Exhibit B Sampling and Analysis Plan (SAP) DNR-Parks & Recreation Clear Lake State Park.pdf

Sampling and Analysis Plan

DNR-Parks & Recreation

Clear Lake State Park

Atlanta, Michigan

January 21, 2026

Prepared by:

Gosling Czubak Engineering Sciences, Inc.

1280 Business Park Drive

Traverse City, Michigan

(231) 946-9191 www.goslingczubak.com

GCES Project # 2023520001.00

P:\2023520001.00\Docs\Wastewater\Discharge Permit\Clear Lake_Sampling and Analysis Plan_112125.docx http://www.goslingczubak.com/

CONTENTS

1.0 INTRODUCTION

2.0 EFFLUENT SAMPLING

2.1 Effluent Flow Monitoring and Locations

2.2 Effluent Quality Sampling and Locations

3.0 GROUNDWATER SAMPLING

3.1 Monitoring Wells

4.0 QA/QC PROCEDURES

4.1 Preliminary Preparations and Equipment Lists

4.1.1 Equipment List (Grab sample)

4.1.2 Equipment List (Bailer Method) [Not Preferred]

4.1.3 Equipment List (Low-Flow/Pump Method) [Preferred]

4.2 General Procedures

4.3 Grab Sample Procedures

4.4 Groundwater Procedures

4.5 Field Duplicate Collection and Analysis

4.6 Sampling Procedures for the Bailor Method [Not Preferred]

4.7 Sampling Procedures for the Low-Flow/Pump Method [Preferred]

5.0 LABORATORY AND FIELD ANALYSIS

5.1 Laboratory Analysis

5.2 Field Analysis and Calibration

6.0 DATA RECORDS AND REPORTING

7.0 ATTACHMENTS

7.1 Att1 – Site Map

7.2 Att2 – Calibration Log

DNR-Parks & Recreation January 21, 2026

Sampling and Analysis Plan Page 1

1.0 INTRODUCTION

The following is the Sampling and Analysis Plan for DNR-Parks & Rec-Clear Lake State Park. The facility is located at 20500 M-33 North, Atlanta, Michigan 49709. This plan has been prepared as required by Groundwater Discharge Permit Number GW1010022, of the Natural Resources and

Environmental Protection Act, 1994 PA 451, as amended. The permit took effect January 1, 2025, and the Department of Environment, Great Lakes, and Energy requires a sampling and analysis of the system’s effluent and groundwater.

The objective of the Sampling and Analysis Plan is to provide monitoring for the groundwater treatment facility discharge.

General Disclaimer: This Sampling and Analysis Plan (SAP) is an enforceable requirement under this site’s groundwater discharge permit after it has been approved by the Department of Environment, Great

Lakes, and Energy. Prior to implementing any modifications to an approved SAP, the permittee must submit a written request for modification to EGLE and receive written approval from EGLE.

Modifications are enforceable requirements under this site’s groundwater discharge permit upon the date of EGLE’s written approval.

Sampling and Analysis Plan Page 2

2.0 EFFLUENT SAMPLING

Treatment system’s effluent will be monitored by the certified treatment operator. As specified Rule

2220 of the "Part 22 Groundwater Quality Administrative Rules": Sampling procedures shall be consistent with the EPA document entitled "Test Methods for the Evaluation of Solid Waste, Physical-

Chemical Methods," SW-846. Results from any monitoring that is conducted more frequently than required by the permit, using approved analytical methods, must be included in Discharge Monitoring

Report calculations and reporting. Such increased frequency must be clearly indicated in reporting notes.

For an ariel view of the effluent sample locations see the Site Map (Attachment Att1).

2.1 Effluent Flow Monitoring and Locations

See Table 1 “EQ-1 Flow Monitoring Description” and Table 2 “EQ-2 Flow Monitoring Description” below:

Table 1 – EQ-1 Flow Monitoring Description

Sample Identification EQ-1

Sample Parameter Flow (Daily)

Sample Location Lift Station Flow Meter (see Site Map)

Sample Type Direct Measurement

Sample Frequency Daily

Sample Units GPD

Table 2 – EQ-2 Flow Monitoring Description

Sample Identification EQ-2

Sample Parameter Flow (Daily)

Sample Location Sanitation Station Flow Meter (Meter Manhole) (see Site Map)

Sample Type Calculation

Sample Frequency Weekly1

Sample Units GPD Note:

1Weekly Average Flow Monitoring

• Record the average daily flow on a weekly basis in a log that shall be available for review upon request.

Sampling and Analysis Plan Page 3

2.2 Effluent Quality Sampling and Locations

Effluent quality samples are required to be taken per the most current groundwater permit. The sample locations can be found in Attachment 1 (Att 1 – Site Map). Detailed sampling requirements are provided in Table 3 “EQ-1 (Dosing Tank) Effluent Sample Description” and Table 4 “EQ-2 (Sanitation Station

Dosing Tank) Effluent Sample Description” below:

Table 3 – EQ-1 (Dosing Tank) Effluent Sample Description

Sample Location: Final Riser in Siphon Dosing Chamber (see Site Map)

Parameter Sample

Type

Sampling

Frequency3

EPA Analytical

Method or SW-846

Filtered or

Unfiltered

Maximum

Hold Time

Sample Preservation

Methods

Detection

Limit

(mg/L)

Flow

(Annual) Calculation Annually NA Unfiltered NA NA NA

Total

Inorganic

Nitrogen

(TIN)1

Calculation Monthly NA Unfiltered NA NA NA

Ammonia

Nitrogen Grab Monthly SM4500-NH3-G Unfiltered 28 days H2SO4 preserved to pH<2, Cooled to 4°C 0.05

Nitrate

Nitrogen Grab Monthly EPA 353.2 Unfiltered 48 days Cooled to 4°C 0.1

Nitrite

Nitrogen Grab Monthly EPA 353.2 Unfiltered 48 days Cooled to 4°C 0.05 pH2 Grab Monthly SM 4500-H/EPA 150.1 Unfiltered 15 minutes NA NA

Biochemical

Oxygen

Demand

(BOD5)

Grab Monthly SM5210-B Unfiltered 24 hours Sterile BOD bottles 1000

Dissolved

Oxygen2 Measured Monthly SM 4500-O Unfiltered 15 minutes NA NA

Chloride Grab Monthly SM4500-Cl-E Unfiltered 28 days Cooled to 4°C 2

Sodium Grab Monthly EPA 200.7 Unfiltered 6 months 1:1 HNO3 preserved to pH<2, Cooled to 4°C

Total

Phosphorus Grab Monthly EPA 365.1 Unfiltered 28 days

H2SO4 preserved to pH<2, Cooled to 4°C 0.05

1Total Inorganic Nitrogen (TIN)

The daily maximum value for TIN shall be reported as the sum of the daily maximum values for ammonia nitrogen, nitrate nitrogen, and nitrite nitrogen.

2The following parameters shall be analyzed on-site, as required by the groundwater discharge permit: pH, Dissolved Oxygen. These parameters will be analyzed on-site using a pH meter, DO probe or equivalent (such as Hach HQ2200 Portable Multi-Meter or HANNA

HI9829 Multiparameter Meter)

3Annual Monitoring

Annual samples taken during the month of August.

Sampling and Analysis Plan Page 4

Table 4 – EQ-2 (Sanitation Station Dosing Tank) Effluent Sample Description

Sample Location: Sanitation Station Metering Manhole (see Site Map)

Parameters Sample

Type

Sampling

Frequency3

EPA Analytical

Method or SW-846

Filtered or

Unfiltered

Maximum

Hold Limit

Sample Preservation

Method

Detection

Limit

(mg/L)

Flow (Annual) Calculation Annually NA Unfiltered NA NA NA

Total

Inorganic

Nitrogen

(TIN)1

Calculation Annually NA Unfiltered NA NA NA

Ammonia

Nitrogen Grab Annually SM4500-NH3-G Unfiltered 28 days

H2SO4 preserved to pH<2, Cooled to 4°C 0.05

Nitrate

Nitrogen Grab Annually EPA 353.2 Unfiltered 48 days Cooled to 4°C 0.1

Nitrite

Nitrogen Grab Annually EPA 353.2 Unfiltered 48 days Cooled to 4°C 0.05 pH2 Grab Annually SM 4500-H/EPA 150.1 Unfiltered 15 minutes NA NA

Biochemical

Oxygen

Demand

(BOD5)

Grab Annually SM5210-B Unfiltered 24 hours Sterile BOD bottles 1000

Dissolved

Oxygen2 Measured Annually SM 4500-O Unfiltered 15 minutes NA NA

Chloride Grab Annually SM4500-Cl-E Unfiltered 28 days Cooled to 4°C 2

Sodium Grab Annually EPA 200.7 Unfiltered 6 months 1:1 HNO3 preserved to pH<2, Cooled to 4°C

Total

Phosphorus Grab Annually EPA 365.1 Unfiltered 28 days

H2SO4 preserved to pH<2, Cooled to 4°C 0.05

Formaldehyde Grab Annually EPA 8315A Unfiltered 30 days Cooled to 4°C 0.01 1Total Inorganic Nitrogen (TIN)

The daily maximum value for TIN shall be reported as the sum of the daily maximum values for ammonia nitrogen, nitrate nitrogen, and nitrite nitrogen.

2The following parameters shall be analyzed on-site, as required by the groundwater discharge permit: pH, Dissolved Oxygen. These parameters will be analyzed on-site using a pH meter, DO probe or equivalent (such as Hach HQ2200 Portable Multi-Meter or HANNA

HI9829 Multiparameter Meter)

3Annual Monitoring

Annual samples taken during the month of August.

Sampling and Analysis Plan Page 5

3.0 GROUNDWATER SAMPLING

Groundwater samples will be collected using the purging and sampling method. This method can be accomplished via manual bailing with dedicated, disposable bailers, or pumping with a submersible pump (low-flow) to purge a calculated volume of water from the well. Purging allows the flow of water from the surrounding aquifer into the well.

Prior to monitoring well purging and sampling, the water level in each well is measured. An electronic probe graduated to 0.01 foot should be used for measurement. Where immiscible layers are present, an interface probe is used to determine depth to water and free product thickness. Depth to water measurements are recorded in the field log. When purging with bailers or pumps, the casing volume of water is calculated by subtracting the depth to water from the total depth of the well to obtain the height of the water column and multiplying this value by the cross-sectional area of the well. A minimum of three casing volumes of water is purged from the well prior to sample collection when using the purge-and-sample method. Wells that have slow recovery periods can be bailed dry then sampled within 24 hours. Groundwater samples collected for analysis of dissolved metals will be filtered in the field using a 0.45-micron pore size filter.

3.1 Monitoring Wells

The hydraulically upgradient and side-gradient groundwater monitoring wells (MW), MW-1S, MW-1D

& MW-5, as well as the downgradient and side-gradient groundwater monitoring wells, MW-2, MW-3, MH-4, and new monitoring wells MW-6 and MW-7, shall be measured for static water levels, as well as sampled and the groundwater analyzed for the parameters listed in Table 6 "Groundwater Monitoring

Well Sample Description". For locations of the below listed monitoring wells, see the attached Site

Map (Attachment Att1) and Table 5 “Monitoring Well Description”. The complete requirements of the groundwater monitoring sampling requirements can be found in the Groundwater Discharge

Permit GW1010022. Results from any monitoring that is conducted more frequently than required by the permit, using approved analytical methods, must be included in Discharge Monitoring Report calculations and reporting. Such increased frequency must be clearly indicated in reporting notes.

Sampling and Analysis Plan Page 6

Table 5 – Monitoring Well Description

Well ID Northing

[Y] Easting [X]

T/C

Elevation

[Z] (ft asml)

Ground

Elevation

(ft amsl)

Well

Depth

(ft)

Drilling Method

Well

Construction

Method

Well

Development

Method1*

Screened

Interval

Depth (ft)

Screened

Elevation (ft amsl)

MW-1S 661996.94 19733005.60 890.30 887.2 30

3.75-inch (I.D.)

Hollow-Stem Auger 2-inch PVC

Low-Flow or

Bailer 25-30 862.2 – 857.2

MW-1D 661999.99 19733001.60 890.20 887.1 60

3.75-inch (I.D.)

Hollow-Stem Auger 2-inch PVC

Low-Flow or Bailer

55-60 832.1 – 827.1

MW-2 662293.01 19732899.20 886.36 883.36 25

3.75-inch (I.D.)

Hollow-Stem Auger 2-inch PVC

Low-Flow or

Bailer 20-25 863.4 – 858.4

MW-3 662096.07 19732839.20 885.05 881.8 25

3.75-inch (I.D.)

Hollow-Stem Auger 2-inch PVC

Low-Flow or Bailer

20-25 861.8 – 856.8

MW-4 662248.20 19733115.40 890.25 887.4 30

3.75-inch (I.D.)

Hollow-Stem Auger 2-inch PVC

Low-Flow or

Bailer 25-30 862.4 - 857.4

MW-5 662188.30 19733241.72 891.45 888.6 35

3.75-inch (I.D.)

Hollow-Stem Auger 2-inch PVC

Low-Flow or Bailer

30-35 858.6 - 853.6

MW-6 662696.76 19732604.44 885.45 882.6 25

3.75-inch (I.D.)

Hollow-Stem Auger 2-inch PVC

Low-Flow or

Bailer 20-25 862.6 – 857.6

MW-7 662627.17 19732638.07 885.1 882.1 25

3.75-inch (I.D.)

Hollow-Stem Auger 2-inch PVC

Low-Flow or Bailer

20-25 862.1 – 857.1

1*Monitoring Well Sampling Methods

Low-flow sampling is the preferred method. The facility acknowledges EGLE’s concerns regarding bailer sampling, including the potential for elevated metal concentration, results due to increased turbidity, and accepts the results of any bailer sampling that takes place on site.

The facility further acknowledges that EGLE may take regulatory action based on these results, including additional monitoring requirements, permit modifications, or possible designation under Part 201. The sampler will identify when each sampling method is used, and sampling records will document the method used for each monitoring well and sampling event.

Sampling and Analysis Plan Page 7

Table 6 – Groundwater Monitoring Well Sample Description

Parameter Sample

Type

Monitoring

Frequency3

EPA Analytical

Method or SW-386

Filtered or

Unfiltered

Maximum

Hold Time

Sample

Preservation

Methods

Detection

Limits

(mg/L) Static Water

Elevation1 Reading Quarterly NA Unfiltered NA NA NA

Dissolved

Oxygen1 Reading Quarterly SM 4500-O Unfiltered 15 minutes NA NA

Specific

Conductance1 Reading Quarterly EPA 120.1 Unfiltered 24 hours Cooled to 4°C NA

Turbidity1 Reading Annually EPA 180.1 Unfiltered 48 hours Cooled to 4°C NA pH1 Grab Quarterly SM 4500-H/EPA 150.1 Unfiltered 15 minutes NA NA

Total

Inorganic

Nitrogen2

Calculation Quarterly NA Unfiltered NA NA NA

Ammonia

Nitrogen Grab Quarterly SM4500-NH3-G Unfiltered 28 days

H2SO4 preserved to pH<2, cooled to 4°C 0.05

Nitrate

Nitrogen Grab Quarterly EPA 353.2 Unfiltered 48 days Cooled to 4°C 0.1

Nitrite

Nitrogen Grab Quarterly EPA 353.2 Unfiltered 48 days Cooled to 4°C 0.05

Chloride Grab Quarterly SM4500-Cl-E Unfiltered 28 days Cooled to 4°C 2

Sodium Grab Quarterly EPA 200.7 Unfiltered 6 months 1:1 HNO3 preserved to pH<2, cooled to 4°C

Total

Phosphorus Grab Quarterly EPA 365.1 Unfiltered 28 days

H2SO4 preserved to pH<2, cooled to 4°C

0.05

Calcium Grab Annually EPA 200.7 Unfiltered 6 months 1:1 HNO3 preserved to pH<2, cooled to 4°C

Total Arsenic Grab Annually EPA 200.8 Unfiltered 6 months 1:1 HNO3 preserved to pH<2, cooled to 4°C 0.001

Total Iron Grab Annually EPA 200.7 Unfiltered 6 months 1:1 HNO3 preserved to pH<2, cooled to 4°C 0.05

Magnesium Grab Annually EPA 200.7 Unfiltered 6 months 1:1 HNO3 preserved to pH<2, cooled to 4°C

Total

Manganese Grab Annually EPA 200.8 Unfiltered 6 months

1:1 HNO3 preserved to pH<2, cooled to 4°C 0.001

Sulfate Grab Annually EPA 300.0 Unfiltered 28 days Cooled to 4°C 1

Potassium Grab Annually EPA 200.7 Unfiltered 6 months 1:1 HNO3 preserved to pH<2, cooled to 4°C 0.5

Bicarbonate Grab Annually SM 2320B Unfiltered 14 days Cooled to 4°C 2 1The following parameters shall be analyzed on-site, as required by the groundwater discharge permit: pH, Dissolved Oxygen, Specific Conductance, Static

Water Elevation, and Turbidity. These parameters will be analyzed using a pH meter, DO probe, nephelometer, and a conductivity meter or equivalent (such as Hach HQ2200 Portable Multi-Meter or HANNA HI9829 Multiparameter Meter) and a Solinst Model 101, 102, or Equivalent

2Total Inorganic Nitrogen (TIN) The daily maximum value for TIN shall be reported as the sum of the daily maximum values for ammonia nitrogen, nitrate nitrogen, and nitrite nitrogen.

3Quarterly and Annual Monitoring Quarterly samples taken during the months of February, May, August, and November. Annual samples taken during the month of August.

Sampling and Analysis Plan Page 8

4.0 QA/QC PROCEDURES

4.1 Preliminary Preparations and Equipment Lists

Sampling events are to be scheduled with the analyzing laboratory to make sure the lab can accept the samples. The laboratory is informed of the approximate number of samples to be collected and the tentative date and time of sample arrival.

Prior to the sampling trip, sampling equipment shall be cleaned and in good working order. EPA approved sample containers, preservatives, coolers, labels, and chain-of-custody forms can be obtained from the laboratory in advance. All monitoring instrumentation will be properly calibrated and maintained to ensure accuracy. A blank calibration log has been attached to aid in keeping track of the calibration of equipment (Attachment Att2). See Manufacturer details about how to calibrate multi-meters and other measurement devices. Equipment lists for each sample collection method have been provided below:

4.1.1 EQUIPMENT LIST (GRAB SAMPLE)

• Sample Bottles

• Chain of Custody Forms

• Personal Protective Equipment o Disposable Nitrile Gloves o Eye Protection

• Sample Dipper

• Preservation Supplies for Sample Bottles, unless SAP specifies bottles are pre-preserved by laboratory o Sulfuric Acid (H2SO4) o Nitric Acid (HNO3) o Ice or Cold Packs

• Container, e.g., Cooler, for filled sample bottles

• Waterproof Pen

• Site Maps, Sampling Forms, Work Orders, Health and Safety Plans, and Other Documents

Sampling and Analysis Plan Page 9

4.1.2 EQUIPMENT LIST (BAILER METHOD) [NOT PREFERRED]

• Depth-to-Water Measuring Device o Solinst Model 101, 102, or Equivalent

• Decontamination Supplies o Squirt Bottle with Alconox Solution o Bucket and Brush o Sufficient Supply of Distilled or GAC Filtered Water for Rinsing o Paper Towels

• Sample Bottles o 6 - 32 Sample Containers and Labels

• Preservation Supplies for Sample Bottles, unless SAP specifies bottles are pre-preserved by laboratory o Sulfuric Acid (H2SO4) o Nitric Acid (HNO3) o Ice or Cold Packs

• Container, e.g., Cooler, for filled sample bottles

• Chain of Custody Forms

• Field Notebook

• Personal Protective Equipment o Disposable Nitrile Gloves o Eye Protection

• Container for Purged Water

• Disposable Bailers. Use only new, disposable, certified-clean high-density polyethylene or polytetrafluoroethylene bailers or laboratory-cleaned stainless-steel bailers for sampling. Reusable PVC bailers can be used for purging only.

• String or Rope. Use a new retrieval line for each sampling point.

4.1.3 EQUIPMENT LIST (LOW-FLOW/PUMP METHOD) [PREFERRED]

• Depth-to-Water Measuring Device o Solinst Model 101, 102, or Equivalent

• Decontamination Supplies o Squirt Bottle with Alconox Solution o Bucket and Brush o Sufficient Supply of Distilled or GAC Filtered Water for Rinsing o Paper Towels

• Sample Bottles o 6 - 32 Sample Bottles/Containers and Labels

Sampling and Analysis Plan Page 10

• Preservation Supplies for Sample Bottles, unless SAP specifies bottles are pre-preserved by laboratory o Sulfuric Acid (H2SO4) o Nitric Acid (HNO3) o Ice or Cold Packs

• Container, e.g., Cooler, for filled sample bottles

• Chain of Custody Form

• Field Notebook

• Personal Protective Equipment o Disposable Nitrile Gloves o Eye Protection

• Container for Purged Water

• Sampling Pump: typically, a peristaltic, submersible, or bladder pump

• Tubing: The tubing is dedicated to each well.

• Power Source for Pump

• Flow (rate) Measurement Supplies

• Multi-Parameter Meter with flow-through-cell, including parameters for pH, oxidation reduction potential

(ORP), dissolved oxygen (DO), specific conductance, and temperature.

o HANNA HI9829 Multiparameter Meter or Equivalent

• Turbidity Meter

4.2 General Procedures

The appropriate protective gloves are worn during any sampling activity, and are changed between each sampling, or if non-disposable gloves are permitted, the gloves are decontaminated using a soap and water scrub, followed by a water rinse. Sampling instruments are decontaminated before use by washing with distilled water or GAC filtered water.

When collecting water samples for volatile organic analysis, an airtight container is used. Water should stand above the top of the container forming a convex meniscus. Carefully but quickly slip the cap onto the container and tighten. Once the cap is tightly in place, invert the container and gently tap against your hand to assure there are no bubbles inside. If bubbles are present, repeat the process.

Water samples to be analyzed for dissolved inorganic parameters are field-filtered and preserved as required. They are preserved by acidifying the samples with the appropriate acid (hydrochloric, nitric, or

Sampling and Analysis Plan Page 11 sulfuric) to lower sample pH to less than two (2), and cooling to 4oC Celsius. Water samples to be analyzed for volatile organics may be preserved in the field with hydrochloric acid. Sodium azide or mercuric chloride may also be used as preservation media. Samples collected for PNA analysis are preserved by cooling only. Other preservatives may be used on a parameter- or method-specific basis.

Following the collection of samples, sample containers are labeled. At a minimum, labels must include the sample location, date, project name, and collector’s initials. Other information that may be included is: the project number, project location, sample matrix, preservatives, time of sample collection, and type of analysis required.

Acid preservation is done in a well-ventilated area. The tip of the acid bottle should not be allowed to come into contact with the sample. Samples remain on ice or are refrigerated at approximately 4oC until they are analyzed.

Fill out the chain-of-custody form, including sample location, time of collection, number of containers, preservation techniques, analyses required, sampler’s name, project name and number, project contact’s name, address, and phone number, and other pertinent information.

4.3 Grab Sample Procedures

When taking a wastewater sample with a dipper, start by putting on the proper safety gear, including gloves and eye protection. Go to the exact sampling point listed in the groundwater discharge permit, since samples must be collected only from approved locations. Make sure the flow looks normal and representative. Use a clean, labeled sample bottle and a clean dipper long enough to safely reach the wastewater stream. You may rinse the dipper with the wastewater a couple of times before collecting the actual sample. Carefully lower the dipper into the flow, facing it upstream or toward the direction of flow so debris does not wash in. Avoid scraping the bottom or sides, since that can cause solids to enter the sample that does not represent the true discharge. Once the dipper is filled, pour the wastewater gently into the sample bottle without touching the inside of the bottle or the cap. Fill the bottle to the required level and close it tightly. Immediately place the bottle in a cooler with ice to meet temperature requirements. After sampling, record the date, time, location, and any observations about the flow or

Sampling and Analysis Plan Page 12 weather. Complete the chain-of-custody form and get the sample to the lab within the required holding time so that it meets requirements. If needed, rinse and store the dipper according to your facility’s cleaning procedure so it is ready for the next sampling event.

4.4 Groundwater Procedures

To avoid cross-contamination during well water sampling the following guidelines are followed. If water quality data is available for the site, the least contaminated well is sampled first, and progressing to the most contaminated well. If no water quality data are available the well suspected to be the cleanest is sampled first, followed by the wells suspected to be most contaminated.

The appropriate protective gloves (typically nitrile) are worn during sampling of monitoring wells and are changed between each well. Non-disposable gloves are not used. Water level probes and other

"down hole" instruments are decontaminated before use in a well, and between wells. The probe end and cord/tape are decontaminated with a soap solution by spraying, wiping with a soaked paper towel, or scrubbing with a brush. The instrument is then rinsed with distilled or GAC filtered water.

Between the collection of each sample, the bailer is scrubbed with soap, followed by a granular activated carbon filtered or distilled water rinse. The nylon rope used on the bailer should be replaced. When non-disposable pump tubing is used, a soap solution is pumped through the tubing followed by distilled or filtered rinse water. The outside of the pump and tubing are sprayed or scrubbed with a soap solution and rinsed. After completion of a round of sampling for a site the equipment is decontaminated as previously described.

Sampling and Analysis Plan Page 13

4.5 Field Duplicate Collection and Analysis

The purpose of duplicate samples is to characterize the variability of the data introduced through the collection and analysis. A field duplicate is defined as a second sample from the same location, collected in immediate succession, and using identical techniques. Duplicate samples are handled and analyzed in the same manner as the primary sample. Duplicates must be submitted “blind” to the laboratory.

Duplicate frequency must be at least once per quarter. Duplicate frequency for all samples locations should rotate as follows:

Time Period Effluent Quality (EQ-1 and EQ-2) Monitoring Wells

Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

Odd Years (2025, 2027, 2029, etc.)

EQ-1 EQ-1 EQ-2 EQ-1 MW-1S MW-3 MW-5 MW-7

Even Years (2026, 2028, 2030, etc.)

EQ-1 EQ-1 EQ-2 EQ-1 MW-1D MW-2 MW-4 MW-6

In limited cases the duplicate frequency may be reduced if historical sampling has been shown to be relatively consistent. Any exception must be approved by EGLE Groundwater Permits Unit staff.

Duplicates are to be collected as sequential samples. Sequential duplicates are collected one after the other, using the same method and equipment.

Duplicate samples must be evaluated for acceptability. One method for determining acceptability is to ensure the Relative Percent Difference (RPD) between the sample and duplicate is less than the maximum acceptable RPD. For field duplicate precision, an RPD of 20% is a standard rule of thumb for aqueous samples.

When the following equation is true, the duplicate is acceptable; when it is false, the sampler should evaluate, report, and address potential causes for the disagreement.

Sampling and Analysis Plan Page 14

𝑅𝑃𝐷 < 20

• Where, 𝑅𝑃𝐷 = |

(𝑋1 − 𝑋2)

(𝑋1 + 𝑋2)

| × 100 o Where,

▪ RPD is the Relative Percent Difference (%),

▪ X1 is the sample concentration, and

▪ X2 is the duplicate concentration.

o Or, if X1 = X2, RPD is 0.

4.6 Sampling Procedures for the Bailor Method [Not Preferred]

1. Calibrate instrumentation

2. Open wells

a. Open or uncap all wells where the water level will be measured to allow them to equilibrate to atmospheric pressure.

3. Decontaminate Equipment

a. Decontaminate equipment by washing equipment with a non-contaminating detergent

(such as Alconox) then rinsing with distilled or deionized water.

b. Review all equipment prior to a sampling event and decontaminate any equipment that may contact samples to ensure it was not contaminated from a previous sampling event or while in storage. Equipment that is dedicated to a single monitoring point, e.g., dedicated pump tubing, does not need to be decontaminated.

4. Measure water levels

a. Collect static water level readings to the nearest 0.01 ft. from all wells prior to pumping.

b. Decontaminate the water level meter between each well.

5. Purge the well

a. Do not allow the bailer or line to touch the ground, a dirty ground cloth, or any other potentially contaminated surface.

b. Do not allow the bailer to freely fall into the water column. The bailer should enter the water column as gently as possible. A knot in the line referencing the groundwater level is useful.

Sampling and Analysis Plan Page 15

c. Try not to submerge the bailer much below the water surface to prevent mixing and to ensure water removal from the top of the water column.

d. Withdraw the bailer gently from the water column and bring it to the surface quickly.

e. Keep the check valve on the bottom clear of sediment and in proper working order to minimize the amount of water that drips back into the well.

f. Purge an amount of water equal to three times the well volume. Record the well volume, height of the water column, well diameter, and amount purged on a field form.

6. Collect the water samples

a. If the same bailer is not used for purging and sampling, discard the first two sample bailer volumes as rinse water.

b. Do not allow the bailer or line to touch the ground, a dirty ground cloth, or any other potentially contaminated surface.

c. Transfer the sample from the bailer to the sample container quickly while minimizing turbulence and exposure to the atmosphere. When possible, use a bottom-emptying device.

d. Label each sample as collected. Samples requiring cooling will be placed into a cooler with ice or refrigerant for delivery to the laboratory.

7. Close the well

a. Ensure that all well caps and coverings are properly in place and locked so that substances cannot enter the aquifer through the monitoring well.

8. Dispose of purged water

a. Observation or monitoring well development or evacuation water is exempted from a Part

22 permit under Rule 2210(h), provided it complies with Rule 2204 of the Part 22 Rules, including that it is not injurious, does not cause runoff to adjacent property, is more than

100 feet inside a property boundary, is isolated from water supply wells, and does not create a facility under Part 201 (R 324.20101 to 324.20141).

b. Purged water is dealt with by disposal on the ground, returning it back into the well, or containerizing for disposal.

9. Repeat steps 5-8 for each monitoring well

10. Sample handling and analysis

a. Samples will be packed and transported to the laboratory on ice. Samples will be dispatched to the laboratory for analysis with a signed chain of custody records.

Sampling and Analysis Plan Page 16

4.7 Sampling Procedures for the Low-Flow/Pump Method [Preferred]

1. Calibrate instrumentation

2. Open wells

a. Open or uncap all wells where the water level will be measured to allow them to equilibrate to atmospheric pressure.

b. Ensure that no surface water enters or has entered the well. If the cap is flooded, bail out below casing before opening.

3. Decontaminate equipment

a. Decontaminate equipment by washing equipment with a non-contaminating detergent

(such as Alconox) then rinsing with distilled or deionized water.

b. Review all equipment prior to a sampling event and decontaminate any equipment that may contact samples to ensure it was not contaminated from a previous sampling event or while in storage. Equipment that is dedicated to a single monitoring point, e.g., dedicated pump tubing, does not need to be decontaminated.

4. Measure water levels

a. Collect static water level readings to the nearest 0.01 ft. from all wells prior to pumping.

5. Install the pump

a. Lower the pump or pump intake, tubing, and electrical lines slowly into the well (to minimize disturbance) to the midpoint of the zone to be sampled. When possible, keep the pump intake at least two feet above the bottom of the well to minimize mobilization of particulates present in the bottom of the well.

b. Do not allow tubing to contact the ground.

6. Measure the water level

a. Before starting the pump, measure the water level.

7. Purge the well

a. Start the pump at its lowest speed setting and slowly increase the speed until discharge occurs.

b. Connect the pump to the flow-through cell.

c. Check the water level. Adjust the pump speed until there is little or no water level drawdown (less than 0.3 feet). If the minimal drawdown that can be achieved exceeds 0.3 feet but remains stable, continue purging until indicator field parameters stabilize.

d. Monitor and record the water level and pumping rate every three to five minutes (or as appropriate) during purging. Record any pumping rate adjustments (both time and flow rate). Pumping rates should be between 0.1 – 0.5 L/min to ensure stabilization of indicator parameters. Adjustments are best made in the first fifteen minutes of pumping to help minimize purging time.

e. Do not allow the water level to fall to the intake level (if the static water level is above the well screen, avoid lowering the water level into the screen).

Sampling and Analysis Plan Page 17

f. Wells with low recharge rates may require the use of special pumps capable of attaining very low pumping rates (bladder, peristaltic), and/or the use of dedicated equipment.

g. If the recharge rate of the well is less than the minimum extraction rate capabilities of the pumps, the drawdown will not stabilize, and the well must be dewatered during purging.

When this occurs, the well should be sampled as soon as the water level has recovered sufficiently to collect the appropriate volume needed for all anticipated samples (the intake should not be moved during this recovery period). The sampling must be completed within 24 hours of beginning the initial drawdown. Samples may be collected even though the indicator field parameters have not stabilized.

8. Monitor the indicator field parameters

a. Using a multi-parameter flow-through cell, monitor the indicator field parameters during well purging. Stabilization is achieved when three consecutive readings, taken at three- to five-minute intervals, are within the following limits for at least four of the six parameters:

i. Temperature (3%),

ii. Dissolved Oxygen (D.O.) (10%),

iii. pH (±0.1 unit),

iv. Specific Conductance (3%),

v. Turbidity (10% or <10 NTU),

vi. Oxidation Reduction Potential (ORP) (±10 millivolts)

b. If stabilization criteria have been achieved and a Turbidity of less than 10 NTU cannot be achieved, both total and dissolved metals may be required to be collected in Step 9, below. Preference should be given to collecting a sample with Turbidity of less than 10

NTU, rather than collecting dissolved metals, when possible.

c. All measurements, except turbidity, must be obtained using a flow-through cell.

Transparent flow-through cells are preferred because they allow field personnel to watch for particulate build-up within the cell. This build-up may affect indicator field parameter values measured within the cell and may also cause an underestimation of turbidity values measured after the cell.

d. If the cell needs to be cleaned during purging operations, continue pumping and disconnect the cell for cleaning, then reconnect after cleaning and continue monitoring activities. The flow-through-cell must be designed in a way that prevents air bubble entrapment in the cell. When the pump is turned off or when cycling on/off (when using a bladder pump), water in the cell must not drain out. Monitoring probes must always be kept moist.

e. Record indicator field parameters readings on a field form.

f. Field observations of water clarity, color, and odor will also be recorded on a field form.

9. Collect the water samples

Sampling and Analysis Plan Page 18

a. Water samples for laboratory analyses must be collected before water has passed through the flow-through-cell (use a by-pass assembly or disconnect the cell to obtain a sample).

b. Do not change the flow rate while sampling.

c. Fill all sample containers by allowing the pump discharge to flow gently down the inside of the container with minimal turbulence. During purging and sampling, the tubing should remain filled with water to minimize possible changes in water chemistry upon contact with the atmosphere.

d. Label each sample as collected. Samples requiring cooling will be placed into a cooler with ice or refrigerant for delivery to the laboratory as soon as possible.

e. If dissolved metals must be collected, attach a 0.45 micrometer (µm) filter to the tubing and purge an additional 750 mL before collecting the sample to be analyzed for dissolved metals. The filter must not be used during the collection of other samples. A new filter must be used at each well.

10. Remove the pump and close the well

a. Ensure that all well caps and coverings are properly in place and locked so that substances cannot enter the aquifer through the monitoring well.

11. Dispose of purged water

a. Observation or monitoring well development or evacuation water is exempted from a Part

22 permit under Rule 2210(h), provided it complies with Rule 2204 of the Part 22 Rules, including that it is not injurious, does not cause runoff to adjacent property, is more than

100 feet inside a property boundary, is isolated from water supply wells, and does not create a facility under Part 201 (R 324.20101 to 324.20141).

b. Purged water is dealt with by disposal on the ground, returning it back into the well, or containerizing for disposal.

12. Decontaminate equipment

a. Decontaminate equipment by washing equipment with a non-contaminating detergent

(such as Alconox) then rinsing with distilled or deionized water.

b. Decontaminate equipment that may contact water samples in between every sample collection (typically: water level meter and gloves). Decontaminate any non-disposable equipment that does not contact samples after each field sampling event (typically: multi-parameter meter, turbidity meter, flow-through cell, and purge water container).

13. Repeat steps 5-12 for each monitoring well.

14. Sample handling and analysis

a. Samples will be packed and transported to the laboratory on ice. Samples will be dispatched to the laboratory for analysis with a signed chain of custody records

Sampling and Analysis Plan Page 19

5.0 LABORATORY AND FIELD ANALYSIS

5.1 Laboratory Analysis

As specified Rule 2220 of the "Part 22 Groundwater Quality Administrative Rules": Samples will be analyzed according to the publication "Guidelines Establishing Test Procedures for the Analysis for

Pollutants," 40 CFR Part 136.

Parameters to be analyzed for effluent and groundwater samples are presented in the permit tables previously mentioned (“Groundwater Monitoring and Limitations”). A State of Michigan and NELAC accredited, independent laboratory will be contracted to perform the required analyses.

5.2 Field Analysis and Calibration

As stated previously, the following parameters shall be analyzed on-site, as required by the groundwater discharge permit: pH, Dissolved Oxygen, Specific Conductance, Static Water Elevation, and Turbidity.

These parameters will be analyzed using a pH meter, DO probe, nephelometer, and a conductivity meter or equivalent (such as Hach HQ2200 Portable Multi-Meter or HANNA HI9829 Multiparameter Meter), as well as a Solinst Model 101, 102, or Equivalent.

See Manufacturer details about how to calibrate multi-meters and other measurement devices.

See Attachment Att2 for blank calibration log.

Sampling and Analysis Plan Page 20

6.0 DATA RECORDS AND REPORTING

The analytical results will be used to assess the wastewater and ground water quality and will be reported on standard Discharge Monitoring Report (DMR) forms. The DMR for Clear Lake State Park

Wastewater Treatment Facility will be submitted monthly (annually as necessary) via MiEnviro Portal and will be compared to permit limits.

Monitoring reports prepared for the EGLE will include flow data, water quality data, static water level data, and analytical results.

Proposed modifications, if necessary, to this sampling and analysis plan will be presented to the EGLE for approval.

The following information will be recorded for each measurement or sample taken:

• The exact place, date, and time of measurement or sampling.

• The person(s) who performed the measurement or sample collection.

• The dates the analyses were performed.

• The person(s) who performed the analyses.

• The analytical techniques or methods used.

• The date of and person responsible for equipment calibration.

• The results of all required analyses.

The permittee must keep a copy of the approved SAP, including any approved modifications, at the facility permanently and shall be provided to the Department of Environment, Great Lakes, and Energy upon request.

All records and information resulting from the monitoring activities in this sampling and analysis plan, including all records of analyses performed and calibration and maintenance of instrumentation and recordings from continuous monitoring instrumentation, will be retained for a minimum of three (3) years, or longer if requested by the Department of Environment, Great Lakes, and Energy.

Sampling and Analysis Plan Page 21

7.0 ATTACHMENTS

7.1 Att1 – Site Map

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CIVIL ENGINEERING | SURVEYING| ENVIRONMENTAL SERVICES | GEOTECHNICAL

CONSTRUCTION SERVICES | DRILLING | LANDSCAPE ARCHITECTURE

1280 Business Park Drive, Traverse City, Michigan 231-946-9191 800-968-1062 www.goslingczubak.com info@goslingczubak.com

SITE MAP

CLEAR LAKE STATE PARK

STATE OF MICHIGAN

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PART OF SECTION 27, T32N, R02E,

MONTMORENCY TOWNSHIP,

MONTMORENCY COUNTY, MICHIGAN

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MONITORING WELL

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WATER WELL

Sampling and Analysis Plan Page 22

7.2 Att2 – Calibration Log

Calibration Log

Site Location: ___________________________________________

# Date Initials pH Meter DO probe Nephelometer Conductivity Meter Used Calibrated Used Calibrated Used Calibrated Used Calibrated

Notes: