# REPORT

To



## M s. Eleanor Ku Codding, P.E. Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151

- 1102

For



# Clean Water Act 308 / Resource Conservation and Recovery Act Section 3007 Information Request

UGI Develo pment Company
390 Route 11
P.O. Box 224 Hunlock Creek, PA 18621

- 0224

Quad3 Project No.: 9477 .0 1

Prepared by:

72 Glenmaura National Boulevard Moosic, PA 18507
Phone: 570.342.5200
Fax: 570.342.6083

Date: July 2010

### Appendix Listing

Appendix Name Size Type Date Created

Appendix A USGW 7.5 minute Topographic Map 10255 KB Adobe Acrobat 7/7/2010

Appendix B PADEP Stormwater Letter 27 KB Adobe Acrobat 7/8/2010

Appendix C Locations and
Boundaries of Management
Ar eas 439 KB Adobe Acrobat 7/7/10

Appendix D PADEP 26R
Forms 3892 KB Adobe Acrobat 7/8/10

Appendix E Flow Diagrams 516 KB Adobe Acrobat 7/7/10

Appendix F Bottom Ash and Fly Ash and Waste Oil Analytical 2599 KB Adobe Acrobat 7/8/10

Appendix G DMRs 29077 KB Adobe Acrobat 7/8/10

Appendix H NPDES Permit 1206 KB Adobe Acrobat 7/7/10

Appendix I Emergency Response Plan 5552 KB Adobe Acrobat 7/8/10

Appendix J Groundwater Monitoring System 55018 KB Adobe Acrobat 7/8/10

Appendix K Spring Analyti cal 1612 KB Adobe Acrobat 7/8/10

Appendix L Drinking Water
Wells 68 KB Adobe Acrobat /
Microsoft Excel 7/8/10

* Appendix A, C and E are attached as a hard copy as well as on disc. All other attachments are on disc only.UGI Development

Hunlock Power Station
Page 1 of 33 1. Identify the name, address, telephone number

, and location of the current legal owner(s) and operator(s) of UGI Development Company, Hunlock Power Station, as well as the name, address, telephone number, and location of its parent company.

UGI Development Company owns and operates electricity generation station. UGI Development Company was incorporated in 1964 and is based in Hunlock Creek, Pennsylvania. UGI Development Company operates as a subsidiary of UGI Energy Services, Inc.

UGI Energy Services, Inc

. (Parent Company)

Mike Mara Director Project Development & Power Plant Operations One Meridian Blvd Suite 2C01 Wyomissing, PA 19610 (610) 743

- 7004 ph one (610) 374

- 4288 fax

UGI Development Company Hunlock Power Station
Mike Mara Director Project Developm ent & Power Plant Operations
390 Route 11 P.O. Box 224 Hunlock Creek, PA 18621

- 0224 (570) 830

- 1267 phone (570) 830

- 1191 fax

This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief Chemist.

2. On a topographic map, using the most recent USGS 7 1⁄2 minute or 15 minute topographic quadrangle map, show the location of the facility boundaries, as well as all surface water flows, including tributaries, streams, rivers, lakes, ponds and wetlands, within the facility boundaries an d that cross into or are adjacent to the facility boundaries.

Appendix A can be found o n the attached disc. A hard copy is also included. UGID has supplied the topographic map containing the most recent USGS 7 1⁄2 minute topographic quadrangle map
available. The map was generated by the United States department of the Interior, Geological Survey; Nanticoke Quadrangle; Pennsylvania; Luzerne County; 7 1⁄2 minute series. Topography by planetable surveys 1944 and revised in 1954. Revisions were made from aerial ph otographs taken in 1969 and 1976. The revisions have not been field checked.

UGID has identified the facility boundaries. The eastern boundary is the Susquehanna River which runs north to south and parallels the UGID facility boundary. The Abandon Canne l travelsUGI Development

Hunlock Power Station
Page 2 of 33 parallel to the Susquehanna River within the UGID Boundary. The cannel flows north to south. UGID has identified the two manmade “surface impoundments” within the UGID boundaries.

According to the National Wetland Mapping and Pennsylvania E

- Map ping system, there are no identified wetlands with the UGID boundaries.

This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief Chemist.

3. List and label each area located at the facility that the company uses or has us ed to collect, store, treat, or dispose of fly ash, bottom ash, slag, combined fly and bottom ash, flue gas desulfurization sludge, co

- disposed and co

- managed ash and coal refuse, solid waste, hazardous water, as well as wastewater, including process waste water, waste slurry or sludge, cooling water, storm water runoff, and sanitary wastewater, on an episodic or routine basis (“management areas”). For each of these areas, describe its function in managing waste or wastewater. Management areas include, but are not limited to, underground mines, underground injection wells, landfills, tanks, ponds, lagoons, surface impoundments , storm drains, pipes and surface impoundments.

In the development of management areas within the UGID facility and property, UGID h as identified a total of six (6) “management areas”. These areas include the following;

Management Area #1

– Fly Ash / Bottom Ash Generation Process

Management Area #1, described as the fly ash / bottom ash generation process, includes a description of it ems use in the g eneration process . Items such as the collection, treatment and disposal of fly ash and bottom ash, the use of surface impoundments and staging areas for both fly ash and bottom ash are discussed.

The H unlock Power Station was a coal burni ng power plant which produces ash as an end product. Process water is sent to surface impoundment s indentified as Ash Surface impoundments 003 and Ash Surface impoundment 005 where the ash is allowed to settle to the bottom. These impoundments were const antly dredged . The dredged ash is stockpiled and allowed to dry. The ash is then removed from the facility.

A t the Hunlock Power Station, the Number 6 Boiler is a coal fired unit rated at a normal 450,000 lbs per hour steam generating capacity. The num ber 6 boiler is a double arch fired furnace manufactured by Foster Wheeler Energy Corporation and was put into service in 1959. The steam is used to produce electricity in a 49.9 megawatt nameplate rating Westinghouse Steam Turbine Generator. Fly Ash and Bottom Ash are the bi

- products of the coal combustion.

The Hunlock Power Station is equipped with two (2) electrostatic precipitators. Rappers have been provided in the electrical section of the collectors as well as the dust hopper of the

electrical col lectors. The fly ash from the dust collectors, superheat soot hoppers and the stackUGI Development

Hunlock Power Station
Page 3 of 33 is transported pneumatically to a jet and then h ydraulically transported to the surface impoundments

.
The bottom ash, which is larger and heavier, falls from the boiler i nto the water filled hopper. From the hopper, the bottom ash is transported hydraulically to the surface impoundments

.

During its operation, the fly and bottom ash enter into the surface impoundments from separate lines, but in the same physical location. The mixing occurs within the surface impoundments

.

Lime is added to the ash slurry being hydraulically transported to the surface impoundments

, through a lime slurry tank. The pH is monitored to assure the pH of the liquid meets the permit ted pH rang e of 6.0 to 9.0.

Each surface impoundment receives the fly ash and bottom ash from process lines leaving the main building and discharge into the surface impoundment . The surface impoundments are designed to store a total of one hundred and forty

- four tho usand eight hundred (144,800 cubic yards) of ash. On average, 2.1 million gallon per day (mgd) of slurry water flow through the surface impoundments, with a maximum of 7.56 mgd.

UGID continuously and routinely dredges the surface impoundments and remove s ash. The ash is temporary stored in two main storage areas located next to the surface impoundments

. The current permit for the impoundments allows the ash to be stored no longer than one year. The material typically is removed within 90 days from the generation.

After the ash is dredged from the impoundment, the material is allowed to dewater before it is loaded onto dump trailers and hauled off site for re

- use. No additional materials or processes are used after the material is stockpiled.

The dis charges from the two surface impoundments are monitored and managed under the

NPDES Permit No. PA

- 0008664, APS ID No. 5551679 and Authorization ID No. 590637. The discharge points are identified as 003 and 005.

NOTE: As of May 22, 2010, this “management a rea” is no longer in service and is currently being closed under the Commonwealth of Pennsylvania, Department of Environmental Protection, Northeast Regional Office. This closure is due to a repowering of the plant.

This information was supplied by; Mr. J eff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief

Chemist.

Management Area #2

– Solid Waste Management

Solid waste is managed in three locations within the facility. Three solid waste dumpsters store
the waste until it is picked up by an outside vendor

. This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief

Chemist.UGI Development

Hunlock Power Station
Page 4 of 33 Management Area #3

– Cooling Water

Cooling Water Intake Structure

The Hunlock Power Station withdraws water for condenser cooling, service water, and as h sluicing from the Susquehanna River using a single Cooling Water Intake Structure (CWIS). The CWIS consists of a screen house at the river with two parallel intake bays that lead to the intake pumps. The condenser cooling water system is a once

- through type.

The screen house structure is located on the shoreline at the end of the intake channel at 41o12’03” N latitude and 76o04’09” W longitudes . The screen house has been designed to include two parallel flow paths from the river to the pumps. Each flo w path includes a trash rack, traveling water screen, chlorination equipment, and service water, ash sluice water, and circulating water pumps. Each traveling screen can be isolated with stop logs in the inlet and outlet sides of the screen. A sluice gat e installed between the two flow paths allows for operation of all pumps with only one traveling screen in operation.

The trash racks extend from the screen house floor at elevation 483.0 feet above mean sea level (MSL) to elevation 512.0 feet (MSL). Ther e are four sections, two per screen house opening, with each section designed for lift

- out by the gantry crane on top of the screen house structure. The trash racks are designed to prevent large floating debris from entering the traveling screens. The tr ash racks are manually cleaned when required.

The traveling screens are Link

- Belt Model No. 45

- A Vertical Traveling “Clean Water” intake screens with #14 (W&M) wire with 3/8” square openings to reduce entrainment of smaller sized materials and organisms i n the plant cooling system. The screen baskets are 6’

- 0” wide with
55’

- 0” shaft centers. A screen washing system is provided for cleaning the traveling screens. The screens are rotated approximately 30 minutes every shift. The screens are cleaned by a high

- pressure spray wash that discharges into a collection / debris trough that is 14” deep x 16” wide and approximately 22 feet long. The trough runs along both screens at the top of the CWIS. At the southern end of the trough, screen wash water passes through a screen approximately 15 1⁄2 “ wide x 32” long with 1⁄4” mesh to a pipe which discharges back into the inlet channel on the Susquehanna River.

The intake pumps include two circulating water pumps for main condenser cooling, three service water pumps, and two ash sluice water pumps. The pump capacities are based on the pump manufacturer’s data and do not account for head loss, pipe capacity and other “as

- built” conditions. A summary of the pumps, pump function, design capacity, and water source is

pr ovided in Table 1

- 1 below. The current total design intake flow is 42,400 gallons per minute (gpm), or 61.1 million gallons per day (MGD).

TABLE 1

- 1: HUNLOCK STATION INTAKE PUMP DESIGN CAPACITIES1

Pump Description Function Capacity of Each Pump (gpm) Wa ter Source
Unit No. 3A Circulating Pump Unit 3 Condenser Feed 17,0002 Unit 3 Intake Tunnels Unit No. 3A Circulating Pump Unit 3 Condenser Feed 17,0003 Unit 3 Intake Tunnels Ash Sluice Pump No. 1 Ash Sluice 1,100 Unit 3 Intake Tunnels Ash Sluice Pump No . 2 Ash Sluice 1,100 Unit 3 Intake Tunnels Service Water Pump No.4 Plant Service Water 2,100 Unit 3 Intake TunnelsUGI Development

Hunlock Power Station
Page 5 of 33 Service Water Pump No. 5 Plant Service Water 2,100 Unit 3 Intake Tunnels No. 3 Service Water Pump 4 Unit 3 Service Water 2,100 Unit 3 Intak e Tunnels Total Capacity CWIS 42,400

The discharge from cooling water is monitored and managed under the NPDES Permit No. PA

0008664, APS ID No. 5551679 and Authorization ID No. 590637. The discharge point is

identified as 001.

This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief

Chemist.

Management Area #4

– Storm Water

Concerning storm water management, there is only one surface drain at the UGID facility. The storm drain is located in the parking lot. In No vember 1993, UGID was granted an exemption concerning the storm water permit. Stormwater permit no. PAR702204 is referenced in the letter. A copy of the letter from the Commonwealth can be found o n the attached disc in Appendix B

.

This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief

Chemist.

Management Area #5

– S ewage Treatment Plant

The Sewage Treatment Plant (STP) is located on the northeast side of the UGID property. The
system is a Smith and Loveness Model V “ADDigest” waste water treatment plant. The system is capable of treating 5,000 gallons per day of raw sanitary wastewater with organic loading of 10 pounds of 5

- day BOD per day. The system includ es a 5,000 gallon aeration tank, a clarifier

tank with a sur face area of 33.2 square feet to provide an average surface loading rate of approximately 151 gallons per day per square foot. The clarifier tank is 6.0’ x 6.0’ x 7’10”. There is a sludge removal system and a scum removal system. The effluent is adjusted for pH with lime and is also chlorinated during the discharge. The chlorine contact tank has the capacity of 500 gallons. The effluent is discharged through a n 8 inch diameter line that leads to the Susquehanna River. The system ’s permitted discharge is m onitored and managed under the

NPDES Permit No. PA

- 0008664, APS ID No. 5551679 and Authorization ID No. 590637. The discharge point is identified as 004.

This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief

Chemist.

Management Area #6

– Coal Storage

While operating, UGID operated four coal staging areas or zones. These zones are described as Coal Zone I, Coal Zone II, Coal Zone III and Coal Zone IV.UGI Development

Hunlock Power Station
Page 6 of 33 During the operation, Coal Zones I & II were operated as one co al Zone. The zone has a joint storage capacity of approximate 26,000 ± cubic yards of coal. The surface area of Coal Zones I & II is 63,000± square feet. Coal Zone III has an estimated 112,546 ± square feet and is the largest of the four coal zones with a capacity of 47,000 cubic yards of coal. Coal Zone IV is located just west of Coal Zones I & II. Coal Zone IV has a coal capacity of 20,700 cubic yards. The square footage area of Coal Zone IV is 51,887±.

Surrounding the coals zones is a water collection trench that leads over to a swale pond. The pond collects rain water from all four coal zones. The water is then pumped over to the surface impoundment, entering surface impoundment 005.

NOTE: As of May 22, 2010, this “management area” is no longer in s ervice and is currently being closed under the Commonwealth of Pennsylvania, Department of Environmental Protection, Northeast Regional Office. This closure is due to a repowering of the plant.

This information was supplied by; Mr. Jeff Steeber

- Staff En gineer; Mr. Jim Dunbar

– Chief

Chemist.

4. For each management area, identify its location and boundaries on the map provided in response to request #2.

Appendix C can be found in the attached disc. A hard copy is also included. Appendix C
contains a site ma p identified as Drawing title; MANAGEMENT AREA and Drawing N umber C

1. The scale of the map is 1” = 100 linear feet. Each of the six “management areas” has been located along with each boundary.

This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief

Chemist.

5. For each management area, describe the area’s approximate storage capacity, the volume of waste or wastewater currently stored, and the approximate proportion of free liquid and settled solids within the stored w astewater. Explain how the company
calculated these volumes.

Management Area #1

– Fly Ash / Bottom Ash Generation Process

Surface Impoundments

Each surface impoundment receives fly ash and bottom ash from process lines leaving the main building and discha rge into the surface impoundment . The surface impoundments are designed to store a total of one hundred and forty

- four thousand eight hundred (144,800 cubic yards) of

ash. The surface impoundments are permitted to handle 2.1 mgd of slurry water, with a

m aximum of 7.56 mgd.UGI Development

Hunlock Power Station
Page 7 of 33 According to the Ash Settling basins and Ash Disposal Area Drawing dated June 12, 1963 , the surface impoundment identified as the East Basin (Ash Basin 003) on the drawing, was constructed to contain the capacity of 71,300 cubic yards. The surface impoundment identified

as the West Basin (Ash Basin 005) on the drawing, was constructed to contain 73,500 cubic yards. Both Surface impoundments together have the capacity to contain 144,800 cubic yards.

According to the drawing, the top o f both dikes were constructed to have an elevation of 535.0

feet. The bottom of each dike was has an elevation of 525.0 feet. Each surface impoundment was constructed with two 16 inch diameter discharge pipes that discharged into the cannel.

Based on the drawing, the surface impoundments were constructed utilizing existing materials placed prior to 1963. The existing materials appear to be a mixture of earth and bottom ash.

The sides of the surface impoundments received 5 feet of earth and were sloped i nward towards the bottom at a 1.5 to 1 slope.

Ash Storage Areas

UGID operates three separate ash storage areas at the facility. The Main Storage Area, located

north of surface impoundment ( Ash Surface impoundment 005 ) located contains 79,800± cubic yards of ash. This storage area has the capacity of holding 350,000± cubic yards of ash. The second area, Center Storage Area, contains 11,000± cubic yards of ash. This area is located

between surface impoundment 003 and s urface impoundment 005 and can conta in up to 25,000± cubic yards. The final storage area, Outer Storage Area, contains 7,400± cubic yards of ash. This area is located just east of s urface impoundment 003. This storage area has a capacity of 80,000± cubic yards.

Currently, the cubic yards staged within the storage areas are near 75 % capacity. The ash material is staged as part of the dewatering procedure. Concrete barriers and hay bales are placed along the perimeters of the storage areas to address runoff potential. The material is

stab le and stored above ground. The facility generates 40,000 to 60,000 tons of ash per year. This is based on burning 200,000± tons of coal with 25% to 30% ash content.

The quantities and area dimensions were generated from a recent survey conducted at th e facility. The licensed surveyor and professional engineer generated the sizes and quantities.

This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief

Chemist.

Management Area #2

– Solid Waste Management

The storage c apacity of Management Area #2, Solid Waste Management, UGID has three dumpsters, 1

- 20 cubic yard container and 2

- 10 cubic yard containers. These containers hold the solid waste (plant trash) for disposal off site at a licensed facility. There are no free l iquids or wastewater generated.

This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief

Chemist.UGI Development

Hunlock Power Station
Page 8 of 33 Management Area #3

– Cooling water

Concerning Management Area #3, there is no waste or wastewater stored; there are no free liquids or solids generated.

This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief

Chemist.

Management Area #4

– Stormwater Runoff

Concerning Management Area #4, there is no waste or wastewater stored; there are no f ree liquids or solids generated.

This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief

Chemist

.

Management Area #5

– S ewage Treatment Plant

The Sewage Treatment Plant (STP) i s capable of treating 5,000 gallons per d ay of raw sanitary

wastewater

. The system includes a 5,000 gallon aeration tank, a clarifier tank with a surface area of 33.2 square feet to provide an average surface loading rate of approximately 151 gallons per day per square foot. The clarifier tank i s 6.0’ x 6.0’ x 7’10”. There is a sludge removal system and a scum removal system. A total of 1500 gallons of sludge is removed on an annual base and is transported and disposed of at Wyoming Valley Sanitary Sewer Authority Sewage Treatment plant, Wilkes

- Barre, PA.

The effluent is adjusted for pH with lime and is also chlorinated during the discharge. The chlorine contact tank has the capacity of 500 gallons. The effluent is discharged through an 8 inch diameter line that leads to the Susquehanna River. Th e system permitted discharge is monitored and managed under the NPDES Permit No. PA

- 0008664, APS ID No. 5551679 and Authorization ID No. 590637. The discharge point is identified as 004. Under the permit, the sewage treatment system is permitted to discha rge on average 2.3 tgd (thousand gallons per day) with a maximum of 4.8 tgd.

This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief

Chemist.

Management Area #6

– Coal Storage

During the operation, Coal Zones I & II wer e operated as one coal Zone. The zone has a joint storage capacity of approximate 26,000 ± cubic yards of coal. The surface area of Coal Zones I & II is 63,000± square feet. Coal Zone III has an estimated 112,546 ± square feet and is the largest of the fou r coal zones with a capacity of 47,000 cubic yards of coal. Coal Zone IV is located just west of Coal Zones I & II. Coal Zone IV has a coal capacity of 20,700 cubic yards. The square footage area of Coal Zone IV is 51,887±.UGI Development

Hunlock Power Station
Page 9 of 33 Free liquid in the form of ra inwater is collected in a concrete trench that leads to the swale pond. The pond collects rain water from all four coal zones. The water is then pumped over to the surface impoundment, entering surface impoundment 005. The volume of the water depends
mai nly on the amount of rainfall and snow cover during the year.

According to the National Weather Service, Avoca, PA, the average precipitation for the 2009 season was 37.56 inches. Using the total square footage of the coal storage area, (237,433

square feet) and knowing the amount of precipitation, the maximum amount of water generated
from the coal surface impoundment storage area was 461,759± gallons . This number does not include a loss to evaporation or groundwater.

The volume of water generated from this collection pond is not recorded on a daily, monthly or yearly basis. The main reason for this is based on the water collected in the coal surface impoundments is discharge to the surface impoundment. The discharge from the surface impoundment accou nts for this water.

This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief

Chemist.

6. Provide the name of any entity with whom you have contracted for the disposal, sale, or reuse/recycling of coal combustion waste gene rated from your facility for the past five (5)

years.

The following is a list of the client s who UGID have contracted for the disposal, sale, or reuse/recycled fly and or bottom ash over the past five years;

2005

Jackson Township

862 Waller D ivide Road, Benton, Columbia County,
Benton, PA 17814 Carl D. Remly, Supervisor (570.925.2401)

707.91 ton Bottom Ash

Franklin Township

P.O. Box 865 Franklin Township, Lycoming County
Lairdsville, PA 17742 Bill Fones, Supervisor (570.584.3240)

1323.96 ton Bottom Ash

Jordan Township

7298 Route 42 HWYUGI Development

Hunlock Power Station
Page 10 of 33 Jordan Township, Columbia County Unityvile, PA 17774 Dale Stackhouse, Supervisor (570.458.5450)

913.29 ton Bottom Ash

Sugarloaf Township

90 School House Road Benton, Columbia County
Benton, PA 17814

Terri Adams, Secretary (570.925.6031)

322.60 ton Bottom Ash

UGI Development Company, Hunlock Power Station 390 Route 11, P.O. Box 224 Hunlock Township, Luzerne County Hunlock Creek, PA 18621 Jeff Steeber, Staff Engineer (570.830.1267)

57.89 ton Bottom Ash

Leh igh Coal & Navigation

101 North Center Street Pottsville, Schuylkill County
Pottsville, PA 17901 Ed Stott, Vice President Operations (570.628.0654) 14,798.64 ton Fly Ash

Emerald Anthracite

P.O. Box 27 Nanticoke, Luzerne County
Nanticoke, PA 18634

Ken Poll ock Jr., General Manager (570.735.4800) 41,842.24 ton Fly Ash

Gale Coal

1441 Oak Road Pottsville, Schuylkill County
Pottsville, PA 17901 Job Seunder, Owner (570.622.2524) 3,786.01 ton Fly AshUGI Development

Hunlock Power Station
Page 11 of 33 2006

Jackson Township
862 Waller Divide Road, Benton, Co lumbia County,
Benton, PA 17814 Carl D. Remly, Supervisor (570.925.2401)

825.77 ton Bottom Ash

Franklin Township

P.O. Box 865 Franklin Township, Lycoming County
Lairdsville, PA 17742 Bill Fones, Supervisor (570.584.3240)
2,120.34 ton Bottom Ash

Sugarl oaf Township

90 School House Road Benton, Columbia County
Benton, PA 17814 Terri Adams, Secretary (570.925.6031)

616.77 ton Bottom Ash

UGI Development Company, Hunlock Power Station 390 Route 11, P.O. Box 224 Hunlock Township, Luzerne County

Hunlock Creek , PA 18621 Jeff Steeber, Staff Engineer (570.830.1267)

50.00 ton Bottom Ash

Stollberg, Inc.

4113 Witmer Road Niagara Falls, NY 15305 Nikki Grunau, Staff Assistant (716.284.8753) 23.24 ton Fly AshUGI Development

Hunlock Power Station
Page 12 of 33 2007

Jordan Township

7298 Route 42 HWY

Jordan Townsh ip, Columbia County Unityvile, PA 17774 Dorothy Whitmoyer, Secretary (570.458.6880)

522.89 ton Bottom Ash

Sugarloaf Township

90 School House Road Benton, Columbia County
Benton, PA 17814 Terri Adams, Secretary (570.925.6031)

103.31 ton Bottom Ash

Susqueh anna Coal (Glen Lyon Operation)

P.O. Box 27 Newport Township, Luzerne County
Nanticoke, PA 18634 Dave Labenski, Engineer (570735.8400) 8,776.03 ton Fly Ash

2008

Jordan Township

7298 Route 42 HWY Jordan Township, Columbia County Unityvile, PA 17774

Doro thy Whitmoyer, Secretary (570.458.6880)
1,176.76 ton Bottom Ash

Sugarloaf Township

90 School House Road Benton, Columbia County
Benton, PA 17814 Terri Adams, Secretary (570.925.6031)
1,360.28 ton Bottom AshUGI Development

Hunlock Power Station
Page 13 of 33 UGI Development Company, Hunlock Power Station 390 Route 11, P.O. Box 224 Hunlock Township, Luzerne County Hunlock Creek, PA 18621 Jeff Steeber, Staff Engineer (570.830.1267)
2,873.01 ton Bottom Ash

Franklin Township

P.O. Box 865 Franklin Township, Lycoming County
Lairdsville, PA 17742 Bill Fones, Supervisor (570.584.3240)

240.17 ton Bottom Ash

Dorrance Township 7844 Blue Ridge Trail Mountaintop, Luzerne Mountaintop, PA 18707 Barbara Wasikowski, Secretary (570.868.6394)

7.21 ton Bottom Ash

Moreland Township 1220 Moreland Township Road

Moreland Tow nship, Lycoming County Muncy, PA 17756

710.77 ton Bottom Ash

Huntington Township 815 Municipal Road Shickshinny, Luzerne County Shickshinny, PA 18655 Bill Siegfred, Road Foreman (570.864.2303)

7.85 ton Bottom Ash

Fishing Creek Township

3188 State Route 4 87 Orange Township, Columbia County Orangeville, PA 17859 Randy Hack Chairman of Supervisors (570.683.5900)

24.47 ton Bottom AshUGI Development

Hunlock Power Station
Page 14 of 33 Susquehanna Coal (Glen Lyon Operation) P.O. Box 27 Newport Township, Luzerne County
Nanticoke, PA 18634 Dave Labenski, Enginee r (570735.8400) 91,325.99 ton Fly Ash

2009

Jordan Township

7298 Route 42 HWY Jordan Township, Columbia County Unityvile, PA 17774 Dorothy Whitmoyer, Secretary (570.458.6880)

661.42 ton Bottom Ash

Sugarloaf Township

90 School House Road Benton, Columbi a County
Benton, PA 17814 Terri Adams, Secretary (570.925.6031)

633.40 ton Bottom Ash

UGI Development Company, Hunlock Power Station 390 Route 11, P.O. Box 224 Hunlock Township, Luzerne County Hunlock Creek, PA 18621 Jeff Steeber, Staff Engineer (570.830 .1267)

22.77 ton Bottom Ash

Franklin Township

P.O. Box 865 Franklin Township, Lycoming County
Lairdsville, PA 17742 Bill Fones, Supervisor (570.584.3240)

572.91 ton Bottom Ash

Black Mountain Quarry

121 Gravel Road Hunlock Township, Luzerne County

Hunloc k Creek, PA 18621UGI Development

Hunlock Power Station
Page 15 of 33 Chris Coleman, President (570.256.3036)

130.91 ton Bottom Ash

Susquehanna Coal (Glen Lyon Operation)

P.O. Box 27 Newport Township, Luzerne County
Nanticoke, PA 18634 Dave Labenski, Engineer (570735.8400) 52,147.70 ton Fly Ash

Appendix D on the attached disc contains the Commonwealth of Pennsylvania, Department of Environmental Protection, Bureau of Waste Management, Form 26R, Chemical Analysis of Residual Waste Annual Report by the Generator.

This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief Chemist.

7. Identify all the waste streams generated at the facility in the past five (5) years. Referring to the labels provided for each management area ; provide a flow diagram showing each waste stream fr om the source of generation to its final disposition. In the flow diagram, include the following information: (a) descriptions of the waste streams (including, but not limited to, fly ash, bottom ash and slag, combined fly and bottom ash, flue gas desulfu rization sludge, co

- disposed and co

- managed ash and coal refuse) and their chemical characterizations; (b) the daily and annual volume of each waste stream flow; and (c) the final disposition of the waste streams, including materials recycled or
otherwise destined for beneficial use.

There are four waste streams generated from two different management areas; Management
Area #1

– Fly Ash / Bottom Ash Generation Process and Management Area #2

– Solid Waste Management . Management Area #1 generates Bottom Ash

, Fly Ash and waste oil . Waste oil is used in the process as a fuel source

. Management Are a #2 generates plant trash.

A Hard copy of the flow diagram of each waste stream can be found in Appendix E . The flow diagrams can also be found in Appendix E on the attached disc.

Below is the list of waste streams generated and removed from the facility; the quantities were obtained from Appendix D on the attached disc. As identified earlier, Appendix D contains the Commonwealth of Pennsylvania, Department of En vironmental Protection, Bureau of Waste Management, Form 26R, Chemical Analysis of Residual Waste Annual Report by the

Generator.UGI Development

Hunlock Power Station
Page 16 of 33 a) Description of waste streams

Fly Ash

- F ly A sh is produced from the burning of pulverized coal in a coal

- fired boiler is a fine

grained, powdery particulate material that is c ollected from the flue gas by means of electrostatic precipitators

.

Bottom Ash

- Bottom ash is a coarse, granular, incombustible byproduct that is collected from

the bottom of furnaces that burn coal for the generation of steam, the production of electric power, or both. Bottom ash is coarser than fly ash, with grain sizes spanning from fine sand to fine gravel.

Plant Trash

– Plant trash is unwanted or undesired waste material generated over the cour se of a day at the facility. Materials such as floor sweepings, office trash, papers, wood, etc.

Waste Oil

- Waste oil is defined as any petroleum

- based or synthetic oil that, through use or handling, has become unsuitable for its original purpose due to t he presence of impurities or loss of original properties.

b) Daily and Annual Volumes

Fly Ash and Bottom Ash

UGID generates an estimated total of 40,000 to 60,000 tons of Ash annually. In 2005 a total of 164,904 dry tons of coal was burned. At 25.08% Ash, a total of 41,358 tons of Ash was generated . Of the 41,358 tons of Ash, 37,222 (90%) was Fly Ash and 4,136 (10%) was Bottom

Ash. Based on UGID’s 322.2 operating days in 2009, an average of 115.5 tons of Fly Ash and 12.8 tons of Bottom Ash was generated p er day.

In 2006 a total of 158,830 dry tons of coal was burned. At 25.57% Ash, a total of 40,613 tons of

Ash was generated . Of the 40,613 tons of Ash, 36,552 (90%) was Fly Ash and 4,061 (10%)

was Bottom Ash. Based on UGID’s 346.5 operating days in 2006, an average of 105.5 tons of Fly Ash and 11.7 tons of Bottom Ash was generated per day.

In 2007 a total of 177,067 dry tons of coal was burned. At 27.10% Ash, a total of 47,985 tons of

Ash was generated . Of the 47,985 tons of Ash, 43,187 (90%) was Fly Ash and 4,799 (10%)

was Bottom Ash. Based on UGID’s 336.9 operating days in 2007, an average of 128.2 tons of Fly Ash and 14.2 tons of Bottom Ash was generated per day.UGI Development

Hunlock Power Station
Page 17 of 33 In 2008 a total of 186,586 dry tons of coal was burned. At 26.84% Ash, a total of 50, 080 tons of

Ash was generated . Of the 50,080 tons of Ash, 45,072 (90%) was Fly Ash and 5, 008 (10%)

was Bottom Ash. Based on UGID’s 333.6 operating days in 2008, an average of 135.1 tons of Fly Ash and 15.0 tons of Bottom Ash was generated per day.

In 200 9 a total of 181,480 dry tons of coal was burned. At 31.94% Ash, a total of 57,965 tons of

Ash was generated . Of the 57,965 tons of Ash, 52,168 (90%) was Fly Ash and 5,796 (10%)

was Bottom Ash. Based on UGID’s 339.5 operating days in 2009, an average of 153.7 tons of Fly Ash and 17.1 tons of Bottom Ash was generated per day.



### Plant Trash

2005

66.99 ton of Plant Trash, Residual Waste Code 710 in solid form and various colors and odors. A daily total generated is 0.18 tons.

2006

42.21 ton of Plant Tra sh, Residual Waste Code 710 in solid form and various colors and odors. A daily total generated is 0.11 tons.

2007

49.20 ton of Plant Trash, Residual Waste Code 710 in solid form and various colors and odors. A daily total generated is 0.13 tons.

2008

70.36 ton of Plant Trash, Residual Waste Code 710 in solid form and various colors and odors. A daily total generated is 0.19 tons.

2009

70.00 ton of Plant Trash, Residual Waste Code 710 in solid form and various colors and odors. A daily total generated is 0.19 tons.UGI Development

Hunlock Power Station
Page 18 of 33 

### Waste Oil

2005

3,907.0 Gal Waste Oil, Residual Waste Code 509 in liquid waste form (EPA Method 9095), brown/black (varies) in color with 1 phase of separation. A daily total generated is 10.7 gallons.

2006

3,520.0 Gal Waste Oil, Resid ual Waste Code 509 in liquid waste form (EPA Method 9095), brown/black (varies) in color with 1 phase of separation. A daily total generated is 9.64 gallons.

2007

No Waste Oil Reported

2008

880.0 Gal Waste Oil, Residual Waste Code 509 in liquid waste f orm (EPA Method 9095), brown/black (varies) in color with 1 phase of separation. A daily total generated is 2.41 gallons.

2009

3,630.0 Gal Waste Oil, Residual Waste Code 509 in liquid waste form (EPA Method 9095), brown/black (varies) in color with 1 pha se of separation. A daily total generated is 9.94 gallons.

c) Final disposition of the waste streams

As requested, the final disposition is listed below. Fly ash and bottom ash are listed together.

T he waste oil is burned on site with the coal

.

T he pla nt trash is transported to Keystone Sanitary Landfill, Dunmore PA. Chemical analysis of the waste streams can be found in Appendix D on the attached disc.

Appendix D on the attached disc contains the Commonwealth of Pennsylvania, Department of
Environment al Protection, Bureau of Waste Management, Form 26R, Chemical Analysis of Residual Waste Annual Report by the Generator.

Fly Ash and Bottom AshUGI Development

Hunlock Power Station
Page 19 of 33 2005

Jackson Township 862 Waller Divide Road, Benton, Columbia County,
Benton, PA 17814 Carl D. Remly, Su pervisor (570.925.2401)

707.91 ton Bottom Ash

Franklin Township

P.O. Box 865 Franklin Township, Lycoming County
Lairdsville, PA 17742 Bill Fones, Supervisor (570.584.3240)

1323.96 ton Bottom Ash

Jordan Township

7298 Route 42 HWY Jordan Township, Columbi a County Unityvile, PA 17774 Dale Stackhouse, Supervisor (570.458.5450)

913.29 ton Bottom Ash

Sugarloaf Township

90 School House Road Benton, Columbia County
Benton, PA 17814 Terri Adams, Secretary (570.925.6031)

322.60 ton Bottom Ash

UGI Development Com pany, Hunlock Power Station 390 Route 11, P.O. Box 224 Hunlock Township, Luzerne County Hunlock Creek, PA 18621 Jeff Steeber, Staff Engineer (570.830.1267)

57.89 ton Bottom Ash

Lehigh Coal & Navigation

101 North Center Street Pottsville, Schuylkill Count y Pottsville, PA 17901UGI Development

Hunlock Power Station
Page 20 of 33 Ed Stott, Vice President Operations (570.628.0654) 14,798.64 ton Fly Ash

Emerald Anthracite

P.O. Box 27 Nanticoke, Luzerne County
Nanticoke, PA 18634 Ken Pollock Jr., General Manager (570.735.4800) 41,842.24 ton Fly Ash

Gale Coal

1 441 Oak Road Pottsville, Schuylkill County
Pottsville, PA 17901 Job Seunder, Owner (570.622.2524) 3,786.01 ton Fly Ash

2006

Jackson Township
862 Waller Divide Road, Benton, Columbia County,
Benton, PA 17814 Carl D. Remly, Supervisor (570.925.2401)

8 25.77 ton Bottom Ash

Franklin Township

P.O. Box 865 Franklin Township, Lycoming County
Lairdsville, PA 17742 Bill Fones, Supervisor (570.584.3240)
2,120.34 ton Bottom Ash

Sugarloaf Township

90 School House Road Benton, Columbia County
Benton, PA 17814

T erri Adams, Secretary (570.925.6031)

616.77 ton Bottom Ash

UGI Development Company, Hunlock Power StationUGI Development

Hunlock Power Station
Page 21 of 33 390 Route 11, P.O. Box 224 Hunlock Township, Luzerne County Hunlock Creek, PA 18621 Jeff Steeber, Staff Engineer (570.830.1267)

50.00 ton Bottom Ash

Stollberg, Inc.

4113 Witmer Road Niagara Falls, NY 15305 Nikki Grunau, Staff Assistant (716.284.8753) 23.24 ton Fly Ash

2007

Jordan Township

7298 Route 42 HWY Jordan Township, Columbia County Unityvile, PA 17774 Dorothy Whitmoyer, Secretary (570.458. 6880)

522.89 ton Bottom Ash

Sugarloaf Township

90 School House Road Benton, Columbia County
Benton, PA 17814 Terri Adams, Secretary (570.925.6031)

103.31 ton Bottom Ash

Susquehanna Coal (Glen Lyon Operation)

P.O. Box 27 Newport Township, Luzerne County

N anticoke, PA 18634 Dave Labenski, Engineer (570735.8400) 8,776.03 ton Fly Ash

2008

Jordan Township

7298 Route 42 HWY Jordan Township, Columbia CountyUGI Development

Hunlock Power Station
Page 22 of 33 Unityvile, PA 17774 Dorothy Whitmoyer, Secretary (570.458.6880)
1,176.76 ton Bottom Ash

Sugarloaf Tow nship

90 School House Road Benton, Columbia County
Benton, PA 17814 Terri Adams, Secretary (570.925.6031)
1,360.28 ton Bottom Ash

UGI Development Company, Hunlock Power Station 390 Route 11, P.O. Box 224 Hunlock Township, Luzerne County Hunlock Creek, PA 18621 Jeff Steeber, Staff Engineer (570.830.1267)
2,873.01 ton Bottom Ash

Franklin Township

P.O. Box 865 Franklin Township, Lycoming County
Lairdsville, PA 17742 Bill Fones, Supervisor (570.584.3240)

240.17 ton Bottom Ash

Dorrance Township

7844 Blue Ri dge Trail Mountaintop, Luzerne Mountaintop, PA 18707 Barbara Wasikowski, Secretary (570.868.6394)

7.21 ton Bottom Ash

Moreland Township 1220 Moreland Township Road Moreland Township, Lycoming County Muncy, PA 17756

710.77 ton Bottom Ash

Huntington Townsh ip 815 Municipal Road Shickshinny, Luzerne County Shickshinny, PA 18655UGI Development

Hunlock Power Station
Page 23 of 33 Bill Siegfred, Road Foreman (570.864.2303)

7.85 ton Bottom Ash

Fishing Creek Township

3188 State Route 487 Orange Township, Columbia County Orangeville, PA 17859 Randy Hack

Chairman o f Supervisors (570.683.5900)

24.47 ton Bottom Ash

Susquehanna Coal (Glen Lyon Operation) P.O. Box 27 Newport Township, Luzerne County
Nanticoke, PA 18634 Dave Labenski, Engineer (570735.8400) 91,325.99 ton Fly Ash

2009

Jordan Township

7298 Route 42 HW Y Jordan Township, Columbia County Unityvile, PA 17774 Dorothy Whitmoyer, Secretary (570.458.6880)

661.42 ton Bottom Ash

Sugarloaf Township

90 School House Road Benton, Columbia County
Benton, PA 17814 Terri Adams, Secretary (570.925.6031)

633.40 ton Bott om Ash

UGI Development Company, Hunlock Power Station 390 Route 11, P.O. Box 224 Hunlock Township, Luzerne County Hunlock Creek, PA 18621 Jeff Steeber, Staff Engineer (570.830.1267)

22.77 ton Bottom AshUGI Development

Hunlock Power Station
Page 24 of 33 Franklin Township

P.O. Box 865 Franklin Township , Lycoming County
Lairdsville, PA 17742 Bill Fones, Supervisor (570.584.3240)

572.91 ton Bottom Ash

Black Mountain Quarry

121 Gravel Road Hunlock Township, Luzerne County Hunlock Creek, PA 18621 Chris Coleman, President (570.256.3036)

130.91 ton Bottom A sh

Susquehanna Coal (Glen Lyon Operation)

P.O. Box 27 Newport Township, Luzerne County
Nanticoke, PA 18634 Dave Labenski, Engineer (570735.8400) 52,147.70 ton Fly Ash

This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief Chemist.

8. Provide any testing and analyses relied on to determine the characterization of the waste streams, as well as any sampling results of the waste streams obtained by the facility for the past five (5) years. For any sampling results provid ed, include a description of the sampling procedures used.

On the attached disc

, Appendix F contains the testing and analysis to determine the
characterization of the waste streams for bottom ash

, fly ash and waste oil over the past five

years. There is n o analysis for plant trash obtained over the past 5 years.

From 2005 through 2007, grab samples on a monthly basis were used to characterize the fly ash and bottom ash. During 2008 and 2009, composite sampling was used. A composite sample of both bottom ash and fly ash was obtained on a weekly basis while the ash was
dewatered. At the end of a calendar month, the samples were composited and set to an independent laboratory for analysis. Concerning waste oil, a grab sample of the oil was obtained prior to burning the oil at the facility.UGI Development

Hunlock Power Station
Page 25 of 33 This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief Chemist.

9. Describe any wastewater discharges, including overflows, diversions, or other releases
that occur or have occurred within the last ten (10) years from the management areas to surface waters, including tributaries, streams, rivers, lakes, ponds, and wetlands. Identify the discharge points and runoff paths on the map provided in response to request #2. Provide any ana lytical data or monitoring results from the last five (5) years that demonstrate hazardous constituents in the wastewater discharges from the management areas to surface waters. Identify the management plans and treatment technologies that the company imp lements to control its wastewater discharges. Provide a copy of the National Pollutant Discharge Elimination System (“NP D ES”) permit that authorizes these wastewater discharges. If the company has not obtained permit coverage, proved an explanation for t his lack of coverage. Submit any discharge monitoring reports in which the company reported wastewater violations from the last five (5) years.

Provide any analytical data or monitoring results from the last five (5) years that demonstrate
hazardous const ituents in the wastewater discharges from the management areas to surface

waters . There are four discharge points, 001, 003, 004 and 005 associated with the NPDES
Permit No. PA

- 0008664, APS ID# 551679, Authorization ID No. 590637. The permit effective
dat e is 2/1/2006 and expires 1/31/2011.

In the event of a wastewater violation, the violation is identified in the Discharge Monitoring Permit (DMR’s) for that particular discharge point. The DMR’s can be found on the attached disc in Appendix G.

Discharge P oint 001

Discharge point is located at Latitude of 41°12’02” and Longitude 76°04’12” at River Index 35.5 and stream code 06685. The description of the discharge is once through cooling water. An average of 49.1 mgd and maximum of 79.2 mgd of water is dra wn into the steam station and used as non contact cooling water. The discharge point has an average of 49.1 mgd and maximum of 79.2 mgd discharge daily. The intake from the river is sampled for Oil and Grease, while the effluent is sampled for Oil and Grea se, Total Chlorine R esidual, pH and T emperature. UGID does not perform treatment to the intake or the effluent from this process. The Discharge Monitoring Reports (DMRs) , for the past five years, for this discharge point can be found in Appendix G on the attached disc

. Discharge Point 003

- 005

Discharge point s 003 and 005 are located at Latitude of 41°1 1’59 ” and Longitude 76°04’ 28 ” at River Index 35.5 and stream code 06685. The description of the discharge is from the boiler blow down, ash transport a nd coal prep plant. An average of 1.0 mgd and maximum of 1.6 mgd of water is drawn into the coal prep plant and used as non contact cooling water. The discharge point has an average of 1.0 mgd and maximum of 1.6 mgd discharge daily into the industrial

wast e treatment, which empties into the impoundments 003 and 005

. Additional processes part of the Industrial Waste Treatment include blow down from Boiler 006 which has an intake of 260 gallons per day (gpd) to a max of 360 gpd. Ash transport from the steam s tation uses 1.2 mgdUGI Development

Hunlock Power Station
Page 26 of 33 to a maximum of 2.4 mgd. The combustion turbine facility adds 0.01 mgd to the impoundments. Stormwater runoff adds 3.5 mgd based on 24 hour duration, 10 year rainfall. In the event of rain, rainwater runoff can contribute 50 tgd to the impoundments. The impoundments discharge point can discharge 2.21 mgd average and has a maximum of 7.56 mgd. The discharge point is sampled for Total Suspended Solids, Oil and Grease, Total Iron, total Manganese and pH.

UGID does perform treatment to t he effluent from this process. Before entering the impoundments, pH is applied. Lime is added to maintain the pH of the slurry water at 6. 0 to 9.0.

The Discharge Monitoring Reports (DMRs) , for the past five years, for th ese discharge point s can be foun d on the attached disc ; Appendix G

.
Discharge Point 00 4

Discharge point is located at Latitude of 41°12’06” and Longitude 76°04’04” at River Index 35.5 and stream code 06685. The description of the discharge is the sewage treatment facility. An average of 2.3 mgd and maximum of 4.8 mgd of water is used in the process

. T he effluent is sampled for flow, CBOD, Total Suspended Solids, Total Residual Chlorine, pH, Fecal Coliform.

UGID does perform treatment to the effluent from this process. The treatment invo lves the settling of solids in an aeration tank and clarifier. Then the waste water is treat ed the discharge
water with chlorination

. The Discharge Monitoring Reports (DMRs) , for the past five years, for this discharge point can be found on the attached di sc ; Appendix G

. UGID has provided a copy of the National Pollutant Discharge Elimination System (“N PD ES”) permit that authorizes these wastewater discharges can be found on the attached disc ; Appendix H

. This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief Chemist.

10. For all storm water discharges associated with the industrial activity from the facility, as defined at 40 C.F.R.§ 122.26(a)(14), identify the industrial activity (including the appropriate NAICS and SIC codes) that requires coverage under an NPDES permit.

NACIS Codes and SIC Codes

NACIS Code 2211 ; Electric Power Generation, Transmission and Distribution

This industry group comprises establishments primarily engaged in generating, transmitting, and/or distributing electric power. Establishments in this industry group may perform one or
more of the following activities: (1) operate generation facilities that produce electric energy; (2) operate transmission systems that convey the electricity from the g eneration facility to the distribution system; and (3) operate distribution systems that convey electric power received from the generation facility or the transmission system to the final consumer.

6 Digit NACIS Code: 221112

- Fossil Fuel Electric Power GenerationUGI Development

Hunlock Power Station
Page 27 of 33 This U.S. industry comprises establishments primarily engaged in operating fossil fuel powered electric power generation facilities. These facilities use fossil fuels, such as coal, oil, or gas, in
internal combustion or combustion turbine con ventional steam process to produce electric energy. The electric energy produced in these establishments are provided to electric power transmission systems or to electric power distribution systems.

The data published with NAICS code 221112 is comprised of these parts of the following SIC
industries:

4911 (pt)

- Electric services (electric power generation by fossil fuels) 4931 (pt)

- Electric and other services combined (electric power generation by fossil fuels) 4939 (pt)

- C ombination utilities nec (electric power generation by fossil fuels)

There are four discharge points, 001, 003, 004 and 005 associated with the NPDES Permit No.
PA

- 0008664, APS ID# 551679, Authorization ID No. 590637. The permit effective date is 2/1/2006 and expires 1/31/2011.

Discharge point 001 is located at Latitude of 41°12’02” and Longitude 76°04’12” at River Index 35.5 and stream code 06685. The description of the discharge is once through cooling water.

Discharge points 003 and 005 are located at Latitude of 41°11’59” and Longitude 76°04’28” at River Index 35.5 and stream code 06685. The description of the discharge is from the boiler blow down, ash transport and coal prep plant.

Discharge point 004 is located at Latitude of 41°12’06” and Longitud e 76°04’04” at River Index 35.5 and stream code 06685. The description of the discharge is the sewage treatment facility

. In addition to the information provided about these discharges in response to request #9, provide a copy of the facility’s current St ormwater Pollution Prevention Plan (SWPPP), as well as copies of its comprehensive site evaluations, inspection records, and monitoring results for the last five (5) years. If the company has not developed a SWPPP, provide an explanation for
this decision

. The Pennsylvania Department of Environmental Protection requires storm water discharges to prepare a Preparedness, Prevention and Contingency Plan (PPC Plan) in place of a SWPPP. A

copy o f UGID’s PPC plan can be found on the 

### attached disc ; Appendix I

This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief Chemist.

11. Describe any groundwater monitoring system in place at the facility. Provide any groundwater sampling and analysis plans, groundwater monitoring results that detected
releases of hazardous constituents, and corrective actions taken in response to groundwater contamination. Identify the location groundwater monitoring wells, both active and inactive, on the map provided in response to request #2UGI Development

Hunlock Power Station
Page 28 of 33 A ground water

- monitoring program was established in July 1997 to provide data on the groundwater in the immediate area of the surface impoundments. A total of four (4) monitoring wells, designated MW

- 4, MW

- 5, MW

- 6 and MW

- 7, were installed throughout the facility. These wells were installed as part of the monitoring requirements for the surface impoundments. Reviewing the installation information, the four (4) wells were completed to a depth of approximately 15 feet below the static water level. Each well was scree ned from approximately 15 feet below the static water level to 5 feet above the static water level. The depth of each

well is 40 to 55

- feet below ground surface (bgs). Each well was cased with Schedule 40 PVC

with 0.020

- inch factory slotted screen. No. 2 grade sand pack was placed in the annulus from the base of the screen to approximately two feet above the top of the screen. A bentonite seal to the ground surface was installed. Following the installation of the PVC casings, steel casing

was installe d to secure the PVC well. The locations of wells were chosen utilizing a number of sources namely soil atlases, topographic maps, the site layout, water well inventory data and historic Fly Ash case studies. The July 1997 report determined the upgradient

- monitoring well

to be MW

- 4. Monitoring well MW

- 4 is located at the northwest corner of the subject property. The monitoring well is located as the point at facility which is not likely to be affected by the two surface impoundments and most likely to pr ovide representative background water data.

According to the July 1997 report, three additional monitoring wells (MW

- 5, MW

- 6 and MW

- 7) were installed at three separate locations; all are hydraulically down gradient in the direction of decreasing static h ead from the surface impoundments. The wells were installed along the strip of land between the surface impoundments and the Susquehanna River. The strip of land makes up the southwest border of the property.

UGID contracted Quad Three Group, Inc. to co nduct a groundwater assessment at the Hunlock Power Station, Hunlock Creek, in August of 2008. The assessment included a total of thirty (30) soil boring were completed throughout the subject property, with each of them being developed into a 0.75” prelimi nary groundwater monitoring well. Two rounds of groundwater samples were collected from the 30 wells in September and October of 2008. From the data collected, a Groundwater Assessment report was submitted the Pennsylvania Department of Environmental
Pro tection (PADEP) in December of 2008.

On February 10, 2009, UGID received correspondence from the PADEP in response to the December 2008 report. Based on PADEP’s recommendation, seven (7) 4” diameter groundwater monitoring wells were installed throughout the subject property. These seven wells, plus the four previously existing wells were sampled once in April and once in May of
2009.

An additional 133 soil borings were performed throughout the subject property in an effort to
address the site

- wide su bsurface media composition as well as surface impoundment liner integrity.UGI Development

Hunlock Power Station
Page 29 of 33 Addendum #1 was submitted to PADEP in August of 2009. PADEP responded with a letter dated January 6, 2010, addressed to Mr. Jeffrey Steeber, UGID, requesting more explanation of
f indings as well as some additional work.

In March of 2010, an additional 4” groundwater monitoring well was installed at the southeast portion of the property. This well was sampled in March of 2010 and analytical data was included in the First Quarter ly Groundwater Report (January, February, March) of 2010.

A copy of the groundwater assessment and addendums including analytical for groundwater and soil samples, boring logs as well as the latest quarterly groundwater monitoring report, can be found on the attached disc ; Appendix J

This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief Chemist.

12. Describe any known spills or released from each management area within the last ten (10) years.

There have been no know n spills or releases from any management area within the past ten years, with the exception of Management Area #1

– Fly Ash / Bottom Ash Generation Process

. As outlined in question #11, UGID has conducted a groundwater investigation and assessment
into th e possibility slurry water contained in the surface impoundments may have migrated laterally and impacted groundwater. The investigation is ongoing with the PADEP Northeast Regional Office overseeing monthly groundwater sampling events.

This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief Chemist.

13. F or each management area, identify any seepage flows, as well as their origins, flow paths and destinations. Indicate the location of these flows on the map provided in response to request #2. Provide any reports or documentation with sampling results and/or information about the volumes of these seepage flows from the last five (5) years.

In 2007, a spring was sampled north of the impoundments. The spring is identifie d as Hunlock Spring

- North. No volume or flow rate was determined, however, the spring continues to flow. Analytical results can be found on the attached disc in Appendix K

.
In June 2009, an additional wet area was discovered just south of the impoundme nts. The spring was identified as Hunlock Spring

– South. The spring was monitored and sampled. Analytical results can be found on the attached disc in Appendix K

. It has been noted that since
the operation of the impoundments has stopped in May 2010, th e area has dried and is no longer available for sampling.

Both springs have been identified on the map provided in Appendix C

.UGI Development

Hunlock Power Station
Page 30 of 33 This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief Chemist.

14. Provide any hydrological studies conducted at the facility within the last five (5) years.

A groundwater

- monitoring program was established in July 1997 to provide data on the groundwater in the immediate area of the surface impoundments. A total of four (4) monitoring
wells, desi gnated MW

- 4, MW

- 5, MW

- 6 and MW

- 7, were installed throughout the facility. These wells were installed as part of the monitoring requirements for the surface impoundments. Reviewing the installation information, the four (4) wells were completed to a depth o f approximately 15 feet below the static water level. Each well was screened from approximately 15 feet below the static water level to 5 feet above the static water level. The depth of each

well is 40 to 55

- feet below ground surface (bgs). Each well w as cased with Schedule 40 PVC

with 0.020

- inch factory slotted screen. No. 2 grade sand pack was placed in the annulus from the base of the screen to approximately two feet above the top of the screen. A bentonite seal to the ground surface was installed. Following the installation of the PVC casings, steel casing was installed to secure the PVC well. The locations of wells were chosen utilizing a number of sources namely soil atlases, topographic maps, the site layout, water well inventory data and

hist oric Fly Ash case studies. The July 1997 report determined the upgradient

- monitoring well

to be MW

- 4. Monitoring well MW

- 4 is located at the northwest corner of the subject property. The monitoring well is located as the point at facility which is not l ikely to be affected by the two surface impoundments and most likely to provide representative background water data.

According to the July 1997 report, three additional monitoring wells (MW

- 5, MW

- 6 and MW

- 7) were installed at three separate locations; a ll are hydraulically down gradient in the direction of decreasing static head from the surface impoundments. The wells were installed along the strip of land between the surface impoundments and the Susquehanna River. The strip of land makes up the southw est border of the property.

UGID contracted Quad Three Group, Inc. to conduct a groundwater assessment at the Hunlock Power Station, Hunlock Creek, in August of 2008. The assessment included a total of thirty (30) soil boring were completed throughout th e subject property, with each of them being developed into a 0.75” preliminary groundwater monitoring well. Two rounds of groundwater samples were collected from the 30 wells in September and October of 2008. From the data collected, a Groundwater Assess ment report was submitted the Pennsylvania Department of Environmental Protection (PADEP) in December of 2008.

On February 10, 2009, UGID received correspondence from the PADEP in response to the December 2008 report. Based on PADEP’s recommendation, se ven (7) 4” diameter groundwater monitoring wells were installed throughout the subject property. These seven wells, plus the four previously existing wells were sampled once in April and once in May of
2009.UGI Development

Hunlock Power Station
Page 31 of 33 An additional 133 soil borings were performe d throughout the subject property in an effort to
address the site

- wide subsurface media composition as well as surface impoundment liner integrity.

Addendum #1 was submitted to PADEP in August of 2009. PADEP responded with a letter dated January 6, 2010 , addressed to Mr. Jeffrey Steeber, UGID, requesting more explanation of findings as well as some additional work.

In March of 2010, an additional 4” groundwater monitoring well was installed at the southeast portion of the property. This well was samp led in March of 2010 and analytical data was included in the First Quarterly Groundwater Report (January, February, March) of 2010.

A copy of the groundwater assessment and addendums including analytical for groundwater and soil samples, boring logs as we ll as the latest quarterly groundwater monitoring report, can
be found on the attached disc ; Appendix J

This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief Chemist.

15. Identify any known drinking water wells withi n a five (5) mile radius of the facility’s outer boundaries. Provide any monitoring or sampling results that demonstrate hazardous constituents present within these wells.

Appendix L , on the attached disc, contains a list of 2 46 wells identified in a 5 mi le radius surrounding the Hunlock Power Station facility.

Environmental Data Resources provide d a n EDR GeoCheck® Report. This report is a l ist of groundwater monitoring wells located within a 3 mile radius. It also includes analytical results for publi c wells if available. A five mile radius with analytical results was not available.

This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief Chemist.

16. Describe the cooling system at the facility. If applicable, submit t he source of the water withdrawn and the amount of water withdrawn in gallons per day. If applicable, describe the cooling water intake screen backwash system and identify the individual backwash flows, the volume, and the discharge points for each flow. Submit any sampling results
of the backwash.

Cooling Water Intake Structure

The Hunlock Power Station withdraws water for condenser cooling, service water, and ash sluicing from the Susquehanna River using a single Cooling Water Intake Structure (CWIS). The CWIS consists of a screen house at the river with two parallel intake bays that lead to the intake pumps. The condenser cooling water system is a once

- through type.UGI Development

Hunlock Power Station
Page 32 of 33 The screen house structure is located on the shoreline at the end of the intake channe l at 41o12’03” N latitude and 76 o 04’09” W longitudes . The screen house has been designed to include two parallel flow paths from the river to the pumps. Each flow path includes a trash rack, traveling water screen, chlorination equipment, and service w ater, ash sluice water, and circulating water pumps. Each traveling screen can be isolated with stop logs in the inlet and outlet sides of the screen. A sluice gate installed between the two flow paths allows for operation of all pumps with only one trav eling screen in operation.

The trash racks extend from the screen house floor at elevation 483.0 feet above mean sea level (MSL) to elevation 512.0 feet (MSL). There are four sections, two per screen house opening, with each section designed for lift

- out by the gantry crane on top of the screen house structure. The trash racks are designed to prevent large floating debris from entering the traveling screens. The trash racks are manually cleaned when required.

The traveling screens are Link

- Belt Model No . 45

- A Vertical Traveling “Clean Water” intake screens with #14 (W&M) wire with 3/8” square openings to reduce entrainment of smaller sized materials and organisms in the plant cooling system. The screen baskets are 6’

- 0” wide with
55’

- 0” shaft centers. A screen washing system is provided for cleaning the traveling screens. The screens are rotated approximately 30 minutes every shift. The screens are cleaned by a high

- pressure spray wash that discharges into a collection / debris trough that is 14” deep x 16” wide and approximately 22 feet long. The trough runs along both screens at the top of the CWIS. At the southern end of the trough, screen wash water passes through a screen approximately 15 1⁄2 “ wide x 32” long with 1⁄4” mesh to a pipe which discharg es back into the inlet channel on the Susquehanna River.

The intake pumps include two circulating water pumps for main condenser cooling, three service water pumps, and two ash sluice water pumps. The pump capacities are based on the pump manufacturer’s data and do not account for head loss, pipe capacity and other “as

- built” conditions. A summary of the pumps, pump function, design capacity, and water source is provided in Table 1

- 1 below. The current total design intake flow is 42,400 gallons per minu te (gpm), or 61.1 million gallons per day (MGD).

TABLE 1

- 1: HUNLOCK STATION INTAKE PUMP DESIGN CAPACITIES1

Pump Description Function Capacity of Each Pump (gpm) Water Source
Unit No. 3A Circulating Pump Unit 3 Condenser Feed 17,0002 Unit 3 Intake Tunne ls Unit No. 3A Circulating Pump Unit 3 Condenser Feed 17,0003 Unit 3 Intake Tunnels Ash Sluice Pump No. 1 Ash Sluice 1,100 Unit 3 Intake Tunnels Ash Sluice Pump No. 2 Ash Sluice 1,100 Unit 3 Intake Tunnels Service Water Pump No.4 Plant Service Water 2, 100 Unit 3 Intake Tunnels Service Water Pump No. 5 Plant Service Water 2,100 Unit 3 Intake Tunnels No. 3 Service Water Pump 4 Unit 3 Service Water 2,100 Unit 3 Intake Tunnels Total Capacity CWIS 42,400UGI Development

Hunlock Power Station
Page 33 of 33 The discharge from cooling water is monitored and managed under the NPDES Permit No. PA

0008664, APS ID No. 5551679 and Authorization ID No. 590637. The discharge point is

identified as 001.

This information was supplied by; Mr. Jeff Steeber

- Staff Engineer; Mr. Jim Dunbar

– Chief Chemist.

17. Provide analyses performed on the slop e stability (including liquefaction studies), inflow design floods, or dam breaks for any of the management areas within the last five (5)

years.

UGID has not performed any slope stability analysis, inflow design floods, dam breaks within the past 5 years in any of the management areas.

The surface impoundments walls are observed by the UGID operato rs on a regular basis. From this visual observation, there has not been any observed failure issues, these include, erosion, over topping, or berm sluffing. Any evidence of erosion has been immediately addressed and repaired.

The surface impoundments are within the NPDES permit areas. The hydraulic capacity and design of the stormwater is addressed in the stormwater management plan and this plan addresses the capacity of the ability of the hydraulic structures to pass the required rainfall
event. These plans have been reviewed and approved by the appropriate Commonwealth Agencies (County SCS and PA DEP).

Within M anagement A rea #1 , there are installed a series of monitoring points to determine groundwater elevation and perform groundwater sampling. Some o f the monitoring points are
located in berm area, areas up and down slope. While overall the points were installed for groundwater elevations, that shows that the Freatic water level through the berms is not
elevated and the area is well drained. The down gradient slopes of the berms are well vegetated and provide erosion protection. They are well maintained and offer quick evidence of seepage or sluffing.

The low levels coupled with long term observation indicate that the slopes are stable and the potent ial for failure will be mitigated by stability and regular observation.

James P Palumbo, PE

NOTE: As of May 22, 2010, this “management a rea” is no longer in service and is currently being closed under the Commonwealth of Pennsylvania, Department of Environmental Protection, Northeast Regional Office. This closure is due to a repowering of the plant.

L: \ Projects \ 94 \ 9477.01 UGI Fly Ash \ EPA Data Request \ EPA Requested Information.Docx

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