DAVID C. CANNON JR. Vice President, Environment, Health & Safety



### VIA FEDERAL EXPRESS Eleanor Ku Codding, P.E. Eastern Research Group, Inc. 14555 Avion Parkway Suite 200 Chantilly, VA 20151-1102



### Re: Allegheny Energy I 

### Mitchell Power Station 

# 4 AlleghenyEnergy
800 Cabin Hill Drive Greensburg, PA 15601 (724) 838-6709 FAX (724) 830-5142
August 9, 2010



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

Dear Ms. Codding: Enclosed please find the second production ofinformation and documents responsive to the undated Inforn1ation Request referenced above, which**Alleghen~** Energy ("AE") received on June 11, 2010 ("Second Production"). AE is providing this information in accordance with the June 17, 2010 correspondence between Donald C. Bluedom and Amanda Helwig ofthe Environmental Protection Agency. The Second Production includes both the enclosed CD and the attached narrative response. The documents on the enclosed CD are in

. pdfformat and organized in folders according to Question numbers. You will note that some ofthe documents appear to be duplicates ofthose on the previous CD. We have included these substitutions to improve the quality and legibility ofthe document where possible.
AE is renewing and reaffirming a claim ofConfidential Business Information ("CBI") for information originally submitted to EPA on August 21, 2007. Document AE-M0006, provided in response to Question 5 contains CBI, as further explained in the Attachment. Pursuant to 40 C.F.R. 

### § 2.203(b), this information is marked CONFIDENTIAL on the relevant pages.Eleanor Ku Codding, P.E. August 9, 2010 Page2

Please do not hesitate to contact Randy Cain ofmy staffat (724) 838-6004 or Donald Bluedom ofBabst, Calland, Clements, and Zomnir, P.C. at (412) 394-5450 ifyou have questions.

Very truly yours,

Vice President Environment, Health & Safety

Enclosures

- CD and Attachment

VERIFICATION AND CERTIFICATION

I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, orthose persons directly responsible for gathering the information, I certify that the information submitted is, to the best ofmy knowledge and belief, true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility offine and imprisonment for knowing violations.

Date:_f+--/

# £L-+-~_r_o__ !)

# ~ Vice President Environment, Health & Safety Allegheny EnergyATTACHMENT

ALLEGHENYENERGY RESPONSES TO EPAINFORMATION REQUEST <RECEIVED ON ORABOUT 

### JUNE 11, 2010)

Question 1. Identify the name, address, telephone number, and location ofthe current legal owner(s) and operator(s) ofAllegheny Energy Supply Company, LLC, Mitchell Power Station, as well as the name, address, telephone number, and location ofits parent company. Response 

### 1. 

### Please see the CD submitted onJuly 12,2010 ("July CD"), folder QOl.
Question 2. On a topographic map, using the most recent USGS 7 

### Y2 minute or 15 minute topographic quadrangle map, showthe location ofthe facility boundaries, as well as all surface water flows, including tributaries, streams, rivers, lakes, ponds, and wetlands, withinthe facility boundaries and that cross into or adjacent to the facility boundaries. Response 2. 

### Please see the CD submitted onAugust 9, 2010 ("August CD"), folder Q02, which contains a 7 

### Y2 minute USGS map. A version ofthis map was previously submitted onthe July CD; it 

### has been revised to provide more complete information. As perthe June 1 7, 2010 letter to AmandaHelwig, AE is notproviding a separate delineation ofsurface water flows.
i Three distinct boundaries are identified onthe map-the Closed CCRDisposal Site, the Active FGD Disposal Site, and the Mitchell Power Station ("Mitchell"). Additional maps/diagrams that are responsive to other Questions are identified in the textblockbelowthe map.
Question 3. List and label each area located at the facility that the company uses orhas used to collect, store, treat, ordispose offly ash, bottom ash, slag, combined fly and bottom ash, flue gas desul:furization sludge, co-disposed and co-managed ash and coal refuse, solid waste, hazardous waste, as well as wastewater, including process wastewater, waste slurry or sludge, cooling water, storm waterrunoff, and sanitary wastewater, on an episodic orroutine basis ("management areas"). For each ofthese areas, describe its function inmanaging waste orwastewater. Management areas include, but are not limited to, underground mines, underground injection wells, landfills, tanks, ponds, lagoons, basins, storm drains, pipes, and surfact impoundments.

{80226494.2) 1Response 3. Please see the August CD, folder Q03, which contains a TRI Process Map, identifying all the waste streams generated at Mitchell. A version ofthe TRI map was previously submitted onthe July CD; the resubmitted document is ofbetter quality with improved legibility. Waste management areas include CCR landfills, sedimentationponds, and lagoons. Question 4. For each management area, identify its location and boundaries onthe map provided inresponse to Question #2. Response 4. Please see the August CD, folder Q04. This map identifies locations and boundaries ofthe landfills, lagoons, and impoundments. See the August CD, folder Q03, for the TRI waste water process.
Question 5. For each management area, describe the area's approximate storage capacity, the volume ofwaste orwastewater currently stored, andthe approximate proportion offree liquid and settled solids withinthe stored wastewater. Explainhowthe company calculatedthese volumes. Response 5. Please see the July CD, folder Q05, for: 1) information on station lagoons; and 2) capacity and volumes for ponds at the FGD disposal site. See the July CD, folder Q07, for capacities ofthe FGD disposal site landfill inthe Annual Operation Reports therein. Please also see the August CD, folder Q05. The last full paragraph onpage one ofthe closed CCRdisposal site closure plan (excerpt) indicates that the site contains a total ofapproximately 730,000 cubic yards ofcoal combustion residuals.
i PLEASE NOTE: Document AE-M 00006-AE-M 00139 contains information that was claimed as Confidential Business Information ("CBI") when it was originally submitted to EPA onAugust 21,2007. Pursuant to 40 C.F.R. 

### § 2.203(b), AErenews and reaffirms this claim ofCBI and has marked the confidential information as "CONFIDENTIAL" onthe relevant pages, specifically, AE-M 00021, AE-M 00022, AE-M 00054, AE-M 00066, AE-M 00070, and AE-M 00074.

Question 6. Provide the name ofany entity with whom you have contracted for the disposal, sale, orreuse/recycling ofcoal combustion waste generated from your facility for the past five (5) years. Identify the type and amount ofcoal combustion waste that the company disposed ofthrough such contracts each year for the past five (5) years. 

### •

{80226494.2) 2Response 6. 

### Please see the July CD, folder Q06, for names ofthe entities with whom AE has contracted for disposal, sale, orreuse ofcoal combustion wastes, as well as the types and amounts disposed throughthese contracts. Question 7. Identify all the waste streams generated at the facility inthe past (5) years. Referring to the labels provided for each management area, provide a flow diagram showing each waste stream from the source ofgenerationto its final disposition. Inthe flow diagram, include the following information: (a) descriptions ofthe waste streams (including, butnot limited to, fly ash, bottom ash and slag, combined fly and bottom ash, flue gas desulfurization sludge, co-disposed and co-managed ash and coal refuse) and their chemical characterizations; 

### (b) the daily and annual volume ofeachwaste stream flow; and (c) the final disposition ofthe waste streams, including materials recycled or otherwise destined for beneficial use. Response 7. 

### Please see the August CD, folder Q07, which contains the the TRI Process Map for all wastes produced at the facility. 

### Please also see the July CD, folder Q07 for (a) waste descriptions and chemical characterization; 

### (b) volumes; and (c) final disposition ofthese wastes inthe annual operation and 26Rchemical analysis reports provided (calendar years 2005-2009). A Notification ofRegulated Waste Activity, as well as types and amounts ofcoal combustionwastes generated are also provided. Asperthe June 17, 2010 letterto Amanda Helwig, AE is not separately producing daily generation volumes. These numbers canbe calculated by dividing the total tons ofeachwaste stream bythe number ofoperating days inthe report period as identified ineach annual operation report provided.

! Question 8. Provide any testing and analyses relied onto determine the characterization ofthe waste streams, as well as any sampling results ofthe waste streams obtained bythe facility for the past five (5) years. For any sampling results provided, include a description ofthe samplingprocedures used. Response 8. 

### Please see the July CD, folder Q08, for the 26Rportions ofthe Annual Operations Reports provided for years 2005-2009.
Question 9. Describe any wastewater discharges, including overflows, diversions, or other releases, that occur orhave 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 runoffpaths onthe map provided in response to Question#2. Provide any analytical dataormonitoring results from the last five (5) years that demonstrate hazardous constituentsjnthe wastewater discharges from the management areas to surface waters. Identify the management plans andtreatment technologies that the company implements to control its wastewater discharges. Provide

{80226494.2} 3a copy ofthe National Pollutant Discharge Elimination System (NPDES) permitthat authorizes these wastewater discharges. Ifthe company has not obtained permit coverage, provide an explanation for this lack ofcoverage. Submit any discharge

·monitoring reports inwhich the companyreported wastewater violations from the last five (5) years. Response 9. As perthe June 17, 2010 letterto AmandaHelwig, AE is producing: 1) the NPDES permit and flow schematic; 2) analytical information from the NPDES permit application; 

### 3) DMRs for the last five years; 4) background information onbypasses, spills, diversions; and 

### 5) any analytical results available for the last five years. Mitchell's management planto control wastewater discharges is to follow the requirements and technologies identified in EPA's Steam Electric Power Generation Effluent Limitations Guidelines (40 CFR Part423). 

### Please see the July CD, folder Q09, for documents related to Mitchell's NPDES permit application. Mitchell utilizes sedimentationponds and elementary neutralizationfor wastewatertreatment as identified inthe NPDES permit and permit application documents provided onthe July CD, folder Q09. To date, a final NPDES permithas notbeen issued since the permitapplication in 1996. 

### Please see the August CD, folder Q02, for discharge points for the station lagoons and disposal site ponds onthe USGS map. 

### Please see the July CD, folder Q09, which contains monthly discharge monitoring reports (DMRs) for the last five years as well as copies ofall non-compliance, bypass orrelease reports submitted to the PADEP and occurring inthe lastten years.

! Question 10. For all stormwater discharges associated with industrial activity from the facility, as defined at40 C.F.R. §122.26(a)(14), identify the industrial activity (including the appropriate NAICS and SIC codes) thatrequires coverage under anNPDES permit. In additionto the informationprovided aboutthese discharges inresponse to Question #9, provide a copy ofthe facility's current Stormwater Pollution Prevention Plan ("SWPPP"), as well as copies ofits comprehensive site evaluations, inspectionrecords, and monitoring results for the last five (5) years. Ifthe company

### has not developed a SWPPP, provide an explanation for this decision.

{80226494.2)Response 10. As perthe June 17,2010 letterto AmandaHelwig, AE has provided the stormwater discharge application still pending with PADEP. 

### Please see the July CD, folder Q09. Additionally, the NAICS code for Mitchell is 221112- Fossil Fuel Electric Power Generation. The SIC is 4911- Electric Services. The station 

### has no SWPPP because the stormwater permit

### has not been issuedrequiring such a plan. •



### 4Question 11. Describe any groundwater monitoring system inplace atthe facility. Provide any groundwater sampling and analysis plans, groundwater monitoring results that detected releases ofhazardous constituents, and corrective actions taken in response ·to groundwater contamination. Identify the location ofgroundwater monitoring wells, both active and inactive, on the map provided in response to Question #2. Response 11. Please see the July CD, folder Q11, for a description ofthe groundwater monitoring system at each ofthe three management areas identified. The groundwater sampling protocol used for Mitchell and disposal site wells is provided atAE-M 06115. Forpurposes ofclarity, the location ofgroundwater monitoring wells is provided on separate documents (identified onthe USGS map inresponse to Question #2): Closed CCR disposal site: FGD disposal site: Mitchell station lagoons: AE-M06119 AE-M06120 AE-M 06121 Please see the July and August CDs, f6lder Q11, which contains quarterly groundwater monitoring results for the past five years from the lagoons, the closed disposal site, and the active FGD disposal site.
Question 12. Describe any known spills or releases to groundwater from each management area within the last ten (10) years. Response 12. As perthe June 17 letterto Amanda Helwig, AE has produced a list ofall spills overthe lastten years without attempting to determine whether they were ''to groundwater." Please see the July CQ, folder Q12, for a complete spill and release history spanning the past ten years.
Question 13. For eachmanagement area, identity any seepage flows, as well as their origins, flow paths, and destinations. Indicate the location ofthese flows onthe map provided inresponse to Question #2. Provide any reports or documentation with sampling results and/or information about the volumes ofthese seepage flows from the last (5) years.

{80226494.2}Response 13. As perthe June 17,2010 letterto AmandaHelwig, AE has provided a summary ofthe two existing seeps that are routed to the Sedimentation Pond for treatment. Please see the August CD, folder Q13, for documentation identifying seepage flows at the closed CCR disposal site and the FGD disposal site (Seep N and Seep S). While there are no regulatory orpermit requirements to monitor, sample or analyze these seeps,**Mitch~ll** has gathered analytical characterization data, which is provided. These two seeps are identified onthe USGS map provided onthe August CD, folder Q02.

5There is a spring adjacent to the permitted FGD disposal site. 

### Please see the August CD, folder Q13, for documents describing the spring and its location. The spring is also identified onthe USGS map provided onthe August CD, folder Q02. As perthe June 17 correspondence with AmandaHelwig, AE is providing some background information regarding the Monview Mine seep, which runs along Mitchell's property line. This mine flow does not originate onorregularly flow overthe facility's property. The mine flow, however, occasionally backs up and enters Mitchell's property. 

### Please see a narrative and photographs inthe August CD, folder Q13, for information about the flow and its location.
Question 14. Provide any hydrological studies conducted atthe facility withinthe last five (5) years. Response 14. No hydrological studies have been conducted atthe facility inthe last five years.
Question 15. Identify any known drinking water wells within a five mile radius ofthe facility's outerboundaries. Provide any monitoring or sampling results that demonstrate hazardous constituents present withthese wells. Response 15. As perthe June 17,2010 letter to AmandaHelwig, AE is providing information available from PADEP's Groundwater Information System. 

### Please see the July CD, folder Q15. Additionally, the 1997 Form 11Rreport and water survey maps, submitted inresponse to Question 13**~hove,** provide information about water supplies atthattime.
Question 16. Describe the cooling system atthe facility. Ifapplicable, submitthe source ofthe water withdrawn and the amount ofwater withdrawn ingallons per day. If applicable, describe the cooling water intake screenbackwash system and identify the individual backwash flows, the volume, and the discharge points for each flow. Submit any sampling results ofthe backwash.

{B0226494.2}Response 16. 

### As perthe June 17, 2010 letter to Amanda Helwig, AE 

### has provided a copy ofthe Section 316 

### (b) Impingement 

### & Entrainment Study. 

### Please see the July CD, folder Q16. The intake screen backwash system uses river water, for whichno sampling otherthan flow is required bythe NPDES permit. 

### Please see the July CD, folder Q9, for average and maximum flow rates ofoutfall 003Ainthe DMRsprovided. 

### See thCi July CD, folder Q16, for water withdrawal data for years 2005 through 2009.



### 6Question 

### 17. Provide analyses performed on slope stability, inflow design floods, or 

### dambreaks for any ofthe management areas withinthe last five (5) years.

{B0226494.2}Response 

### 17. Slope stability analyses have not been required orperformed 

### inthe last five years. As perthe June 

### 17,2010 letter to AmandaHelwig, AEhas providedthe Mitchell Emergency Action Plan for the Sedimentation Pond. 

### Please see the July CD, folder 

### Q17.



### •

7