## Genoa Off-site Project Frequently Asked Questions Updated May 2008



### Table of Contents

2 - Environmental Regulations and Project Need
3 - Alternatives and Recycling

5 - Landowner Communication and Public Information Process
6 - Facility Operation and Safety
8 - Coal Combustion Byproduct and Landfilled Materials
10 - Tax Impacts and Zoning Requirements-2-



### Environmental Regulations and Project Need

Why is Dairyland putting in a “scrubber?” Dairyland Power Cooperative is reducing air emissions (gases released from the combustion processes in the power plant) from our l argest existing Genoa and Alma coal power plants. These facilities reliably provide the m ajority of power for more than a half million people served by the Dairyland system of cooperat ives.

Current air emission control technologies, such as the sulfur dioxide s crubber that Dairyland is installing at Genoa, will improve the ai r quality in the communities where we serve and live. Additionally, these controls are environmentally-res ponsible solutions necessary for compliance with state and federal air quality regulations such as the Wisconsin Acid Rain Law and the U.S. Environmental Protection Agency (EPA) Clean Air Interstate Rule (CAIR).

If Dairyland already removes 80 percent of the sulfur w ith existing technology, why are scrubbers being added for only another 10 percent more re moval of sulfur? It is not correct to say that Dairyland is currentl y removing 80 percent of the sulfur with existing technology. Currently, there is no “techno logy” or equipment installed on any of Dairyland’s coal-fired boilers to remove sulfur fro m the coal or sulfur dioxide from the boiler exhaust gases. Since the early 1970s to the early 2000 s, the annual sulfur dioxide emissions from all of Dairyland’s coal-fired electric gene rating units declined by 80 percent. Dairyland decreased the annual sulfur dioxide emi ssions over this period by making strategic purchases of lower sulfur content fuels, not from any technology or equipment installed at Dairyland’s coal-fired electric genera ting units.

It is also not correct to suggest that the scrubber s will only remove another 10 percent of the sulfur. The scrubber currently under constructio n at the Genoa generating station is designed to reduce the sulfur dioxide in the flue g as by 90 to 95 percent as compared to untreated flue gas. Emission controls this effective wil l be required to meet emission limits of the new federal Clean Air Interstate Rule (CAIR). We believe the installation of a scrubber to remove sulfur dioxide is the environm entally responsible approach to managing our air emissions. By capturing the sulfu r dioxide before it is emitted to the air, we can recycle or dispose of this material in a way that is more protective of human health and the environment.-3-



### Alternatives

What alternatives to siting a new landfill in Verno n County were examined and why were they not chosen? Dairyland hired RMT, a Wisconsin-based consulting firm tha t specializes in waste management engineering, to seek and evaluate options for disposal of the byproduct from our Genoa facility. RMT reviewed several possibilities, including e xisting third party disposal facilities. Existing third party landfills, i ncluding the Vernon County landfill and the La Crosse County landfill were not designed o r permitted to accept the large volume of coal combustion byproducts that will be produced byDairyland’s scrubber system.

Utilizing Dairyland’s current off-site disposal faci lity near Alma was also considered. Trucking this material over 80 miles one way is not cost ef fective and not consistent with good environmental stewardship. In addition, landfill ca pacity at the Alma Off-site must be preserved for when the scrubber at Dairyland’s John P. Madgett plant comes online in 2012. None of the options evaluated presented a long-te rm viable solution. Dairyland will continue to evaluate other alternatives; however, sinc e siting and permitting a landfill takes several years, it is important that we also mo ve forward with that process. As alternative opportunities present themselves, they will be carefully considered.

Did you consider government land? Government lands have been specifically set aside for the public’s use and enjoyment because of their unique characteristics (many inclu de waterways, shore lands and wetlands). Wisconsin Department of Natural Resourc es (DNR) landfill siting criteria prohibits siting a landfill within 1,000 feet of the boundary of any public park or state natural area, unless the landfill is screened by natural ob jects, plantings, fences or other appropriate means so that it is not visible from th e highway, park or natural area. Because of the DNR siting criteria, Dairyland’s con sultant did not evaluate government lands as potential landfill sites.

Why can’t you recycle this material? Dairyland has been recycling over 80 percent of the fly ash from the Genoa plant and we intend to pursue opportunities to recycle as much as po ssible. We plan to continue to recycle as much bottom ash as possible and the majority of the fly ash captured in our precipitator. However, once the scrubber is install ed to significantly reduce sulfur dioxide emissions, we may only be able to recycle a fractio n of the ash we do today.

Regarding recycling, if you look at Dairyland’s historyof recycling over 80 percent of the fly ash—and nearly all of the bottom ash— from the coal plants, you can see that this is an option we have chosen in our operations. Nati onally, about 30 percent of the fly ash from power plants such as the Genoa plant is recycl ed, as compared to our 80 percent. With the changes in ash composition that will be br ought on by the environmental projects, we have searched for a viable recycling op tion to continue that commitment. Unfortunately, viable beneficial reuse options are n ot available to us right now. For instance, in Wisconsin and other neighboring states it is not permitted to land-apply this byproduct for agricultural use.-4-

We will continue to evaluate our options, including possible future recycling of the ash, as technologies develop and situations (such as reu se restrictions) may change. We also support financially the research and development in to these technologies, and it is our sincere hope that additional options will become viable

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If you find beneficial reuse options, would you still need the landfill? We are currently reusing/recycling more than 80 percent of our coal combustion byproducts. The remainder is disposed of in our AlmaOff-site. Our experience with beneficial reuse has indicated that rarely are we a ble to find reuse options for 100 percent of our byproduct. The beneficial reuse options are typically inconsistent and dependant on several factors including available markets and demand, env ironmental regulations, seasonal usage, and feasibility of techn ologies.

Given the uncertainties associated with beneficial re use of such a large volume of scrubber material, we must prepare for the long-term management and disposal of this material. We hope that over time beneficial reuse options for the scrubber material will be developed, but if not, we will need the disposal option available to ensure reliable power generation for our member cooperatives.

There is also the potential of mining material out of th e landfill for beneficial reuse in the future given a viable market demand. However, the landfill would still need to be constructed for storage until such a market is found

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Why can’t Dairyland return the ash to the coal mine for disposal on the rail cars that deliver the coal? Although, this is being done in some states, USEPA and various sta te regulatory agencies are re-evaluating this disposal process. There are con cerns about the potential environmental impacts of this process, in particular the potential for adverse impacts to groundwater. Many coal mines are in direct contact with the groundwater table. Disposal of coal combustion byproducts (CCBs) in unlined mines may allow direct contact between groundwater and the CCBs, and thus enable metals to leach from the CCBs into the groundwater. We believe there is the potential for future substantial legal risk should this occur. Our interest is in meeting the highest environmental standards possible to deal with our waste product. Finally, c oal is not delivered by rail at the Genoa plant, and there is no room for construction of a ra il facility. Therefore, at this time Dairyland has decided that it is not a feasible stra tegy to dispose of CCBs in mines.

Since sulfur and lime are by-products of the ash – why doe sn’t Dairyland process these such that they can be used by farmers on their lands? It is correct that scrubber material is largely made up of sulfur compounds and lime. In a few states, limited land application is occurring. The reuse of this material for agricultural uses is an area of extensive study. The US Dep artment of Agriculture and the Electric Power Research Institute are leading this effort in the US. DPC is a sponsor of this research. While there have been promising results from many of the early tests, the practice is currently not accepted by regulator y agencies in Wisconsin, Minnesota or Iowa. We remain hopeful that in the future agriculture application may become a significant reuse option. Additional information o n reuse options can be found on our web site ( http://www.dairynet.com/energy_resources/bene_reuse .php ).-5-



### Landowner Communication and Public Information

Why did you contact landowners before holding a public meeti ng? We believe it is important that potentially impacted landowners be contacted prior to any public forum regarding a project that could involve their personal property. Our policy is to make sure that landowners and public officials a re among the first to know, and that they have a chance to ask questions in person with Dairyland representatives early in the project process. A letter was sent to landowners o utside the testing area as the next step to give general background about the project and to inf orm them of Dairyland’s planned public meeting (held in October 2007). Our intent i s to work with everyone involved to make sure they have the information they need throughpersonal and public meetings.

Why didn’t Dairyland inform the public earlier? Dairyland began informing landowners and the publc veryearly in what will be a multiyear, state-regulated siting and permitting pro cess outlined by the DNR, which is the permitting agency. The DNR will have final say as to whether the proposed sites meet their stringent landfill siting criteria. DNR regulati ons for siting, design and operation of landfills have been created specifically to protect the environment. We believe in communicating about the need and impact of projects as soon as we reas onably can, and did so regarding the Genoa Off-site. However, it is important that we have the prop er information to communicate.

RMT, the consulting firm based in Madison, just performed the siting s tudy for Dairyland this year, submitting the results to us at the end of June 2007. After reviewing the results of the study internally, Dairyland’s Board of Directo rs approved moving forward with the project on August 17, 2007. We set up a schedule to m eet with cooperative members, Dairyland employees, landowners, public officials, media and scheduled a public meeting. All of this occurred in a very tight timel ine. Additionally, we delayed some of those communications by a week or so because of the serious flooding and storm damage that occurred in the area in late August 2007.

Are you condemning landowners’ property? We are not seeking to acquire property at this time . Dairyland’s first contact with landowners was to generally describe the project an d to discuss permission to access the land for testing purposes (test wells and soil bori ngs) and not to discuss acquisition of their property for the landfill itself. There is a possibili ty that testing would prove the sites to be unacceptable and eliminate them from consid eration.

The visits included the delivery of information as required by the State of Wisconsin whenever Dairyland or any other entity with the ability t o acquire land rights using eminent domain is in the process of acquiring land ri ghts. Since an agreement that authorizes testing and soil borings would involve land rights, D airyland was required to deliver a pamphlet published by the state of Wiscon sin Department of Commerce titled “The Rights of Landowners Under Wisconsin Eminent Dom ain Law” (pursuant to chapter 32.26 (6), Wisconsin Statutes). This is required for any property that Dairyland acquires, including easements for power lines, substati ons and other facilities.-6-



### Facility Operation and Safety

How much truck traffic would this operation require? It is certainly in the best interest of both area r esidents and Dairyland to minimize transportation impacts and costs associated with hauling material to a Genoa Off-site facility.

Based on the current estimate of 165,000 cubic yards of mater ial to be disposed of per year, we calculated that approximately 12 pneumatic t ankers (37 cubic yard capacity) per day, seven days a week, would carry the dry materia l from the Genoa power plant to the Genoa Off-site disposal site.

One of the main factors that could impact transportation is the type of coal that is burned. A number of factors could impact trucking, so we have been using a preliminary range of eight to 20 trucks per day, seven days per week. Si nce we do not have long-term coal contracts in place, our preliminary range was based ona slightly higher sulfur coal blend than we are using today.

Different coal types have differing levels of sulfur would a ffect the number of trucks. Plus, new opportunities for beneficial reuse and recycling of th is material could reduce the amount of trucking in the future.

Do I need to worry about this facility’s operation? (Lights, d ust, etc.) The disposal facility would be operated in compliance withall state and federal environmental regulations. This includes management of du st through operational controls such as road watering, crusting agents and compact ion. Dairyland is committed to minimizing impacts to land owners adjacent to Highway 56 and the proposed disposal facility through prudent, considerate management of the trucking schedule and hours of operation at the facility.

Aren’t you just moving the pollution from the air to the ground? The new air quality controls will improve the air qua lity by removing more sulfur dioxide, nitrogen oxides and mercury from the emissi ons from the G-3 plant. By removing more of these contaminants from the stack emission s we can control these materials. Rather than being released to the air, the removed materials along with the fly ash (coal combustion byproducts) will be either beneficially reu sed or disposed of in a landfill.

Both beneficial reuse and landfill disposal are con trolled and regulated to prevent release of these contaminants to the environment. The disp osal facility will be constructed with a state-of-the-art composite liner system to provide three layers of groundwater protection. Additionally, a leachate collection sys tem would be installed. All precipitation and water that comes into contact with the material would be collected and treated.

The site would also have a groundwater monitoring well network that would be sampled and monitored for the life of the facility, plus a minimum of 40 years of post-closure care. All necessary and appropriate controls will be followed so that beneficial reuse or landfill operations are safe to human health and the environment.-7-

Will my well or aquifer be contaminated by the propose d landfill? The landfill has several safeguards to protect grou ndwater quality, including a leachate collection system designed to collect water within the landfill liner that has contacted the material. As long as the water (leachate) is collec ted, it can’t pass through the liner system and affect groundwater quality. In addition, the lan dfill will be constructed with a state-of-the-art composite liner system to provide three layers of groundwater protection. This system would consist of two to four feet of clay or l ow permeability material, overlain with a geosynthetic clay liner and a geomembrane line r. Thus, nearby well water should not be adversely affected.

Would the landfill be designed to be able to contain material in the event of a severe flood, such as the one in August 2007? Sites 1 and 2 were specifically chosen as the sites having the best potential for landfill development specifically because of their geographic l ocation and topography. Sites 1 and 2 are both literally bowls on top of the ridge. They were chosen because precipitation and stormwater from the surrounding area would natu rally flow around and away from the sites, not through them.

In the state of Wisconsin, landfills are required to be designed to withstand a 25 year, six-hour storm event. The material within the landf ill is compacted and totally contained within the walls of the lined disposal facility and would not be able to move beyond the limits of the cell walls. Precipitation and stormwater a re routed around the facility, via ditches designed to control flow and minimize erosi on. Prior to discharge, stormwater passes through sedimentation basins that are design ed to improve water quality and reduce flow rates. Dairyland’s Alma Off-site disposal fa cility received unusually high amounts of rainfall this summer and early fall. Ex cessive erosion or slope failures at that facility did not occur.-8-



### Coal Combustion Byproduct and Landfilled Materials

Some say this is toxic waste. Others say it is caust ic. What exactly is this material and is it hazardous? After the installation of the scrubber, the G-3 unit will b e generating coal combustion byproducts that are a combination of scrubber mater ial and fly ash. The scrubber material will be primarily calcium sulfite with lesser amounts of calcium sulfate, calcium hydroxide (lime) and calcium carbonate. Fly ash is prima rily iron oxides, aluminum oxides, calcium oxide and silica. This byproduct also co ntains oxidized forms of other naturally occurring elements found in coal, such as arsenic, barium, cadmium, chromium, copper, lead, mercury, selenium and zinc.

The toxicity of a substance is its ability to cause harmful effects. All chemicals can cause harm. When only a very large amount of the substanc e can cause damage, the substance is considered to be relatively non-toxic. When a small amoun t can be harmful, the chemical is considered toxic.

Hazardous is not the same as toxic. The toxicity of a substanc e is the potential of that substance to cause harm, and is only one factor in determining whether a hazard exists. The hazard of a chemical is the practical likelihoo d that the chemical will cause harm. This material is not listed by the U.S. Environmental Protection Agency (USEPA) as a hazardous waste. A non-listed solid waste is determ ined to be hazardous by USEPA only if it is characterized as ignitable, corrosive, rea ctive or toxic.

Available information on scrubber material that has been tested indicates that it does not exhibit these characteristics. Therefore, it is a non-hazardous waste . In fact fly ash, bottom ash, slag, and flue gas emission control waste, gener ated primarily from the combustion of coal are specifically identified by U SEPA as non-hazardous wastes

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Dairyland’s testing of G-3 fly ash has consistently indicated that the fly ash is not hazardous . Recent studies indicate that scrubber material, minus the fly ash, has trace metal content less than fly ash and comparable to th at of soil. It is expected that the byproducts generated at G-3 in the future (after th e scrubber is installed) will have lower concentrations of trace metals than the current flyash and thus will also not have toxic characteristics . Dairyland has and will continue to test and characterize its byproducts.

Caustic is a term that is given to any material capa ble of burning, corroding, dissolving, or eating away by chemical action. USEPA defines corrosive (caustic) as having a pH of less than 2 or greater than 12.5. Our current information on G-3 fly ash and scrubber material from other facilities indicate that byproducts have a pH in the 12.2 to 12.3 range. (For comparison, barn lime has a pH of 12.5 and dis hwasher detergent has a pH of 11.) Since characteristics can vary, Dairyland will cond uct further pH testing of byproducts after the scrubber is installed to ensure this mate rial meets USEPA standards for nonhazardous wastes.-9-

Is the coal combustion byproduct radioactive? Radioactivity is present everywhere in North America. N aturally occurring radioactive material (NORM) is found in cities, in the mountains and everywhere. The levels of naturally occurring radioactivity will vary in different part s of the country. Some western states have higher levels of NORM than are found in east ern areas.

The United States Geological Survey (USGS) has publi shed a fact sheet on radioactivity in coal ash “Radioactive Elements in Coal and Fly Ash: Abundan ce, Forms, and Environmental Significance ” (PDF). Trace elements in coal include uranium, th orium and the numerous decay products, including radium an d radon. However, this USGS pamphlet concludes the “Radioactive elements in coal and fly ash should not be sources of alarm. The vast majority of coal and the majority of fly ashare not significantly enriched with radioactive elements, or in associated radio activity, compared to common soils or rocks.” Furthermore, “Limited measurements of dissolved uranium and radium in water leachates of fly ash and in natural water from some ashdisposal sites indicate that dissolved concentrations of these radioactive element s are below levels of human health concern.”

Your current Alma landfill allows disposal of asbestos. Will you dispose of asbestos in the Genoa Off-site? Dairyland has permitted our Alma Off-site landfills withthe DNR to allow for safe disposal of asbestos. This authorized disposal of asbestos has been conducted in full compliance with DNR regulations. The Genoa landfil l will be for coal combustion byproducts only. No asbestos will be placed in the landfill, nor will we seek any approval at a later date to do so.-10-



### Tax Impacts and Zoning Requirements

I’ve heard Dairyland is tax-exempt. Does this mean that 600 acres will be taken off the tax rolls? The property would still be taxed, but a portion of it would be in the form of a gross receipts tax. Dairyland, like all utilities in Wisc onsin, pays a 1.59 percent gross receipts tax on income in lieu of paying property taxes on our utili ty property. Counties and municipalities receive shared revenue payments from th e state for utility property located in their jurisdiction which is intended to roughly substit ute for property taxes. In the case of a landfill, the operating cells and facilities would be s ubject to state shared revenue payments to the Town of Harmony and Vernon County. Dairyland would continue to pay property taxes indefinitely on the portion of the projec t which is nonoperating, including all buffer areas.

What happens if the Town of Harmony denies the necessary zoning permits and approvals for the Genoa Off-site faci lity? Dairyland is committed to working with the public an d local officials to obtain all applicable zoning permits and approvals for the facility. The acquisition of zoning and other local approvals is governed by Wisconsin’s la ndfill siting law. The law provides a process for Dairyland to engage in negotiations with a local committee representing the Town and any other affected municipality to address economi c, social and land use impacts of the facility. If the parties are unable to reach an agreement, there is a procedure for submitting issues to binding arbitrati on. The process is overseen by the Wisconsin Waste Facility Siting Board, an impartial body o f the Wisconsin Department of Administration.

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