Appendix B 

DATA REVIEW NARRATIVES 
1

MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD 

CC: Jezebele Alicea, Alternate Work Assignment Manager, EPA EAD 

 Deb Bartram, ERG 

 TJ Finseth, ERG 

From: Randy Mercurio, ERG 

Date: 9/21/2011

Subject: TestAmerica Data Review Narrative for Total Metals by 200.8 – Episode 6576

TestAmerica generated analytical data for total metals (antimony, arsenic, cadmium, 

chromium, copper, lead, nickel, selenium, silver, thallium and vanadium) for Sample 

Episode 6576. The samples were analyzed according to EPA Method 200.8. 

Table 1 summarizes the samples TestAmerica extracted and analyzed for total metals by 

EPA Method 200.8.

Table 1. EPA Episode 6576 Total Metals – Sample Identification 

EPA 

Sample 

# EPA Sample Description 

Lab Sample 

ID # 

Sample 

Matrix 

Sampling 

Date 

Receipt 

Date 

72511 FGD Influent, Day 3 280-14451-1 Aqueous 4/7/2011 4/11/2011

72512 FGD Influent, Day 2 280-14362-1 Aqueous 4/6/2011 4/8/2011

72513 Distillate from Brine Concentrator, Day 1 280-14362-3 Aqueous 4/5/2011 4/8/2011

72514 Distillate from Brine Concentrator, Day 2 280-14362-7 Aqueous 4/6/2011 4/8/2011

72515 Distillate from Brine Concentrator, Day 3 280-14451-2 Aqueous 4/7/2011 4/11/2011

72516 Condensate from Crystallizer, Day 1 280-14362-5 Aqueous 4/5/2011 4/8/2011

72517 Condensate from Crystallizer, Day 2 280-14362-8 Aqueous 4/6/2011 4/8/2011

72518 Condensate from Crystallizer, Day 3 280-14451-3 Aqueous 4/7/2011 4/11/2011

72519 FGD Influent Field Blank, Day 1 280-14362-2 Aqueous 4/5/2011 4/8/2011

72520 Distillate from BC Field Blank, Day 1 280-14362-4 Aqueous 4/5/2011 4/8/2011

72523 Condensate from Crystallizer Field 

Blank, Day 1 

280-14362-6 Aqueous 4/5/2011 4/8/2011

SUMMARY 

The samples were prepared for total metals analysis according to TestAmerica’s “FGD 

ICP/MS SOP: Inductively Coupled Plasma Mass Spectrometry for Trace Element 

Analysis in Flue Gas Desulfurization Wastewaters,” dated October 6, 2010, based on 

EPA Method 200.8, by ICP/MS analysis. 
2

There were no findings from the data review that required additional data qualifiers 

(excluding those identified by the laboratory) in this dataset. 

INTERNAL STANDARDIZATION 

All internal standards used by TestAmerica were within the method criteria. 

INITIAL CALIBRATION 

TestAmerica performed the initial calibrations on each analysis day. The initial 

calibration for the ICP-MS analysis consisted of a blank and four calibration standards. 

INITIAL AND CONTINUING CALIBRATION VERIFICATION (ICV/CCV) 

The initial calibration verifications (ICV) and continuing calibration verifications (CCV) 

performed by TestAmerica all had recoveries within the method criteria. 

METHOD/INSTRUMENT BLANKS 

All the method blanks were less than the reporting limit. No additional qualifiers were 

required for method blanks. 

All instrument blanks (ICB and CCB) were less than the reporting limit; however, some 

elements were above the MDL and flagged with a “J” qualifier. No additional qualifiers 

were required for instrument blanks. 

REPORTING LIMIT VERIFICATION STANDARD (CRI) 

All CRI samples passed TestAmerica’s SOP control limits of 50–150% recovery. 

LABORATORY CONTROL SAMPLES (LCS) 

All LCS samples passed the method QC limits of 85–115% recovery. 

SYNTHETIC FGD INTERFERENCE CHECK SOLUTION (ICSA) 

Based on TestAmerica’s SOP, all interference check sample A (ICSA) results had 

analytes of interest with concentrations less than the RL or less than five times the RL 

when known inherent contaminants are present in the stock solution used to make the 

ICS. 

All interference check sample B (ICSAB) synthetic spikes recovered within 

TestAmerica’s SOP criteria of 70–130% of the true value. 
3

SERIAL DILUTION (SRD) 

The serial dilution performed for the total sample 72514 Distillate from Brine 

Concentrator, Day 2 (280-14362-7) met Test America’s requirement of ±10% difference. 

FIELD DUPLICATES 

Field duplicates were not collected for this sampling episode. 

MATRIX SPIKE AND MATIX SPIKE DUPLICATES (MS/MSD) 

Matrix spikes (MS) and matrix spike duplicates (MSD) were performed on the total 

samples of 72514 Distillate from Brine Concentrator, Day 2 (280-14362-7 MS/MSD) and 

72518 Condensate from Crystallizer, Day 3 (280-14451-3 MS/MSD). The MS/MSD of 

both samples passed the method control limits of 70–130% recovery and the RPD control 

limits of ±20% from the FGD ICP/MS SOP. No additional data qualifiers were required 

for MS/MSD samples. 

POST DIGESITON SPIKES 

A post digestion spike was performed on sample 72514 Distillate from Brine 

Concentrator, Day 2 (280-14362-7 PDS), which passed TestAmerica’s control limits of 

85–115% recovery. No additional data qualifiers were required. 

DETECTION LIMITS 

The laboratory performed an MDL study in the synthetic FGD wastewater matrix, instead 

of reagent water. 
1

MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD 

CC: Jezebele Alicea, Alternate Work Assignment Manager, EPA EAD 

 Deb Bartram, ERG 

 TJ Finseth, ERG 

From: Randy Mercurio, ERG 

Date: 9/21/2011

Subject: TestAmerica Data Review Narrative for Total Metals by 200.7 – Episode 6576

TestAmerica generated analytical data for total metals (aluminum, boron, barium, 

beryllium, calcium, cobalt, iron, magnesium, manganese, molybdenum, sodium, tin, 

titanium, and zinc). The samples were analyzed according to EPA Method 200.7. 

Table 1 summarizes the samples TestAmerica extracted and analyzed for total metals by 

EPA Method 200.7.

Table 1. EPA Episode 6576 Total Metals – Sample Identification 

EPA 

Sample 

# EPA Sample Description 

Lab Sample 

ID # 

Sample 

Matrix 

Sampling 

Date 

Receipt 

Date 

72511 FGD Influent, Day 3 280-14451-1 Aqueous 4/7/2011 4/11/2011

72512 FGD Influent, Day 2 280-14362-1 Aqueous 4/6/2011 4/8/2011

72513 Distillate from Brine Concentrator, 

Day 1 

280-14362-3 Aqueous 4/5/2011 4/8/2011

72514 Distillate from Brine Concentrator, 

Day 2 

280-14362-7 Aqueous 4/6/2011 4/8/2011

72515 Distillate from Brine Concentrator, 

Day 3 

280-14451-2 Aqueous 4/7/2011 4/11/2011

72516 Condensate from Crystallizer, Day 1 280-14362-5 Aqueous 4/5/2011 4/8/2011

72517 Condensate from Crystallizer, Day 2 280-14362-8 Aqueous 4/6/2011 4/8/2011

72518 Condensate from Crystallizer, Day 3 280-14451-3 Aqueous 4/7/2011 4/11/2011

72519 FGD Influent Field Blank, Day 1 280-14362-2 Aqueous 4/5/2011 4/8/2011

72520 Distillate from BC Field Blank, Day

1 

280-14362-4 Aqueous 4/5/2011 4/8/2011

72523 Condensate from Crystallizer Field 

Blank, Day 1 

280-14362-6 Aqueous 4/5/2011 4/8/2011
2

SUMMARY 

The samples were prepared for total metals analysis according to Test America’s SOP for 

ICP Analysis for Trace Metals by Method 200.7. Any significant findings are 

summarized below. No additional data qualifiers were required for this data set. 

• The post digestion spike (PDS) for total sodium for sample 72514 failed the 

method criteria of 85–115%. 

• The post digestion spike (PDS) for total boron for sample 72514 failed the 

method criteria of 85–115%, but was not qualified because the sample 

concentration was greater than 4 times the spike concentration. 

SAMPLE RECEIPT, HANDLING AND STORAGE ISSUES 

No issues were found with sample receipt, handling, or storage. 

INTERNAL STANDARDIZATION 

While the internal standard (ISTD) Yttrium was used for these analyses, no checks on the 

ISTD recoveries in the ±30% criterion of the calibration blank as per Section 9.11 of the 

SOP were seen. All ISTD were within the control limits. 

INITIAL CALIBRATION 

TestAmerica performed the initial calibrations on each analysis day. The initial 

calibration for the ICP analysis consisted of a blank and one calibration standard. 

INITIAL AND CONTINUING CALIBRATION VERIFICATIONS 

The initial calibration verifications (ICV) and continuing calibration verifications (CCV) 

performed by TestAmerica all had recoveries within the method criteria. In some cases 

the CCVs failed the method criteria, but the affected samples were re-analyzed. 

METHOD/INSTRUMENT BLANKS 

All the method blanks were less than the reporting limit; however, some had levels above 

the MDL and were flagged with the “J” qualifier. 

All instrument blanks (ICB and CCB) were less than the reporting limit; however, some 

elements were above the MDL and were flagged with the “J” qualifier. 

REPORTING LIMIT VERIFICATION STANDARD (CRI) 

All CRI samples passed Test America’s SOP control limits of 50–150% recovery. 
3

LABORATORY CONTROL SAMPLES (LCS) 

All LCS passed the method control limits of 85–115% recovery. 

INTERFERENCE CHECK SOLUTIONS 

Interference checks were performed using the synthetic matrix as the check solution. All 

recoveries met the method-specified criteria. 

SERIAL DILUTION (SRD) 

The serial dilution performed for the total sample 72514 Distillate from Brine 

Concentrator, Day 2 (280-14362-7) met Test America’s requirement of ±10% difference. 

FIELD DUPLICATES 

Field duplicates were not collected for this sampling episode. 

MATRIX SPIKE AND MATIX SPIKE DUPLICATES (MS/MSD) 

Matrix spikes (MS) and matrix spike duplicates (MSD) were performed on the total 

samples of 72514 Distillate from Brine Concentrator, Day 2 (280-14362-7 MS/MSD) and 

72518 Condensate from Crystallizer, Day 3 (280-14451-3 MS/MSD). 

The MS of sample 72514 failed EPA Method 200.7 spike recovery control limits of 70–

130% for boron, but was flagged with a “4” qualifier indicating that the concentration in 

the parent sample was greater than 4 times the spike and could not be reliably calculated. 

Otherwise, the MS/MSD spike recoveries were always within the control limits of 70-

130% for both samples. The relative percent difference (RPD) for the MS/MSD of 

samples 72514 and 72518 passed TestAmerica’s SOP requirement of ± 20%. 

POST DIGESTION SPIKE 

A PDS of total sample 72514 Distillate from Brine Concentrator, Day 2 (280-14362-7 

PDS) failed the method criteria of 85–115% for sodium, which was qualified with a “W”. 

Boron also failed at 158% recovery but was not qualified because the sample 

concentration was greater than 4 times the spike concentration. Boron, did however, pass 

the serial dilution criteria for this sample demonstrating that there was no significant 

matrix interference. No additional data qualifiers are required. 

DETECTION LIMITS 

The laboratory performed an MDL study in the synthetic FGD wastewater matrix, instead 

of reagent water. 
1

MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD

CC: Jezebele Alicea, Alternate Work Assignment Manager, EPA EAD 

 Deb Bartram, ERG 

 TJ Finseth, ERG 

From: Ariel Atkinson, ERG 

 Donna Tedder, ERG 

Date: 9/21/2011

Subject: FGS Data Review Narrative for Total Mercury – Episode 6576

Frontier Global Sciences (FGS) generated analytical data for total mercury. The samples 

were analyzed according to EPA Method 1631E for total mercury by Cold Vapor Atomic 

Fluorescence Spectrometry (CVA-FS) analysis. 

Table 1 summarizes the 15 samples (excluding laboratory prep blanks) FGS extracted 

and analyzed for total mercury. 

Table 1. EPA Episode 6576 Total Mercury – Sample Identification 

EPA 

Sample # 

Lab Sample 

ID # 

Sample 

Matrix Sample Description 

Sampling 

Date 

72511 1104114-13 Aqueous FGD Influent, Day 3 04/07/2011 

72512 1104114-01 Aqueous FGD Influent, Day 2 04/06/2011 

72513 1104102-04RE2 Aqueous Distillate from Brine Concentrator, Day 1 04/05/2011 

72514 1104103-04RE2 Aqueous Distillate From Brine Concentrator, Day 2 04/06/2011 

72515 1104114-06 Aqueous Distillate From Brine Concentrator, Day 3 04/07/2011 

72516 1104102-09 Aqueous Condensate from Crystallizer, Day 1 04/05/2011 

72517 1104103-09 Aqueous Condensate from Crystallizer, Day 2 04/06/2011 

72518 1104114-11RE1 Aqueous Condensate From Crystallizer, Day 3 04/07/2011 

72519 1104114-02 Aqueous FGD Influent Field Blank, Day 1 04/05/2011 

72520 1104102-05 Aqueous Distillate from BC Field Blank, Day 1 04/05/2011 

72521 1104103-05 Aqueous Distillate from BC Field Blank, Day 2 04/06/2011 

72522 1104114-07 Aqueous Distillate From BC Field Blank, Day 3 04/07/2011 

72523 1104102-10 Aqueous Cond. from Crystlzr., Field Blank, Day 1 04/05/2011 

72524 1104103-10 Aqueous Cond. from Crystlzr., Field Blank, Day 2 04/06/2011 

72525 1104114-12 Aqueous Cond. From Crystlzr., Field Blank, Day 3 04/07/2011 
2

SUMMARY 

The samples were prepared according to EPA Method 1631E to be analyzed by CVAFS. 

There were no findings from the data review that required additional qualifiers in this 

dataset. 

SAMPLE RECEIPT, HANDLING, AND STORAGE ISSUES 

The FGD Influent Day 2 sample ID was wrong on the chain of custody; the sample 

number was given as 72511 when it should have been 72512. There were no other sample 

receipt issues in this data package. 

INITIAL CALIBRATION 

FGS performed the initial calibrations on the analysis day. The initial calibration for the 

CVAFS analysis consisted of a blank and five calibration standards with a correlation 

coefficient ≥0.995. All method-specified criteria were met. 

INITIAL AND CONTINUING CALIBRATION VERIFICATIONS 

All initial and continuing calibration verifications (ICVs, CCVs) met method-specified 

criteria. 

BLANKS 

All the preparation blanks or laboratory reagent blanks (LRBs) and the continuing 

calibration blanks (CCBs) met method-specified criteria. There was an FGD Influent 

field blank (FB) on Day 1, while the Influent samples were collected on Days 2 and 3.

DUPLICATES 

No field duplicate samples were collected with these sampling episodes. One sample was 

analyzed as a laboratory duplicate, Condensate from Crystallizer, Day 3 (sample 72518). 

The RPD was 5.62%. The laboratory’s RPD criteria between analytical duplicates is 

24%. 

LABORATORY CONTROL SAMPLES 

All laboratory control samples were within Frontier’s control limits of 80-120% recovery 

and 24% RPD. 

MATRIX SPIKE AND MATIX SPIKE DUPLICATES (MS/MSD) 
3

Matrix spikes (MS) and matrix spike duplicates (MSD) were performed on samples 

72518 and 72514. All aqueous MS/MSD recoveries were within method specifications of 

71-125%. All RPDs met method-specified criteria. 

DETECTION LIMITS 

The laboratory MDL in the synthetic matrix was 0.239 ng/L. Results below this MDL 

were reported as not detected (ND). 
1 

MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD 

CC: Jezebele Alicea, Alternate Work Assignment Manager, EPA EAD 

 Deb Bartram, ERG 

 TJ Finseth, ERG 

From: Donna Tedder, ERG 

Date: 9/21/2011 

Subject: TestAmerica Data Review Narrative for Classicals Analyses – Episode 6576 

TestAmerica Denver Laboratory generated analytical data for classical wet chemistry 

analyses for Sample Episode 6576. All samples were tested for the following analytes: 

• Ammonia by EPA method 350.1, 

• Chloride and Sulfate by EPA method 300.0, 

• Chemical Oxygen Demand (COD) by EPA method 410.4, 

• Nitrate/Nitrite by EPA method 353.2, 

• Phosphorus (total) by EPA method 365.1, 

• Total Dissolved Solids (TDS) by SM 2540C, 

• Total Kjeldahl Nitrogen (TKN) by EPA method 351.2, and 

• Total Suspended Solids (TSS) by SM 2540D. 

Table 1 summarizes the 11 samples that TestAmerica analyzed for the above analytes. 

Table 1. EPA Episode 6576 Classical Analytes – Sample Identification 

EPA 

Sample # 

Sample 

Matrix Sample Description 

Sampling 

Date 

72511 Water FGD Influent, Day 3 4/7/11 

72512 Water FGD Influent, Day 2 4/6/11 

72513 Water Distillate From Brine Concentrator, Day 1 4/5/11 

72514 Water Distillate From Brine Concentrator, Day 2 4/6/11 

72515 Water Distillate From Brine Concentrator, Day 3 4/7/11 

72516 Water Condensate From Crystallizer, Day 1 4/5/11 

72517 Water Condensate From Crystallizer, Day 2 4/6/11 

72518 Water Condensate From Crystallizer, Day 3 4/7/11 

72519 Water FGD Influent Field Blank, Day 1 4/5/11 

72520 Water Distallate From BC Field Blank, Day 1 4/5/11 

72523 Water Conds. From Crystllzr Field Blank, Day 1 4/5/11 
2 

SUMMARY 

All samples were analyzed within the holding time specified in 40 CFR 136 Table II. All 

samples were preserved appropriately unless otherwise specified below. Group I and 

Group II samples 72511, 72515, and 72518 were received at 15.4°C and 17.1°C due to 

international shipping issues. The client was notified and analyses performed. 

 

If applicable, the appropriate number of standards was used to create a calibration curve. 

If sample results were above the highest standard used to create the curve, the sample was 

diluted and reanalyzed. All sample results were between the lowest and highest standards 

unless noted below. Additionally, unless otherwise noted, all calibration blanks and 

calibration verification samples met the criteria specified in the method. 

If required by the method, the quality control sample (QCS), a secondary source standard 

used to verify calibration, was always within the control limits specified by the method. 

As described below, the analyte of interest was detected above the method detection limit 

(MDL) in some laboratory reagent blanks (LRB). However, the analyte of interest was 

never detected above the reporting limit (RL) in the LRBs. If required by the method, all 

laboratory fortified blanks (LFB) met the criteria specified in the method unless specified 

below. 

If required by the method, a matrix spike (MS) sample was analyzed on samples 72514 

and 72518 for each analyte to check for matrix interferences. For some analytes, 

TestAmerica spiked more samples than required. All MS samples analyzed met the 

criteria specified in the method unless described below. 

DATA NOTES/ISSUES 

Ammonia 

Samples 72511, 72515, and 72518 were received at 15.4°C and 17.1°C. The method 

requires samples to be maintained at 4°C between collection and analysis. The results for 

these samples were qualified as estimated values. 

The MS/MSD analysis on sample 72518 yielded percent recoveries for the MS and MSD 

of 100% and 94%, respectively. Since the sample concentration was greater than 4 times 

the spike amount in the MS and MSD samples, TestAmerica stated that the percent 

recoveries and RPDs could not be reliably calculated and the results were flagged with a 

“4”. 

BOD5 

No BOD was analyzed for this sampling episode. 
3 

Chloride and Sulfate 

Samples 72511, 72515, and 72518 were received at 15.4°C and 17.1°C. The method 

requires samples to be maintained at 4°C between collection and analysis for sulfate (no 

temperature requirements for chloride analysis). Sulfate in samples 72515 and 72518 

was not detected, and therefore, does not need additional qualification. Sample 72511 

was qualified as an estimated value. 

The MS/MSD chloride recoveries for sample 72514 were above the EPA Method 300.0 

control limits and qualified with an “F”. The LFB associated with this sample met the 

method criteria. There was no need for additional qualifiers for the sample. 

Sample 72514 and its laboratory duplicate had results below the lowest calibration 

standard and the RL, but above the MDL. This result was flagged with a “J,” and does 

not need additional qualification. 

COD 

Samples 72511, 72515, and 72518 were received at 15.4°C and 17.1°C. The method 

requires samples to be maintained at 4°C between collection and analysis. Samples 

72515 and 72518 have been qualified with a “J”, and do not need additional qualification. 

Sample 72511 was qualified as an estimated value. 

The MS/MSD recoveries for sample 72514 were above the control limits of 90-110% 

required by EPA method 410.4 with recoveries at 122% and 112%, respectively. The 

RPD between the MS and MSD was 11%, which is also outside the method control 

limits. COD for sample 72514 was not detected, and the MS and MSD results were 

qualified with an “F.” The LFB percent recoveries associated with this sample met the 

method criteria. There was no need for additional qualifiers for the sample. 

Sample 72515 had a result below the lowest calibration standard and the RL, but above 

the MDL. This result was flagged with a “J,” and does not need additional qualification. 

Cyanide 

No cyanide was analyzed for this sampling episode. 

Nitrate/Nitrite 

Samples 72511, 72515, and 72518 were received at 15.4°C and 17.1°C. The method 

requires samples to be maintained at 4°C between collection and analysis. Samples 

72511, 72515, and 72518 were qualified as estimated values. 
4 

Phosphorus 

Samples 72511, 72515, and 72518 were received at 15.4°C and 17.1°C. The method 

requires samples to be maintained at 4°C between collection and analysis. Phosphorus in 

samples 72515 and 72518 was not detected, and therefore, does not need additional 

qualification. Sample 72511 was qualified as an estimated value. 

TDS 

Constant weight was not achieved after 3 drying cycles for sample 72517. The samples 

were not qualified, but results may be biased high. 

The RPD for the laboratory duplicate for sample 72518 was 43%, which is greater than 

10% as required by SM 2540C. Because the RPD was greater than the method control 

limits, sample 72518 should be qualified as an estimated value. However, this sample is 

already qualified with a “J” meaning that the result is less than the RL but greater than or 

equal to the MDL and the concentration is an approximate value. Therefore, no additional 

qualifier is needed. The RPD for the sample 72514 laboratory duplicate was within 

method limits. 

TKN 

The ammonia concentrations were greater than the TKN, particularly for samples 72512 

and 72517, and were re-analyzed for confirmation. Since TKN is a sum of free ammonia 

and organic nitrogen compounds, the ammonia concentrations should be less than the 

TKN numbers. The method states that in samples with high nitrate levels the TKN may 

be biased low. The TKN results for samples 72512 and 72517 were qualified as 

estimated values. 

Samples 72511, 72515, and 72518 were received at 15.4°C and 17.1°C. The method 

requires samples to be maintained at 4°C between collection and analysis. These results 

were qualified as estimated values. 

 

TestAmerica performed MS/MSD analysis on sample 72514. The percent recoveries for 

the MS and MSD samples were 85% and 78%, respectively. These did not meet the 

method control limits of 90-110%, but did meet the laboratory control limits of 54-131%. 

Since the sample concentration was greater than 4 times the spike amount in the MS and 

MSD samples, TestAmerica stated that the percent recoveries and RPDs could not be 

reliably calculated. Therefore, sample 72514 was not additionally qualified because it is 

not possible to determine if the failure was a result of matrix interferences or caused by 

spiking the sample with too little analyte. 

TKN was detected at 0.124 mg/L in the LRB associated with samples 72511, 72514, and 

72518. This blank result was greater than the MDL (0.077 mg/L), but less than the RL 

(1.0 mg/L). Because the blank result was less than the RL, no samples were qualified 

based on the LRB result. 
5 

TSS 

Constant weight was not achieved after 3 drying cycles for sample 72512 and the 

laboratory duplicate. 

The RPD for the laboratory duplicate of sample 72512 was 33%. This RPD was greater 

than the method control criteria of 10%. Sample 72512 was qualified as an estimated 

value. The RPD for the laboratory duplicates of samples 72514 and 72518 could not be 

calculated because all results were not detected. 

Table 2. Data Review Summary Table 

Sample Analyte Qualifier/Action Reason Level Detected

72511 Sulfate Estimated Value Sample received at > 4°C 5700 mg/L 

72511 Ammonia Estimated Value Sample received at > 4°C 12 mg/L 

72515 Ammonia Estimated Value Sample received at > 4°C 15 mg/L 

72518 Ammonia Estimated Value Sample received at > 4°C 22 mg/L 

72511 COD Estimated Value Sample received at > 4°C 100 mg/L 

72511 Nitrate/nitrite Estimated Value Sample received at > 4°C 46 mg/L 

72515 Nitrate/nitrite Estimated Value Sample received at > 4°C 0.16 mg/L 

72518 Nitrate/nitrite Estimated Value Sample received at > 4°C 0.1 mg/L 

72511 Phosphorus Estimated Value Sample received at > 4°C 6 mg/L 

72511 TKN Estimated Value Sample received at > 4°C 11 mg/L 

72512 TKN Estimated Value TKN value < Ammonia 

value 

3.6 mg/L 

72515 TKN Estimated Value Sample received at > 4°C 16 mg/L 

72517 TKN Estimated Value TKN value < Ammonia 

value 

37 mg/L 

72518 TKN Estimated Value Sample received at > 4°C 25 mg/L 

72512 TSS Estimated Value Lab duplicate RPD > 

method-specified criteria 

2600 mg/L 
Appendix C 

PICTURES FROM THE SAMPLING EPISODE 
C-1 

Figure C-1. Sampler Working Inside a “Cleanbox” 

 
C-2 

Figure C-2. Picture of Sampling Location and Tubing Attached to the PVC Pipe at the 

Influent to the FGD Wastewater Treatment Sytem 
C-3 

Figure C-3. Sample Collection Set-Up at the Distillate from the Brine Concentrator 
C-4 

Figure C-4. Sample Collection Set-Up at the Condensate from the Crystallizer