Draft

Sampling Plan

Duke Energy Carolinas’

Belews Creek Steam Station

Belews Creek, NC

Sampling Episode XXXX

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

5 September 2008

EPA Contract No. 68-C02-095

Work Assignment 5-22

TABLE OF CONTENTS

Page

  TOC \o "1-3" \h \z    HYPERLINK \l "_Toc208387823"  1.	Introduction	 
PAGEREF _Toc208387823 \h  1-1  

  HYPERLINK \l "_Toc208387824"  1.1	Background	  PAGEREF _Toc208387824
\h  1-1  

  HYPERLINK \l "_Toc208387825"  1.2	Objectives and Scope	  PAGEREF
_Toc208387825 \h  1-2  

  HYPERLINK \l "_Toc208387826"  1.3	Plant Selection	  PAGEREF
_Toc208387826 \h  1-2  

  HYPERLINK \l "_Toc208387827"  2.	Facility Overview	  PAGEREF
_Toc208387827 \h  2-1  

  HYPERLINK \l "_Toc208387828"  2.1	FGD Scrubber Systems	  PAGEREF
_Toc208387828 \h  2-2  

  HYPERLINK \l "_Toc208387829"  2.2	FGD Wastewater Treatment System	 
PAGEREF _Toc208387829 \h  2-3  

  HYPERLINK \l "_Toc208387830"  3.	Sampling Procedures	  PAGEREF
_Toc208387830 \h  3-1  

  HYPERLINK \l "_Toc208387831"  3.1	Sampling Point Selection	  PAGEREF
_Toc208387831 \h  3-1  

  HYPERLINK \l "_Toc208387832"  3.2	Analyte Selection	  PAGEREF
_Toc208387832 \h  3-1  

  HYPERLINK \l "_Toc208387833"  3.3	Sample Collection Procedures	 
PAGEREF _Toc208387833 \h  3-2  

  HYPERLINK \l "_Toc208387834"  3.3.1	Influent to FGD Wastewater
Treatment System (SP-1)	  PAGEREF _Toc208387834 \h  3-3  

  HYPERLINK \l "_Toc208387835"  3.3.2	Influent to Bioreactor System
(SP-2)	  PAGEREF _Toc208387835 \h  3-8  

  HYPERLINK \l "_Toc208387836"  3.3.3	Effluent from Bioreactor System
(SP-3)	  PAGEREF _Toc208387836 \h  3-13  

  HYPERLINK \l "_Toc208387837"  3.4	Sample Preservation, Shipping, and
Analysis	  PAGEREF _Toc208387837 \h  3-18  

  HYPERLINK \l "_Toc208387838"  3.5	Field Measurements and Engineering
Data Collection	  PAGEREF _Toc208387838 \h  3-19  

  HYPERLINK \l "_Toc208387839"  3.6	Sample Labeling	  PAGEREF
_Toc208387839 \h  3-19  

  HYPERLINK \l "_Toc208387840"  3.7	Traffic Reports	  PAGEREF
_Toc208387840 \h  3-20  

  HYPERLINK \l "_Toc208387841"  3.8	Quality Assurance/Quality Control	 
PAGEREF _Toc208387841 \h  3-20  

  HYPERLINK \l "_Toc208387842"  3.9	Sample Splitting	  PAGEREF
_Toc208387842 \h  3-22  

  HYPERLINK \l "_Toc208387843"  4.	Sampling Activities	  PAGEREF
_Toc208387843 \h  4-1  

  HYPERLINK \l "_Toc208387844"  4.1	Sampling Team Organization	  PAGEREF
_Toc208387844 \h  4-1  

  HYPERLINK \l "_Toc208387845"  4.2	Pre-Sampling Preparation	  PAGEREF
_Toc208387845 \h  4-1  

  HYPERLINK \l "_Toc208387846"  4.3	Field Sampling Activities	  PAGEREF
_Toc208387846 \h  4-1  

  HYPERLINK \l "_Toc208387847"  4.4	Logistics	  PAGEREF _Toc208387847 \h
 4-2  

  HYPERLINK \l "_Toc208387848"  4.4.1	Belews Creek Steam Station
Contacts	  PAGEREF _Toc208387848 \h  4-2  

  HYPERLINK \l "_Toc208387849"  4.4.2	EPA Contacts	  PAGEREF
_Toc208387849 \h  4-2  

  HYPERLINK \l "_Toc208387850"  4.4.3	Analytical Laboratories	  PAGEREF
_Toc208387850 \h  4-3  

  HYPERLINK \l "_Toc208387851"  4.4.4	ERG Contacts	  PAGEREF
_Toc208387851 \h  4-3  

  HYPERLINK \l "_Toc208387852"  4.4.5	Freight Forwarders	  PAGEREF
_Toc208387852 \h  4-3  

  HYPERLINK \l "_Toc208387853"  5.	Sample Shipment	  PAGEREF
_Toc208387853 \h  5-1  

  HYPERLINK \l "_Toc208387854"  5.1	Sample Set Preparation	  PAGEREF
_Toc208387854 \h  5-1  

  HYPERLINK \l "_Toc208387855"  5.2	Sample Packing	  PAGEREF
_Toc208387855 \h  5-1  

  HYPERLINK \l "_Toc208387856"  6.	Site-Specific Health and Safety
Procedures	  PAGEREF _Toc208387856 \h  6-1  

  HYPERLINK \l "_Toc208387857"  6.1	Emergency/Medical Procedures	 
PAGEREF _Toc208387857 \h  6-1  

  HYPERLINK \l "_Toc208387858"  6.1.1	First Aid	  PAGEREF _Toc208387858
\h  6-1  

  HYPERLINK \l "_Toc208387859"  6.1.2	Site Evacuation/Emergency Response
Plan	  PAGEREF _Toc208387859 \h  6-1  

  HYPERLINK \l "_Toc208387860"  6.1.3	Emergency Showers and Eye Washes	 
PAGEREF _Toc208387860 \h  6-1  

  HYPERLINK \l "_Toc208387861"  6.1.4	Local Hospital	  PAGEREF
_Toc208387861 \h  6-1  

  HYPERLINK \l "_Toc208387862"  6.2	ERG Health and Safety
Responsibilities and Authority	  PAGEREF _Toc208387862 \h  6-2  

  HYPERLINK \l "_Toc208387863"  6.2.1	Work Assignment Manager	  PAGEREF
_Toc208387863 \h  6-2  

  HYPERLINK \l "_Toc208387864"  6.2.2	Crew Chief	  PAGEREF _Toc208387864
\h  6-2  

  HYPERLINK \l "_Toc208387865"  6.2.3	Sampling Team Members	  PAGEREF
_Toc208387865 \h  6-2  

  HYPERLINK \l "_Toc208387866"  6.3	Briefings	  PAGEREF _Toc208387866 \h
 6-2  

  HYPERLINK \l "_Toc208387867"  6.3.1	Off-Site Briefings	  PAGEREF
_Toc208387867 \h  6-2  

  HYPERLINK \l "_Toc208387868"  6.3.2	On-Site Briefings	  PAGEREF
_Toc208387868 \h  6-3  

  HYPERLINK \l "_Toc208387869"  6.4	Safety Procedures	  PAGEREF
_Toc208387869 \h  6-3  

  HYPERLINK \l "_Toc208387870"  6.4.1	Personal Protective Equipment
(PPE)	  PAGEREF _Toc208387870 \h  6-3  

  HYPERLINK \l "_Toc208387871"  6.4.2	Safety Practices	  PAGEREF
_Toc208387871 \h  6-3  

  HYPERLINK \l "_Toc208387872"  6.4.3	Safe Work Practices	  PAGEREF
_Toc208387872 \h  6-4  

  HYPERLINK \l "_Toc208387873"  6.5	Sampling Point-Specific Safety
Procedures	  PAGEREF _Toc208387873 \h  6-4  

  HYPERLINK \l "_Toc208387874"  6.5.1	Physical Hazards	  PAGEREF
_Toc208387874 \h  6-4  

  HYPERLINK \l "_Toc208387875"  6.5.2	Thermal Hazards	  PAGEREF
_Toc208387875 \h  6-5  

  HYPERLINK \l "_Toc208387876"  6.5.3	Chemical Hazards	  PAGEREF
_Toc208387876 \h  6-5  

  HYPERLINK \l "_Toc208387877"  6.6	Temperature Extremes	  PAGEREF
_Toc208387877 \h  6-5  

  HYPERLINK \l "_Toc208387878"  6.6.1	Heat Stress	  PAGEREF
_Toc208387878 \h  6-5  

  HYPERLINK \l "_Toc208387879"  6.6.2	Heat Stress Monitoring	  PAGEREF
_Toc208387879 \h  6-6  

  HYPERLINK \l "_Toc208387880"  6.7	First Aid	  PAGEREF _Toc208387880 \h
 6-7  

  HYPERLINK \l "_Toc208387881"  6.8	Sample Preservation and Safety
Considerations	  PAGEREF _Toc208387881 \h  6-8  

  HYPERLINK \l "_Toc208387882"  6.9	Training and Medical Monitoring
Requirements	  PAGEREF _Toc208387882 \h  6-8  

  HYPERLINK \l "_Toc208387883"  6.10	Shift Work Protocol	  PAGEREF
_Toc208387883 \h  6-9  

  HYPERLINK \l "_Toc208387884"  7.	References	  PAGEREF _Toc208387884 \h
 7-1  

 

  SEQ CHAPTER \h \r 1 Appendix A:	List of Metals Constituents for
Analysis

LIST OF TABLES

Page

  TOC \t "Table Heading" \c  3-1	Sample Collection at the Belews Creek
Steam Station	  PAGEREF _Toc208387885 \h  3-23 

3-2	Analytical Methods and Procedures for Samples Collected at Belews
Creek	  PAGEREF _Toc208387886 \h  3-24 

3-3	Summary of Sample Container and Planned Preservation	  PAGEREF
_Toc208387887 \h  3-25 

3-4	Sampling Point Field Measurements	  PAGEREF _Toc208387888 \h  3-26 

6-1	Sample-Point-Specific Personal Protective Equipment and Potential
Hazards	  PAGEREF _Toc208387889 \h  6-10 

 

LIST OF FIGURES

Page

  TOC \t "Figure Title" \c  2-1	Simplified Diagram of the FGD Wastewater
Treatment System, Belews Creek Steam Station	  PAGEREF _Toc208387890 \h 
2-7 

2-2	Physical/Chemical Separation and Biological Reactor Portion of FGD
Wastewater Treatment System, Belews Creek Steam Station	  PAGEREF
_Toc208387891 \h  2-8 

2-3	Contructed Wetland Treatment System Portion of FGD Wastewater
Treatment System, Belews Creek Steam Station	  PAGEREF _Toc208387892 \h 
2-10 

3-1	Sample Preservation Log Sheet	  PAGEREF _Toc208387893 \h  3-27 

3-2	Field Sampling Log Sheet	  PAGEREF _Toc208387894 \h  3-28 

3-3	Engineering Data Collection Sheet (Page 1 of 3)	  PAGEREF
_Toc208387895 \h  3-29 

3-4	Engineering Data Collection Sheet (Page 2 of 3)	  PAGEREF
_Toc208387896 \h  3-30 

3-5	Engineering Data Collection Sheet (Page 3 of 3)	  PAGEREF
_Toc208387897 \h  3-31 

3-6	Example SCC Traffic Report	  PAGEREF _Toc208387898 \h  3-32 

 

Introduction

	The Engineering and Analysis Division (EAD) of the U.S. Environmental
Protection Agency (EPA) is currently conducting a site visit and
sampling program at steam electric power plants. The sampling program
will characterize raw wastewaters generated by coal-fired steam electric
power plants, as well as evaluate treatment technologies and best
management practices used to reduce pollutant discharges. This sampling
plan, developed for the Duke Energy Carolinas’ Belews Creek Steam
Station (Belews Creek), provides plant-specific sampling procedures and
methods EPA and its contractors will follow when conducting sampling
activities. Sampling will be performed by EPA’s technical contractor,
Eastern Research Group, Inc. (ERG), under Contract No. 68-C02-095, Work
Assignment 6-22. This document, in combination with the Generic Sampling
and Analysis Plan for Coal-Fired Steam Electric Power Plants [3], is
intended to serve as a guide to the ERG field sampling crew, a review
mechanism for EPA personnel, and a source of procedural information for
plant personnel. 

Background

	Section 304(m) of the Clean Water Act (CWA) requires EPA to develop and
publish a biennial plan that establishes a schedule for the annual
review and revision of national effluent limitations guidelines and
standards (ELGs) required by CWA section 304(b). During EPA’s
2005/2006 review of ELGs, EPA determined that the steam electric power
generating point source category (40 CFR Part 423) is the second-largest
discharger of toxic-weighted pollutants. EPA’s analyses indicated that
the toxic-weighted loadings are predominantly driven by metals present
in wastewater discharges, and that the waste streams contributing the
majority of the metals are associated with air pollution controls
(APCs). Other potential sources of metals include coal pile runoff,
metal/chemical cleaning wastes, coal washing, and certain low volume
wastes.

	In presenting the findings of the 2005/2006 study, EPA noted certain
data limitations affect the Agency’s estimate of the potential hazard
posed by discharges from this category and, therefore, EPA continued the
review of these discharges during the 2007/2008 ELG planning cycle. Due
to the limited resources and time available for conducting the study,
EPA concentrated its efforts for the 2007/2008 study on better
characterizing the sources generating the pollutants responsible for the
majority of the toxic-weighted pollutant loadings from steam electric
plants and available pollution control technologies/practices. Based on
the information collected during the 2007/2008 study, EPA is continuing
the study of the steam electric discharges during the 2009/2010 ELG
planning cycle to further evaluate the pollutant loadings and available
pollution control technologies/practices. 

	This sampling plan will focus on characterizing wastewaters and
treatment system discharges at Belews Creek. For a general description
of the steam electric process and the wastewaters generated during the
operation of a coal-fired steam electric power plant, see Section 3.2 of
the Interim Detailed Study Report for the Steam Electric Power
Generating Point Source Category [1].

  SEQ CHAPTER \h \r 1 Objectives and Scope

	EPA is preparing to collect and analyze samples to characterize
wastewater streams generated at coal-fired steam electric power plants.
In particular, EPA is interested in characterizing waste streams
associated with air pollution control devices, evaluating the
cross-media air-to-water transfers occurring in these air pollution
control devices, identifying sources of metals, and evaluating the
capability of various types of treatment systems to remove metals prior
to discharge. 	

	Data from the sampling program will be used to support the following
objectives:

Determine pollutants present in waste streams generated by or associated
with air pollution controls (e.g., wet scrubber flue gas desulfurization
(FGD) units, wet ash handling systems) and how those waste streams are
handled;

Characterize the treatment performance of steam electric wastewater
treatment systems;

Determine which treatment systems are effective in reducing pollutant
loadings;

Characterize the pollutants ultimately discharged to surface water from
steam electric plants; and

Determine the contribution of the pollutants from air pollution control
wastewaters to the overall pollutant load discharged from steam electric
plants.

	The steam electric sampling and analysis program will consist of one-
or two-day sampling at selected plants. The sampling will characterize
the wastewaters generated by air pollution control devices and the
treatment performance of the systems used to treat the APC wastewaters.
EPA will also collect field quality control (QC) samples consisting of
bottle blanks, field blanks, equipment blanks, duplicate samples, and
laboratory QC samples used for matrix spike/matrix spike duplicate
analyses and serial dilutions.

	EPA’s sampling program will provide data to perform an engineering
assessment of the design, operation, and performance of treatment
systems at steam electric plants. Specifically, EPA will collect
information regarding system design and day-to-day operation. The
sampling will focus on in-process streams from steam electric
operations, influent to and effluent from wastewater treatment, and may
include collection of final effluent discharges and recycle streams.

  SEQ CHAPTER \h \r 1 Plant Selection

	EPA expects to select up to six coal-fired steam electric plants for
wastewater sampling. EPA is basing the plant selection on the process
configurations and characteristics of the plants, as well as the site
visits conducted for the study. The following characteristics are being
used to select plants for sampling (not listed in any priority order):

Coal-fired boilers;

Wet FGD scrubber system, including:

Type of scrubber,

Sorbent used,

Year operation began,

Chemical additives used,

Forced oxidation process,

Water cycling, and

Solids removal process;

FGD wastewater treatment system;

Type of coal;

NOx controls;

Ash handling systems;

Ash treatment system; and

Mercury air controls.

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

The plant is a coal-fired power plant that burns Eastern Bituminous coal
in each of its two generating units;

The plant operates limestone forced oxidation wet FGD systems on both
units;

The plant operates a segregated FGD wastewater treatment system, which
includes the following steps:

Equalization,

pH adjustment (lime addition),

Organosulfide addition,

Ferric chloride addition,

Polymer addition,

Clarification,

Filtration,

Biological treatment (nitrogen and metals), and

Constructed wetlands treatment;

The plant operates a SCR on both units; and

The plant produces a commercial-grade gypsum byproduct.

  SEQ CHAPTER \h \r 1 Facility Overview

	Belews Creek operates two steam electric units and each has a
coal-fired boiler. Belews Creek burns approximately 19,000 tons of
Eastern Bituminous coal per day. Units 1 and 2, which came on line in
1974 and 1975, respectively, each have a capacity of 1,200 megawatts
(MW). The Belews Creek plant and supporting facilities are located on
approximately 700 acres   is located on approximately XXX acres in
Belews Creek, NC, adjacent to Belews Lake. The plant owns an additional
approximate 7,000 XXX acres adjacent to Belews Lake. for a total of
7,000 acres. 

	Belews Creek recently retrofitted both units with a wet FGD scrubber
system to control the sulfur dioxide (SO2) releases from the plant. The
Unit 1 FGD system was installed in February 2008, and the Unit 2 FGD
system was installed in May 2008. [QUESTION FOR BELEWS CREEK: Please
confirm that the Unit 2 FGD system began operation in May.  Confirmed] 
The wet FGD scrubbers are designed to achieve a XX percent removal of
SO2. [QUESTION FOR BELEWS CREEK: What is the design removal efficiency
for SO2 in the scrubber? >95%]  With the recent addition of the FGD
scrubber systems, Belews Creek also installed an FGD wastewater
treatment system to control the discharges of the wastewater generated
during the operation of the FGD scrubbers. The FGD scrubber systems are
discussed further in Section 2.1 and the FGD wastewater treatment system
is discussed further in Section 2.2.

	In 2003 and 2004, Belews Creek retrofitted Units 1 and 2 with selective
catalytic reduction (SCR) systems in August 2003 and February 2004,
respectively, to control nitrogen oxide (NOx) releases from the plant.
Initially, Belews Creek was only operating the SCRs during ozone season,
May through September; however, in January 2007, Belews Creek began
operating the SCR systems year-round. Belews Creek personnel stated that
the plant plans to continue operating the SCRs year-round into the
foreseeable future.

[QUESTION FOR BELEWS CREEK:  Does the plant operate any type of sulfur
trioxide mitigation system (i.e., trona or ammonia injection)? No  If
so, what type of system is used, what are the associated chemical
reactions, and where are the chemicals added to the flue gas?]

	The ESPs at Belews Creek are particulate control devices that remove
the fly ash and other particulates from the flue gas. Belews Creek
utilizes ESPs to remove the fly ash from both units. The ESPs are
designed to remove > 99.8 percent of the fly ash from the flue gas.
[QUESTION FOR BELEWS CREEK:  What percentage of the fly ash is removed
from the flue gas in the ESPs?]  The fly ash and other particulates are
collected in hoppers and typically are pneumatically transferred to fly
ash silos. However, Belews Creek also has the capability to handle the
fly ash wet, by sluicing the fly ash in the hoppers and transferring the
fly ash sluice water to the ash basin. 

	Units 1 and 2 have the following configuration:

Boiler;

Air preheater;

SCR system;

Electrostatic precipitator (ESP); and

FGD scrubber system.

FGD Scrubber Systems

	Belews Creek operates a wet FGD scrubber system on both Units 1 and 2,
downstream of the ESP, to control the emission of sulfur dioxide from
the unit. The plant uses limestone slurry as the sorbent for sulfur
dioxide absorption. Belews Creek has ball mills onsite to pulverize the
limestone. After the limestone is pulverized, Belews Creek dilutes it
with water to approximately  a target concentration of 27 to 30 per cent
XX percent solids (by weight). [QUESTION FOR BELEWS CREEK: What is the
percent solids (by weight) of the limestone slurry sent to the FGD
system?] 

	The fresh limestone slurry is pumped to the various levels of the FGD
scrubber (typically three of four spray levels are operating at one
time). The slurry is pressurized and sprayed downward into the scrubber
vessel through spray nozzles. As the slurry falls downward and the flue
gas flows counter-current to the slurry, the spray droplets of the
limestone slurry contact the flue gas and absorb the sulfur dioxide,
which reacts with the limestone particles and produces calcium sulfite.
The spray droplets continue to flow downward in the scrubber until it
reaches the reaction tank. Belews Creek bubbles air through the reaction
tank to oxidize the calcium sulfite to calcium sulfate (i.e., gypsum).

	Belews Creek intermittently blows down the gypsum slurry from the
reaction tank to control the solids concentration in the scrubbers
around 15 percent solids. The chlorides concentration in the scrubbers
is maintained between 8,000 and 10,000 ppm, with a design maximum
chlorides concentration of 12,000 ppm. Belews Creek transfers the blow
down from the scrubber to the gypsum dewatering operations. 

	The gypsum slurry is pumped to the primary hydrocyclones where the
solid gypsum is separated from the water by centrifugal force. The solid
gypsum is forced outward to the walls of the hydrocyclones and falls
downward, while the water exits the top of the hydrocyclones. The gypsum
from the primary hydrocyclones is transferred to the filter feed tank,
which is then transferred to the vacuum filter belts. The overflow from
the primary hydrocyclones is transferred to a holding tank, and then
pumped to the secondary hydrocyclones. The underflow from the secondary
hydrocyclones is returned to the scrubber or sent to the filter feed
tank. The overflow from the secondary hydrocyclones is sent to the purge
tank and then pumped to the FGD wastewater treatment system.

	Belews Creek washes the gypsum sent to the vacuum filter belts with
service water, as it is poured onto the belts. The vacuum filter belts
dry the gypsum to a moisture content of approximately 10 percent. Belews
Creek transfers the dry gypsum to an uncovered gypsum storage area and
then trucks the gypsum to a wallboard manufacturer in Mount Holly, NC.
[QUESTION FOR BELEWS CREEK:  How far (miles) is the wallboard plant? –
 approximately 105 miles] Taking into account the reduced schedule of
operation for the two scrubber systems, Belews Creek personnel expect to
produce approximately 250,000 tons of gypsum during 2008. [QUESTION FOR
BELEWS CREEK:  What is the projected gypsum production for “normal
full operation”?]  Approximately 500,000 tons per year.  The amount of
gypsum is influenced by the coal that is being used and the amount of
sulfur in the coal.

FGD Wastewater Treatment System

	The FGD wastewater treatment system is designed to receive intermittent
transfers of FGD wastewater from the purge tank, which contains
secondary hydrocyclones overflow, at a flow rate of approximately see
below in red XXX gpm for X hours per day. [QUESTION FOR BELEWS CREEK: 
How often, and for what duration, is the scrubber purge transferred to
the FGD wastewater treatment system equalization tank?  What is the
typical flow rate (instantaneous and daily total) for these transfers? 
What is the maximum purge flow rate (instantaneous and daily total)?] 
The plant operates the FGD wastewater treatment system 24 hours per day.
The wastewater treatment system was installed to treat the wastewater
discharge that is necessary to control the concentration of chlorides in
the scrubber system. The Belews Creek FGD wastewater treatment system
contains the following treatment operations:

Purge is transferred, on average about 18 hours per day.  Flow varies
from 350 to 600 gpm depending on whether one or two of the scrubber are
purging and the level in the tanks.  An average daily flow is about 340
gpm +/- 20 gpm or 489,000 gpd.  

Physical/Chemical Separation;

Equalization,

pH adjustment (lime addition),

Sulfide addition,

Ferric chloride addition,

Polymer addition,

Clarification, and

Filtration;

Biological Reactors;

Cooling (heat extraction),

Nutrient addition,

First-stage biological reaction,

Nutrient addition, and

Second-stage biological reaction; and

Constructed wetlands;

Dilution,

Equalization,

First-stage bulrush cells,

Second-stage bulrush cells,

Cascading rocks,

Cattail cells, and

Cascading rocks.

	Figures 2-1, 2-2, and 2-3, located at the end of this section, present
process flow diagrams of the FGD wastewater treatment system, as well as
the sampling locations for EPA’s sampling episode. Figure 2-1 presents
a simplified diagram of the FGD wastewater treatment system, showing
different portions of the system. Figure 2-2 presents a diagram of the
chemical precipitation and biological reactor portions of the treatment
system and Figure 2-3 presents a diagram of the constructed wetland
portion of the treatment system.

	The secondary hydrocyclone overflow from the scrubbers is transferred
to the purge tank and then sent to the equalization tank at the start of
the wastewater treatment system. The equalization tank also receives
water from the filtrate sump (which includes filter press filtrate),
gravity filter backwash reject, backflush waste from the biological
treatment system, and off-specification biological treatment effluent.

	From the equalization tank, the wastewater enters three reaction tanks
in series: reaction tank 1 in which lime is added to increase the pH to
between 8.5 and 9.2 (target 8.8); reaction tank 2 in which organosulfide
is added; and reaction tank 3 in which ferric chloride is added. The
wastewater flows from reaction tank 3 to a mix chamber where polymer is
added.

	From the mix chamber, the wastewater is split and enters two clarifiers
in parallel. The clarifiers are solids contact clarifiers that contain a
sludge bed which attracts the solids in the wastewater. Each of the
clarifiers is capable of handling 100 percent of the waste stream
capacity.   Hydrochloric acid is added at a point between the clarifiers
and the sand filters to ensure that the pH is adjusted closer to neutral
prior to the biological treatment system.  The overflow from the two
clarifiers is split and sent through three sand filters in parallel.
Each of the sand filters can handle 75 percent of the waste stream
capacity. From the sand filters the wastewater enters a feed tank where
hydrochloric acid is added to reduce the pH prior to the biological
treatment system. The target maximum TSS level for the sand filter
effluent is 50 ppm; however, the plant tries to keep TSS below 20 ppm.
The sand filters are continuous backwash gravity filters. The filter
backwash is sent to a sump, then transferred to the equalization tank.

	The sludge from the clarifiers is transferred to a sludge tank and then
to a filter press for dewatering. Belews Creek achieves a solids
concentration of 15 percent in the sludge tank, which is higher than the
designed percentage. The filter press cake is transferred to the fly ash
landfill and the filtrate is sent to the filtrate sump. Each filter
press operation produces an average weight of 28,000-30,000 lbs of
filter cake. Belews Creek performs approximately 10 filter press
operations per week. A portion of the clarifier sludge is also recycled
to reaction tank 1. 

	The bioreactor portion of the treatment system consists of 16
bioreactor cells. Belews Creek treats the wastewater in two stages. Each
stage contains eight bioreactor cells, which are operated in parallel.
Each cell contains an activated carbon bed. Within the activated carbon
bed, specialized microbes fill the voided areas and reduce the nitrogen
and metals, specifically selenium, in the wastewater. The wastewater
from the sand filters is transferred to a holding tank prior to entering
a heat exchanger to reduce the temperature from  XXX oF to 95oF.
[QUESTON FOR BELEWS CREEK: What is the temperature of the FGD wastewater
entering the heat exchanger?]  The temperature varies seasonally and
with flow.  The temperature range thus far has been between 105 F and
115 F prior to the heat exchanger.  Belews Creek adds nutrients
(molasses-based) to the wastewater as it flows from the heat exchanger
to the first-stage of bioreactor cells. The nutrients provide a source
of carbon to feed the bacteria. The wastewater is divided evenly among
the eight first-stage cells. The flow to each cell is sent to 16
distribution pipes to create an even distribution of flow into the top
of the cell. The water level in the cells is approximately three feet
above the activated carbon bed.

	The effluent from the first-stage bioreactor cells is transferred to
the first-stage effluent storage area. The effluent from all eight
first-stage bioreactor cells is commingled in the storage area. The
wastewater is then transferred to the second-stage bioreactor cells,
which consist of eight parallel biological cells. Nutrients are added to
the wastewater as feed for the microbes as the wastewater is
transferred. As in the first stage, the wastewater is divided evenly
among the eight second stage cells and each cell has 16 distributor
pipes to evenly distribute the flow into the cell. 

	Occasionally the bioreactor cells will need to be backflushed to remove
the solids that have built up in the system. Belews Creek will send
service water backwards through each cell, starting at the bottom and
pushing the solids upward. The cells have a spill over area to collect
the backflush water which is then sent to the equalization tank at the
start of the FGD wastewater treatment system

	Because the first-stage bioreactor cells denitrify the waste stream,
they produce nitrogen and carbon dioxide gas. To remove the gas from the
cells, the plant occasionally performs a degassing operation where water
is sent backwards through the cells, like a backflush, but the flush is
only long enough for the gas to “burp” out of the system. The
second-stage bioreactor cells are primarily anoxic and do not produce as
much gas as the first-stage cells; therefore, Belews Creek does not
perform the degassing operation on the second-stage cells. [QUESTON FOR
BELEWS CREEK: Is it correct that the second-stage cells are not
degassed, or just that they are degassed less frequently?]  The
degassing for the second-stage is less frequent.

	From the second stage of the biological treatment system, the
wastewater enters the wetland supply tank, where cooling water is added
to the wastewater to reduce the temperature and chlorides level. The
plant dilutes the wastewater with the cooling water from the heat
exchanger at a ratio of 1:1 prior to its entering the biological system.
The plant can increase this dilution to a 2:1 ratio (cooling water: FGD
wastewater) to keep the chlorides level around 4,000 ppm. From the
wetlands supply tank, the wastewater enters the constructed wetland
system. Figure 2-3 presents a simplified process flow diagram of the
constructed wetlands treatment system.

	The first stage of the constructed wetlands system consists of two
equalization basins tanks which allow further cooling of the wastewater.
The wastewater is then split to enter two identical constructed wetland
treatment trains operated in parallel. The first and second cells of
each train contain primarily cattails bulrush.  These cells are operated
in a more reduced environment to aid in the removal of selenium and
mercury  These two cells provide a reduced environment with anoxic
conditions which allow for removal of selenium and mercury. The
wastewater then flows over cascading rocks and enters the third fourth
cells containing bulrush cattails.  After the bulrush cattail cell, the
wastewater flows over another cascade of rocks and then the wastewater
from the two trains are commingled and discharged to the ash basin.

	The redox potential in each of the constructed wetlands cells is
controlled by the water level. The higher the water level in the cells,
the more anoxic the conditions. Belews Creek controls the water level by
adding or removing wooden planks to the overflow weir. The water level
in the cells is typically 12 to 15 inches deep. 

	Each of the constructed wetlands cells is approximately 2.5 acres and
has a geosynthetic clay liner. Belews Creek planted 13,000 plants in
each of the cells. The plants prevent the wastewater from channeling
through the cells, provide organic material, and also provide oxygen to
the wastewater. [QUESTION FOR BELEWS CREEK: Does the plant have a target
dissolved oxygen level in the wetland cells?  If so, what level?]  The
target for DO leaving the wetland treatment system is for the DO to be
greater than 5 mg/l.    Belews Creek has experienced some issues in the
bulrush cells because the plants have not spread throughout the cell as
expected, leaving open spaces within the cell. 

	The effluent from the constructed wetlands is sent to the ash pond
where it is commingled with other waste streams. Belews Creek dilutes
the FGD wastewater treatment effluent at a ratio of 5:1 (ash pond: FGD
wastewater) by sending it to the ash pond. The effluent from the ash
pond is discharged to the Dan River, via NPDES Outfall 003. 

	Figure 2-2 shows the planned sampling points for the sampling episode
at Belews Creek. The influent sampling point at Belews Creek’s FGD
wastewater treatment system is located downstream of the purge tank and
upstream of the equalization tank. Thus, the influent sampling point is
upstream of any chemical addition. The in-process sampling point within
Belews Creek’s FGD wastewater treatment system is located downstream
of the sand filters and upstream of the holding tank. The biological
reactor effluent sampling point at Belews Creek’s FGD wastewater
treatment system is located downstream of the second-stage effluent
storage area and upstream of the wetland supply tank. EPA does not
intend to collect samples of the constructed wetlands portion of the FGD
wastewater treatment system.

 

Figure  SEQ CHAPTER \h \r 1    SEQ CHAPTER \h \r 1 2-1. Simplified
Diagram of the FGD Wastewater Treatment System, Belews Creek Steam
Station 

 

Note:  The hydrochloric acid addition is located after the clarifiers
and prior to the sand filters.

Figure  SEQ CHAPTER \h \r 1    SEQ CHAPTER \h \r 1 2-2.
Physical/Chemical Separation and Biological Reactor Portion of FGD
Wastewater Treatment System, Belews Creek Steam Station

 

1 – Bulrush  Cattails

2 – Bulrush  Cattails and Bulrush

3 – Cascading Rocks

4 – Cattails  Bulrush

5 – Cascading Rocks

Note this system is being planned to be removed from the FGD wastewater
treatment system.  It will still be utilized for rainfall run-off.  The
NPDES outfall 002 will move further upstream to a location after
discharge from the wetland supply tank.

 

Figure  SEQ CHAPTER \h \r 1    SEQ CHAPTER \h \r 1 2-3. Contructed
Wetland Treatment System Portion of FGD Wastewater Treatment System,
Belews Creek Steam Station

Sampling Procedures

	This section discusses the planned sampling procedures to be followed
during the sampling episode at Belews Creek. This section also provides
the necessary information to plan for the logistics of this sampling
episode. All tables and figures in this section are presented at the end
of the section.

Sampling Point Selection

	Figure 2-2 shows the three sampling point locations for Belews
Creek’s FGD wastewater treatment system. The three proposed sampling
points and the related Quality Assurance/Quality Control (QA/QC) samples
result in a total of seven sampling points, defined as follows:

SP-1	Influent to FGD Wastewater Treatment System;

SP-2	Influent to Bioreactor System;

SP-3	Effluent from Bioreactor System;

SP-4	Duplicate of Effluent from Bioreactor System (SP-3);

SP-5	Influent to FGD Wastewater Treatment System (SP-1) Field Blank;

SP-6	Influent to Bioreactor System (SP-2) Field Blank; and

SP-7	Effluent from Bioreactor System (SP-3) Field Blank.

Analyte Selection

	Analytes in EPA’s Belews Creek sampling episode 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,

Hexane extractable material (HEM), and

Silica-gel treated hexane extractable material (SGT-HEM);

Metals:

Routine total metals by EPA Methods 200.7, 245.1 and 245.5 (27 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, yttrium, and zinc),

Routine dissolved metals by EPA Methods 200.7 and 245.1 (27 metals),

Routine total metals by EPA Method 200.8 (25 metals: 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),

Routine dissolved metals by EPA Method 200.8 (25 metals),

Routine hexavalent chromium,

Low-level total mercury,

Low-level dissolved mercury,

Low-level hexavalent chromium,

Low-level total metals (11 metals: antimony, arsenic, cadmium, chromium,
copper, lead, nickel, selenium, silver, thallium, zinc), and

Low-level dissolved metals (11 metals).

	The analytes selected reflect the current understanding of coal-fired
power plant air pollution control wastewaters, including contributions
from coal, scrubber sorbents, treatment chemicals, and other sources.
Table 3-1 lists the potential analytes for each sampling point, Table
3-2 lists the analytical methods that will be used, and Table 3-3 lists
the sample container and volume and planned on-site preservation for
each parameter or parameter group. Appendix A lists the individual
parameters for each group of analytes. 

Sample Collection Procedures

	To characterize the influent to FGD wastewater treatment system (SP-1),
the influent to bioreactor system (SP-2), and the effluent from
bioreactor system (SP-3) at Belews Creek, the sampling team will employ
varying methods of sample collection depending on the sampling point and
pollutant parameters. This section describes in detail the sample
collection techniques. 

	Samples are collected as a series of “fractions,” or bottles
designated for particular analyses requiring the same preservation. The
comprehensive sample set consists of sample fractions for all pollutant
classes listed in Section 3.2. Note that some sample fractions will be
collected in the same sample bottle. These include Group I analytes
(TSS, TDS, COD, sulfate, and chloride); and Group II analytes (ammonia
as nitrogen, nitrate/nitrite as nitrogen, TKN, and total phosphorus,
COD). All other parameters will be collected in individual bottles. 

	In general, samplers will work in teams of two to ensure that proper
sampling techniques are followed and adequate notes are taken at each
sampling location. Samplers will wear disposable gloves, Tyvek® suits,
masks (when sampling for low-level mercury), steel-toed boots, hard
hats, and safety eyewear, and will observe precautions while collecting
samples, remaining aware of his/her surroundings.

	Sample containers and bottles will be purchased pre-cleaned and
certified and will not require rinsing with sample. The sample bottles
for the low-level metals analyses will be pre-cleaned according to EPA
Method 1669. For this sampling episode, all samples will be collected
directly from the waste stream of interest into specification-cleaned
sample containers. Thus, all samples will be “grab samples.”  No
composite samples will be collected.

	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.

Influent to FGD Wastewater Treatment System (SP-1)

	The influent to FGD wastewater treatment system (SP-1) has a sample tap
located on the wastewater piping downstream of the purge tank and
upstream of the equalization tank. ERG will collect the sample prior to
the equalization tank because the FGD scrubber purge is commingled with
other waste streams in the equalization tank and, therefore, the
sampling point upstream of the tank provides the best representation of
the FGD scrubber purge from the Belews Creek FGD system. Because the
flow from the purge tank to the equalization tank is not continuous, ERG
will need to coordinate closely with Belews Creek personnel during the
sampling episode to determine when wastewater is being transferred to
the FGD wastewater treatment system. ERG will follow protocols described
in EPA Method 1669 to collect low-level metal sample fractions from
SP-1.

	ERG plans to collect split samples with Belews Creek (or its
representative), where possible; therefore, ERG plans to attach a piece
of silicone tubing to the end of the sample tap with a “Y” splitter
at the other end of the tubing to allow ERG and Belews Creek (or its
representative) to collect samples simultaneously. If problems occur
during the collection of split samples (e.g., the splitters become
clogged and the flow is split unevenly between the sampling crews), then
EPA may stop the split sample collection and offer instead to collect
duplicate samples with Belews Creek or its representative. For all
analyses (except routine dissolved metals, routine hexavalent chromium,
low-level dissolved metals, and HEM/SGT-HEM), the samplers will collect
samples through the tubing directly into the specified containers. For
the HEM/SGT-HEM samples, the bottles will be filled directly from the
sample tap to avoid the oil and grease adhering to the sides of the
tubing. For the dissolved metals and routine hexavalent chromium
samples, the samplers will fill one 10-L container, allow the solids to
settle for one hour, and then pump the aqueous portion of the sample
through a 0.45 μm filter and then through a “Y” splitter into the
specified containers; therefore, the dissolved metals and routine
hexavalent chromium samples will be collected as split samples. 

	Due to the high solids content of the samples collected at the influent
to the FGD wastewater treatment system, EPA anticipates that the samples
may need to be analyzed as bi-phasic samples. If necessary to analyze as
biphasic samples (e.g., the solids content is greater than one percent
solids for Method 200.7 analysis), 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. Group I (chloride and sulfate
only), Group II (ammonia as nitrogen, nitrate/nitrite as nitrogen, TKN,
and total phosphorus only), routine total metals, low-level total
metals, and low-level total mercury samples are potential candidates for
analysis as bi-phasic samples. Group I (TSS, and TDS only), Group II
(COD only), BOD5, HEM/SGT-HEM, routine hexavalent chromium, routine
dissolved metals, low-level dissolved metals, and low-level dissolved
mercury samples will not be analyzed as bi-phasic samples.

	The samples for the influent to the FGD wastewater treatment system
(SP-1) will be collected from a sample tap. 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 mercury samples); 

Masks (for mercury samples); and

Sample containers.

	All low-level 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 low-level metal
sample fractions. Two 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 only describes the set up of the sample
point and collection of the EPA samples, and does not describe the
collection of the split samples.

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.

Both samplers put on Tyvek® suits, masks, and gloves. “Dirty hands”
covers work surfaces (ground or table) with HDPE plastic wrap and places
the double-bagged sample bottles within easy access on the covered
surface.

“Dirty hands” opens the outer bag of the cleanbox and “clean
hands” opens the inner bag and the translucent 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.

“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, holding the two ends pointing downward
to reduce atmospheric contamination. “Clean hands” places clean
plastic bags over the ends of the silicone tubing.

“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.

“Dirty hands” opens the outer bags of the low-level total mercury
field blank water and low-level 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 low-level
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 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
low-level total metals field blank.

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. 

“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.

“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 one 10-L
container for the collection of low-level dissolved metals, routine
dissolved metals, and routine 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 plastic bag over the end of the silicone tubing. Both
samplers change their gloves.

“Dirty hands” opens the outer bag for the low-level total metals
sample bottle. “Clean hands” removes the inner bag and bottle and
places it in the cleanbox. “Clean hands” opens the inner bag and
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 low-level total and dissolved
mercury and routine total metals by 200.7/245.1/245.5 samples, as well
as the QC sample volume for routine total metals by 200.7/245.1/245.5
(Note: the low-level total metals, low-level total mercury, and
low-level dissolved mercury sample bottles will contain sufficient
volume for both the sample analysis and QC sample analysis).

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

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. 

Both samplers collect the BOD5, Group I, and Group II samples from the
sample location.

Samplers remove the tubing from the sample tap and collect the
HEM/SGT-HEM samples.

Dissolved Metals Sample Collection

Samplers allow the 10-L sample container to continue to settle if one
hour has not elapsed since the collection of the sample.

 

“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.

“Dirty hands” opens the outer bag of the clean box and “Clean
hands” opens the inner bag and the translucent 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.

“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”
opens the inner bag and removes the tubing, holding the two ends
pointing downward to reduce atmospheric contamination. “Clean hands”
places a clean plastic bag over the end of the silicone tubing and
places the end of the tubing in the cleanbox.

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

Both samplers change gloves.

“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.

“Dirty hands” opens the outer bag of the low-level dissolved metals
field blank water and low-level dissolved metals field blank sample
bottle. “Clean hands” removes the low-level dissolved metals field
blank sample bottle and places it in the cleanbox. “Clean hands”
opens the inner bags of the field blank water and the waste bottle.
“Clean hands” removes the lid from the low-level 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 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 low-level dissolved metals field
blank sample bottle, and removes the lid. “Dirty hands” operates the
pump to collect the low-level dissolved metals field blank sample.
“Dirty hands” stops the pump. If a new filter is needed, “clean
hands” removes the used filter and samplers following step 21 to
replace the filter.

Both samplers change gloves.

“Dirty hands” opens the outer bag of one of the 10-L
specially-cleaned 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 500
mL through the tubing and filter. “Dirty hands” stops the pump.

“Dirty hands” opens the outer bag of the low-level 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
low-level dissolved metals sample. “Dirty hands” stops the pump.
“Clean hands” closes the lid on the sample bottle and closes the
inner bags. “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 routine dissolved metals by 200.7/245.1
and routine hexavalent chromium samples, as well as the routine
dissolved metals by 200.7/245.1 QC sample (Note: the low-level dissolved
metals sample bottle will contain sufficient volume for both the sample
analysis and QC sample analysis). 

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

	The influent to the FGD wastewater treatment system is expected to
contain a high percentage of solids, approximately 0.8  XX percent.
[QUESTION FOR BELEWS CREEK:  What is the typical percent solids in the
FGD scrubber purge?]  The pH of the wastewater is estimated to be
approximately 6.7 to 6.9  XX S.U. [QUESTION FOR BELEWS CREEK: What is
the pH of the FGD scrubber purge wastewater?]  [QUESTION FOR BELEWS
CREEK:  Does the plant have a flow meter that monitors the purge flow
rate to the equalization tank?  Yes  If not, how will the plant estimate
the influent flows during the sampling event?]

Influent to Bioreactor System (SP-2)

	The influent to the bioreactor system (SP-2) will be collected
downstream of the sand filters after the wastewater from the three
filters is commingled. Belews Creek has a sample tap located on the
wastewater piping after the three sand filter effluent streams are
commingled, and prior to the heat exchanger them entering the holding
tank. [QUESTION FOR BELEWS CREEK:  Please confirm the sample tap
location. Is the description correct, or is the sampling tap located
after the holding tank or is it even after the heat exchanger or
nutrient addition?]  ERG will follow protocols described in EPA Method
1669 to collect low-level metal sample fractions at SP-2. 

0.45 μm filter and then through a “Y” splitter into the specified
containers; therefore, the dissolved metals and hexavalent chromium
samples will be collected as split samples.	

	The samples for the influent to the bioreactor system (SP-2) will be
collected from a sample tap. The sampling equipment will consist of the
following:

Colorless, electronic-grade, non-nitrile gloves;

Silicone tubing with “Y” splitter;

10-L container;

Funnel;

Peristaltic pump;

Tyvek® suits (for mercury samples);

Masks (for mercury samples);

0.45 um filter;

Cleanbox; and

Sample containers.

	All low-level metals sampling equipment will be specially-cleaned
according to procedures described in EPA Method 1669. ERG will follow
protocols described in EPA Method 1669 to collect low-level metal sample
fractions. Two ERG samplers (“clean hands” and “dirty hands”)
will follow the protocol described in the steps below to set up the
sampling point, collect the equipment field blank samples, and collect
wastewater samples. This section only describes the set up of the sample
point and collection of the EPA samples, and does not describe the
collection of the split samples.

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.

Both samplers put on Tyvek® suits, masks, and gloves. “Dirty hands”
covers work surfaces (ground or table) with HDPE plastic wrap and places
the double-bagged sample bottles within easy access on the covered
surface.

“Dirty hands” opens the outer bag of the cleanbox and “clean
hands” opens the inner bag and the translucent 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.

“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, holding the two ends pointing downward
to reduce atmospheric contamination. “Clean hands” places clean
plastic bags over the ends of the silicone tubing.

“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.

“Dirty hands” opens the outer bags of the low-level total mercury
field blank water and low-level 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 low-level
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 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
low-level total metals field blank.

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. 

“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.

“Dirty hands” opens the outer bag for the low-level total metals
sample bottle. “Clean hands” removes the inner bag and bottle and
places it in the cleanbox. “Clean hands” opens the inner bag and
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 low-level total and dissolved
mercury, routine total metals by 200.7/245.1, and routine total metals
by 200.8 samples.

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

“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 one 10-L
container for the collection of low-level dissolved metals, routine
dissolved metals, and routine hexavalent chromium, which are all
required to be filtered. The samplers will allow the solids to settle
while collecting the remaining samples. “Clean hands” places the
plastic bag over the end of the silicone tubing. Both samplers change
their gloves.

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. 

Both samplers collect the BOD5, Group I, and Group II samples from the
sample location.

Samplers remove the tubing from the sample tap and collect the
HEM/SGT-HEM samples.

Dissolved Metals Sample Collection

“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.

“Dirty hands” opens the outer bag of the clean box and “Clean
hands” opens the inner bag and the translucent 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.

“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”
opens the inner bag and removes the tubing, holding the two ends
pointing downward to reduce atmospheric contamination. “Clean hands”
places a clean plastic bag over the end of the silicone tubing and
places the end of the tubing in the cleanbox.

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

Both samplers change gloves.

“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.

“Dirty hands” opens the outer bag of the low-level dissolved metals
field blank water and low-level dissolved metals field blank sample
bottle. “Clean hands” removes the low-level dissolved metals field
blank sample bottle and places it in the cleanbox. “Clean hands”
opens the inner bags of the field blank water and the waste bottle.
“Clean hands” removes the lid from the low-level 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 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 low-level dissolved metals field
blank sample bottle, and removes the lid. “Dirty hands” operates the
pump to collect the low-level dissolved metals field blank sample. The
samplers repeat this for the low-level hexavalent chromium field blank
sample. “Dirty hands” stops the pump. If a new filter is needed,
“clean hands” removes the used filter and samplers following step 21
to replace the filter.

Both samplers change gloves.

“Dirty hands” opens the outer bag of the 10-L specially-cleaned
container. “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 500 mL through the tubing and
filter. “Dirty hands” stops the pump.

“Dirty hands” opens the outer bag of the low-level 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
low-level dissolved metals sample. “Dirty hands” stops the pump.
“Clean hands” closes the lid on the sample bottle and closes the
inner bags. “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 low-level hexavalent chromium, routine
dissolved metals by 200.7/245.1, routine dissolved metals by 200.8, and
routine hexavalent chromium samples. 

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

	EPA plans to collect samples at the influent to the bioreactor system
on two separate days. The sample collection setup for both days of
sampling will be the same, but the samples collected will vary depending
on the day of sampling. On the first day of sampling at the influent to
the bioreactor system (SP-2), EPA will collect samples for all of the
analytes. On the second day of sampling at the influent to the
bioreactor system, EPA will collect samples for only the following
analytes:

Low-level total mercury (and field blank);

Low-level dissolved mercury;

Routine total metals by 200.8;

Routing dissolved metals by 200.8;

Routine hexavalent chromium;

BOD5;

Group I; and

Group II.

	The wastewater that is entering the bioreactor system has been treated
in a chemical precipitation process and therefore, has reduced levels of
solids and some metals compared to the FGD scrubber purge. The pH of the
wastewater is expected to be approximately 8 to 8.2  XX S.U. [QUESTION
FOR BELEWS CREEK:  What is the pH of the influent to the bioreactor
system?]  [QUESTION FOR BELEWS CREEK:  Does the plant have a flow meter
that monitors the influent flow rate to the first-stage bioreactors? 
Yes  If not, how will the plant estimate the flow at the bioreactor
influent during the sampling event?]

Effluent from Bioreactor System (SP-3)

	The effluent from bioreactor system (SP-3) will be collected downstream
of the second-stage effluent storage from the second-stage bioreactor
cells. Belews Creek has a sample tap located on the wastewater piping
downstream of the second-stage effluent storage tank. ERG will follow
protocols described in EPA Method 1669 to collect low-level metal sample
fractions from SP-3.

	ERG plans to collect split samples with Belews Creek (or its
representative), where possible; therefore, ERG plans to attach a piece
of silicone tubing to the end of the sample tap with a “Y” splitter
at the other end of the tubing to allow ERG and Belews Creek (or its
representative) collect samples simultaneously. If problems occur during
the collection of split samples (e.g., the splitters become clogged and
the flow is split unevenly between the sampling crews), then EPA may
stop the split sample collection and offer instead to collect duplicate
samples with Belews Creek or its representative. For all analyses
(except routine dissolved metals, routine hexavalent chromium, low-level
dissolved metals, and HEM/SGT-HEM), the samplers will collect samples
through the tubing directly into the specified containers. For the
HEM/SGT-HEM samples, the bottles will be filled directly from the sample
tap to avoid the oil and grease adhering to the sides of the tubing. For
the dissolved metals samples, the samplers will fill two 10-L containers
and then pump the aqueous portion of the sample through a 0.45 μm
filter and then through a “Y” splitter into the specified
containers; therefore, the dissolved metals samples will be collected as
split samples.

	For all analytes, ERG will collect QC samples at the effluent from the
bioreactor system (SP-3). In addition, for all analytes except
HEM/SGT-HEM, ERG will collect a duplicate sample of the effluent from
bioreactor system (SP-4).

	The sample of the effluent from the bioreactor system (SP-3) will be
collected from a sample tap. The sampling equipment will consist of the
following:

Colorless, electronic-grade, non-nitrile gloves;

Silicone tubing with “Y” splitter;

10-L containers;

0.45 um filter;

Funnel;

Peristaltic pump;

Small table;

Cleanbox;

Tyvek® suits (for mercury samples); 

Masks (for mercury samples); and

Sample containers.

	All low-level 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 low-level metal
sample fractions. Two 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 only describes the set up of the sample
point and collection of the EPA samples, and does not describe the
collection of the split samples.

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.

Both samplers put on Tyvek® suits, masks, and gloves. “Dirty hands”
covers work surfaces (ground or table) with HDPE plastic wrap and places
the double-bagged sample bottles within easy access on the covered
surface.

“Dirty hands” opens the outer bag of the cleanbox and “clean
hands” opens the inner bag and the translucent 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.

“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, holding the two ends pointing downward
to reduce atmospheric contamination. “Clean hands” places clean
plastic bags over the ends of the silicone tubing.

“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.

“Dirty hands” opens the outer bags of the low-level total mercury
field blank water and low-level total mercury field blank sample bottle.
“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 low-level 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 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 low-level total
metals, routine total metals by 200.7/245.1, and routine total metals by
200.8 field blanks.

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. 

“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.

“Dirty hands” opens the outer bag for the low-level total metals
sample bottle. “Clean hands” removes the inner bag and bottle and
places it in the cleanbox. “Clean hands” opens the inner bag and
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 low-level total and dissolved
mercury, routine total metals by 200.7/245.1, routine total metals by
200.8 samples, as well as the duplicate samples for each analyte. The
samplers also collect additional QC samples for the routine total metals
by 200.7/245.1 and routine total metals by 200.8 samples (Note: the
low-level total metals, low-level total mercury, and low-level dissolved
mercury sample bottles will contain sufficient volume for both the
sample analysis and QC sample analysis).

“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 two 10-L
containers for the collection of low-level dissolved metals, routine
dissolved metals, and routine hexavalent chromium, which are all
required to be filtered. The samplers will allow the solids to settle
while collecting the remaining samples. “Clean hands” places the
plastic bag over the end of the silicone tubing. Both samplers change
their gloves.

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

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. 

Both samplers collect the BOD5, Group I, and Group II samples, as well
as the QC and duplicates samples for each analyte, from the sample
location.

Samplers remove the tubing from the sample tap and collect the
HEM/SGT-HEM and the HEM/SGT-HEM QC samples.

	Dissolved Metals Sample Collection

Samplers move the two 10-L sample containers to the sample pump-off
location.

“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.

“Dirty hands” opens the outer bag of the clean box and “Clean
hands” opens the inner bag and the translucent 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.

“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”
opens the inner bag and removes the tubing, holding the two ends
pointing downward to reduce atmospheric contamination. “Clean hands”
places a clean plastic bag over the end of the silicone tubing and
places the end of the tubing in the cleanbox.

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

Both samplers change gloves.

“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.

“Dirty hands” opens the outer bag of the low-level dissolved metals
field blank water and low-level dissolved metals field blank sample
bottle. “Clean hands” removes the low-level dissolved metals field
blank sample bottle and places it in the cleanbox. “Clean hands”
opens the inner bag of the field blank water. “Clean hands” removes
the lid from the low-level 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 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 low-level dissolved metals field blank sample bottle, and
removes the lid. “Dirty hands” operates the pump to collect the
low-level 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 low-level hexavalent chromium,
routine dissolved metals by 200.7/245.1, routine dissolved metals by
200.8, and routine 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
following step 21 to replace the filter.

Both samplers change gloves.

“Dirty hands” opens the outer bag of one of the 10-L
specially-cleaned 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 500
mL through the tubing and filter. “Dirty hands” stops the pump.

“Dirty hands” opens the outer bag of the low-level 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
low-level dissolved metals sample. “Dirty hands” stops the pump.
“Clean hands” closes the lid on the sample bottle and closes the
inner bags. “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 low-level hexavalent chromium, routine
dissolved metals by 200.7/245.1, routine dissolved metals by 200.8, and
routine hexavalent chromium samples, as well as the duplicate samples
for each analyte. The samplers also collect additional QC samples for
the routine dissolved metals by 200.7/245.1, routine dissolved metals by
200.8, and routine hexavalent chromium samples (Note: the low-level
dissolved metals and low-level hexavalent chromium sample bottles will
contain sufficient volume for both the sample analysis and QC sample
analysis).

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

	EPA plans to collect samples at the effluent from the bioreactor system
on two separate days. The sample collection setup for both days of
sampling will be the same, but the samples collected will vary depending
on the day of sampling. On the first day of sampling at the effluent
from the bioreactor system (SP-2), EPA will collect samples for all of
the analytes, including QC samples for all analytes and duplicate
samples for all analytes except HEM/SGT-HEM. On the second day of
sampling at the effluent from the bioreactor system, EPA will collect
samples for only the following analytes:

Low-level total mercury (and field blank);

Low-level dissolved mercury;

Routine total metals by 200.8;

Routing dissolved metals by 200.8;

Routine hexavalent chromium;

BOD5;

Group I; and

Group II.

	The effluent from the bioreactor system is expected to contain very
little solids. The pH of the wastewater is expected to be 7.8 to 8.0 XX
S.U. [QUESTION FOR BELEWS CREEK:  What is the pH of the influent to the
bioreactor system?]  [QUESTION FOR BELEWS CREEK:  Does the plant have a
flow meter that monitors the effluent flow rate from the second-stage
bioreactors?  Yes If not, how will the plant estimate the flow for the
bioreactor effluent during the sampling event?]

  SEQ CHAPTER \h \r 1 Sample Preservation, Shipping, and Analysis 

	All samples will be maintained on ice immediately upon collection
(except routine metals and all low-level metals samples which do not
require cooling). Although the low-level hexavalent chromium samples are
required to be cooled by EPA Method 1636, EPA will not place the samples
on ice because of contamination concerns. In addition, all samples,
except metals, will be preserved on site according to method-specified
protocols. The dissolved routine metals, dissolved low-level metals
(except low-level mercury), and hexavalent chromium samples will be
filtered in the field. All metals samples, except hexavalent chromium,
will be acid preserved prior to extraction at the laboratory. Routine
and low-level hexavalent chromium samples will be preserved on site,
according to the method-specified protocols. Samplers will filter
samples within 15 minutes of grab collection or sample fraction
preparation (or as soon thereafter as possible). For the FGD influent,
filtration of dissolved samples will occur approximately one hour after
sample collection to allow for solids settling because it has a high
solids content that would clog the filter.

	Table 3-3 lists the parameters, bottle types, sample volume, and
on-site preservation requirements for each type of analysis. The type
and amount of preservation used will be recorded on sample preservation
log sheets (Figure 3-1). To avoid diluting the sample, 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 routine and low-level metals, will be packed
in ice chests with a sufficient quantity of ice to maintain a
temperature of ≤6(C. All samples can be prepared for overnight
shipment via Federal Express to laboratories specified by EPA’s Sample
Control Center (SCC).

  SEQ CHAPTER \h \r 1 Field Measurements and Engineering Data Collection

	Temperature and pH will be measured and recorded by the sampling crew
at each sampling point (SP-1, SP-2, and SP-3) when each grab sample is
collected. A 1-liter glass jar will be filled during collection of each
grab sample set for field measurements. Temperature and pH will be
measured immediately after the collection of the field measurement
aliquot. Samplers will follow applicable test kit calibration procedures
specified by the manufacturer. Table 3-4 summarizes the field
measurements, the method to be used for the measurement, and the
detection range of each field test instrument. In addition, EPA will
collect flow rate data for each sampled waste stream. 

	Field sampling log sheets (Figure 3-2) will be completed at each
sampling point. This sheet will record the sampling methodology, names
of the samplers, sample collection time, field measurements, and any
notes and observations.

	Engineering information will be collected with regard to design and
operation of the plant. 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
will be collected. Engineering data collection sheets (Figures 3-3, 3-4,
and 3-5) will be completed for the plant. This information will be used
to determine if the specific design or operational criteria of the steam
electric operations affect the wastewater characteristics.

  SEQ CHAPTER \h \r 1 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 (i.e., SCC 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. For low-level metal samples, the
samplers will not label the sample bottles, but will label the outer
plastic bag of the sample bottle.

  SEQ CHAPTER \h \r 1 Traffic Reports

	To maintain a record of sample collection, transfer between personnel,
shipment, and receipt by the laboratory, a SCC 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. SCC traffic report forms are completed for all samples sent
to all laboratories. Figure 3-6 includes an example of a SCC traffic
report. At the time of sample shipment, a copy of the traffic report is
sent to SCC, 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
whether samples have been filtered on site or how to composite separate
samples prior to analysis. The sampling team will also comment if sample
bottles are not completely filled (i.e., less than 75 percent full). In
addition, the comments section will be used to note deviations from
standard sampling protocols (for example, if a sample could not be
acid-preserved because of excessive buffering).

  SEQ CHAPTER \h \r 1 Quality Assurance/Quality Control

	QA/QC procedures applicable to this project are outlined in the Quality
Assurance Project Plan for the Steam Electric Detailed Study [2]. The
QA/QC program for sample collection at Belews Creek will include the
following:

Documentation for samples through laboratory traffic reports;

Collection of duplicate samples;

Collection of bottle blank(s) for low-level metals;

Collection of field blank(s) for routine total metals, routine dissolved
metals, low-level total metals, and low-level dissolved metals;

Collection of equipment blank(s) for low-level metals; and

Collection of laboratory QC samples for matrix spike/matrix spike
duplicate analyses and serial dilutions.  Why are serial dilutions
needed?

	Duplicate sample sets will be collected as part of the quality
assurance program for sampling. EPA will collect one duplicate sample
(SP-4) on the first day that the effluent from the bioreactor system
(SP-3) is sampled. The duplicate samples will be collected as separate
aliquots at the sampling point, filled immediately after the original
sample fraction. Results of the duplicate analyses will be used to
evaluate precision, including variability in sample collection,
handling, preparation, and analysis. 

	Bottle blanks will be used to evaluate possible contamination from the
sample bottles. Bottle blanks will be prepared and analyzed for
low-level metals. The supplier of the low-level metals bottles will
prepare and analyze the bottle blanks for low-level metals.

	Field blanks will be used to evaluate possible contamination caused by
sampling equipment or by sampling equipment decontamination procedures.
Field blanks will be prepared in the field prior to sample collection
and analyzed for all sampling equipment, other than sample bottles, that
come into direct contact with samples (e.g., tubing or filters). 

	EPA will prepare field blanks for each of the low-level total and
dissolved metals analyses at each of the three sampling points and
routine total and dissolved metals at the effluent from the bioreactor
system (SP-3). ERG samplers will use “clean hands / dirty hands”
sampling techniques to prepare the low-level metals field blanks.
Section 3.3 discusses the details of the field blank collection
techniques. The field blanks at each of the sampling points for the
low-level total metals and routine total metals will be prepared by
gravity feeding ASTM Type 1 water through Teflon® and/or silicone
tubing into the sample bottles. The field blanks at each of the sampling
points for routine dissolved metals, routine hexavalent chromium,
low-level hexavalent chromium, and low-level dissolved metals will be
prepared by pumping ASTM Type 1 water through the Teflon® and silicone
tubing, through a 0.45 um filter, and into the sample bottles before
filtering the samples. The field blanks will evaluate if there is any
contamination from the sampling equipment, atmospheric contamination or
other contamination from the surroundings.

	EPA Method 1669 requires that equipment blanks also be prepared and
analyzed for low-level metals. The supplier of the tubing and composite
containers will prepare and analyze these equipment blanks and provide a
report certifying the equipment as clean.   

	As part of standard laboratory QC, matrix effects on analytical
performance are assessed through the analysis of matrix spikes and
laboratory duplicates.   Are laboratory duplicates to be run at a set
frequency?  Consequently, additional sample volume must be collected for
these QC analyses. The ERG sampling team will collect, label, and ship
the laboratory QC volumes. Laboratory QC volumes will be collected as
duplicate samples collected immediately after the original sample
aliquot. For metals analyses, the sampling team will collect QC sample
volume from the influent to the FGD wastewater treatment system (SP-1),
and for the first day that the effluent from the bioreactor system
(SP-3) is sampled. For classicals analyses, the sampling team will
collect QC sample volume for the first day that the effluent from the
bioreactor system (SP-3) is sampled. 

  SEQ CHAPTER \h \r 1 Sample Splitting

	Belews Creek or its representative has elected to collect split samples
at each of the sampling points. Belews Creek or its representative will
supply all of the personnel, equipment, glassware, and reagents required
to collect the split samples and to coordinate the analysis of samples.
For each of the sampling points, the sampling crew will attempt to
collect split samples with Belews Creek or its representative as
described in this plan; however, if problems occur (e.g., the splitters
become clogged and the flow is split unevenly between the sampling
crews), then EPA may stop the split sample collection and offer instead
to collect duplicate samples with Belews Creek or its representative. 
Table   SEQ CHAPTER \h \r 1 3-1. Sample Collection at the Belews Creek
Steam Station



Sampling Point Number	Sampling Point Name	Low-Level Total Metals

(11 Analytes)	Low-Level Dissolved Metals (11 Analytes)	Low-Level Total
Mercury	Low-Level Dissolved Mercury	Low-Level Hexavalent Chromium
Routine Total Metals by 200.7/245.1/245.5  (27 Analytes)	Routine
Dissolved Metals  by 200.7/245.1 (27 Analytes)	Routine Total Metals by
200.8  (25 Analytes)  a	Routine Dissolved Metals  by 200.8 (25 Analytes)
a	BOD5	Group I b	Group II c	HEM / SGT-HEM	Routine Hexavalent Chromium

  SEQ CHAPTER \h \r 1 SP-1	Influent to FGD Wastewater Treatment System
1+1QC	1+1QC	1+1QC	1+1QC

1+1QC	1+1QC

	1	1	1	1	1

SP-2	Influent to Bioreactor System – Day 1 	1	1	1	1	1	1	1	1	1	1	1	1	1
1

	Influent to Bioreactor System – Day 2

	1	1



1	1	1	1	1

1

SP-3	Effluent from Bioreactor System – Day 1	1+1QC	1+1QC	1+1QC	1+1QC
1+1QC	1+1QC	1+1QC	1+1QC	1+1QC	1+1QC	1+1QC	1+1QC	1+1QC	1+1QC

	Effluent from Bioreactor System – Day 2

	1	1



1	1	1	1	1

1

SP-4	Duplicate of Effluent from Bioreactor System 	1	1	1	1	1	1	1	1	1	1	1
1

1

SP-5	Influent to FGD Wastewater Treatment System Field Blank	1	1	1











	SP-6	Influent to Bioreactor System Field Blank – Day 1	1	1	1

1











Influent to Bioreactor System Field Blank – Day 2

	1











	SP-7	Effluent from Bioreactor System Field Blank – Day 1	1	1	1

1	1	1	1	1



	1

	Effluent from Bioreactor System Field Blank – Day 2

	1











	Total Number of Samples	7+2QC	7+2QC	11+2QC	6+2QC	5+1QC	5+2QC	5+2QC
6+1QC	6+1QC	6+1QC	6+1QC	6+1QC	3+1QC	7+1QC

a – Analysis of the sample will be performed both with and without a
dynamic reaction cell or collision cell; however, both analyses will be
performed using sample collected in the same bottle.

b – Group I includes total suspended solids (TSS), total dissolved
solids (TDS), sulfate and chloride.

c – Group II includes ammonia as nitrogen, nitrate/nitrite as
nitrogen, total Kjeldahl nitrogen (TKN), chemical oxygen demand (COD),
and total phosphorus.

Table 3-2. Analytical Methods and Procedures for Samples Collected at
Belews Creek



Method Number	Parameter	Method Type

Classicals

SM 5210 B 	Biochemical Oxygen Demand (BOD5)	Probe

EPA 410.3	Chemical Oxygen Demand (COD)	Titrimetric

SM 2540 D 	Total Suspended Solids (TSS)	Gravimetric

SM 2540 C 	Total Dissolved Solids (TDS)	Gravimetric

ASTM D516-90	Sulfate	Turbidimetric

SM 4500–Cl–C 	Chloride	Titrimetric, mercuric nitrate

SM 4500—NH3 B, F (18th ed.)	Ammonia as Nitrogen 	Distillation,
potentiometric

SM 4500—NO3 -H 	Nitrate/Nitrate as Nitrogen	Autoanalyzer

SM 4500—NH3 B or C, F (18th ed.)	Total Kjeldahl Nitrogen (TKN)
Digestion, distillation, potentiometric

EPA 365.3 (Rev 1978)	Total phosphorus	Digestion, spectrophotometric

EPA 1664A 	Hexane Extractable Material (HEM)	Gravimetric

EPA 1664A	Silica Gel Treated Hexane Extractable Material (SGT-HEM)
Gravimetric

Metals

	EPA 1631	Mercury in Water by Oxidation, Purge and Trap, and Cold Vapor
Atomic Fluorescence Spectrometry	Oxidation, Purge and Trap, and CVAFS

EPA 1636	Determination of Hexavalent Chromium by Ion Chromatography	Ion
Chromatography

EPA 1638	Determination of Trace Elements in Ambient Waters by
Inductively Coupled Plasma – Mass Spectroscopy (includes antimony,
arsenic, cadmium, chromium, copper, lead, nickel, selenium, silver,
thallium, and zinc)	ICP/MS

EPA 200.7	Metals by Inductively Coupled Plasma Atomic Emission
Spectrometry	ICP

EPA 245.1, 245.5	Mercury by Atomic Absorption Spectroscopy	CVAA

EPA 200.8	Determination of Trace Elements in Waters and Wastes by
Inductively Coupled Plasma – Mass Spectrometry (with & without dynamic
reaction cell or collision cell)	ICP/MS

ASTM D1687-92	Hexavalent Chromium	Colorimetric

CVAFS – Cold vapor atomic fluorescence spectrometry.

AA – Atomic Adsorption.

ICP/MS – Inductively coupled plasma with mass spectrometry.

ICP – Inductively coupled plasma.

CVAA – Cold vapor atomic adsorption.

Table 3-3.   SEQ CHAPTER \h \r 1 Summary of Sample Container and
Planned Preservation

≤6oC

Group I a	Two 1-L plastic bottle	≤6oC

Group II b	Two 1-L plastic bottle	H2SO4 to pH <2, ≤6oC

HEM/SGT-HEM	Two 1-L wide mouth glass jar	H2SO4 to pH <2, ≤6oC

Metals

Routine total metals by 200.7/245.1, 27 element quantitation (Method
200.7, 245.1)	One 500-mL plastic bottle	None

(acid preserve at laboratory)

Routine dissolved metals by 200.7/245.1, 27 element quantitation (Method
200.7, 245.1)	One 500-mL plastic bottle	0.45 µm filter (performed in
field)

(acid preserve at laboratory)

Routine total metals by 200.8, 25 element quantitation (Method 200.8) c
One 500-mL plastic bottle	None

(acid preserve at laboratory)

Routine dissolved metals by 200.8, 25 element quantitation (Method
200.8) c	One 500-mL plastic bottle	0.45 µm filter (performed in field)

(acid preserve at laboratory)

Routine hexavalent chromium	One 250-mL plastic bottle	0.45 µm filter
(performed in field)

Ammonium sulfate buffer to 

pH 9.3 – 9.7, ≤6oC

Low-level total mercury (Method 1631)	One 250-mL glass (ultraclean),
fluoropolymer lined caps	None

(acid preserve at laboratory)

Low-level dissolved mercury (Method 1631)	Two 250-mL glass (ultraclean),
fluoropolymer lined caps	None

(acid preserve and filter at laboratory)

Low-level total elements by ICP/MS (11 elements, Method 1638) 	One
250-mL LDPE (ultraclean), fluoropolymer lined caps	None

(acid preserve at laboratory)

Low-level dissolved elements by ICP/MS (11 elements, Method 1638) 	Two
250-mL LDPE (ultraclean), fluoropolymer lined caps	0.45 µm filter
(performed in field)

 (acid preserve at laboratory)

Low-level hexavalent chromium (Method 1636)	One 250-mL LDPE
(ultraclean), fluoropolymer lined caps	0.45 µm filter (performed in
field)

2 mL 50% NaOH per 250 mL sample (performed in field) d

a – Group I includes TSS, TDS, sulfate, and chloride.

b – Group II includes ammonia as nitrogen, nitrate/nitrite as
nitrogen, TKN, COD and total phosphorus.

c – Analysis of the sample will be performed both with and without a
dynamic reaction cell or collision cell; however, both analyses will be
performed using sample collected in the same bottle.

d – Method 1636 has a preservation requirement that the low-level
hexavalent chromium sample be cooled to ≤6C; however, EPA will not
place the low-level hexavalent chromium samples on ice due to
contamination concerns.



Table 3-4. Sampling Point Field Measurements



Field Measurements	Method	Detection Range (or Gradation of Scale)

Temperature 	Thermometer	-20 to 150 ± 1oC

pH (Standard Units) 	Four color indicator strip

pH meter	0 to 12 ± 1 pH S.U.

-1.0 to 15.0 ± 0.1 pH S.U.





  SEQ CHAPTER \h \r 1 Sampling Episode  	

Preservation Chemicals – List Strength of Solution from Bottle and Lot
Number 



H2SO4  		NH4SO4  	

NaOH  		



Sample

Number	Analysis	Date	Time	Name	Chemical	Initial pH	Final pH	Number of
Drops

































































































































































































Figure 3-1. Sample Preservation Log Sheet

  SEQ CHAPTER \h \r 1 Sampling Episode:  	

Sampling Point:  	

Sample Numbers:  	

Date:  	

Manual Composite   	 G         Grab   G

Automatic Composite  	 G

Time of Grab Sample Collection:

		Start Time                	G AM   G PM

		End Time                  	G AM   G PM

Equipment Used: _________________________________________________ 

Samplers’ Names: ________________________________________________

Sample Point	Time	Temp

C	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 3-2. Field Sampling Log Sheet

  SEQ CHAPTER \h \r 1 Plant Name:  	

Plant Contact:  	

Date of Sample Collection: 	 

Time(s) of Sample Collection:  	

Data Collected by:  	

Instruction:  Provide actual data if possible. If not, provide estimated
data. 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.

Unit Operating Characteristics During Sample Collection

Unit ID	Boiler Type	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	Capacity (MW)	Electricity Production

(or Percent Capacity)	SCR

(No, On, Off)	Particulate Control System (HS/CS ESP, or BH)	Wet FGD
System (Yes/No)















	













	

Note changes in operation over the past month (e.g., turned off SCRs on
October 1 or burned 5% petroleum coke previous week):

	

	

	

	

	

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



  SEQ CHAPTER \h \r 1 Plant Name:  	

Plant Contact:  	

Date of Sample Collection:  	

Time(s) of Sample Collection:  	

Data Collected by:  	

Instruction:  Provide actual data if possible. If not, provide estimated
data. Some of the data requested may not be susceptible to estimation.
Enter “URE” for “unable to reasonably estimate.”  Otherwise,
specify whether data provided are actual or estimated by writing in
“ACT” or EST” wherever appropriate.

FGD Scrubber Information

Unit ID

Type of Scrubber

Sorbent

Additives (DBA, formic acid, etc.)

FGD Make-up Water Source

SO2 Removal Percentage

Forced Oxidation (Yes/No)

Percent Solids in Absorber Blowdown

Type of Solids Separation

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:

	

	

	

	

FGD Solids Dewatering (for last cycle prior to sampling or while
sampling):

Scrubber slurry blowdown flow rate   ________________

Scrubber slurry blowdown duration   ________________  

Scrubber slurry percent solids    ________________ 

Dewatering cycle frequency    ________________ 

Time since last dewatering cycle    ________________ 

Percent filtrate recycled back to scrubber   ________________ 

FGD Wastewater Treatment System Operation During Sample Collection:

Scrubber purge flow rate   ________________

Scrubber purge duration   ________________

Lime usage   ________________ 

Ferric chloride usage   ________________ 

Organosulfide usage   ________________ 

Polymer Type    ________________ 	Polymer Usage (amt)   
________________

Acid Type    ___________________	Acid usage (amt)    ________________ 

Amount of solids generated    ________________     

Effluent from bioreactor flow rate   ________________ 

Effluent duration   ________________   

Retention time of equalization tank   ________________

Retention time of reaction tanks   ________________     ________________
     ________________         

Retention time of clarifier   ________________   ________________   

Retention time of first-stage bioreactors  ________________  

Retention time of second-stage bioreactors   ________________  





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

Plant Name:  	

Plant Contact:  	

Date of Sample Collection: 	 

Time(s) of Sample Collection:  	

Data Collected by:  	

  SEQ CHAPTER \h \r 1   SEQ CHAPTER \h \r 1   SEQ CHAPTER \h \r 1 

Instruction:  Provide actual data if possible. If not, provide estimated
data. 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.

Ash System Information

Unit ID	Fly Ash System a	Bottom Ash System

	Fly Ash Generation (tph)	Fly Ash Sluice Water Flow Rate (gph)	Source of
Fly Ash Sluice Water	Sluice Cycle Duration and Frequency	Continuous
Sluicing (Yes/No)	Bottom Ash Generation (tph)	Bottom Ash Sluice Water
Flow Rate (gph)	Source of Bottom Ash Sluice Water	Sluice Cycle Duration
and Frequency	Continuous Sluicing (Yes/No)





























a – Information only needs to be provided in the event that the plant
is sluicing the fly ash during the during sampling episode.

Other information and observations (e.g., presence of emergent
vegetation or floating vegetation, other factors influencing ammonia).
Provide photos.

	

	

	

	

	

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



Figure 3-6. Example SCC Traffic Report

Sampling Activities

  SEQ CHAPTER \h \r 1 	This section discusses the sampling team
organization, sampling preparation, and sampling activities.

Sampling Team Organization

	The sampling crew will consist of a crew chief and two crew members
from ERG, and two EPA representatives. The crew chief will be
responsible for all health and safety, sample collection, preservation,
and shipping activities while at Belews Creek. 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 Belews Creek for
review.

Pre-Sampling Preparation

	On March 12, 2008, ERG and EPA conducted a site visit at Belews Creek.
The site visit and subsequent telephone calls provided ERG and EPA the
necessary information to prepare for the sampling episode. The
information collected during the site visit and telephone calls was used
to create this sampling plan. 

	As part of preparing the team for the sampling event at Belews Creek,
the ERG crew chief will distribute this sampling plan to each team
member and make sure they are completely familiar with the sampling plan
and the health and safety requirements specific to Belews Creek. The
crew chief will also give copies of this sampling plan to Belews Creek
personnel before sampling begins. 

	The ERG crew chief will also coordinate the procurement and shipment of
all necessary sampling and health and safety equipment. 

  SEQ CHAPTER \h \r 1 Field Sampling Activities

	Upon arrival at Belews Creek, the ERG crew chief, in conjunction with
the EPA representatives, will meet with Belews Creek personnel to
determine whether samples can be collected as planned at each of the
planned sampling points. Upon confirming the methods to collect samples,
the ERG crew chief will update the descriptions of the proposed sampling
points, if necessary, in consultation with EPA and Belews Creek
personnel. If necessary, the crew chief will obtain additional equipment
and glassware. The revised sampling description will include:

A sampling point description and collection procedure for each sampling
point;

A list of the sample fractions to be collected at each point:

A list of potential physical hazards (e.g., pH, temperature, and
potentially hazardous equipment);

A list of potential chemical hazards associated with each sampling
point; and

A list of proposed health and safety procedures. 

	Prior to sampling, the ERG crew chief will notify the ERG Health and
Safety Coordinator (HSC) of any revised sampling activity descriptions
along with recommended revisions to the proposed health and safety
procedures. Together, the crew chief and HSC will review the proposed
health and safety procedures. The crew chief will incorporate any
plant-specific changes indicated by the HSC and receive approval for
sampling from the HSC before proceeding with sampling activities.

	All sample bottles will be labeled, collected, and preserved, according
to method protocols. Sample fractions requiring ≤6oC preservation will
be placed on ice until desired temperature is reached. Sample fractions
will then be sealed, and placed in coolers for shipment to the
laboratory. The SCC 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 SCC laboratories.
At the conclusion of the sampling episode, the sampling equipment will
be prepared for return shipping.

	The ERG crew chief will contact SCC prior to sampling in order to
confirm the laboratories and to communicate the number of samples being
collected. The crew chief will also contact SCC after shipping samples
to communicate shipping information.

  SEQ CHAPTER \h \r 1 Logistics

	This subsection summarizes Belews Creek contacts, analytical laboratory
contacts and addresses, and sampling team personnel and support
functions.

Belews Creek Steam Station Contacts

Robert Wylie

Duke Energy Carolinas

526 S. Church Street

Charlotte, NC 28201

(704) 382-4669

	[QUESTION FOR BELEWS CREEK:  Please provide contact information for a
plant contact.]

		Melonie Martin

		Duke Energy Carolinas

		Belews Creek Steam Station

		3195 Pine Hall Road

		Belews Creek, NC 27009

		(336) 445-0610

EPA Contacts

Ron Jordan

Engineering and Analysis Division

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, NW (4303T)

Washington, D.C. 20460

(202) 566-1003

Josh Hall

Engineering and Analysis Division

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, NW (4303T)

Washington, D.C. 20460

(202) 566-1002

Analytical Laboratories 

	Sample Control Center

Barb Beard 

Computer Sciences Corporation

6101 Stevenson Avenue

Alexandria, VA 22304

Phone: (703) 461-2154

Fax: (703) 461-8056

Laboratory contact information to be added later

ERG Contacts

TJ Finseth (Crew Chief)

Eastern Research Group, Inc.

14555 Avion Parkway, Suite 200

Chantilly, VA  20151

(703) 994-7130

Deborah Bartram (Work Assignment Manager)

Eastern Research Group, Inc.

14555 Avion Parkway, Suite 200

Chantilly, VA  20151

(703) 633-1669

Freight Forwarders

	Federal Express (FedEx)

	General Information (800) 238-5355

FedEx World Service Center (14 miles from plant)

6313 A Bryan Blvd

Greensboro, NC 27409

Hours of Operation:  Tues. – Fri.: 5:00 p.m. to 9:30 p.m.

		Last Express Drop-off:  Tues. – Fri.: 9:30 p.m.

FedEx Express Ship Center (15 miles from plant)

100 Progress Court

Winston Salem, NC 27105

Hours of Operation:  Tues. – Fri.: 8:00 a.m. to 8:00 p.m.

		Last Express Drop-off:  Tues. – Fri.: 8:00 p.m.

Sample Shipment

	All sample containers will be labeled with ERG's standard address
labels. All samples will be tracked using SCC 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 at Belews Creek will not be
classified as IATA dangerous goods.

  SEQ CHAPTER \h \r 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 3.2, collected as one-time grab samples
directly into the individual sample containers.

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):

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. Low-level metal sample bottles will not be labeled;
instead, the outer plastic bag for each bottle will be labeled.

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 low-level sample bottles.

Place each sample bottle requiring ≤6C preservation into an ice
chest with wet ice prior to packaging to cool.

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. VOA vials may be
placed in VOA bricks and placed in a freezer bag.

Place two garbage bags inside each other in the cooler.

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.

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 one-gallon sealable freezer bags. Put at least
4 × ½ gallons of ice (4 × 2.5 lbs of ice) in each large cooler and 2
× ½ 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.

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. 

Seal the SCC Traffic Report form in a plastic zip-lock bag and tape
securely to the inside of the cooler lid.

Place a "Return to ..." label on the inside of the cooler lid.

Close cooler.

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.

Tape the cooler drain plug so it will not open.

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.

Site-Specific Health and Safety Procedures

	This section specifies the health and safety procedures and practices
to be used by the sampling team during sampling at Belews Creek. This
section provides general health and safety information for this sampling
episode. The sampling team is obligated to follow all safety procedures
specified in this section.

Emergency/Medical Procedures

	  SEQ CHAPTER \h \r 1 The following procedures will be followed in the
event of a medical or other emergency situation. 

First Aid

	Belews Creek has first aid kits available throughout the plant. In
addition, ERG will also bring a first aid kit. The ERG crew chief will
coordinate with the plant personnel to determine if ERG personnel will
have access to the plant’s first aid provisions.

[QUESTION FOR BELEWS CREEK:  Does the plant have an on-site first aid or
medical staff?  Belews Creek has a first responder team but no onsite
medical staff.  Will ERG and EPA staff be able to have access to the
plant’s first aid provisions? Yes]

Site Evacuation/Emergency Response Plan

	The sampling team will be informed of the Belews Creek evacuation
procedures and routes by plant personnel. 

Emergency Showers and Eye Washes

	Emergency showers and eye wash stations are located throughout the
plant. Before collecting samples at any point, sampling team members
will locate the nearest operating safety shower and eye wash station.

Local Hospital

	The nearest hospital is Stokes-Reynolds Memorial Hospital, located in
Danbury, NC. This hospital is approximately 13 miles from Belews Creek
Steam Station. The hospital address is:

Stokes-Reynolds Memorial Hospital

1570 NC 8 & 89 Hwy North

Danbury, NC 27106

	The local emergency phone number in Belews Creek, NC is 911.

[QUESTION FOR BELEWS CREEK:  Is this the nearest hospital to the plant? 
Yes  If there is another one closer, please provide the name and
address.]

ERG Health and Safety Responsibilities and Authority

	The ERG Work Assignment Manager (WAM), crew chief, and sampling team
members have different responsibilities to maintain a safe sampling
environment. These responsibilities are described below.

Work Assignment Manager

	The WAM, Deborah Bartram, has the overall responsibility to ensure that
this health and safety plan is developed and implemented in accordance
with regulations and corporate guidelines, that proper health and safety
procedures have been initiated, and that all ERG activities are
conducted in accordance with the health and safety plan. The WAM will
also ensure that proper resources are allocated so that the project is
conducted in a safe manner, and that the crew chief is competent in his
ability to oversee health and safety during the sampling episode.

Crew Chief

	The ERG crew chief, TJ Finseth, is responsible for ensuring that ERG
sampling team members adhere to this plan. The crew chief must report
any accident, near miss, or injury to any sampling team member to the
ERG Chantilly Office Health and Safety Coordinator (HSC), Kevin Sikora,
verbally within 8 hours, or sooner. The HSC will investigate the
incident to identify the cause of the accident, near miss, or injury. If
sufficient cause exists, ERG’s general health and safety plan and
in-house training program will be modified to avoid similar accidents in
the future.

	At the start of the sampling visit, the crew chief will inspect all
sampling points and review sample collection procedures with the Belews
Creek personnel to ensure that all potential hazards have been
identified.

	The crew chief has the authority to enforce ERG’s health and safety
requirements contained in this plan, and any facility-specific
requirements. Changes to this plan or the sampling plan can be made if
both the crew chief and the Chantilly HSC agree that the changes are
appropriate.

Sampling Team Members

	All field personnel are responsible for following the requirements of
this plan, for adhering to plant-specific procedures, and donning
required/recommended PPE. They are also responsible for bringing health
and safety issues to the attention of the crew chief.

Briefings

	ERG sampling team personnel will attend on- and off-site health and
safety briefings.

Off-Site Briefings

	All members of the sampling team will receive a copy of this sampling
plan prior to arriving onsite. All ERG employees will be required to
sign a health and safety sign-off sheet stating that they have read,
understood, and agree with this health and safety plan prior to
participating in field sampling activities.

On-Site Briefings

	ERG sampling team personnel must attend a one- to two-hour safety
course prior to conducting sampling activities at Belews Creek. This
safety course will review plant-specific health and safety procedures,
including:

Locating on-site first aid/emergency medical procedures;

Required PPE;

High hazard areas and other specific areas or hazards of concern;

Emergency alarms and evacuation procedures; and 

Other site safety requirements and procedures that ERG personnel must
follow.

[QUESTION FOR BELEWS CREEK:  Will ERG and EPA staff be required to
participate in any safety course/training prior to collecting samples? 
Yes  If so, how long is the course/training and what does it cover? 
approximately 1 ½ hour]

Safety Procedures

	ERG personnel will follow general safety procedures, which include
wearing PPE and engaging in safe work practices.

Personal Protective Equipment (PPE)

	The PPE listed below will be worn by ERG personnel at all times while
inside the premises of Belews Creek:

Steel-toed safety shoes;

Long sleeves (when sampling) and pants;

Hard hat, where required by Belews Creek;

Hearing protection, where needed;

Nitrile or non-colored, electronic grade gloves, when collecting or
preserving; and

Safety glasses with side shields or chemical splash goggles, when
collecting or preserving samples.

	For all phases of sample collection, decontamination of the PPE may not
be necessary because disposable PPE will be used. If gloves become torn
or degraded, they will be thrown away and replaced with a new pair.
Disposable PPE, including gloves, will be removed, bagged, and left at
the site in a controlled manner.

Safety Practices

	  SEQ CHAPTER \h \r 1 ERG personnel will conduct themselves at all
times in a manner judged to be safe by site supervisors. 

	All sample collection will be scheduled so that no ERG employee
collects samples alone. Each worker will maintain visual contact with at
least one other worker at all times. This buddy system will ensure
against an employee becoming injured or contaminated with chemicals
without a co-worker being aware of his or her condition. Workers should
“watch out” for each other while working close to potential chemical
and physical hazards. A Belews Creek or EPA employee may be used as a
buddy by ERG personnel. This arrangement will be agreed to and
acknowledged by the employee. 

	ERG employees will not enter any permit-required confined space areas. 


Safe Work Practices

	  SEQ CHAPTER \h \r 1 The following safety rules will be obeyed while
working in the facility:  

Wearing PPE, where required;

Staying within designated areas;

Not wearing loose clothing or jewelry; 

Keeping long hair in hard hat or tied back; 

Not eating in the sampling or staging areas; and

Not smoking in the sampling or staging areas.

Sampling Point-Specific Safety Procedures

	All sampling team members will be advised of any sampling
point-specific safety protocols during the on-site health and safety
briefing. Table 6-1 summarizes all potential sampling point-specific
safety hazards as well as the personal protective equipment (PPE)
required at each sampling point. The sampling team health and safety
officer (HSO) for this sampling episode is the crew chief, TJ Finseth
(ERG). The HSO and the sampling team will inspect each sampling point
area to identify unique or additional hazards not already covered in
this plan or during the formal health and safety briefing. If additional
hazards are found, the sampling team will be informed of each hazard and
required control measures prior to the start of work. Where identified
hazards may affect the plant’s personnel, the HSO will notify the
appropriate Belews Creek personnel.

Physical Hazards

	ERG personnel will be alert for all physical hazards present while on
site. Physical hazards may arise from using catwalks, hitting low
hanging overhead piping, and working around moving equipment or
vehicles. ERG personnel will be aware of the potential splash hazards at
SP-1, SP-2, and SP-3 due to the location of the sample taps. To prevent
splashing, ERG personnel will ensure that the sample tubing is connected
securely to the sample tap and will open the sample valve slowly when
collecting samples. Other potential hazards may include falling hazards
during sample collection, tripping on metal grates, or operation of
large trucks and machinery in the vicinity of the sample collection
area. See Table 6-1 for potential hazards that may be associated with
specific sampling points.

	Noise may be a hazard in certain areas of the facility. Hearing
protection will be used by the sampling team where required by the
plant, when sampling members are having trouble hearing or being heard
when standing 3 feet or less away from another person, or when deemed
necessary by the Belews Creek personnel or ERG crew chief. 

Thermal Hazards

	Heat stress may be a concern during the sampling episode. Samplers may
be suited in Tyvek® and temperatures could reach extremes. Of
particular concern is SP-1, which are located outside. The sampling team
members are to consume plenty of fluids prior to the start of sampling,
and will monitor each other for symptoms of heat stress. 

	Wastewater sampling points are not expected to be too hot for safe
handling using typical PPE. Thicker nitrile gloves may be used during
sampling if sample bottles are too hot to hold. If extremely hot samples
are encountered, samplers will handle samples with heat-resistant
gloves.

Chemical Hazards

	The only chemical hazards expected are chemicals used to preserve
samples. All sampling team members will be advised of any potential
chemical hazards at each sampling point as well as any special PPE
recommendations during the formal health and safety briefing. If the
sample tap (i.e., the point from which the wastewater flows) is above
waist height, a face shield or goggles must be worn during sample
collection. To avoid ingesting chemicals, sampling team members will be
required to wash hands thoroughly before eating or drinking. ERG
personnel will not be permitted to enter areas where the facility has
determined that respiratory protection equipment is necessary to protect
against inhalation hazards. 

Temperature Extremes

	Extremely hot temperatures can be a health and safety hazard for this
sampling episode. ERG personnel will take precautions to avoid injuries
due to extreme temperatures.

Heat Stress

	  SEQ CHAPTER \h \r 1 Heat stress is not only a concern in hot/humid
outdoor environments, it is a concern due to the thermal or radiant heat
generated by equipment and/or processes. Sampling team personnel will
monitor each other for the following symptoms:

Heat rash that may result from continuous exposure to heat or humid air.
Treatment:  Wear cotton clothing under coveralls or Tyvek®.

Heat cramps which are caused by heavy sweating and inadequate
electrolyte replacement. Many times, cramps may not occur until after
work or until the worker is sleeping. Signs and symptoms include:

Muscle spasms

Pain in the hands, feet, and abdomen

Treatment:  Gently stretch and massage muscles and replace fluids. Rest
in a cool shaded area.

Heat exhaustion which occurs from increased stress on various body
organs including inadequate blood circulation due to cardiovascular
insufficiency or dehydration. Signs and symptoms include:

Pale, cool, moist, clammy skin

Heavy sweating

Headache and dizziness

Nausea

Fainting or fatigue

Elevated pulse rate (above 150)

Treatment:  Replace fluids, pour cool water over face, neck, hands,
arms, and legs. Place worker in cool air and seek medical care.

Heat stroke is the most serious form of heat stress. Temperature
regulation fails and the body temperature rises to critical levels.
Immediate action must be taken to cool the body before serious injury
and death occur. Competent medical help must be obtained. Signs and
symptoms are:

F (oral)

Lack of or reduced perspiration

Nausea

Headache, dizziness, and confusion

Strong, rapid pulse

Coma

Treatment:  Remove worker to cool area, saturate clothes with cold
water, wrap worker in wet cold sheets (if possible), monitor ABC
(airway, breathing, circulation), treat for shock, and call emergency
services for basic life support (BLS) or advanced life support (ALS).

Heat Stress Monitoring

	A worker who exhibits any of the above symptoms will be immediately
relieved of responsibilities and requested to consume electrolyte fluid
or cool water while resting in a shaded area. The individual should not
return to work until symptoms are no longer recognizable. If symptoms
appear critical, persist, or get worse, the crew chief will seek
immediate medical attention for the employee. If the individual does
resume work, he/she will be monitored for any increase in heart rate for
the remainder of their shift. In addition, the worker will be requested
to consume electrolyte fluid or cool water every hour.

	The crew chief will visually monitor workers hourly when:

Symptoms of heat stress are reported or observed;

F and workers are dressed in impervious clothing; or

Ambient temperatures exceed 90F and workers are dressed in normal
clothing.

	For sampling on this project, work periods will be considered to be
approximately two hours in length.

	At ambient temperatures of 87F and above, workers will be monitored
for heat stress conditions by measuring the heart rate (HR) by radial
(wrist) pulse for 30 seconds after one minute of rest. The HR after one
minute of rest should not exceed 110 beats per minute. If higher, the
next work period shall be shortened by 33 percent, while the length of
rest period remains the same. If the pulse rate is still 110 beats per
minute after one minute of rest in the next rest period, the following
work cycle will be shortened by another 33 percent. This shortening of
the work period must continue until the worker's HR is no greater than
110 beats per minute.

First Aid

	  SEQ CHAPTER \h \r 1 First aid procedures in response to chemical
exposures will be conducted in accordance with the appropriate MSDS for
the chemical involved. If an incident occurs and MSDSs are not available
for a particular hazardous chemical (e.g., wastewater), the following
general first aid procedures will be performed:

Skin Contact - The affected area will be rinsed thoroughly and copiously
with clean water. Seek medical attention if irritation is experienced
after cleaning.

Eye Contact - The eyes will be flushed thoroughly at the nearest eyewash
station for 15 minutes. Follow up with medical attention.

Ingestion - The hospital will be notified and any procedures recommended
will be carried out. 

	The first aid kit will be maintained on each site in the equipment
staging area. The contents of the first aid kit include at a minimum:  

Adhesive bandages;

Antiseptic wipes;

A compress;

An eyewash solution;

Gauze pads;

A cold pack; and 

A triangular bandage.

	The injuries most likely to be encountered at Belews Creek are cuts and
bruises; the first aid kit will be maintained and stocked accordingly.

Sample Preservation and Safety Considerations

	  SEQ CHAPTER \h \r 1 Water samples to be analyzed for various
contaminants may be preserved with sulfuric acid (H2SO4), hydrochloric
acid (HCl), sodium hydroxide (NaOH), or an ammonium sulfate buffer
solution (NH4SO4) before shipment to the analytical laboratory. Nitrile
gloves and splash goggles must be worn when handling these corrosive
chemicals to prevent chemical burns. Sample preservation must be
performed in a well-ventilated area (preferably an operational lab hood)
to avoid potential accumulation and inhalation of any toxic vapors. When
pouring samples, skin protection must also be worn (long-sleeved cotton
coveralls or uncoated Tyvek®, safety glasses with side shields or
splash goggles, and nitrile gloves).

	In some instances, the use of these preservation chemicals could create
a chemical reaction (i.e., generation of heat or release of toxic
vapors). For instance, if acids are added to a wastewater sample
containing cyanide or sulfides, dangerous and toxic vapors will be
emitted. If the sample reacts violently, notify the crew chief and stop
preserving the sample immediately.

	In the case of a chemical spill, the following procedures must be
followed:

Don protective clothing (nitrile gloves as a minimum).

Ventilate area (open doors, windows, or turn on ventilation).

Use spill control pillows or prepared neutralizers to contain/clean up
spill. Do not add water to acid.

Place spilled material in a heavy plastic container, label the
container, and contact site for disposal information.

Notify crew chief of the spill and the procedures used.

	At any time, if personnel do not feel comfortable about cleaning up the
spilled material or if a large quantity has been spilled, notify site
personnel. The site may have an emergency response team who will respond
to the chemical spill. 

	In the case of fire, notify the site contact. If the fire can be easily
extinguished using a portable fire extinguisher, and personnel have
received fire extinguisher training, extinguish the fire using the
portable extinguisher.

Training and Medical Monitoring Requirements

	  SEQ CHAPTER \h \r 1 All ERG sampling crew personnel have participated
in ERG's annual 8-hour health and safety training program as specified
by ERG's Corporate Health and Safety Policy. 

This training includes:

Toxicology;

Exposure limits;

Chemical, biological, and physical hazards;

Heat and cold stress;

Confined spaces;

PPE;

Decontamination; and

Emergency plans and procedures.

	All ERG personnel involved with sample collection and preservation are
active participants in the Medical Monitoring Program. Field sampling
personnel have received a baseline medical information review and
undergo a clinical assessment every one to two years.

Shift Work Protocol

	  SEQ CHAPTER \h \r 1 This section provides guidance for field
personnel project schedules and field work, particularly overtime. It is
important to remember extended work schedules will contribute to poor
production and motivation. All field teams will rotate to ensure that
sampling team members receive sufficient rest to avoid injuries
resulting from fatigue or inattention.

	It is common practice to perform 12-hour work days under project
management direction. If this work schedule is exceeded the following
guidelines will be recognized:

1A 15-hour maximum work day, provided that it does not occur on
consecutive days, or more than three times in ANY SEVEN-DAY PERIOD.

2Each shift should be followed by nine hours off per 24-hour period,
excluding driving time to and from the hotel.

No more than seven consecutive days of work allowed without a minimum of
24 hours off.

Each work day will be reviewed as a 24-hour cycle to assure all field
workers receive adequate time off.Table 6-1. Sample-Point-Specific
Personal Protective Equipment and Potential Hazards



Sampling Point Number	Sampling Point Description	Personal Protective
Equipment Required a	Potential Physical Hazards b

SP-1	Influent to FGD Wastewater Treatment System	Steel-toed boots, hard
hats, gloves and safety glasses.	Splash hazard: Potential for splashing
from the sample tap. Sample tap will be below waist level.

SP-2	Influent to Bioreactor System	Steel-toed boots, hard hats, gloves,
and safety glasses.	Splash hazard: Potential for splashing from the
sample tap. Sample tap will be below waist level.

SP-3/SP-4	Effluent from Bioreactor System	Steel-toed boots, hard hats,
gloves, and safety glasses.	Splash hazard: Potential for splashing from
the sample tap. Sample tap will be below waist level.

a – Splash protection (face shield) required if sampling port is waist
high or above. Hearing protection (ear plugs) will be worn if needed.

b – Additional physical hazards, if any, will be identified during the
formal on-site health and safety briefing. Updates to this table will be
made as needed.

References

  SEQ CHAPTER \h \r 1 U.S. Environmental Protection Agency, 2006.
Interim Detailed Study Report for the Steam Electric Power Generating
Point Source Category, EPA/821-R-06-015, November.

Eastern Research Group, Inc., 2007. Quality Assurance Project Plan for
the 2007 Steam Electric Detailed Study – Revision 1. September.

Eastern Research Group, Inc., 2007. Generic Sampling and Analysis Plan
for Coal-Fired Steam Electric Power Plants. May.

Appendix A

LIST OF METALS CONSTITUENTS FOR ANALYSIS  SEQ CHAPTER \h \r 1 Table A-1

List of Constituents for Analysis -

200.7/245.1/245.5 Metal Analytes

CAS

Number	Common Name	Technique	Method

7429905	ALUMINUM	ICP	200.7

7440360	ANTIMONY	ICP	200.7

7440382	ARSENIC	ICP	200.7

7440393	BARIUM	ICP	200.7

7440417	BERYLLIUM	ICP	200.7

7440428	BORON	ICP	200.7

7440439	CADMIUM	ICP	200.7

7440702	CALCIUM	ICP	200.7

7440473	CHROMIUM	ICP	200.7

7440484	COBALT	ICP	200.7

7440508	COPPER	ICP	200.7

7439896	IRON	ICP	200.7

7439921	LEAD	ICP	200.7

7439954	MAGNESIUM	ICP	200.7

7439965	MANGANESE	ICP	200.7

7439976 	MERCURY	CVAA	245.1, 245.5 

7439987	MOLYBDENUM	ICP	200.7

7440020	NICKEL	ICP	200.7

7782492	SELENIUM	ICP	200.7

7440224	SILVER	ICP	200.7

7440235	SODIUM	ICP	200.7

7440280	THALLIUM	ICP	200.7

7440315	TIN	ICP	200.7

7440326	TITANIUM	ICP	200.7

7440622	VANADIUM	ICP	200.7

7440655	YTTRIUM	ICP	200.7

7440666	ZINC	ICP	200.7

 

27 METALS ANALYTES

  SEQ CHAPTER \h \r 1 Table A-2

List of Constituents for Analysis -

200.8 Metal Analytes

CAS

Number	Common Name
敔档楮畱॥敍桴摯഍㐷㤲〹व䱁䵕义䵕䤉偃䴯॓〲⸰സ
㐷〴㘳र乁䥔位奎䤉偃䴯॓〲⸰സ㐷〴㠳ल剁䕓䥎ृ䍉
⽐卍㈉〰㠮㜍㐴㌰㌹䈉剁啉्䍉⽐卍㈉〰㠮㜍㐴㐰㜱䈉
剅䱙䥌䵕䤉偃䴯॓〲⸰സ㐷〴㈴स佂佒ॎ䍉⽐卍㈉〰㠮
㜍㐴㐰㤳䌉䑁䥍䵕䤉偃䴯॓〲⸰സ㐷〴〷ल䅃䍌啉्䍉
⽐卍㈉〰㠮

I

¢

ÿ

#

}

â

 

%

&

'

A

 h]

 h]

"A

B

C

F

G

H

I

J

K

g

h

i

j

l

m

~



€

š

›

œ

Ÿ

 

¡

¢

£

¤

À

Á

 h]

 h]

 h]

 h]

Á

Â

Ã

Æ

Ç

Û

Ü

Ý

÷

ø

ù

ü

ý

þ

ÿ

 h]

 h]

 h]

 h]

 h]

 h]

 

!

"

#

$

%

A

B

C

D

G

H

Y

Z

[

u

v

w

z

{

|

}

~



›

œ

 h]

 h]

-œ

ž

¡

¢

¾

¿

À

Ú

Û

Ü

ß

à

á

â

ã

ä

 h]

 h]

 h]

 h]

j/

j¸

 h]

 h]

j;

j¬

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

j

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

gd}

`„`úgd}

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

 h]

h}

h}

  h}

h}

h}

h}

 h]

 h]

gdÝ-

 hÝ-

 hÝ-

hÝ-

 hÝ-

摧ờ

 hÝ-

 hÝ-

 hÝ-

$

@

*	 h¢

*	 h¢

 h¢

 h¢

  h¢

 h¢

h

h

h«

h«

h«

h[

h[

@

)

+

,

1

N

Z

{

}

~

™

›

œ

»

¿

å

æ

è



[

\

·

¹

hö

hö

hö

hö

 hö

 hö

 hö

 hö

 hö

 hö

hö

 hö

 hö

hö

 hö

hö

 hö

 hö

h

 hö

hö

 hö

 hö

h

@

@

@

 hk

_

hŽ

hŽ

hŽ

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

hŽ

hŽ

Çÿ#

\

Çÿ#

\

Çÿ#

\

Çÿ#

\

Çÿ#

\

Çÿ#

\

Çÿ#

\

Çÿ#

\

Çÿ#

\

Çÿ#

\

Çÿ#

\

Çÿ#

\

 hŽ

hŽ

hŽ

hŽ

hŽ

Çÿ#

\

Çÿ#

\

Ö

@

Ö

Æ

@

@

&

&

&

&

&

&

&

&

 h

 h

 h

愀Ĥ摧᣻1

gd¶

gd¶

葞̠摧ж

 h

㓿ۖĀ̊d搃昀Ĵ

 h

옍

 h

 h

摧嘟

h4

h4

h4

h

h4

h4

h4

h4

h4

 h4

h4

h4

R

T

¥

§

Ã

Ä

÷

ø

š

í

ï

GÄ

Ò

÷

ø

9

H

_

f

z

š

›

 hN

7440473	CHROMIUM	ICP/MS	200.8

7440484	COBALT	ICP/MS	200.8

7440508	COPPER	ICP/MS	200.8

7439896	IRON	ICP/MS	200.8

7439921	LEAD	ICP/MS	200.8

7439954	MAGNESIUM	ICP/MS	200.8

7439965	MANGANESE	ICP/MS	200.8

7439987	MOLYBDENUM	ICP/MS	200.8

7440020	NICKEL	ICP/MS	200.8

7782492	SELENIUM	ICP/MS	200.8

7440224	SILVER	ICP/MS	200.8

7440235	SODIUM	ICP/MS	200.8

7440280	THALLIUM	ICP/MS	200.8

7440315	TIN	ICP/MS	200.8

7440326	TITANIUM	ICP/MS	200.8

7440622	VANADIUM	ICP/MS	200.8

7440666	ZINC	ICP/MS	200.8

	

 

25 METALS ANALYTES

Table A-3

List of Constituents for Analysis -

Low-Level Metal Analytes

CAS

Number	Common Name 	Technique	Method

7440360	ANTIMONY	ICP/MS	1638

7440382	ARSENIC	ICP/MS	1638

7440439	CADMIUM	ICP/MS	1638

7440473	CHROMIUM	ICP/MS	1638

7440473	CHROMIUM-HEXAVALENT	IC	1636

7440508	COPPER	ICP/MS	1638

7439921	LEAD	ICP/MS	1638

7439976 	MERCURY	OPT/CVAFS	1631

7440020	NICKEL	ICP/MS	1638

7782492	SELENIUM	ICP/MS	1638

7440224	SILVER	ICP/MS	1638

7440280	THALLIUM	ICP/MS	1638

7440666	ZINC	ICP/MS	1638

 

13 LOW-LEVEL METALS ANALYTES

 ERG will collect the low-level dissolved mercury sample using the same
technique as the low-level total mercury sample, but the dissolved
sample will be filtered at the laboratory. A low-level 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 low-level dissolved mercury field blank
sample in the field. In addition, a routine total metals field blank
will be collected at the effluent from bioreactor system (SP-3) and not
from the influent to FGD wastewater treatment system (SP-1).

 ERG will collect the low-level dissolved mercury sample using the same
technique as the low-level total mercury sample, but the dissolved
sample will be filtered at the laboratory. A low-level 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 low-level dissolved mercury field blank
sample in the field. In addition, a routine total metals field blank
will be collected at the effluent from the bioreactor system (SP-3) and
not from the influent to the bioreactor system (SP-2). ERG will use
blank water from the clean metals supplier for the routine total metals
field blank to prevent contamination so two different sets of sampling
equipment are not required.

 ERG will collect the low-level dissolved mercury sample using the same
technique as the low-level total mercury sample, but the dissolved
sample will be filtered at the laboratory. A low-level 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 low-level dissolved mercury field blank
sample in the field.

 ERG will use blank water from the clean metals supplier for the routine
dissolved metals field blank and routine hexavalent chromium field blank
to prevent contamination so two different sets of sampling equipment are
not required.

 For routine total and dissolved metals, EPA is collecting field blanks
for each different type of sampling technique; therefore, only one field
blank is needed for the influent to the FGD wastewater treatment system,
the influent to the bioreactor system, and the effluent from the
bioreactor system because a similar technique is used to collect the
samples.

 PAGE   

TABLE OF CONTENTS (Continued)

Page

 PAGE   ii 

 PAGE   i 

LIST OF TABLES (Continued)

 PAGE   iii 

 PAGE   iii 

LIST OF FIGURES (Continued)

 PAGE   2-6 

 PAGE   iv 

  PAGE  3-21 

 PAGE   3-28 

  PAGE  3-25 

 PAGE   3-30 

 PAGE   3-32 

 PAGE   6-9 

 PAGE   7-1 

A-  PAGE  2 

A-  PAGE  1 

Ash Pond

Wetland Supply Tank

002

5A

4A

3A

2A

1A

5B

4B

3B

2B

1B

EQ B

EQ A

 PAGE  3-23 

 PAGE  3-23 

 PAGE  2-10 

 PAGE  3-29 

 PAGE  3-31 

