Miami Fort Questions

Miami Fort sent an original analytical spreadsheet on 3/31/2014 and an updated analytical 

spreadsheet on 6/24/2014 with modified cell values highlighted in grey. ERG performed a QC of the two 

spreadsheets to make sure all changes were captured with these highlights and have determined some 

missing highlights and discrepancies.

1. For the FGD purge total mercury results on 8/3/2011, please confirm that your changes to the 

updated (6/24/2014) spreadsheet are based on essentially “throwing out” the U8 result because of 

the mixing of the U7 and U8 FGD wastewater and that Duke Energy is suggesting that the U7 

result be used as the average for that day. If this is not correct, please explain your reasoning. 

See Tables 1 and 2 below for the data reported in the two different version of the spreadsheet for 

these samples.

Table 1. Records for mercury in CP Influent on 8/3/2011 in updated spreadsheet

Date Analyte Procedure Units U7-FGD U8-FGD Amount RL Dilution

8/3/2011 Mercury Total ng/L 300,000 50,000 100,000

8/3/2011 Mercury Total ng/L (see J. Potts 

comment)

50,000 10,000

8/3/2011 Mercury Average ng/L 300,000

J. Potts comment: U7 & U8 Mixed sample; (290,000+320,000 dup)/2 = 305,000 avg but sample had both 

U7 and U8 flowing

Table 2. Records for mercury in CP Influent on 8/3/2011 in original spreadsheet

Date Analyte Procedure Units U7-FGD U8-FGD Amount RL Dilution

8/3/2011 Mercury Total ng/L 320,000 50,000 100,000

8/3/2011 Mercury Total ng/L 290,000 50,000 10,000

8/3/2011 Mercury Average ng/L 305,000

2. For CP effluent total arsenic result on 5/7/2013 (non-detect), the dilution factor was added into 

the updated spreadsheet, but not highlighted by the facility as a modification. EPA notes that the 

dilution factor added matches the value in the laboratory report.

3. For the effluent total mercury result on 1/6/2011 (99.6 ng/L), the reporting limit and dilution 

factor were added in the updated spreadsheet, but not highlighted as a modification. Please 

confirm this addition. EPA notes that the reporting limit and dilution factor added match the 

values in the laboratory report.

Arsenic Lab Report Comparison

4. There were discrepancies between the RL in the spreadsheet Duke provided for Miami Fort and 

the Lab Reports (see Table 3). Please indicate which RL is correct.
Table 3. RL Discrepancies between the Analytical Data Spreadsheet and the Lab Reports

DATE COLLECTED ANALYTE PROCEDURE RL in 

Spreadsheet

RL in 

Lab Report

9/1/2009 Arsenic Total 20 1

10/5/2009 Arsenic Total 20 1

11/2/2009 Arsenic Total 20 1

12/1/2009 Arsenic Total 20 1

2/2/2010 Arsenic Total 20 1

3/2/2010 Arsenic Total 40 2

4/6/2010 Arsenic Total 20 1

5/4/2010 Arsenic Total 20 1

6/1/2010 Arsenic Total 20 1

7/6/2010 Arsenic Total 20 1

8/3/2010 Arsenic Total 20 1

5. The CP effluent total arsenic result on 1/5/2010 was noted as non-detect in the spreadsheet with 

RL = 20. The lab report indicates a detected result at 3.30 ug/L with RL =1. Please confirm which 

record is correct.

6. For the total arsenic sample results on 7/31/12, 8/1/12, 8/8/12, and 8/9/12, there is a comment 

from Joe Potts indicating that the samples were diluted in the field by URS and then diluted in the 

laboratory by Applied Speciation.

a. Why were the samples diluted in the field by URS?

b. In the Joe Potts comments, it indicates the Applied Speciation result that was used to 

calculate the value presented in the spreadsheet. For 7/31/12, 8/8/12, and 8/9/12, the 

value identified in the comment is based on the result associated with “IDI-4” in the 

laboratory report. However, for 8/1/12, the value identified in the comment is based on 

the result associated with “IDI-1” in the laboratory report. Please explain what these 

sample points represent and explain the discrepancy for the value used for the 8/1/12 

result.

Mercury Lab Report Comparison

7. For the FGD purge total mercury results on 9/26/2011, the U7 and U8 results presented in the 

spreadsheet do not represent the average of the native and the duplicate sample. Instead, they 

represent only the native sample result. However, the “average” value presented in the 

spreadsheet (245,000 ng/L) does reflect the average of all four mercury results (i.e., U7 native, 

U7 duplicate, U8 native, U8 duplicate). Please confirm that the reported U7 result should be 

285,000 ng/L (average of 220,000 ng/L and 350,000 ng/L) and that the U8 result should be 

205,000 ng/L (average of 210,000 ng/L and 200,000 ng/L). Also, please confirm that the correct 

RL and dilution factor to use are RL= 50,000 and DF=100,000, which were obtained from the lab 

reports.

8. Several total mercury results in the spreadsheet do not have a reported RL and Dilution Factor,

but the laboratory reports contain these values (see Table 4). Please confirm the RLs and Dilution 

Factors.
Table 4. RL and Dilution Factor Discrepancies between the Analytical Spreadsheet and Lab 

Reports.

Date Unit

NonDetect 

Indicator

Amount RL in 

Spreadsheet

RL in 

Lab 

Report

Dilution in 

Spreadsheet

Dilution 

in Lab 

Report

Sample 

Description

9/26/2011 ng/L D

220,000 

(U7) 50,000 100,000

Influent to 

FGD 

WWTS (SP1, NPDES 

601)

9/26/2011 ng/L D

210,000 

(U8) 50,000 100,000

3/1/2012 ng/L D

1,300,000

(U7) 200,000 400,000

3/1/2012 ng/L D

830,000

(U8) 100,000 200,000

8/1/2013 ng/L D 104,500 5,000 10,000

2/2/2011 ng/L D 424 20 40

Effluent 

from FGD 

WWTS (SP2, NPDES 

608)

3/2/2012 ng/L D 49 10 20

2/5/2013 ng/L D 54.5 5 10

3/5/2013 ng/L D 110 5 10

5/2/2013 ng/L D 91.5 5 10

8/2/2013 ng/L D 66 5 10