainder of Question C3-26 should be blank and the respondent should skip to Question C3-29. 

C3-27 Changes required for installed retrofit Check that corresponding fields, where applicable, are completed for each checkbox 

that is selected. If “Marketed, sold...” and “If other, specify” are selected, make sure treatment system is identified. Make sure that the “% of the dry bottom ash” is provided for each dropdown completed and each box selected. If “Other” is selected, make sure that the respondent provides an explanation. If YES is checked and “I have attached...” are checked, make sure the documentation/costs are provided. Make sure that if YES is checked and “I did not attach...” are checked, make sure that the respondent provides an explanation. If NO is checked, the remainder of Question C3-29 should be blank. If NO is checked for question C3-30, Table C-22 should be blank. Respondent should skip to section 3.2. If YES is checked for question C3-30, Table C-22 should be complete. 

Table C-22 Unscheduled generating unit outages due to 

the wet bottom ash handling systems in the last 5 years.

Check that any row that has a value listed for the "Total Days of Outage" has explanations for the "Reason(s) for outage(s)" and "Method(s) Used to Resolve Outage(s)" fields.

Section 3.2 Bottom Ash Handling - Storing and Use 

Data

Confirm that Table C-23 contains ALL storage destinations and not just the initial storage destinations listed in Table C-21. Check all copies of Table C-21. 

If Table C-21 contains only destinations marked “intermediate” and Table C-23 does not contain any other destinations, follow up is required. If Table C-23 does not contain “final” destinations (i.e., ponds, landfills in Table A-6, landfills not in Table A-6, marketed, or other with description of a final destination) follow up is required.

Table C-23 Table C-18

Table C-21

Bottom ash storage destination information.

C3-30 Table C-5 Unscheduled generating unit outages due to 

the wet bottom ash handling systems in the last 5 years.

C3-29 Consideration of dry bottom ash system.C3-26 Provide cost estimates for 

conversion/installation

C3-28 Expected destinations for dry bottom ashC3-25 Plan to install dry bottom ash handling.

follow up is required.Only applicable rows need to be completed (i.e., Storage Destination 2 row may be empty). Check that the sum of Wet & Dry Conveyed tpd multiplied by the dpy, from all the copies of Table C-18, is less than or equal to the sum of the Tons of Bottom Ash Transported to Destination in 2009 in Table C-23.If “other” is selected in any of the dropdowns in the “Type of destination” column, make sure that the respondent provides an explanation for each “other” option selected.If NO is checked for question C3-33, Table C-24 should be blank. Respondent should continue answering questions starting with C3-34. If YES is checked for question C3-33, Table C-24 should be complete. 

Table C-24 Marketing of bottom ash from dry ash Only applicable rows need to be completed (i.e., some rows may be empty). 

If NO is checked for question C3-34, Table C-25 should be blank. Respondent should skip to section 3.3. If YES is checked for question C3-34, Table C-25 should be complete. 

Table C-25 Marketing of bottom ash from wet ash 

handling system

Only applicable rows need to be completed (i.e., some rows may be empty). Ensure that if C3-34 is YES, respondent has provided at least one row of data. 

Section 3.3 Bottom Ash Handling - Conveyance May have multiple copies to account for multiple bottom ash handling systems. 

Despite no specific kickout question, this section will be blank for the majority of plants because their conveyance system did not "begin operating or was converted after January 1, 2000."

C3-34 Marketing of bottom ash from wet ash 

handling system

C3-33 Marketing of bottom ash from dry ash 

handling system
General C3-24

C2-25

Installing or planning to install dry bottom ash handling system

For each copy of questions C3-24 or C3-25 that are answered "Yes", check that one of the copies of section 3.3 has the checkbox associated with "Planned" marked and the appropriate fields populated.

General Comments Multiple units using the same bottom ash 

handling system

Check the comments section related to section 3.3 to see if the plant has multiple units utilizing the same bottom ash handling system. If that is the case, flag for followup to ensure that the situation is properly represented in our database for modeling 

purposes. Additionally, ensure that the respondent only listed the shared components on one copy of Section 3.3If “Other” is selected for Type of Component, make sure that the respondent provides an explanation. If “Other” is selected for the units for Total System Capacity of Component, make sure that the respondent provides an explanation. Check that there is a value for Number of Components in the System and Total System Capacity of Component for each Type of Component specified. 

C3-36 Bottom ash 

handling 

diagram 

attachment

Bottom ash handling diagram attachment If “Diagram attached” is checked, make sure the document is provided. 

Check that all fields have a value (some may be $0) and make sure that all values make logical sense (i.e. the year on which the modification cost is based is >= 2000) Check that if components are listed in C3-37 or C3-38 that "Other Contractor's Fees" or "Engineering Costs" have values greater than $0. 

C3-40 Major conveyance components If "No" is checked, make sure the respondent provided explanations of what system 

components are and are not included. 

Table C-28 O&M Cost for Conveyance of Bottom Ash 

Handling for 2009

Check that all fields have a value (some may be $0) and make sure that all values make logical sense 

Section 3.4 Bottom Ash Handling - Intermediate 

Storage

May have multiple copies to account for intermediate bottom ash storage systems.Despite no specific kickout question, this section will be blank for the majority of plants because their intermediate fly ash storage systems did not "begin operating or was modified after January 1, 2000."

General C3-24

C2-25

Installing or planning to install dry bottom ash handling system

For each copy of questions C3-24 or C3-25 that are answered "Yes", check that one of the copies of section 3.4 has the checkbox associated with "Planned" marked and the 

Table C-27 C3-37

C3-38

Capital cost for conveyance of bottom ash handling

Table C-26 Table C-4 Bottom ash system components - 

conveyance

appropriate fields populated.

C3-42 Table A-8

Part C, 

Section 2.4

Bottom and fly ash shared storage If “Yes” to C3-42, verify the unit IDs are populated and consistent with Table A-8 and 

confirm that Section 2.4 was completed for the same Storage ID. The respondent should then skip to section 3.5.

If YES is checked for question C3-43, Table C-29 should be blank. Respondent should skip to Section 4. If “Yes”, confirm that the storage ID is for a pond/impoundment listed in Table A-4. If NO is checked for question C3-43, Table C-29 should be complete. If “Other” is selected for Type of Component, make sure that the respondent provides an explanation. If “Other” is selected for the units for Total System Capacity of Component, make sure that the respondent provides an explanation. Check that there is a value for Number of Components in the System and Total System Capacity of Component for each Type of Component specified. Check that all fields have a value (some may be $0) and make sure that all values make logical sense (i.e. the year on which the modification cost is based is >= 2000) Check that if components are listed in C3-45 or C3-46 that "Other Contractor's Fees" or "Engineering Costs" have values greater than $0. 

C3-48 Major intermediate storage components If "No" is checked, make sure the respondent provided explanations of what system 

components are and are not included. 

Table C-30 C3-45

C3-46

Capital cost for intermediate storage of bottom ash handling

Table C-29 Bottom ash system components - 

intermediate storage

C3-43 Table A-4 Storage destination pond/impoundment?
Table C-31 O&M Cost for Intermediate Storage of 

Bottom Ash Handling for 2009

Check that all fields have a value (some may be $0) and make sure that all values make logical sense 

Section 3.5 Bottom Ash Handling - 

Transport/Disposal

Despite no specific kickout question, this section will be blank for the majority of plants because their transport/disposal systems did not "begin operating or was modified after January 1, 2000."

C3-50 Bottom and fly ash shared transport and 

disposal

If "Yes" is checked, verify the unit IDs are populated and consistent with Table A-8. Also check that the respondent checked "Yes" for question C2-45. If YES, confirm that a pond/impoundment is included in Table C-23. The remainder of section 3.5 should be blank. Respondent should skip to Section 4. If NO, respondent should proceed to C3-52. Check that the respondent has identified at least one method of transportation. Check that the respondent has identified the number of units for each method of transportation selected. Check that the respondent has identified whether the units are bought, leased, or contracted out for each method of transportation selected. Check that all fields have a value (some may be $0) and make sure that all values make logical sense (i.e. the year on which the modification cost is based is >= 2000) Check that if components are listed in C3-53 or C3-54 that "Other Contractor's Fees" or "Engineering Costs" have values greater than $0. 

C3-56 Major transportation components If "No" is checked, make sure the respondent provided explanations of what system 

components are and are not included. 

Table C-33 O&M Cost for Transportation of Bottom 

Ash collection for 2009

Check that all fields have a value (some may be $0) and make sure that all values make logical sense 

Section 4 Economizer Ash Handling

General Table A-8 Verify the unit IDs are populated and consistent with Table A-8 for each copy of 

section 4. 

C4-1 Part C, 

Section 5

Economizer has collected with air heater ash?

If “No” to C4-1, confirm that Section 5 is completed. If not, review comments to determine if follow up is required. 

C4-2 Method of handling economizer ash If "Segregated from fly and bottom ash" is selected, check that description is provided 

and C4-3 is blank. 

C4-3 Method of combining economizer ash with 

fly and bottom ash

Check that "Combined with fly and bottom ash" is selected in C4-2 and that a description is provided if "other" is selected. 

C4-4 Amount of economizer ash produced Check that respondent has entered reasonable values. C4-5 Process wastewater generated from 

economizer ash handling

If “No” to C4-5, confirm that question C4-6 was completed. If not, follow up may be required. Check that a percent value is entered for each final destination selected. Check that "% of economizer ash" values sum to 100% 

C4-6 Final destination of economizer ash

Table C-32 C3-53

C3-54

Capital cost for transportation of bottom ash collection

C3-52 Method of transportation to final 

destination

C3-51 Table C-23 Is a pond/impoundment the final 

destination?

Section 5 Economizer Ash Handling

General Table A-8 Verify the unit IDs are populated and consistent with Table A-8 for each copy of 

section 5. 

C5-1 Method of handling air heater ash If "Segregated from fly and bottom ash" is selected, check that description is provided 

and C5-2 is blank. 

C5-2 Method of combining air heater ash with fly 

and bottom ash

Check that "Combined with fly and bottom ash" is selected in C5-1 and that a description is provided if "other" is selected. 

C5-3 Amount of air heater ash produced Check that respondent has entered reasonable values. C5-4 Process wastewater generated from air 

heater ash handling

If “No” to C5-4, confirm that question C5-5 was not completed. If not, follow up may be required. Check that a percent value is entered for each final destination selected. Check that "% of air heater ash" values sum to 100% 

Comments

Entire Section Check that all comments have a question number identified and the comment is 

understandable. 

Entire Section Resolve comments that indicate a change must be made to any electronic response. 

C5-5 Final destination of air heater ash
Part D Name Date(s) Reviewed

Reviewer No. 1Reviewer No. 2Status of Review

Questionnaire 

Part/Section/ 

Question 

Number

Copy Number Related Section Type of Information Coding and Review Activity First Reviewer Comments Second Reviewer Comme

Part D Steam Electric Plant Operations

TOC Ensure that plant name and ID have been populated in the TOC page 

Section 1 Plant Pond/Impoundment Systems and Wastewater Treatment Systems 

D1-1 and D1-2 Pond/impoundment systems and wastewater 

treatment systems located at the plant. 

If YES to at least one question, respondent should have completed the remainder of Part D.If NO for both questions, respondent should not have completed Part D of the questionnaire. Ensure no other answers are completed in Part D; technical review is 

complete.If NO to D1-1, confirm that respondent answered "No" to A3-1.

Section 2 Pond/Impoundment System and 

Wastewater Treatment System Identification

D2-1 Plant involvement with ash or FGD 

wastewater treatment full- or pilot-scale studies.

If NO, questions D2-2 and D2-3 should be skipped. Question D2-4 should be answered. 

D2-3 Plant involvement with ash or FGD 

wastewater treatment full- or pilot-scale studies.

If YES, make sure a copy of the summary/report is attached. Make sure that descriptions cover ash or FGD wastewater treatment technologies.Flag any potentially interesting studies.If NO, make sure an explanation of the study is provided in the free response cell. Make sure that descriptions only cover ash or FGD wastewater treatment technologies.

D2-4 Plant involvement with ash or FGD 

wastewater treatment studies, including 

bench-scale.

Make sure that the response to question D2-4 only covers studies not accounted for in previous questions and that the technologies listed are for ash or FGD wastewater treatment. If YES, both or one of Tables D-1 and D-2 should be completed. Respondent should also complete Section 3.If NO, the remainder of Section 2 and all of Section 3 should not be completed. The respondent should skip to Section 4.1. Ensure no answers are provided in Part D Sections 2 and 3. Confirm that D1-2 is "NO".If there are ponds/impoundments listed in Table A-4 that contain coal combustion byproducts, respondents should answer "YES" to this question 

If the respondent indicates that the FGD scrubber purge or gypsum wastewater is sent to a settling pond in Part B Section 7 or Question B4-16, respondents should answer "YES" to this question and include those ponds in Table D-1

D2-6 Table A-4 Plant Pond/Impoundment System 

Identification

If YES, Table D-1 should be complete. Check that the “Individual Ponds/Impoundments” column matches the information provided in Table A-4.If NO, Table D-1 should be blank.[Table D-1. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-1).]

D2-5 Table A-4; Part B 

Question 4-16; 

Part B Section 7 

(QB7-1 through 

B7-3)

Plant operation of any systems for the treatment of process wastewaters from ash handling or FGD operations.
If YES, Table D-2 should be complete. Check that the information provided matches 

any footprints or diagrams the plant provides along with the questionnaire.If NO, Table D-2 should be blank and Table D-1 should be complete. Confirm that D1-2 is "NO".[Table D-2. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-2).]If the respondent indicates that the FGD scrubber purge or gypsum wastewater is sent to a wastewater treatment system in Part B Section 7 or Question B4-16, respondents should answer "YES" to this question and include those systems in Table D-2. 

Section 3.1

Wastewater Treatment Diagram

May have multiple copies to account for multiple pond/impoundment system or wastewater treatment system IDs.

Check that the plant attached a block diagram(s). Note that there may be multiple diagrams. If not, check comments tab for explanation 

Check that the diagram(s) includes all information identified in the “Block Diagram Checklist” on pages D-7 through D-10 

Tables D-1/D-2 Check that the diagram(s) includes all pond/impoundment systems and wastewater 

treatment systems identified in Table D-1 and/or Table D-2 

Tables A-4/B-1/B2 Check that the diagram(s) use EPA-assigned numbers from Part A or B (e.g., FGD-1) and that they are used correctly, if applicable. 

Tables D-3/D-4 Check that the flow rates provided in the diagram(s) match those provided in Tables D3 and D-4 within a reasonable amount. 

Table D-11 Check that the diagram(s) includes all wastewater treatment units identified in Table D11. 

Codes Tables Check that the diagram(s) identifies process operations and wastewater treatment 

systems using appropriate codes. 

Tables A-5/C-3/C19/B-8 Check that the flow rates provided in the diagram(s) are balanced and generally make sense. Bottom ash, fly ash, and scrubber purge influent flow rates can be checked in 

Tables C-3, C-19, and B-8. Also check against Table A-5 for process wastewaters entering the pond/impoundment

Section 3.2 Wastewater Treatment Wastewater 

Flows

May have multiple copies to account for multiple pond/impoundment system or wastewater treatment system IDs.

Check that all influents in Table D-3 correspond to block diagram(s) with the same System ID submitted by the plant 

Check that only influents are included in Table D-3 

Table D-4 Check that the influents correspond to the same System ID effluents in Table D-4. 

Check that the influent flow rates provided generally make sense. For example, corresponding gpm, hpd, and dpy values match the information provided in the diagram(s). Bottom ash, fly ash, and scrubber purge influent flow rates can be checkein Tables C-3, C-19, and B-8.Check that the plants properly identify the process or treated wastewater and that influents correspond to diagram attached in D3-1 Table D-3. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-3). 

Check that all effluents in Table D-4 correspond to block diagram(s) with the same System ID submitted by the plant 

Check that only effluents are included in Table D-4 

Table D-3 Check that the effluents correspond to the same System ID influents in Table D-3. 

Check that units are selected for the amount of solids/sludge, if applicabl Check that the effluent flow rates provided generally make sense. For example, corresponding gpm, hpd, and dpy values match the information provided in the diagram(s) submitted by the plantCheck that the plants properly identified the treated wastewater and final destination and that effluents correspond to diagram attached in D3-1 Table D-4. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-4). 

Section 4.1 Active/Inactive/Open and Planned Pond/Impoundment Unit Information May have multiple copies to account for multiple pond(s)/impoundment(s) reported in Table A-4.

Diagram RequestPond/impoundment system or wastewater treatment system influent flows 

D3-2

Pond/impoundment system or wastewater treatment system effluent flows

D3-3D3-1D2-7 Plant Wastewater Treatment System 

Identification

Question B4-16; 

Part B Section 7
D4-1 Table A-4 The use or planned use of any 

active/inactive/open ponds/impoundments for the storage, treatment, and/or disposal of process wastewater, residues or by-products from the combustion of coal, pet-coke, or oil.

Question D4-1 should be answered regardless of the response to question D2-5. If YES, Section 4.1 should be completed for every active/inactive/open pond/impoundment unit identified in Table A-4. If NO, Section 4.1 should be skipped. Check to make sure no ponds are listed in Table A-4. Ensure no answers are provided for Part D Section 4.2.

D4-2 Residence time, life, and number of cells of 

the pond/impoundment uni

Make sure that the number of cells for the pond/impoundment unit matches the block diagram(s) submitted by the plant, if applicable. 

D4-3 Volume, surface area, bottom and top 

elevation, freeboard height, maximum heigh

of the berms/dams, total amount of solids placed, and expected year of closure/retirement of the pond/impoundment unit when it was originally built, at its current status, and at its expected end of life.

Make sure that responses logically make sense. For example, all height and elevation responses should correspond to one another; total solids placed in the pond should increase from current to end of life status.Reminder: Operating capacity = Free water + Added solids

D4-4 Does the pond/impoundment unit have a 

liner?

If YES, Table D-6 should be complete.If NO, skip to question D4-5. Table D-6 should not be completed.If NA, skip to question D4-10. [Table D-6. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-6).]

D4-5 Has the pond/impoundment unit ever been 

dredged?

If YES, the following fill in the blanks should be complete. If NO, skip to question D4-7.If NA, skip to question D4-10. Make sure that answers logically make sense. For example, if the last year of dredging was 2000, no answers should be provided for the responses required for the last 5 years. 

D4-6 Transfer location of dredged solids If “other” is checked, make sure that the respondent provides an explanation 

D4-7 Pond/Impoundment unit expansion. If YES, questions D4-8 and D4-9 should be completed. 

If NO, skip to question D4-10.If NA, skip to question D4-10.

D4-9 Description of pond/impoundment 

expansions.

Make sure that plant provides starting/ending dimensions and total cost associated with the expansion. 

D4-10D4-11

If YES, Table D-7 should be completed.If NO, skip to Section 4.2. Ensure that no answers are provided for Part D Section 4.1.If NA, Table D-7 should be completed to the extent possible.Make sure that units are selected for in the “Average Addition Rate” column and make sure that the units selected make logical sense for the chemical liquid/solid addition. 

Section 4.2 Closed Pond/Impoundment Unit 

Information

May have multiple copies to account for multiple pond(s)/impoundment(s) reported in Table A-4.

Pollutants targeted for removal other than “solely settling”.

If “other” is checked, make sure that the respondent provides an answer.Based on pollutants listed in D4-11, make sure the appropriate pollutant categories are selected in D4-10.Make sure any limitations provided have corresponding units selected.

D4-12 Chemical addition to pond/impoundment 

unit in 2009.
D4-13 Table A-4 Closed pond/impoundments. If YES, Section 4.2 should be completed.

If NO, skip to Section 5.1. Check to make sure there are no closed ponds listed in Tabl

A-4. Ensure no answers are provided for Part D Section 4.2.This section should only contain ponds closed on or after January 1, 2000 identified in Table A-4.

D4-14 Date closed, life, and number of cells in the 

close pond/impoundment

Make sure that the number of cells in the pond match the block diagram(s) submitted by the facility, if applicable 

D4-15 Volume, surface area, bottom and top 

elevation, freeboard height, max height of dams/berms, and total solids in the closed 

pond/impoundment

Make sure that responses logically make sense. For example, all height and elevation responses should correspond to one another; total solids placed in the pond should increase from current to end of life status.

D4-16 Does the pond/impoundment unit have a 

liner?

If YES is checked, Table D-9 should be complete.If NO is checked, skip to question D4-17. Table D-9 should not be completed.Make sure that the thickness and permeability entries are in the correct units.[Table D-9. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-9).]

D4-17 Does the pond/impoundment unit have a 

cap/cover?

If YES is checked, Table D-10 should be complete.If NO is checked, skip to question D4-18. Table D-10 should not be completed.Make sure that the thickness and permeability entries are in the correct units.[Table D-10. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-10).]If YES, all questions should be completed.If NO, skip to question D4-21

Make sure that plant provides starting/ending dimensions and total cost associated with the expansion. 

D4-21 and D4-22 Closure plan/process for the 

pond/impoundment unit.

If YES, make sure that a copy of the closure plan is attached.Check to make sure that closure plan is attached and contains all necessary information if there is not answer provided for question D4-22. 

D4-23 Has the plant built any structures on top of 

the closed pond/impoundment unit?

If YES, make sure that a description of the structures is provided.If NO, skip to question D4-24. 

D4-24 Long-term groundwater, soil, or overflow 

monitoring of the closed pond/impoundment unit.

If YES, make sure that a description of the monitoring plan is provided.

Section 5.1 Wastewater Treatment Unit Information 

– System Level

May have multiple copies to account for multiple wastewater treatment IDs reported in Table D-5.

D5-1 Table D-2 Identification of wastewater treatment 

systems in Table D-2.

If YES, Section 5.1 should be completed for each wastewater treatment system identified in Table D-2.If NO, skip to Section 6.1. Make sure no wastewater treatment systems were identified in Table D-2. Ensure that no answers are provided in Part D Sections 5.1 and 5.2.

Check to make sure the wastewater treatment IDs match the block diagram(s) submitted by the facility.[Table D-11. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-11).]

Table A-4 If a pond/impoundment is selected, check to make sure that the ID listed matches Table 

A-4 and block diagram(s) submitted by the facility. 

D5-2 Wastewater Treatment Units

D4-18 through 

D4-20

Expansions of pond/impoundment unit
Check that the respondents identify wastewater treatment units using appropriate code

Request new codes if necessary. 

Table D-2 Check to make sure that the surface area of the WWT Unit makes sense/corresponds to 

the surface area submitted for the entire treatment system (Table D-2). 

D5-3 Flow rates, duration, and frequency for the 

wastewater treatment system.

Check to make sure the flow rates, duration, and frequency logically make sense and match block flow diagram attached in D3-1. 

D5-4 and D5-5 Pollutants targeted for removal other than 

“solely settling”.Note D5-6 through D5-9 only need completeness checks.

If “other”, make sure that the respondent provides an answer.Based on pollutants listed in D5-5, make sure the appropriate pollutant categories are selected in D5-4.Make sure any limitations provided have corresponding units selected.

D5-10 Planned improvements to existing 

wastewater treatment systems

Make sure that bid proposals are attached or that an explanation is provided. 

D5-11 Planned improvements to existing 

wastewater treatment systems.

Make sure that all wastewater treatment unit IDs correspond to units entered in Table D-11.[Table D-12. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-12).]

D5-12 Table D-11 Planned improvements based on potential 

limit changes in the future.

If YES, no explanation is necessary.If NO, make sure that the respondent provides an explanation

Section 5.2 Wastewater Treatment System Chemical 

Addition

May have multiple copies to account for multiple wastewater treatment IDs reported in Table D-5.

If YES, Table D-13 should be completed for every wastewater treatment system identified in Table D-2.If NO is checked, skip to Section 6.1. Make sure there are no wastewater treatment systems identified in Table D-2. Ensure that no answers are provided for Part D Section 2.If NA is checked, Table D-13 should be completed until the extent possible.[Table D-13. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-13).]Make sure that units are selected for in the “Average Addition Rate” column. Make sure that the units selected make logical sense for the chemical liquid/solid addition. 

Section 6.1 Pond/Impoundment System and 

Wastewater Treatment System Costs

May have multiple copies to account for multiple pond/impoundment system or wastewater treatment system IDs that began operating on or after January 1, 2000.If YES, Sections 6.1 and 6.2 should be completed for each pond/impoundment system or wastewater treatment system identified in Tables D-1/D-2.If NO, respondents are instructed to skip to the next Part. Make sure there are no pond/impoundment or wastewater treatment systems identified in Tables D-1/D-2. Ensure no answers are provided in Part D Sections 6.1 and 6.2.Check to make sure that all pond/impoundment or wastewater treatment systems identified in Tables D-1 and D-2 as being installed on or after January 1, 2000, have a completed copy of Sections 6.1 and 6.2Make sure that Table D-14 is complete. If not, follow-up with the plant may be necessary.Information may not be provided in Table D-14 if the pond/poundment or wastewater treatment system was not operated in 2009.Make sure that the individual O&M costs match the total provided at the end of the table. 

D6-2 O&M costs for the pond/impoundment 

system or the wastewater treatment system operated in 2009.

D5-13 Chemical addition to wastewater treatment 

units.

6.1 Tables D-1/D-2 Pond/impoundment systems and/or 

wastewater treatment systems identified in Tables D-1 or D-2 installed after January 1, 2000.
D6-3 Capital costs for the pond/impoundment 

system or the wastewater treatment system.

Make sure that Table D-15 is complete. If not, follow-up with the plant may be necessary.Make sure that there are no discrepancies between the individual indirect/direct costs, the indirect/direct totals, and the total capital cost provided at the end of the table.Information may not be provided in Table D-15 if the pond/poundment or wastewater treatment system was not operated in 2009.

D6-4 Capital costs for the pond/impoundment 

system or the wastewater treatment system.D6-5 and D6-6 – only need to be checked for completeness.

If NO, make sure that a list of key components not included is included in the explanation.

D6-7 Tables D-1/D-2 Ancillary equipment of the 

pond/impoundment system or wastewater treatment system.

Check to make sure that all systems identified in Tables D-1 and D-2 as being installed on or after January 1, 2000, have a completed copy of Section 6.2.[Table D-16. Only applicable rows need to be completed (i.e., there may be empty rows in Table D-16).]

Comments

Entire Section Check that all comments have a question number identified and the comment is 

understandable. 

Entire Section Resolve comments that indicate a change must be made to any electronic response. 
Part E Name Date(s) Reviewed

Reviewer No. 1Reviewer No. 2Status of Review

Questionnaire 

Part/Section/ 

Question 

Number

Copy Number Related Section Type of Information Coding and Review Activity First Reviewer Comments Sec

Revi

Part E WASTES FROM CLEANING METAL 

PROCESS EQUIPMENT

TOC Ensure that plant name and ID have been populated in the TOC page 

Universal All questions are answered except for those that can be skipped. Section 1 Metal Cleaning Operations

E1-1 N/A If "No" is selected for either Question, Part E should not have been completed. 

Section 2 Generating Unit Cleaning Data May have multiple copies to account for multiple SEGUs

Each SEGU Id reported should match an ID in Table A-8. If "yes" to specific cleaning method are all necessary data fields complete including 'Other' specific data. Check comments to be sure dose concentration and chemical added are in proper units. If not, calculate the proper value. 

Check frequency reported to determine if understandable. Each SEGU Id reported should match an ID in Table A-8. If "yes" to specific cleaning method are all necessary data fields complete including 'Other' specific data. If plant reports no metal cleaning waste generated, check comments to determine why (typically, they have used steam and there is no residual waste). Check frequency reported to determine if understandable. 

Section 3 Cleaning Operation Data May have multiple copies to account for multiple SEGUs

E3 Table E1/E-2 All For each type of cleaning for each unit identified in Tables E-1/E-2, there should be a completed Section 3. 

E3 Table E1/E-2 All If "Other" is selected for Tables E-1 or E-2; be sure that the Metal Cleaning Operation ID is listed as follows:

Table E-1, First Other Option is selected: Chem_Other1Table E-1, Second Other Option is selected: Chem_Other2Table E-2, First Other Option is selected: No_Chem_Other 1Table E-2, Second Other Option is selected: No_Chem_Other 2

E3-1 Cleaning Operation Data Description must include: Type of Equipment, Type of Metal Cleaned, Chemical 

Preparation Steps, Short Description 

E3-2 Cleaning Operation Data Answer "yes" or "no" E3-3 Cleaning Operation Data Ensure all data are complete. Check that reported NPDES outfall number(s) match 

Part A, Section 2.2. 

E3-4 Cleaning Operation Data Answer "yes" continue on. "No" Skip out E3-5 Cleaning Operation Data Answer ALWAYS or SOMETIME HAZARDOUS continue on. Answer ALWAYS 

NON-HAZARDOUS OR UNKNOWN jump to E3-7 

E3-6 Cleaning Operation Data Answered only if ALWAYS or SOMETIME HAZARDOUS in E3-5 E3-7 Cleaning Operation Data Ensure all data is complete including "expanded info" E3-8 Cleaning Operation Data If 'yes" ensure all data is complete including "expanded info" 

Comments

Entire Section Check that all comments have a question number identified and the comment is 

understandable. 

Entire Section Resolve comments that indicate a change must be made to any electronic response. 

E2-2./Table E-2

E2-1/Table E-1

Non-Chemical Method/Water Source Used

Table A-8 Specific Chemical/Water Source UsedTable A-8
Part H Name Date(s) Reviewed

Reviewer No. 1Reviewer No. 2Status of Review

Questionnaire 

Part/Section/ 

Question 

Number

Copy Number Related Section Type of Information Coding and Review Activity First Reviewer Comments Sec

Revi

Part H NUCLEAR POWER GENERATION

TOC Ensure that plant name and ID have been populated in the TOC page 

Universal All questions are answered except for those that can be skipped. Section 1 Nuclear Generating Unit Data

H1-1 and H1-2 If "No" is selected for either Question, Part H should not have been completed. 

Ensure data are complete. If "Other" is selected, ensure "Other" is specified. Ensure there is a Section 2 for each wastewater reported. 

H1-3/Table H-1 Part H, 

Section 3

Nonradioactive/Radioactive Is selected, check to ensure that QH3-1 in Section 3 for systems that treat this 

wastewater are marked as radioactive. 

H1-3/Table H-1 Table A-8 Nuclear Unit(s) If "Other" is selected, ensure "Other" is specified. Confirm that SE Unit IDs match 

those reported in Table A-8. 

N/A Part H, 

Section 1, 

Table H-1

Process wastewater code Code identified needs to match the process wastewater code indicated in H1-3/Table 

H-1. 

N/A N/A Process wastewater code Different wastewater code name for each new Tab created by user. 

Section 2 Process Wastewater Generation May have multiple copies to account for multiple wastewaters

Check that typcial duration does not exceed 24 hrs/day or 365 days/yr 

Ensure that typical frequency is understandable. 

Recycled process wastewater If "Immediately recycled back..." is selected, ensure a process description is selected. 

If "Other" is selected, ensure that "Other" is specified. 

Discharged to surface water and treated If "Discharged to surface water following on-site treatment..." is selected, ensure the 

NPDES permit outfall number is provided and is reported in Part A, Section 2.2. 

Discharged to surface water untreated If "Discharged to surface water untreated..." is selected, ensure the NPDES outfall 

number is provided and is reported in Part A, Section 2.2. 

Other If "Other" is selected, ensure "Other" is explained. 

Section 3 Wastewater Treatment Systems May have multiple copies to account for multiple treatment systems

Entire Section Wastewater Treatment System Name Ensure the plant used a different Treatment System Name for each new copy created

by user. 

H3-1 Table H-1 Nonradioactive/Radioactive Check if radioactive process wastewaters reported in table H-1 are treated in this 

system, that "Radioactive" is selected. 

H3-2 Table H-1 All Ensure that all process wastewater codes identified for each wastewater treatment 

system is also reported in H1-3/Table H-1. Check that maximum flow rate is >= typical flow rate. Check that days/yr is <=365 days and hrs/day is <=24 hrs/day. 

Wastewater Treatment Technology If "Other" is selected, ensure "Other" is specified. 

If "Metals" is selected, ensure "Metals" are specified. If "Other" is selected, ensure "Other" is specified. 

Unit Selected and matches value Wastewater Treatment Technology If "Other" is selected, ensure "Other" is specified. 

If "Metals" is selected, ensure "Metals" are specified. If "Other" is selected, ensure "Other" is specified. 

H3-7 Recycled process wastewater If "Immediately recycled back..." is selected, ensure a process description is selected. 

If "Other" is selected, ensure that "Other" is specified. 

Discharged to surface water and treated If "Discharged to surface water following on-site treatment..." is selected, ensure the 

NPDES permit outfall number is provided and is reported in Part A, Section 2.2. 

Discharged to surface water untreated If "Discharged to surface water untreated..." is selected, ensure the NPDES outfall 

number is provided and is reported in Part A, Section 2.2. 

N/A Other If "Other" is selected, ensure "Other" is explained. 

If "Recycled back..." is selected in H3-6, make sure question is answered. Check that maximum flow rate is >= typical flow rate. 

H3-6 All

Part A, 

Section 2.2

H3-6H3-7

Pollutants Targeted for Removal...All

H3-4/Table H-3

Pollutants Targeted for Removal...

H2-1/Table H-2H3-5/Table H-4H1-3/Table H-1 Part H, 

Section 2

Process Wastewater

Part A, 

Section 2.2

H2-2H3-3

Process Wastewater Flows
Check that days/yr is <=365 days and hrs/day is <=24 hrs/day. 

Comments

Entire Section Check that all comments have a question number identified and the comment is 

understandable. 

Entire Section Resolve comments that indicate a change must be made to any electronic response. 
Project Name: Steam Electric Project No: 0172.07.029.022 (non-coal)

0172.07.029.025 (coal)

CBI = Yes (Y)

Questionnaire 

Part

Question 

Number Copy # Question/Answer

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Q: 

A: 

Steam Electric Questionnaire Follow-Up Questions

Date:

This document contains CBI: yes/no

General Subject: Steam Electric Questionnaire Assistance / Follow-Up 

Contact Email Address:

ERG Staff (or ERG Rep) Name:

Company Affiliation: 

Type of Contact (Email/Tele):

Company Name:

Plant Name:

Point of Contact:

Contact Phone Number:
Project No.: 0172.07.029.022 (non-coal)

Project No.: 0172.07.029.025 (coal)

Contact Phone No.: 

Contact Email Address: 

Date: 

Time: __ AM ___ PM

Type of Contact (Email/Telephone):

CBI = Question

Yes (Y) No.

Steam Questionnaire Contact Record

General Subject: 

QUESTIONNAIRE ASSISTANCE / FOLLOW-UP: 

Topics Discussed

Contact Name:

ERG Staff Name: 

This document contains CBI (yes/no):

Project Name: Steam Electric

Plant ID: 

Plant Name: 
Reviewer: Date Completed:

Questionnaire 

Part

Section & 

Question #

Copy # (if 

necessary) Description of Change

Source for Change 

(list telecon or other 

source)

Approved/ 

Rejected D

Steam Electric Questionnaire - Change Form

Instructions:1) Include as much identifying information as possible in the "Description of Change" column to document the change made (e.g., if the information is about a spboiler/unit ID).2) Include a source/reference for the change, such as a specific telecon where the change was discussed with the point of contact.

ER
Part A Name Date(s) Reviewed

Reviewer No. 1Reviewer No. 2Status of Review

Questionnaire 

Part/Section/ 

Question Number

Type of Information Coding and Review Activity Notes for Copy Buttons First Reviewer Comments Second 

All General Instructions

Unlocking Tabs Must unlock each tab separately. 

Password: FinalSteamLocked0510Note that the copies of tabs Part A Section 2.2 and 8 do not have the same password. Password: steam

Select Tools > Protection > Unprotect Sheet > Copy and past password

Clear Radio Buttons Clear if respondent accidentally selected a 

radio button.

Unlock tabRight click on the radio button > Format Control > Select "Control" Tab > Unchecked

Check Modified Files All Check to make sure that the plant is not on the 

"modified files" list (See Modified Files tab). If Yes - Thoroughly check the mapping for the changed

tabs. Note that some of the infromation will not be automatically uploaded and will have to hand enter that data. Highlight additional rows in green that are not programmed to bring to our attention.Also note that in some cases there may be tabs that are copied that did not originally have a copy button. That is OK for these files.

Steps to Thoroughly Check Mapping

1. Unlock tab2. Unhide mapping rows at the bottom (Row 300)3. Check to make sure that the answers in the map match the answers selected above on the copied tab and that no linking is present between the original tab and the copied tab.4. Check the offset functions (mostly the drop downs) to see if they reference the previous tab.5. If they do reference the original tab; do a find and replace on the previous tab name for a space (“ “). 

All General Instructions

Check for True Zeroes All number fields Review each questionnaire part for answers where the 

respondent entered "0". If the answer is truly zero, delete the "0" and enter "-555" into the field. 

Check for Missing Data All fields Review each section for missing data. If there are 

questions in tab that don't have answers, but should be answered, enter "-111". All "-111" entries should be removed after plant follow-up, but incase they are not, this will designate missing data in the database.

Part A Tab Name

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part A Section 2.2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per outfall ID.

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. 

Part A Section 1.1Part A Section 1.2Part A Section 2.1Part A Section 2.2Part A Section 3

Check Tab Names
Check to make sure that tab name is not changed or 

that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part A Section 8 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per SE Unit ID.

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. 

Part B Tab Name

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab copies in tandem with "Part B Section 4 Tables". Make sure that there is a "Part B Section 4 Tables" copy for every copy of Part B Section 4. If copied, confirm that tab names follow the format: Part B Section 4 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Copy button for multiple wet FGD systems. Make sure that the same FGD System ID is on the corresponding Part B Section 4 Tables copy. Make sure there are not two or more sets of copies with the same ID. 

Check to make sure that tab name is not changed or that tab is deleted. Tab copies in tandem with "Part B Section 4". Make sure that there is a "Part B Section 4" copy for every copy of Part B Section 4 Tables. If copied, confirm that tab names follow the format: Part B Section 4 Tables Cop (#). Note that original tab name should NOT change or contain the word "copy" and that the word "Copy" may cut off. 

Copy button for multiple wet FGD systems. Make sure that the same FGD System ID is on the corresponding Part B Section 4 copy. Make sure there are not two or more sets of copies with the same ID. 

Check to make sure that tab name is not changed or that tab is deleted. 

Part A Section 4Part A Section 5Part A Section 6Part A Section 7Part A Section 8Part A Section 9Part A Section 10Part A Section 11Part A Section 12Part A Section 13Part A CommentsPart B Section 5

Check Tab Names

Part B Section 4Part B Section 3Part B Section 2Part B Section 1Part B Section 4 Tables
Check to make sure that there are no copies of the tab. 

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab copy button is actually on tab Part B Section 6. If copied, confirm that tab names follow the format: Part B Section 6 Table Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Copy button for provided incase respondent needs more space. In this case, copies can refer to the same data set. 

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab copies in tandem with "Part B Section 8 Tables". Make sure that there is a "Part B Section 8 Tables" copy for every copy of Part B Section 8. If copied, confirm that tab names follow the format: Part B Section 8 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Copy button for multiple dry FGD systems. Make sure that the same FGD System ID is on the corresponding Part B Section 8 Tables copy. Make sure there are not two or more sets of copies with the same ID. 

Check to make sure that tab name is not changed or that tab is deleted. Tab copies in tandem with "Part B Section 8". Make sure that there is a "Part B Section 8" copy for every copy of Part B Section 8 Tables. If copied, confirm that tab names follow the format: Part B Section 8 Tables Cop (#). Note that original tab name should NOT change or contain the word "copy" and that the word "Copy" may cut off. 

Copy button for multiple dry FGD systems. Make sure that the same FGD System ID is on the corresponding Part B Section 8 copy. Make sure there are not two or more sets of copies with the same ID. 

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. 

Part C Tab Name

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part C Section 2.1 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per SE Unit ID.

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part C Section 2.3 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per SE Unit ID.

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part C Section 2.4 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Storage ID.

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part C Section 3.1 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per SE Unit ID.

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. 

Part C Section 2.1Part C Section 2.4Part C Section 2.3Part C Section 2.2

Check Tab Names Part C Section 1

Part C Section 2.5Part C Section 3.2Part C Section 3.1Part B CommentsPart B Section 8 TablesPart B Section 8Part B Section 7Part B Section 6 TablePart B Section 6
Check to make sure that tab name is not changed or 

that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part C Section3.3 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per SE Unit ID.

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part C Section 3.4 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Storage ID.

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part C Section 4 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per SE Unit ID.

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part C Section 5 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per SE Unit ID.

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. 

Part D Tab Name

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part D Section 3.1 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Pond/Impoundment System or Wastewater Treatment System ID. 

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part D Section 3.2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Pond/Impoundment System or Wastewater Treatment System ID. 

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part D Section 4.1 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Pond/Impoundment Unit ID. 

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part D Section 4.2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Pond/Impoundment Unit ID. 

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part D Section 5.1 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Wastewater Treatment System ID. 

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part D Section 5.2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Wastewater Treatment System ID. 

Check to make sure that tab name is not changed or that tab is deleted. 

Part D Section 5.1Part D Section 5.2Part D Section 6.1Part C Section 3.4Part D Section 1Part D Section 2Part D Section 3.1Part D Section 3.2Part D Section 4.1Part D Section 4.2Part C CommentsPart C Section 5Part C Section 4Part C Section 3.5Part C Section 3.3
Tab copies in tandem with "Part D Section 6.2". Make 

sure that there is a "Part D Section 6.2" copy for every copy of Part D Section 6.1. If copied, confirm that tab names follow the format: Part D Section 6.1 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Pond/Impoundment System or Wastewater Treatment System ID. Make sure that the same ID is on the corresponding Part D Section 6.1 copy. 

Check to make sure that tab name is not changed or that tab is deleted. Tab copies in tandem with "Part D Section 6.1". Make sure that there is a "Part D Section 6.1" copy for every copy of Part D Section 6.2 Tables. If copied, confirm that tab names follow the format: Part D Section 6.2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Pond/Impoundment System or Wastewater Treatment System ID. Make sure that the same ID is on the corresponding Part D Section 6.2 copy. 

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. 

Part E Tab Name

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part E Section 2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per SE Unit ID.

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part E Section 3 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Metal Cleaning Operatoin ID, note that there may be multiple copies with the same SE Unit ID. 

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. 

Part F Tab Name

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part F Section 2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Pond/Impoundment Unit ID. 

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part F Section 3.1 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Landfill ID.

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part F Section 3.2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Landfill ID.

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part F Section 4.2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Leachate Treatment System ID. 

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part F Section 4.3 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Leachate Treatment System ID. 

Part D CommentsPart D Section 6.2

Check Tab Names Part F Section 1

Part F Section 2Part F Section 3.1Part F Section 3.2Part F Section 4.1Part F Section 4.2Part F Section 4.3

Check Tab Names Part E Section 1

Part E Section 2Part E Section 3Part E Comments
Check to make sure that tab name is not changed or 

that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part F Section 4.4 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Leachate Treatment Unit ID. Note that there may be multpile copies with the same Leachate Treatment System ID. 

Check to make sure that tab name is not changed or that tab is deleted. Tab copies in tandem with "Part F Section 4.6". Make sure that there is a "Part F Section 4.6" copy for every copy of Part F Section 4.5. If copied, confirm that tab names follow the format: Part F Section 4.5 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Leachate Treatment System ID. Make sure that the same ID is on the corresponding Part F Section 4.5 copy. 

Check to make sure that tab name is not changed or that tab is deleted. Tab copies in tandem with "Part F Section 4.5". Make sure that there is a "Part F Section 4.5" copy for every copy of Part F Section 4.6. If copied, confirm that tab names follow the format: Part F Section 4.6 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Leachate Treatment System ID. Make sure that the same ID is on the corresponding Part F Section 4.6 copy. 

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part F Section 5 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Pond/Impoundment ID or Landfill ID. 

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. 

Part G Tab Name

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part G Section 2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Pond/Impoundment ID or Landfill ID. 

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part G Section 5 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Copy button for provided incase respondent needs more space. In this case, copies can refer to the same data set. 

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part G Sampling Results Cop (#). Note that original tab name should NOT change or contain the word "copy" and that the word "Copy" may cut off. 

Make sure that there is only one copy per Pond/Impoundment ID or Landfill ID.

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. 

Part H Tab Name

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. Check to make sure that tab name is not changed or that tab is deleted. 

Check Tab Names Part H Section 1

Part H Section 2Part F Section 4.6Part F Section 5Part F CommentsPart F Section 4.4Part F Section 4.5

Check Tab Names Part G Section 1

Part G Section 2Part G Section 3Part G Section 4Part G Section 5Part G Sampling ResultsPart G Comments
Tab has a copy button. If copied, confirm that tab 

names follow the format: Part H Section 2 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per Process Wastewater Code. 

Check to make sure that tab name is not changed or that tab is deleted. Tab has a copy button. If copied, confirm that tab names follow the format: Part H Section 3 Copy (#). Note that original tab name should NOT change or contain the word "copy". 

Make sure that there is only one copy per wastewater treatment system name. 

Check to make sure that tab name is not changed or that tab is deleted. Check to make sure that there are no copies of the tab. 

Part H Section 3Part H Comments
Attachment 3 

FOLLOW-UP PHONE CALL AND EMAIL INSTRUCTIONS
Phone Call Script 

 “Hello, Mr/Ms [name], my name is [name] and I’m a contractor for the U.S. EPA 

for the Steam Electric Questionnaire. I have reviewed your survey and have a 

few questions on some of the information you provided. Do you have time to 

discuss these questions?” [If No, schedule a day and time to call back]. “Do you 

have your copy of the completed survey for this plant available?” 

 If you faxed or emailed review questions prior to the call, ask “Do you have a 

copy of your completed survey for this plant and the review questions I sent to 

you on [date]?” 

 Ask questions, note responses. 

 “Would you like to consider any of this information as confidential business 

information?” If Yes, have the contact identify CBI questions and mark on the 

telecon form or review question document. NOTE: If any questions were already 

marked CBI, they remain CBI for the telecon. If CBI is claimed for new questions, 

verify that they want to change the CBI status for the question.

 “These are all the questions I have at this time. If I have any additional questions, 

I will contact you again. Thank you for your time.” 

Email or Faxed Review Example 

Dear [Contact Name]: 

Per our discussion on [mm/dd/yy], attached are follow-up questions to clarify survey 

responses for [company name/plant name]. As discussed on [mm/dd/yy], I will call you 

on (day, date, and time) to discuss these questions. 

These are all the questions I have at this time. If I have any additional questions, I will 

contact you again. Thank you in advance for your time. 

[Name and phone number], 

[Company Affiliation] 
Appendix F 

COMPLETENESS CHECKLIST 
Completeness Checker:

Plant ID:Questionnaire Version #:Survey Ready for Review:Status of Review

Complete? Action 

Questionnaire package received from Marla

Note date received on package

 Log in questionnaire

Enter date received into Survey Tracking database table on CBI serverEnter response data into the Survey Review database table on CBI server

Place a pre-populated label on the CDFill out label with date uploaded to Network, Your Initials, and Plant ID

Check that all required parts are present & can be opened/read electronically

Certification statementABCDEFGHIOther files/documents

Copy files to CBI network (P:\Steam Electric\Rulemaking\Survey\Survey Working Copies\ )

Create a folder for the plant ID (e.g., 12345)Copy files to folder and rename with ID (e.g., 12345_PartA.xls)Create log of hard copy docs submitted and where stored (e.g., 12345_HardcopyLog.doc)Scan hardcopy docs into PDF where feasible

Set up physical plant folder

Create a file folder with label (Plant ID/Plant Name/Version #)Include any hard copy documents received in the folderStore the folder in the CBI archive room in Plant ID order

Initial check of questionnaire

Did plant "kick out" of questionnaire? (A1-6=YES, A1-7=NO, A1-8=NONE, OR A1-11=NO)Did plant "kick out" of Part B (answer B1-1 = "NO")?Did plant "kick out" of Part C (answer C1-1 = "NO")?Did plant "kick out" of Part D (answer D1-1 AND D1-2 = "NO")?Did plant "kick out" of Part E (answer E1-1 = "NO")?Did plant "kick out" of Part F (answer F1-1 = "NO")?Did plant "kick out" of Part G (answer G1-1 = "NO")?Did plant "kick out" of Part H (answer H1-1OR H1-2 = "NO")?

Prepare Part I for delivery

Move (don't copy) the Part I file to the "Part I Deliveries" folder

Is survey ready for technical review?

Completeness Check

If any part is missing, if the questionnaire parts are not submitted electronically, or if the electronic files(s) cannot be read, contact plant immediately for resolution.If you can tell that the respondent kicked out of the survey or any part inappropriately, discuss with Deb/TJ and contact plant immediately for resolution.
Appendix G 

ENVIRONMENTAL SAMPLING SUPPLY PRODUCT DOCUMENTATION
ESS - Preparation and Cleaning Procedures Page 1 of 1

Technical Background

- Certificationl

Qualitv Control - PREPARATION/CLEANING

PROCEDURESPreDaration &

Cleanil}g

Procedures

PROCEDURE 1

Container preparation includes nonphosphate detergent washing,

multiple tap water and ASTM Type I deionized water rinses, and

1:I HN03 (Nitric Acid) and solvent rinses. Containers are oven

dried.

ODerational

Advallt9-9~.

Recommended for extractable organic, semivolatile and

pesticide analysis.

PROCEDURE 2

Container preparation includes nonphosphate detergent washing,

multiple tap water and ASTM Type I deionized water rinses.

Containers are oven dlied.

All PC Class

containers from ESS

come with a

kel1~at~.oJ

GQffiPlig!1_ce,

Recommended for purgeable volatile organic analysis.

PROCEDURE 3

Container preparation includes nonphosphate detergent washing, multiple tap water and

ASTM Type I deionized water rinses, and 1:1HN03 (Nitric Acid) rinses. Containers are

oven dried.

Recommended for metal, cyanide, sulfide and fluoride analysis.

PROCEDURE 4

Container preparation includes nonphosphate detergent washing, multiple tap water and

ASTM Type I deionized water rinses, and 1:] H2S04 (SulfUlic Acid) rinses. Containers

are oven dtied.

Recommended for nitrate/nitrite analysis.

ESS CUSTOM

Containers are prepared per customer specifications to meet unique project needs.

Recommended for your special projects.

Home I Technical Backaround I Comoanv Ba_c15g[QIJ!1QI E'£Qduq$ I S;;ont§!~.J>~ I Whql's New

ESS. WeSell Experience With Every Container.

ENVIRONMENTAL SAMPLING SUPPLY

Oakland, CA . info@essviaU;olJ1 . 1-800-233-8425

http://www.essvial.com/prep_cleaning.html 1/23/04 - --- -
ESS -Certification and Quality Control Page 1 of 1

Tech nkal Background

Certification!

Qualitv Control CERTIFICATION/QUALITY CONTROL

Automation

Lower detection limits: ESS was the

first and is the ONLY container

supplier to test below drinking water levels, providing the lowest detection limits for

organic and inorganic parameters.

Preparation &

~Ieaning

Procedures

Independent certification: ESS was

the first sample container company to

have independent certified laboratories

analyze Ouality CertifiedTM Class and

PreCleaned CertifiedTM Class

containers, and ESS is the ONLY

company to provide actual test results

with each case of QC Class product. If

litigation is a concern, ESS QC Class

containers give the ultimate

certification, keeping your company

one step ahead of the competition.

Operational

!'.dvantaQes

Direct Trace@: ONLY ESS can trace QC Class containers two ways: (1) The QC lot

number can trace containers to independent QC analytical reports (included in each case

of QC Class containers) which are backed up with standard laboratOlYaudit procedures;

and (2) the ability to trace QC Class containers to their exact destination of purchase.

ESS is the ONLY container company to offer this "cradle to grave" feature. Direct

Trace@is based on the original U.S. EPA Superfund container tracking requirements.

Direct distribution and dedicated warehouses: ONLY ESS sample containers are

stored in ESS warehouses. ESS does not store its containers with thousands of other

laboratory items such as chemicals, solvents or fuels. With our direct distribution there is

only one step in the chain of custody that has to be accounted for: shipment from ESS to

your facility. There is no tighter or more sensitive chain of custody in the industry.

EP Acertification: ESS PC Class containers are provided with certification that exceeds

U.S. EPA standards for precleaned containers.

Experience: The ESS staff has more experience in the precleaned sample container field

than any company in the industIy.

QAProgram: In the precIeaned sample container industI.y,ESS is the ONLY company

to offer a distinctive Quality Assurance Program. For a copy of our Quality Assurance

Manual, call 1-800-233-8425.

ESS' cleaning procedures are based on the U.S. EP A "Specifications and Guidance for

Contaminant-Free Sample Containers"

fj.Qfl1Jz I TechnicaLfJ?#.c:;M[OJlnq I C;Ofl1P?#.l1Y,fJar:;kmQ(I!Jq I Prqq(iGt$ I C;ql1taGt~~~ I What'sJ'feyv

ESS. We Sell Experience With Every Container.

ENVIRONMENTAL SAMPLING SUPPLY

Qaklancl, CA . !I]tq@~§~yi~f&om. 1-IJIJIJ-2JJ-1J420

http://www.essvial.com/quality .html 1/23/04 -- --- - --
Technical Background

IIIIh , A

Certificationl

Qualitv Control - ESS CONTAINER CLASS DEFINITIONS

Automation

Preparation &

g~<ill!ng

Procedures

liC CLASS

UnCertifiedTM containers with Teflon@-lined* closures attached.

PC CLASS

PreCleaned CertifiedTM containers with Teflon@-lined*closures attached. Certification

is provided with each case. Operational

Advantagm>

QC CLASS

Quality CertifiedTM precleaned containers with Teflon@-lined*closures attached are

analyzed by independent, certified laboratories. Analytical test results are provided with

each case of QC Class containers, which are excellent for use in litigation applications.

* Not all HDPE/LDPE products are available with Teflon@-linedclosures.

Home I Technical Backaround I Company Backaround I Products I Contact ESS I What's New

ESS. We Sell Experiellce With Evel)' Contailler.

ENVIRONMENTAL SAMPLING SUPPLY

Oakland. CA. info@essvial.com . 1-800-233-8425

http://www.essvial.comldefinitions.html 1/23/04

I
http://essvial.com/images/ certificate. gif

Page 1 of1

1/23/04
--- --- - .-- .- -----

~J!Rt~JiQjtl~_~_i'!nJj

GI~~~ Vi~l~

GI~~~ Wide Mouth

HDPE Narrow Mouth

1j!1<LLDPE

Cubitainers

HDPE Wide Mouth

!:i.alg§!l?_~ HQPI;

Wide Mouth and

Narrow Mouth

PrePreserved

$S!mpJ~~Q!1ti'!ineI

Info

PLQP!Jle 1M Bottles

and EasvPourTM

Vials

Chemical

PLe~~Natives

Ultra Pure~ank

WaterTM

jgJ~tj.J~9ttle~jm<tAlr:

Samolina Baas

Cold Ice@

Refriaerant and

FoamPaj::-'~

5035

PrePreJ>~rved@Vials

and Samplina Tool~

Analvtical Reference

Materials

Polvethvlene and

J~llQn@ ..~<ille.L~

"'-_@el~_<ill.~<::-1!stodv

Seals

..----.......--

- PrePreserved@ CONTAINERSDropuleTM Field Preservative Dropper Bottles

TIle 15 mL DropuleTlIfwith the leak-proof cap dispenses .05 mL of preservative per

drop, which is ideal for preserving containers in the field. TIle 15 mL DropuleTl\f;

. has a hinged cap for one-hand operation

. is security sealed

. has color-coded closures for easy chemical identification

. is washed to ESS'):}!"9ceJiure 2

. is filled with J. T. Baker or Mallinckrodt analytical grade chemicals

. fits perfectly in a Tuff-Tainer@polypropylene box for field kits

15 mL of Ascorbic

Acid

] Closure Product Number I Per Case II Price Per Case Color

I White IIpCOOI5-ASCB 1~1$18.60 I

EJlpCOOI5-HCL 1~1$]8.60 I

I::::J PCOOI5-HN03~1$18.60 I

I White IIpCOOI5-PHOS1~1$32.36 I

I White I PC0015-NAOH ~1$18.60 I

I Orange IlpC0015-S0TH 1~1$18.60 I

IYellOW IlpCOOI5-SULF 1~1$18.60 I

15 mL of

Hydrochloric Acid

15 mL of Nitric

Acid

15 mL of

Phosphoric Acid

15 mL of Sodium

Hydroxide

15 mL of Sodium

Thiosulfate

15 mL of Sulfuric

Acid

- - http://www.essvial.com/products/ containerspecs.html 1/23/04
ESS Products - PrePreserved Containers

Tuff Tainer@

Easy PourTM Field Preservatives

ESS offers vials of premeasured chemicals in amounts up to 10 111Lfor easy

preservation while in the field. The Easy PourTM Field Preservative Vial:

. has a screw threaded cap for resealing

. is washed to ESS' Procedure 2

. is filled with J.T. Baker or Mallinckrodt analytical grade chemicals

Home I Technical Backaround ICompany Backaround I Products I Contal2t~:'i IWflgf§JY(~llt

ESS. We Sell Experience Witlt Every Container.

ENVIRONMENTAL SAMPLING SUPPLY

Oakland. CA. info@('issvia/.com. 1-800-233-8425

http://www.essvial.comlproducts/ containerspecs.html

Page 2 of2

1/23104

15 mL of Zinc

ItJlpCOOI5-ZINC ItJl$18.60 I Acetate

15mLof Sodium

I Greon I PCOO15-ZNSH []LJ Hydroxide/Zinc

Acetate mixture

I Description II ProductNumber II Quantity I

Tuff-Tainer@polypropylene

carrying case for 15 mL DropuleTM IUCOOI5-TUFF IDE]

I Type II Product Number II Quantity II Price I

10mLclearborosilicateglass PCOOI0-0311

DLJ vial with 15 mm-425 white

polypropy lene/F217 -lined

closed-top closure.
Gall tSUU-~;:s;:s-tS4~:>to oraer

A;!I

$epl<!J'!Qlttes_<!Dd

Glass Vials

Glass Wide Moultl

HOPE Narrow Moulh

aJl(LlQ~E

Cubilainers

HOPE Wide Moulh

N<!lgefl~~.i:H;JEI::

Wide Mouth and

Narrow Mouth

PrePreserved

Samp.!!t~...Qn1<!jl1~[

Info

OroDule TM Bottle~

and EasyPourTM

Vials

Chemical

Preservatives

Ultra p..Qr.eBlank

WaterTh'

Bac!L6.otUes a.l1t:LAir

SamDlina Baas

Cold Ice@

RefriQerant and.

FoamPa_c!~.

5035

PrePreserved~ Vials

and Sam[1JjngJ::_QQlli

Analytical Reference

Matj3ri<!J?

Polyethylene and

LE!.floo.~J~<!i!~rs

.kabels and CI,g;lQQY

~als

Qtbex

- PRESERVATIVES/LABELS -

Chemical Preservatives

[TYPe

Liquid

I [ Assay ] I Concentration %

10 mL to

15mL

Ammonium.

1

[99.6%110 g/IOOO~f$03Ol~

Chloride(NH4CI)~ mL L--JL-JL-J

Ascorbic Acid

I

r99.7%IlO g/IOOO~f$03Ol~

(C6H806) ~ mL L--JL-JL-J

Hexane

(CH3(CH2)4CH3)~I r99.l%I1100% l~f$03Ol~ L--JL-JL-J

~~)chloricAcid1136.5-38%111:1 IEJEJEJ

MercuricChloride [99.5%110 g/IOOO f$035If$OA5l~

(HgCI2) ~ mL L--JL-JL-J I Nitric Acid (HN03) 1170-71% 111:1 11$0.20 11$0.30 11$0.40 1

Phosphoric Acid 175-78% III: I I (H3P04) L--JL-JL-J f$0.5OIf$0.75l~

Sodium Bisulfate

I

G5.4%IIOg/IOOO ~f$03Ol~

(NaHS04H20)~ mL L--JL-JL-J

~~~~~HYdrOXide1c:=J1100% IEJEJEJ

DDLJLJLJ

r::=]1:g/IOOO

~l:g/IOOO

195-98% 111:1

r:=]1:g/IOOO

II Assay II Concentration %

Sodium

Hydroxide/Zinc

Acetate

Sodium Sulfite

(Na2S03)

Sodium Thiosulfate

(Na2S203)

Sulfuric Acid

(H2S04)

Zinc Acetate (Zn

. (CH2COO)2)

E

Dry

Ammonium

Chloride (NH4CI)

50.0mg to

99.99mg

199.6% 11100% IE:JEJEJ

http://www.essvial.com/products/ chemical.html 1/23/04 -----

1
ESS Product~ -Preservatives, Labels Page 2 of3

Lust Preservative (GRO/DRO)

Preservative Dot Labels

These are the same color-coded dot labels with the chemical description that accompany our

PrePreserved@containers.The dot labels are

PrePreserved@containersare custom orders. Please allow additional lead time.

Chemicals are mixed with ESS Ultra Pure Blank WaterTM.Other preservatives available upon

request and may require a lead time 0[2 to 3 weeks.

http://www.essvial.com/products/ chemical.html 1/23/04 --

1

Ascorbic Acid

(C6H806) llOO% IEJE:Jt:J

Mercuric Chloride

(HgCI2) 1100% 11$0.55 IE]

Potassium LJLJEJLJEJ Dichromate

(K2Cr207)

SodiumBisulfate

(NaHS04H20) IIOO% IEJE:JEJ

SodiumSulfite

(Na2S03) EJllOO% IEJE:JEJ

Sodium Thiosulfate

(Na2S203) EJllOO% IEJE:JEJ

Zinc Acetate (Zn

(CH2COO)2) EJllOO% IEJE:JEJ

I Type IEJlconc.% 110-4mL115-9011.1114 1115-19mL1120-24011.IIL30 I

Other Chemicals

1999tO1o 11$050 11$060 1[$080 ILJLJI$L40 I

Methanol

(CH30H)

I Type II Assay II Cone. % 110-1 011. 111-2 011. 112-3 mL 113-401L 114-5 mL I

Monochloroacetic Acid

DDDDDDD (C2H3CI02,C2H3K02)

Chloroacetic

AcidJPotassium Acetate

Buffer

I Type II Product II Quantity II Price I

25 mL purge and trap grade

Methanol in 40 mL amber CT vial I PC 0040-0490 1r=JE:J

I Type II Product II Quantity II Price I

Preservative dot label (please specify

I PRES-LBLS Ilooo/labels I $45.00 I chemical)
ESS Products -Blank Water, Trip Blanks

Products

Call 800-233-8425 to order

I~ ,,3

SeRt"LSp!!l~~-,;,)JlQ

Glass Vials

§Iass Wi<J~Moutl}

HOPE Narrow Mouth

al1<J.J,O PJ;

Cubitainers

HOPE Wide Mouth

~a!.g~.D..E;J~J::tQJ:..1;.

Wide Mouth and

Narrow Mouth

PrePreserved

s9m.QL~~9ntainE;JS

Lnfo

.Prop_ul~_T"J20t!1~..S

and EasyPour TM

yjals.

Chemic_ai

E'LE;J'§!'1rYativ~

Ultra Pure Blank

WaterTM

125!.G.tLE\pttJes _aOd AiL

Samolina Baas

Cold Ice~

Refriqerant am)

E.QErnPQC_~':'.

-BLANK WATER/TRIP BLANKS -

Ultra Pure Blank Water TM

~A§

PrePreserved@Vials

and5.aJIlPliillLiooLs PrePreserved@ Trip Blanks

Analytical Reference

Matesii'!ls

Polyethylene and

Lefloo~J~i'!!lE;JLS

!"aP!!1s...i'lH9J::;J!sto_QY

Seals.

Qt[ler

. Applications: Ideal for organic, inorganic or HPLC applications

. Convenience: Superb quality for both field and lab applications

.Packaging: UPBW is packaged into ESS PreCleaned CertifiedTM containers for

added integlity; Teflon@silicone closures prevent leakage

. Certification: Analyzed to drinking water levels for both volatile organic and

inorganic parameters

http://essvial.comlproducts/blankwater .html

I

Page I of2

1/23/04

I Part II Part Number Price Per Case I

IBW 1000-0150 III L bottles 4/case $28.00 I

I BW 4000-0250 114 L bottles 4/case $50.00 1

1 BW 0005-1035 1120 L LDPE cube lIcase $30.00 1

I Part II Per Case II Price Per Case I

1 TB 7240-0300 1140mL vial/septa 72/case II $151.20 I

1 TB 1240-0300 1140 mL vial/septa l2/case 11$27.60 I





Appendix H 

INDUSTRY SELF-MONITORING ON-SITE AUDIT CHECKLISTS
Effluent/Midpoint Composite Setup/Breakdown – Sampling Checklist 

Plant Name: 

Sampling Point Description: 

Set Number: 

Date of Audit: 

Auditor: 

Plant must collect a 24-hour composite sample at the effluent and midpoint (if 

applicable). The compositor should collect 1 sample, every hour, for a 24-hour period. 

Complete the following checklist for the composite setup. Use the space below each 

check to record notes on setup procedures. 

Set-Up Portion of Composite Collection

 

 Samplers set up compositor at correct sample location/tap. 

 Samplers used clean hands/dirty hands techniques. 

 

 Designated “clean hands” (only handles inner, “clean” bags). 

 Designated “dirty hands” (only handles outer, “dirty” bags). 

 All samplers wore tyvek® coveralls (or equivalent). 

 All samplers wore gloves. 

 

 Samplers covered all supporting tables. 

 All equipment used was previously cleaned and double bagged according to EPA 

instructions. 

 Dirty hands set up clean box and T-splitter tubing for clean hands (e.g., removed 

“dirty” bags). 

 New tubing was used for each different day of sampling. If new tubing was not 

used, describe how the samplers kept the tubing from becoming contaminated 

between breaking down and setting up the new compositor. 

 Clean hands removed T-splitter tubing from “clean” bag in clean box and covered 

ends for protection (i.e., used Ziploc baggies to avoid “clean” tubing ends from 

becoming “dirty”). 
 Dirty hands/clean hands set up the ISCO. 

 

 Samplers were able to remove ISCO pump cover and “lay” sample tubing 

into the pump versus threading tubing through the ISCO. 

 If samplers threaded tubing through the ISCO, were the ends covered the 

entire time? What precautions were taken to keep the tubing “clean”? 

 Dirty hands/clean hands set up the double bagged 20 L field blank carboy using 

appropriate clean hands/dirty hands techniques (i.e., dirty hands only handles outer 

bag, clean hands only handles inner bag, clean hands handles clean caps). 

 Clean hands removed 20 L carboy cap, and replaced with double bagged, “clean” 

vent cap. 

 Samplers double bagged (or single bagged) original (closed) carboy cap to 

keep “clean” during of the field blank collection. 

 Clean hands attached the clean tubing to the clean vent cap for field blank samples. 

 Clean hands placed the end of the tubing into the reagent grade blank water and 

dirty hands operated the pump to collect the field blank sample. 

 Clean hands removed vented cap and tubing from the field blank 20 L carboy and 

replaced with original “clean” cap. 

 Clean hands recovered the end of the T-splitter tubing and bagged the vented cap to 

keep “clean” during 20 L composite carboy setup. 

 Samplers iced 20 L field blank carboy (to fluid level). 

 Samplers covered 20 L field blank carboy (e.g., with trash bag, tarp, trash can lid). 

 Dirty hands attached tubing to correct sample tap, used zip-tie to secure, and purged 

the line for 2 minutes. 
 Dirty hands/clean hands calibrated the ISCO by volume, not flow rate (record 

volumes below). 

 Samplers checked the ISCO calibration to ensure the volume of wastewater 

delivered by the pump is correct. 

 Dirty hands/clean hands set up the double bagged 20 L composite carboy using 

appropriate clean hands/dirty hands techniques (i.e., dirty hands only handles outer 

bag, clean hands only handles inner bag, clean hands handles clean caps). 

 Clean hands removed the cap and replaced with the vented cap used during the field 

blank sample. 

 Samplers double bagged original carboy cap to keep “clean” for duration of 

compositing period. 

 Clean hands attached the “clean” end of the T-splitter tubing to the vented cap and 

used a zip-tie to secure tubing. 

 Samplers programmed the ISCO to take 24 equal aliquots, every hour for a 24 hour 

period (by volume, not flow rate). 

 Samplers started the program (Time: ________ am / pm). 

 Samplers iced 20 L carboy (to fluid level). 

 Samplers covered 20 L carboy (e.g., with trash bag, tarp, trash can lid). 

Icing/Water Pump Out Portion of Composite Collection

 Samplers put additional ice on the compositors to keep them cold during the 24-

hour composite period, ensuring that there was always ice surrounding the carboy 

and that the carboy was not just sitting in water. 

 
 Samplers pumped water out of the composite trash can, as needed. 

 During icing and water pump-out times, the samplers took precautions to ensure 

they didn’t touch the tubing, the inner bag, and the carboy/caps. 

 

 Samplers did NOT ice or pump out water while a composite aliquot was being 

collected. 

Break-Down Portion of Composite Collection

 REVIEWER CHECK: Prior to the samplers breaking down the compositors, check 

that the ISCO does not have an asterisk on the screen, which could indicate that one 

of the samples was missed. 

 REVIEWER CHECK: Check the ice level of the compositors to see if the samples 

ice is at least to the shoulder of the 20 L carboy. 

 Samplers used clean hands/dirty hands techniques. 

 

 Designated “clean hands” (only handles inner bags). 

 Designated “dirty hands” (only handles outer bags). 

 All samplers wore tyvek® coveralls (or equivalent). 

 All samplers wore gloves. 

 Samplers got the “clean” original carboy cap ready to place on the carboy prior to 

removing the tubing and vented cap. The transition from the vented cap to the 

closed cap was done as quickly as possible to minimize contamination. 

 Clean hands closed the inner bag around the 20 L carboy and clean hands or dirty 

hands closed the outer bag. 

 The field blank and sample 20 L carboys were transported to the pump-off location 

in the trash cans. 

 
Effluent/Midpoint Composite Pump Off – Sampling Checklist 

Plant Name: 

Sampling Point Description: 

Set Number: 

Date of Audit: 

Auditor: 

Plant must pump off the effluent/midpoint composite samples after the 24-hour collection 

period. Complete the following checklist for midpoint/effluent pump off. Use the space 

below each check to record notes on pump-off procedures. 

 Samplers used clean hands/dirty hands techniques. 

 

 Designated “clean hands” (only handles inner bags). 

 Designated “dirty hands” (only handles outer bags). 

 All samplers wore tyvek® coveralls (or equivalent). 

 All samplers wore gloves. 

 

 Samplers covered all supporting tables. 

 All equipment used was previously cleaned and double bagged according to EPA 

instructions. 

 Dirty hands set up clean box and pump off tubing for clean hands (e.g., removed 

outer bags). 

 Dirty hands shook 20 L field blank carboy to mix volume prior to pump off and 

removed outer bag. 

 Clean hands removed clean pump off tubing from inner bag inside the clean box 

and covered ends for protection (i.e., used Ziploc baggies to avoid “clean” tubing 

ends from becoming “dirty”). 

 Clean hands untied the inner bag of the 20 L field blank carboy. 

 Samplers got the pump-off cap ready to place on the carboy prior to removing the 

closed cap. The transition from the closed cap to the pump-off cap was done as 

quickly as possible to minimize contamination. 
 Clean hands inserted the clean, Teflon end of the pump off tubing into the 20 L field 

blank carboy. 

 Dirty hands set up the ISCO for pump off. 

 Samplers were able to remove ISCO pump cover and “lay” sample tubing 

into the pump versus threading tubing through the ISCO. 

 If samplers threaded tubing through the ISCO, were the ends covered the 

entire time? What precautions were taken to keep the tubing “clean”? 

 Samplers recorded the volume of the 20 L field blank carboy and purged 1-2 L prior 

to sample collection. 

 Clean hands filled metals field blank bottles in the clean box using appropriate clean 

hands/dirty hands techniques (i.e., dirty hands only handles outer bag, clean hands 

only handles inner bag, clean hands opens/closes bottles and inner bags inside clean 

box). 

 Dirty hands shook 20 L composite carboy to mix volume prior to pump off and 

removed outer bag. 

 Clean hands untied the inner bag of the 20 L composite carboy. 

 Clean hands removed pump off cap, along with attached tubing, from the field 

blank carboy and transferred it to the composite carboy as quickly as possible to 

minimize contamination. 

 Samplers recorded the volume of the 20 L composite carboy and purged 2 L prior to 

sample collection. 

 Clean hands handled the tubing inside the clean box during sample collection. 

 If clean hands removed sample tubing from the clean box (i.e., during purge 

or in between bottle changes), end of tubing was covered with plastic bag. 
 Samplers used correct bottles for metals and classicals collection. 

 Metals – 500 mL plastic bottles. 

 Classicals – 1 L plastic bottles. 

 Metals bottles were double-bagged. 

 Bottle labels were on the outer bag, not on the inner bag, unless labeled prior in 

“clean” laboratory (not applicable for classicals). 

 Dirty hands opened the outer bag(s). 

 Clean hands opened the inner bag(s) and bottle(s) inside the clean box. 

 Clean hands filled the bottle(s) with the sample. 

 Clean hands closed the inner bag(s) in the clean box and placed in the outer bag. 

 Dirty hands closed the outer bag(s). 

 All metals samples were collected in clean box (clean hands sampling does not 

apply to the classical samples). 

 Classical samples were preserved 15 minutes after collection (see Preservation 

Checklist for further notes). 

 Field test jar was collected and temperature was measured within 5 minutes of grab 

to make sure samples were at ≤6 °C in the carboy. 

 
Effluent/Midpoint Mercury Grab – Sampling Checklist 

Plant Name: 

Sampling Point Description: 

Set Number: 

Date of Audit: 

Auditor: 

Plant must collect 4 mercury grab samples over a 24-hour period (1 sample, every 6 

hours). Complete the following checklist for each grab sample taken by the plant in the 

designated 24-hour period. Use the space below each check to record notes on the 

sampling procedure. NOTE: Reviewers are not expected to observe all four mercury 

grabs; however, they should observe at least two, or preferably three, grabs. 

Additionally, the reviewers should observe the first grab to note the field blank 

collection. 

G1: ________ am / pm 

G2: ________ am / pm 

G3: ________ am / pm 

G4: ________ am / pm 

G1 G2 G3 G4 

 Samplers collected sample from correct sample location/tap. 

 Samplers used clean hands/dirty hands techniques. 

 G1 G2 G3 G4 

 Designated “clean hands” (only handles inner bags). 

 Designated “dirty hands” (only handles outer bags). 

 All samplers wore tyvek® coveralls (or equivalent). 

 All samplers wore gloves. 

 All samplers wore dust masks. 

 Samplers shrouded the sample tap with a clean shroud (i.e., clear 

plastic bag). 

 NA NA NA Samplers collected the field blanks under the shroud using appropriate 

clean hands/dirty hands techniques (i.e., dirty hands only handles outer 

bag, clean hands only handles inner bag, clean hands opens/closes 

bottles and inner bags inside shroud). 
G1 G2 G3 G4 

 NA NA NA Samplers used reagent grade blank water for field blank collection. 

 Samplers purged sample tap for 2 minutes prior to sample collection. 

 Samplers used correct bottles for mercury collection. 

G1 G2 G3 G4 

 NA NA NA Total Hg V1 (Field Blank) – 250 mL glass bottle. 

 NA NA NA Total Hg V2 (Field Blank) – 250 mL glass bottle. 

 Total Mercury Grab – 125 mL glass bottle. 

 Bottles were double-bagged. 

 Bottle labels were on the outer bag, not on the inner bag, unless 

labeled prior in “clean” laboratory. 

 Dirty hands opened the outer bag. 

 Clean hands opened the inner bag and bottle underneath the shroud. 

 Clean hands filled the bottle with the sample. 

 Clean hands closed the inner bag and bottle underneath the shroud and 

placed it back in the outer bag. 

 Dirty hands closed the outer bag. 

 Field test jar was collected and pH/temp was measured within 5 

minutes of grab collection. 

 Clean hands collected CN sample. 

 CN sample was preserved 15 minutes after collection (see Preservation 

Checklist for further notes). 
Influent Grab – Sampling Checklist 

Plant Name: 

Sampling Point Description: 

Set Number: 

Date of Audit: 

Auditor: 

Plant must collect a grab sample from the FGD Wastewater Treatment influent. Complete 

the following checklist for the influent grab collection. Use the space below each check 

to record notes on sampling procedures. 

There are two different versions for the influent checklist: one for collection using tubing 

along with a clean box and one for collection directly from the sample tap under a 

shroud. If split samples are being collected, the samplers should be using the tubing set 

and clean box. Otherwise, the samplers will probably collect directly from the tap. 

Sample Tap/Shroud Collection Checklist:

 

 Samplers set up at correct sample location/tap. 

 Samplers used clean hands/dirty hands techniques. 

 Designated “clean hands” (only handles inner bags). 

 Designated “dirty hands” (only handles outer bags). 

 All samplers wore tyvek® coveralls (or equivalent). 

 All samplers wore gloves. 

 All samplers wore dust masks until mercury samples complete. 

 Samplers covered all supporting tables. 

 All equipment used was previously cleaned and double bagged according to EPA 

instructions. 

 Samplers shrouded the sample tap with a clean shroud (i.e., clear plastic bag). 
 Samplers collected the field blanks under the shroud using appropriate clean 

hands/dirty hands techniques (i.e., dirty hands only handles outer bag, clean hands 

only handles inner bag, clean hands opens/closes bottles and inner bags inside 

shroud). 

 Samplers used reagent grade blank water for mercury and metals field blank 

collection. 

 Dirty hands turned sample tap on and purged the line for 10 minutes prior to sample 

collection (Note: If influent purge does not last long, purge at least 2 minutes). 

 Influent flow was continuous for entire influent grab sample. 

 Bottles were double-bagged. 

 Bottle labels were on the outer bag, not on the inner bag, unless labeled prior in 

“clean” laboratory (not applicable for classicals). 

 Dirty hands opened the outer bag(s). 

 Clean hands opened the inner bag(s) and bottle(s) underneath the shroud. 

 Clean hands filled the bottle(s) with the sample. 

 Clean hands closed the bottle(s) and inner bag(s) underneath the shroud and placed 

it back in the outer bag. 

 Dirty hands closed the outer bag(s). 

 All mercury and metal samples were collected in clean box (clean hands sampling 

does not apply to the classical samples). 

 Samplers used correct bottles for mercury, metals, classicals, and cyanide 

collection. 
 Mercury (including field blanks) – 250 mL glass bottles. 

 Metals – 500 mL plastic bottles. 

 Classicals – 1 L plastic bottles. 

 Cyanide – 1 L plastic bottle. 

 Classical samples were preserved 15 minutes after collection (see Preservation 

Checklist for further notes). 

 CN sample was preserved 15 minutes after collection (see Preservation Checklist 

for further notes). 

 Field test jar was collected and pH/temp was measured within 5 minutes of grab. 
Influent Grab – Sampling Checklist 

Plant Name: 

Sampling Point Description: 

Set Number: 

Date of Audit: 

Auditor: 

Plant must collect a grab sample from the FGD Wastewater Treatment influent. Complete 

the following checklist for the influent grab collection. Use the space below each check 

to record notes on sampling procedures. 

There are two different versions for the influent checklist: one for collection using tubing 

along with a clean box and one for collection directly from the sample tap under a 

shroud. If split samples are being collected, the samplers should be using the tubing set 

and clean box. Otherwise, the samplers will probably collect directly from the tap. 

Sample Tubing/Clean Box Collection Checklist:

 Samplers set up at correct sample location/tap. 

 Samplers used clean hands/dirty hands techniques. 

 

 Designated “clean hands” (only handles inner bags). 

 Designated “dirty hands” (only handles outer bags). 

 All samplers wore tyvek® coveralls (or equivalent). 

 All samplers wore gloves. 

 All samplers wore dust masks until mercury samples complete. 

 

 Samplers covered all supporting tables. 

 All equipment used was previously cleaned and double bagged according to EPA 

instructions. 

 Dirty hands set up clean box and sample tubing for clean hands (e.g., removed outer 

bags). 

 Clean hands removed clean sample tubing from inner bag in clean box and covered 

ends for protection (i.e., used Ziploc baggies to avoid “clean” tubing ends from 

becoming “dirty”). 
 Clean hands connected the “clean” sample tubing and the “clean”, double bagged 

funnel using the inner bag as a shroud. 

 Clean hands poured reagent grade blank water through the funnel (covered with the 

clean shroud) to fill mercury and metals field blanks. 

 Clean hands filled field blank bottles in the clean box using appropriate clean 

hands/dirty hands technique (i.e., dirty hands only handles outer bag, clean hands 

only handles inner bag, clean hands opens/closes bottles and inner bags inside clean 

box). 

 Dirty hands attached tubing to the sample tap and used zip-tie to secure. 

 Dirty hands turned sample tap on and purged the line for 10 minutes prior to sample 

collection (Note: If influent purge does not last long, purge at least 2 minutes). 

 Influent flow was continuous for entire influent grab sample. 

 Clean hands handled the tubing inside the clean box during grab samples. 

 If clean hands removed sample tap from clean box (i.e., during purge or in 

between bottle changes), end of tubing was covered with plastic bag. 

 All mercury and metal samples were collected in clean box (clean hands sampling 

does not apply to the classical samples). 

 Samplers used correct bottles for mercury, metals, classicals, and cyanide 

collection. 

 Mercury (including field blanks) – 250 mL glass bottles. 

 Metals – 500 mL plastic bottles. 

 Classicals – 1 L plastic bottles. 

 Cyanide – 1 L plastic bottle. 
 Bottles were double-bagged. 

 Bottle labels were on the outer bag, not on the inner bag, unless labeled prior in 

“clean” laboratory (not applicable for classicals). 

 Dirty hands opened the outer bag(s). 

 Clean hands opened the inner bag(s) and bottle(s) in the clean box. 

 Clean hands filled the bottle(s) with the sample. 

 Clean hands closed the inner bag(s) in the clean box and placed it back in the outer 

bag. 

 Dirty hands closed the outer bag(s). 

 Classical samples were preserved 15 minutes after collection (see Preservation 

Checklist for further notes). 

 CN sample was preserved 15 minutes after collection (see Preservation Checklist 

for further notes). 

 Field test jar was collected and pH/temp was measured within 5 minutes of grab. 

 
Preservation Checklist 

Plant Name: 

Sampling Point Description: 

Set Number: 

Date of Audit: 

Auditor: 

Plant must preserve all classicals and cyanide samples according to the instructions 

provided by EPA in Table 2 of Enclosure 1 of the 308 Monitoring Letter received by the 

plant. Use the following table to mark the sample collection time, preservation time, and 

any notes regarding the preservation for the effluent, midpoint, and influent samples. 

Parameter On-site Preservation 

Sample 

Collection 

Time 

Preservation 

Time Notes 

BOD5 ≤6°C 

 

 

Group I ≤6°C 

 

Group II H2SO4 to pH <2, ≤6°C 

 

 

Total 

Cyanide 

Dilution until sulfide is not 

detected, NaAsO2 until total 

chlorine is not present, NaOH 

to pH >10, ≤6°C