Document 6w7Gqo9eMox8LQ6dy0mKXqv8E

LSASD Project ID: 23 - 0290 Sampling and Analysis Plan NPDES NCI Compliance Sampling Inspection Hunter Engineering Company Location: 2489 Raymond Clinton Road Raymond, MS Project Date(s): July 18th - 19th, 2023 Final SAP Approval Date: July 13, 2023 LSASDFORM-064-R3 052923 Project Leader: Chris McHugh Water Quality Section Field Services Branch Laboratory Services & Applied Science Division USEPA - Region 4 980 College Station Road Athens, Georgia 30605-2720 The ANSI National Accreditation Board attests that U.S. EPA Region 4 Laboratory Services and Applied Science Division fulfills the requirements of ISO/IEC 17025:2017 ANAB Forensic Testing & Calibration AR 3125:2019 in the field of Forensic Testing. The activities contained in this report fall within the scope of accreditation, Certificate Number: AT-2628. Expires 08 June 2024. LSASD Project ID: 23 - 0290 Page 1 of 10 Sampling and Analysis Plan Project Requestor: Laurie Jones Wastewater Enforcement Section Enforcement & Compliance Assurance Division USEPA - Region 4 61 Forsyth Street, SW Atlanta, GA 30303-8960 LSASDFORM-064-R3 052923 Analytical Support: Inorganic Chemistry Section Laboratory Services Branch Laboratory Services and Applied Science Division 980 College Station Rd Athens, GA 30605 Approvals: McHugh, Christopher Date: 2023.07.13 09:03:44 -04'00' Digitally signed by McHugh, Christopher Chris McHugh Water Quality Section Field Services Branch Date Approving Officials: Digitally signed by DEREK LITTLE Date: 2023.07.13 09:33:50 -04'00' Derek Little, Technical Reviewer Water Quality Section Field Services Branch Date GREGORY WHITE Date: 2023.07.13 10:03:46 -04'00' Digitally signed by GREGORY WHITE Greg White, Supervisor Water Quality Section Field Services Branch Date This Sampling and Analysis Plan (SAP) is designed to be used in conjunction with the Applied Science Branch Quality Assurance Project Plan December 2019. LSASD Project ID: 23 - 0290 Page 2 of 10 Sampling and Analysis Plan LSASDFORM-064-R3 052923 SECTION A: Project Planning Elements A1. Distribution List Recipient Laurie Jones Dennis Sayre Jairo Castillo Shelia M. Hollimon Organization U.S. EPA Region 4 Enforcement & Compliance Assurance Division U.S. EPA Region 4 Enforcement & Compliance Assurance Division U.S. EPA Region 4 Enforcement & Compliance Assurance Division U.S. EPA Region 4 Enforcement & Compliance Assurance Division A2. Project Personnel Address/Email 64 Forsyth St. SW Atlanta, Georgia 30303-8960 Jones.laurie@epa.gov 64 Forsyth St. SW Atlanta, Georgia 30303-8960 Sayre.dennis@epa.gov 64 Forsyth St. SW Atlanta, Georgia 30303-8960 Castillo.jairo@epa.gov 64 Forsyth St. SW Atlanta, Georgia 30303-8960 Hollimon.Shelia@epa.gov Team Members1 Organization Responsibilities Chris McHugh EPA/R4/LSASD LSASD Project Lead, Safety, Sampling Asher Sampong EPA/R4/LSASD Safety, Sampling 1Project Leader and all Task Leaders assisting with this project have been deemed competent by LSASD management to conduct the tasks required to fulfill the prescribed goals. A3. Site Description and Background Information Hunter Engineering Company in Raymond, MS, is permitted by NPDES permit MSP090222 to discharge its pretreatment effluent discharge from outfall labeled Outfall 001 to the Raymond POTW East MS0025852. The facility has been inspected previously by EPA NEIC and Region 4 Enforcement and Compliance Assurance Division (ECAD) to evaluate the NPDES permit exceedances for Total Recoverable Copper. LSASD Project ID: 23 - 0290 Page 3 of 10 Sampling and Analysis Plan LSASDFORM-064-R3 052923 A4. Problem Definition The purpose of this Industrial Pretreatment Compliance Sampling Inspection (CSI) is to evaluate the facility's NPDES pretreatment sampling, collect representative pretreatment samples for analysis by EPA and provide evidence for potential compliance problems where appropriate. The analytical data will be provided to U.S. EPA Region 4 ECAD for evaluation of the effluent discharge parameters in Section B1 below. A5. Project Description, Goals, and Study Boundaries Study Goal: Support the Enforcement and Compliance Assurance Division (ECAD) by collecting NPDES effluent discharge samples at Hunter Engineering Company. LSASD will provide a sample evaluation report containing the analytical results compared to the effluent limitations set forth in the NPDES permits limitations in Effluent Limitations and Monitoring Requirements table of the permit. Analyses and containers to be used for sampling are referenced in Table B1. LSASD will also provide observations and an evaluation of the sampling set - up and procedures. Study Objectives: Set - up and collect effluent 24-hour composite samples at the effluent discharge location and collect grab samples from the circuit board wash discharge, eco-wash stage, and the facility's water incoming water source. In-situ pH, temperature, and dissolved oxygen will be measured at the effluent discharge location. Evaluate the facility's sampling procedures and plant condition. Study Area: The study area is the grounds of the facility and the pretreatment discharge equipment. Study Design/Approach: The planned approach utilizes an automatic sampler and a collection container to collect an effluent 24-hour composite sample. Operating procedures for all sampling and field measurement activities outlined in this study plan are referenced in Section B5: Sampling and Measurement Procedures. LSASD Project ID: 23 - 0290 Page 4 of 10 Sampling and Analysis Plan Quality Control Samples Trip blank with DI water prepared before going on-site. Duplicate Sample at Outfall 001 Temperature blank. Project Timeline: All field activities are planned for the week of July 17th, 2023. Proposed schedule (subject to change): July 17th - Drive to Jackson, MS July 18th - Inspection at Hunter engineering July 19th - Collect composite samples July 20th - Drive back to LSASD and deliver samples. LSASDFORM-064-R3 052923 A6. Applicable Regulatory Information 40 CFR 136 NPDES Permit No: MSP090222 A7. Decision(s) to be made based on data The results of this study will support the ECAD Water Enforcement Branch workplan. ECAD will use the analytical data as needed for any future enforcement actions against the wastewater treatment facilities. LSASD Project ID: 23 - 0290 Page 5 of 10 Sampling and Analysis Plan LSASDFORM-064-R3 052923 SECTION B: Data Generation, Acquisition, and Reporting Will samples or physical evidence be collected: Yes - If yes, complete all subsections in Section B. No - If no, no action needed for B1, B2, B3 or B4, proceed to B5. B1. Sampling Design/Information Inputs Sample Media Pretreatment Effluent Total Number of Samples 4 - 1L Metals Analyses Total Copper, Zinc, Cadmium, Chromium, Nickel, Lead, and Silver B2. Sampling Handling and Custody As outlined in the Field Services Branch Quality Assurance Project Plan, all samples will be handled and custody maintained in accordance with the LSASD Laboratory Services Branch Laboratory Operations and Quality Assurance Manual, LSASD Operating Procedure for Sample and Evidence Management, LSASDPROC-005, and LSASD Operating Procedure for Packing, Labeling and Shipping of Environmental and Waste Samples, LSASDPROC-209. Will a Chain-of-Custody be produced? Yes No Throughout the duration of the event, have preparations been made to ensure that custody is maintained? Custody of a sample or physical evidence is defined as: It is in the actual possession of an investigator It is in the view of an investigator, after being in their physical possession It was in the physical possession of an investigator and then they secured it to prevent tampering It is placed in a designated secure area Yes No B3. Quality Control Field quality control measures will be conducted in accordance with the LSASD Operating Procedure for Field Sampling Quality Control, LSASDPROC-011. The sample equipment and in-situ meters will be calibrated and set-up prior to use. Laboratory quality control measures are specified in the LSASD Laboratory Services Branch Laboratory Operations and Quality Assurance Manual. LSASD Project ID: 23 - 0290 Page 6 of 10 Sampling and Analysis Plan LSASDFORM-064-R3 052923 B4. Analytical Methods and Support Samples will be analyzed by the EPA/Region 4 LSASD laboratory in Athens, GA in accordance with the LSASD Laboratory Services Branch Laboratory Operations and Quality Assurance Manual. Specific analytical methods include: Metals by EPA Method 200.7 Laboratory Turn-Around-Time Requested: 30 Days Reporting Levels: Non-Routine Reporting Levels ARE NOT Required, No Further Action. Non-Routine Reporting Levels ARE Required, List Below. Non-Routine Reporting Levels: Waste Samples Anticipated: If answer is yes, specify laboratory name/address to receive samples: Yes No Unknown Not applicable LSASD Project ID: 23 - 0290 Page 7 of 10 Sampling and Analysis Plan LSASDFORM-064-R3 052923 B5. Sampling and Measurement Procedures Sampling and measurement activities will be in accordance with the LSASD operating procedures. The following field procedures will be followed during this study, check all that apply: (Last Update: 09/13/2022) Field Measurement Procedures* LSASD/SESDPROC- Revision Field pH Measurement 100 R5 Field Specific Conductance Measurement 101 R7 Field Temperature Measurement 102 R6 Field Turbidity Measurement 103 R5 Groundwater Level and Well Depth Measurement 105 R4 Field Measurement of Dissolved Oxygen 106 R4 Field X-Ray Fluorescence (XRF) Measurement 107 R5 Wastewater Flow Measurement 109 R5 Global Positioning System 110 R5 In-Situ Water Quality Monitoring 111 R5 Field Measurement of Total Residual Chlorine 112 R6 Field Measurement of Oxidation-Reduction Potential (ORP) General Field Sampling Procedures* Sediment Sampling 113 LSASD/SESDPROC- 200 R3 Revision R4 Surface Water Sampling Hazardous Waste Section Field Sampling Procedures* Soil Sampling 201 LSASD/SESDPROC- 300 R5 Revision R4 Groundwater Sampling 301 R5 Waste Sampling 302 R4 Ambient Air Sampling 303 R5 Potable Water Supply Sampling 305 R4 Wastewater Sampling 306 R5 Soil Gas Sampling Water Quality Section Field Sampling Procedures* Hydrological Studies 307 LSASD/SESDPROC- 501 R4 Revision R6 Reaeration Measurement by Diffusion Dome 505 R5 Sediment Oxygen Demand Multi-Habitat Macroinvertebrate Sampling in Wadeable Freshwater Streams Marine Macroinvertebrate Field Sampling 507 R5 508 R5 511 R5 Fish Field Sampling 512 R5 Pore Water Sampling 513 R4 Bottom Water Sampling for Sulfide 515 R0 *If procedures allow for different sampling and measurement methods, the utilized method(s) must be identified in the project description section. Additionally, verify procedure revision numbers before issuance of SAP. LSASD Project ID: 23 - 0290 Page 8 of 10 Sampling and Analysis Plan LSASDFORM-064-R3 052923 Section C: Reporting C1. Reporting Estimated Report Completion Date: 09/16/2023 Is a Provisional Data Release Anticipated? Yes No Provisional data may be provided prior to the completion of the LSASD final report only if LSASD management approves the release of the information and the analytical data have been released as final from the LSASD Laboratory Services Branch, for LSASD generated data, and/or the LSASD Quality Assurance Section, for non-LSASD generated data. Release of provisional data will be transmitted by electronic or hard copy with official correspondence from the Section Supervisor in accordance with the LSASD Operating Procedure for Report Preparation and Distribution (LSASDPROC-003). Additional Comments: Provisional data may be released to EPA R4 Enforcement and Compliance Assurance Division pending issuance of final report. LSASD Project ID: 23 - 0290 Page 9 of 10 Sampling and Analysis Plan LSASDFORM-064-R3 052923 Site Figures and Tables Table 1: Effluent Limitations for Hunter Engineer Company Parameter Permitted Limit Unit Frequency Statistical Base Copper 0.100 mg/L Weekly Maximum Zinc 1.6 mg/L Weekly Maximum Cadmium 0.003 mg/L Monthly Maximum Nickel 1.27 mg/L Weekly Maximum Chromium 2.77 mg/L Weekly Maximum Lead 0.015 mg/L Weekly Maximum Silver 0.02 mg/L Weekly Maximum Figure 1 - Aerial of Hunter Engineering Company END OF DOCUMENT LSASD Project ID: 23 - 0290 Page 10 of 10 Sampling and Analysis Plan