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 Allegheny Energy 

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 of information 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 of the Environmental 

Protection Agency. The Second Production includes both the enclosed CD and the attached narrative 

response. 

The documents on the enclosed CD are in . pdf format and organized in folders according to 

Question numbers. You will note that some of the documents appear to be duplicates of those on the 

previous CD. We have included these substitutions to improve the quality and legibility of the 

document where possible. 

AE is renewing and reaffirming a claim of Confidential 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 staff at (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, or those persons directly responsible for gathering the information, I 

certify that the information submitted is, to the best of my knowledge and belief, true, accurate and 

complete. I am aware that there are significant penalties for submitting false information, including 

the possibility of fine and imprisonment for knowing violations. 

Date:_f+--/ £L-+-~_r_o __ !) 

~ Vice President 

Environment, Health & Safety 

Allegheny Energy 
ATTACHMENT 

ALLEGHENY ENERGY RESPONSES TO EPA INFORMATION REQUEST 

<RECEIVED ON OR ABOUT JUNE 11, 2010) 

Question 1. Identify the name, address, telephone number, and location of the current 

legal owner(s) and operator(s) of Allegheny Energy Supply Company, LLC, Mitchell 

Power Station, as well as the name, address, telephone number, and location of its parent 

company. 

Response 1. Please see the CD submitted on July 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, 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 and that cross into or adjacent to the facility 

boundaries. 

Response 2. Please see the CD submitted on August 9, 2010 ("August CD"), 

folder Q02, which contains a 7 Y2 minute USGS map. A version of this map was 

previously submitted on the July CD; it has been revised to provide more 

complete information. As per the June 1 7, 2010 letter to Amanda Helwig, AE is 

not providing a separate delineation of surface water flows. 

i 

Three distinct boundaries are identified on the map-the Closed CCR Disposal 

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 text block below the map. 

Question 3. List and label each area located at the facility that the company uses or has 

used to collect, store, treat, or dispose of fly 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 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, basins, storm drains, pipes, and surfact impoundments. 

{80226494.2) 

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Response 3. Please see the August CD, folder Q03, which contains a TRI 

Process Map, identifying all the waste streams generated at Mitchell. A version 

of the TRI map was previously submitted on the July CD; the resubmitted 

document is of better quality with improved legibility. Waste management areas 

include CCR landfills, sedimentation ponds, and lagoons. 

Question 4. For each management area, identify its location and boundaries on the 

map provided in response to Question #2. 

Response 4. Please see the August CD, folder Q04. This map identifies 

locations and boundaries of the 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 of waste or wastewater currently stored, and the approximate 

proportion of free liquid and settled solids within the stored wastewater. Explain how the 

company calculated these 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 of the FGD disposal site landfill in the Annual 

Operation Reports therein. 

Please also see the August CD, folder Q05. The last full paragraph on page one 

of the closed CCR disposal site closure plan (excerpt) indicates that the site 

contains a total of approximately 730,000 cubic yards of coal 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 on August 21,2007. Pursuant to 40 C.F.R. § 

2.203(b ), AE renews and reaffirms this claim of CBI and has marked the 

confidential information as "CONFIDENTIAL" on the 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 of any entity with whom you have contracted for the 

disposal, sale, or reuse/recycling of coal combustion waste generated from your facility 

for the past five ( 5) years. Identify the type and amount of coal combustion waste that 

the company disposed of through such contracts each year for the past five (5) years . 

• 

{80226494.2) 

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Response 6. Please see the July CD, folder Q06, for names ofthe entities with 

whom AE has contracted for disposal, sale, or reuse of coal combustion wastes, as 

well as the types and amounts disposed through these contracts. 

Question 7. Identify all the waste streams generated at the facility in the past (5) years. 

Referring to the labels provided for each management area, provide a flow diagram 

showing each waste stream from 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 desulfurization 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. 

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 of these wastes in the 

annual operation and 26R chemical analysis reports provided (calendar years 

2005-2009). A Notification of Regulated Waste Activity, as well as types and 

amounts of coal combustion wastes generated are also provided. 

As per the June 17, 2010 letter to Amanda Helwig, AE is not separately producing 

daily generation volumes. These numbers can be calculated by dividing the total 

tons of each waste stream by the number of operating days in the report period as 

identified in each annual operation report provided. 

! 

Question 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 provided, include a 

description of the sampling procedures used. 

Response 8. Please see the July CD, folder Q08, for the 26R portions of the 

Annual Operations Reports provided for years 2005-2009. 

Question 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 Question #2. Provide any analytical data or monitoring results from the last 

five (5) years that demonstrate hazardous constituentsjn the wastewater discharges from 

the management areas to surface waters. Identify the management plans and treatment 

technologies that the company implements to control its wastewater discharges. Provide 

{80226494.2} 

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a copy of the National Pollutant Discharge Elimination System (NPDES) permit that 

authorizes these wastewater discharges. If the company has not obtained permit 

coverage, provide an explanation for this lack of coverage. Submit any discharge 

· monitoring reports in which the company reported wastewater violations from the last 

five (5) years. 

Response 9. As per the June 17, 2010 letter to Amanda Helwig, 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 on bypasses, spills, diversions; and 5) any analytical 

results available for the last five years. Mitchell's management plan to control 

wastewater discharges is to follow the requirements and technologies identified in 

EPA's Steam Electric Power Generation Effluent Limitations Guidelines (40 CFR 

Part 423). 

Please see the July CD, folder Q09, for documents related to Mitchell's NPDES 

permit application. Mitchell utilizes sedimentation ponds and elementary 

neutralization for wastewater treatment as identified in the NPDES permit and 

permit application documents provided on the July CD, folder Q09. To date, a 

final NPDES permit has not been issued since the permit application in 1996. 

Please see the August CD, folder Q02, for discharge points for the station lagoons 

and disposal site ponds on the 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 of all non-compliance, 

bypass or release reports submitted to the P ADEP and occurring in the last ten 

years. 

! 

Question 10. For all stormwater discharges associated with 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. 

In addition to the information provided about these discharges in response to Question 

#9, provide a copy of the facility's current Stormwater 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. 

{80226494.2) 

Response 10. As per the June 17,2010 letter to Amanda Helwig, 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 

issued requiring such a plan. • 

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Question 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 of groundwater monitoring wells, 

both active and inactive, on the map provided in response to Question #2. 

Response 11. Please see the July CD, folder Q 11, for a description of the 

groundwater monitoring system at each of the three management areas identified. 

The groundwater sampling protocol used for Mitchell and disposal site wells is 

provided at AE-M 06115. 

For purposes of clarity, the location of groundwater monitoring wells is provided 

on separate documents (identified on the USGS map in response 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 (1 0) years. 

Response 12. As per the June 17 letter to Amanda Helwig, AE has produced a 

list of all spills over the last ten 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 each management area, identity 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 Question #2. Provide any reports or documentation with 

sampling results and/or information about the volumes of these seepage flows from the 

last (5) years. 

{80226494.2} 

Response 13. As per the June 17,2010 letter to Amanda Helwig, AE has 

provided a summary of the 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 or permit requirements to 

monitor, sample or analyze these seeps, Mitch~ll has gathered analytical 

characterization data, which is provided. These two seeps are identified on the 

USGS map provided on the August CD, folder Q02. 

5 
There 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 on the USGS map provided on the August CD, folder 

Q02. 

As per the June 17 correspondence with Amanda Helwig, AE is providing some 

background information regarding the Monview Mine seep, which runs along 

Mitchell's property line. This mine flow does not originate on or regularly flow 

over the facility's property. The mine flow, however, occasionally backs up and 

enters Mitchell's property. Please see a narrative and photographs in the August 

CD, folder Q13, for information about the flow and its location. 

Question 14. Provide any hydrological studies conducted at the facility within the last 

five (5) years. 

Response 14. No hydrological studies have been conducted at the facility in the 

last five years. 

Question 15. Identify any known drinking water wells within a five mile radius of the 

facility's outer boundaries. Provide any monitoring or sampling results that demonstrate 

hazardous constituents present with these wells. 

Response 15. As per the June 17,2010 letter to Amanda Helwig, AE is providing 

information available from P ADEP's Groundwater Information System. Please 

see the July CD, folder Q15. Additionally, the 1997 Form 11R report and water 

survey maps, submitted in response to Question 13 ~hove, provide information 

about water supplies at that time. 

Question 16. Describe the cooling system at the facility. If applicable, submit the 

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. 

{B0226494.2} 

Response 16. As per the June 17, 2010 letter to Amanda Helwig, AE has 

provided a copy of the Section 316 (b) Impingement & Entrainment Study. 

Please see the July CD, folder Q16. The intake screen backwash system uses 

river water, for which no sampling other than flow is required by the NPDES 

permit. Please see the July CD, folder Q9, for average and maximum flow rates 

of outfall 003A in the DMRs provided. See thCi July CD, folder Q16, for water 

withdrawal data for years 2005 through 2009. 

6 
Question 17. Provide analyses performed on slope stability, inflow design floods, or 

dam breaks for any of the management areas within the last five (5) years. 

{B0226494.2} 

Response 17. Slope stability analyses have not been required or performed in the 

last five years. As per the June 17,2010 letter to Amanda Helwig, AE has 

provided the Mitchell Emergency Action Plan for the Sedimentation Pond. 

Please see the July CD, folder Q17. 

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