### Coversheet:

**Tab Tab Description**  Proven This table presents the damage cases designated by EPA as a "proven." A proven damage

case means those cases where: (1) there were documented exceedances of primary MCLs or other health-based standards measured in ground water at sufficient distance from the waste management unit to indicate the hazardous constituents have migrated to the extent that they could cause human health concerns, (2) a scientific study provides documented evidence of another type of damage to human health or the environment (e.g., ecological damage), and/or (3) there has been an administrative ruling or court decisions with an explicit finding of specific damage to human health or the environment. Potential This table presents the damage cases designated by EPA as "potential." A potential damage

case means those cases with: (1) documented exceedances of primary MCLs or other healthbased standards only directly beneath or in very close proximity to the waste source, and/or (2) documented exceedances of secondary MCLs or other health-based standards on site or off site. Rejected This tab contains a listing of damage cases designated by EPA as "rejected." References This tab contains a listing of the damage case references. Abbreviations This tab contains a listing of the acronyms identified in this workbook. This spreadsheet contains a full listing of the identified damage cases and EPA's designation (i.e., proven, potential, or rejected) as of September 18, 2012. Note that this file doesn't address the 19 damage cases identified in Environmental Integrity Project's December 2011 ReportRisky Business: Coal Ash Threatens America’s Groundwater Resources at 19 More Sites(DCN SE01985). These alleged damage cases have not been reviewed or confirmed by EPA.

### Facility

Georgia Power Plant Bowen

NIPSCO Yard 520 Gibson Generating Station Plant, Duke Energy (Cinergy) Constellation Energy's BBSS S&G Quarries PEPCO Morgantwon Faulkner offsite Lansing Board of Water & Light N. Lansing LF

JR Whiting generating Plant - CMS/Consumers Energy Detroit Edison Range Road Landfill
Colstrip PP, PPL Montana Belews Lake Duke energy Hyco Lake Swift Creek Structural Fill Site ReUse Techn Reid Gardner Generating Nevada Energy Don Frame Trucking Fly Ash LF Cayuga Coal Ash Disposal LF, AES Conesville FGD LF, AEP Martin's Creek PP, PPL Bruce Mansfield First Energy's Power Station Hatfield's Ferry Allegheny Energy Power Station

### Fern Valley LF Orion Power Holdings

Canadys Plant, SCE&G DOE Savannah River D-Area Urquhart Station SCE&G

TVA Kingston DOE Oak Ridge Y-12 OU 2 CCW LF Trans Ash Inc. Brandy Branch Reservoir SW Electric Power's Pirkey PP Southwestern Electric Power Welsh Reservoir Texas Utilities Electric Martin Lake VEPCO Chisman Creek Clinch River PP AEP-Appalachian Power (Carbo power plant) Glen Lyn Plant, AEP/Appalachian Power Dairyland Power E.J. Stoneman WEPCO Hwy 59 We Energies WEPCO Cedar Sauk Ash LF Columbia Energy Center Alliant Energy Oak Creek Power Plant – Wisconsin Energy/Wisconsin Electric Power (Caledonia)

John Amos PP, AEP/Appalachian Power

### Location **State**

Cartersville GA

Pines IN Princeton IN Gambrills MD Morgantown MD North Lansing MI

Erie MI East China Township, St. Clair County MI
Colstrip MT Stokes, Rockingham, Guilford, and Forsyth Counties NC Roxboro NC Rocky Mount NC Moapa NV Pomfret NY Lansing NY Conesville OH Mt Bethel Township PA Shippingport PA
Masontown PA

### Elrama PA

Walterboro SC Savannah River SC Beech Island SC

Harriman TN Oak ridge TN Camden TN Marshall TX Mount Pleasant TX Tatum, Rusk and Manola Counties TX Yorktown VA Cleveland VA Glen Lyn VA WI Waukesha WI Cedarburg WI Pardeeville WI Oak Creek WI

Winfield/St. Albans WV

### Key Reference(s) **WU Type**

CCW DC Ass #8 SI

CCW DC Ass #19 LF & BU Out of Control #6 2 LFs & 6 SIs, Cooling Reservoir CCR Proposed Rule, 6/2010 S&G pit CCW DC Ass #5 LFs (3) & SIs (6); artificial wetland CCW DC Ass #18 S&G pit

CCW DC Ass #76 [According to ICF (6/2010)- "Rejected"] SIs (6) EPA-HQ-RCRA-2009-0640-6815 Attachment 5; Becky Cuthbertson Email,11/9/2010. http://www.michigan.gov/documents/deq/DNRE-WHMDSW-DETROIT_EDISON_RANGE_ROAD_OpLicense_320053_7.pdf LF (Type III Low Hazard Industrial LF)

Out of Control #10 SIs (2), Cooling Lake, Evap. Ponds CCW DC Ass #11 Cooling Reservoir CCW DC Ass #7 Cooling Reservoir Out of Control #14 Structural Fill Out of Control #18 LF & SIs (8) CCW DC Ass #3 LF In Harm's Way #22 LF & SI (Leachate Pond) CCW DC Ass #63 LF CCR Proposed Rule, 6/2010 SI In Harm's Way #29 SI In Harm's Way #30 LF

### Out of Control #22 LF

CCW DC Ass #10 SIs (2) CCW DC Ass #12 SIs Out of Control #26 [According to ICF (6/2010)- "Rejected"] LF & SIs (2 Settling basins)

CCR Proposed Rule, 6/2010 SI CCW DC Ass #9 SI Out of Control #29 LF & SI CCW DC Ass #20 Cooling Reservoir CCW DC Ass #21 [According to ICF (6/2010)- "Rejected"] Cooling Reservoir CCW DC Ass #22 Cooling Reservoir CCW DC Ass #6 S&G pit In Harm's Way #36 SI In Harm's Way #37 [According to ICF (6/2010)- "Rejected"] SIs (2) CCW DC Ass #13 SI CCW DC Ass #14 S&G pit CCW DC Ass #16 S&G pit In Harm's Way #38 SIs (3) In Harm's Way #39; Collapse coverage based on EPA Region 5 and WDNR cleanup bulletins and media coverage. 3 LFs; Old Structural Fill

Out of Control #30 [According to ICF (6/2010)- "Rejected"] SIs (2); LF (1)

### Liner **Year Started**

No 1968

Partial 1983 No SIs: 1974 (2 SIs); 1991 (2 SIs); 1995; 1999. LFs: Late 1970s and (not implicated) 2009. Compressed Fly Ash 1995 No; failed 1970; 1979; 1989 No 1980

? 1952 1959 1974 No Early 1950s
3: Clay; 1: Partial Clay; 1: Hypalon; 1-HDPE 1975-76 (2); 1975; 1983 (2); 1992 No 1970s No 1964 No 1991 SIs: No LF: No 1976 No ? No (Phase I); Composite (Phase II) 1980s No 1976 No 1955 No 1977
No 1984

### 3' Cemented Ash 1989

No; Failed slurry wall 1974 1988 No 1950s No Late 1980s to mid-1990s

No 1950s No 1955 0.25" geosynthetic, partial and improperly installed 2002 No 1983 No(?) 1976 No 1974 No 1957 No 1964 ? 1963 1965 No 1950 No 1969 No 1969 No 1975 2 Inactive LFs: probably No; Active LF: Clay (Phase I); Composite w/leachate collect (Phase II). Structural Fill: No 1969, 1976; Fill - from 1950s to late 1960s

SIs: No; LF - ? 1971

### Year Damage Noted **Failure Mode**

2002; 2008 SW, Sediment

2000 GW, Soils SW: 2003; GW: 2007 SW/Ecol, GW 1999 GW, Fugitive Dust 1991 GW & SW; Ecolo (veget. Damage) 1993 GW

2008? SW/Ecol Sediments 1995 GW & SW
Early 1980s GW & SW 1974SW/Ecol 1974SW/Ecol 2004GW 1997 GW, Fugitive Dust 1989 GW Early 2000s GW & SW 1979/80 GW 2005 SW/Sediments, GW 1993 GW & SW
2001 GW & SW

### 1995 GW & SW

1982 2008 GW Mid 1970s SW/Ecol, Sediments 1989; 2007 GW, Soil

2008 GW, SW/Sediments, Soils 1989 SW/Ecol, GW 2005 GW & SW 1986SW/Ecol 1981 SW/Ecol 1978 SW/Ecol 1980 GW (SW) 1967 SW/Ecol Late 1970s SW/Ecol 1976 GW 1988 GW Early 1980s GW 1977 SW/Ecol 2002 or earlier; Fill's partial collapse: 10/31/11 GW; SW: Fill collapsed into Lake Michigan

1974SW/Ecol

### COCs/GW **COCs/SW** As, Cd, Cr, Pb, Hg, Ni, Cu

As, Mo, Fe, Mn, Sf As, Se, B, Fe, Mn As, Se, B, Fe, Mn As, Cd, Pb, Tl, Be, Al, Mn, Sf Fe, pH: (onsite: Al, Cl, Mn, Fe, Sf) Fe, pH Se, Li

As, Se, Br (Oligochates); Se, Br, Co, Ni, Cr (Fish); As, Co, Se, Ni (Sediment) B, Li, Mn, Sf, Fe B, Li, Mn, Sf, Fe
Se (?), B, Mo, Sf, TDS Sf Se/fish Se/fish As, Pb, Hg, Ba, Sf As, Se, V, Cr, Mo, B, Cl, Mg, Mn, Ti, Na, Nitr, Sf, TDS Pb, Mn (TDS, Sf) As, Cd, Se, Pb, B, Al, Mn, Sf, Fe, TDS As, Cd, Se Pb, As, Cd, Se, Cr, Fe, Sf, Ca, Mg, TDS Se, Cr, Fe (onsite) As, Pb, Ni, Ag, Zn, Al, Cu, Fe, Mn Cd, Ba, Pb, TSS, Al, Cl, Fe, Mn, Sf, TDS, pH As, Se, Tl, Cd, Pb, Cr, Sb, B, pH As, Tl, Cr, Mo, B, Al, Fe, Mn, Sf, TDS As, Tl, Cr, Mo, B, Al, Fe, Mn, Sf, TDS

### As, B, Cl, Sf, TDS As, Se, B, Cl, Sf, TDS

As, Ni, Se Se, Cd, Cr, hg, Al, Cu, Zn, Fe, Sf, pH, TSS As, Ni As, Ba, Cr, Co, Hg, Ni, Zn, Mn (Soil)

Se, Co, Mn As, Cd, Cr, Pb; As (Sediment); As, Co, Tl, FE (Soil) Al, Fe, Mn As, Al, Fe, Mn As, Cr, Pb, Hg, Ni, ag, Se/fish Se Se/fish Se, V, Sf ? Al, pH Cd, Se, Ni, TSS, pH, Thermal Cd, B, Fe, Mn, Sf (offsite); Cd, Cr, ba, Sf, Mn, Fe (onsite) As, Sf, B, Mn, Fe, Cl Se, B, Sf As, Cd, Cu, Cr, Ba, Al, Fe, Zn, Conduct Mo, B, Mn, As, Hg, Sf, F Cr, As, TCE, diesel

Se, As

### Reg Action

State/CO, requiring, among others, a fine and corrective action.

State/AOC None. Voluntary closing of cooling lake to fishing. Duke constructed (voluntarily) public water line to homes w/affected wells; no enforcement action by the State. Remedial actions in wildlife reserve - voluntary. State/CO, $1 million penalty; supply of alternative water. Out-of-court settlement of $54 million. State/CO; lawsuit in Federal court State/Remedial Action Plan

State: Final closure of the ponds was approved in 2005 and is still under way. RI/FS; slurry wall installation
In 2/2010, state proposed (but has not yet issued) a CO. Previous corrective action involved installing hundreds of monitoring wells, lining the more recently installed SIs with a rubber-like liners, and the introduction of a pump-and-treat system. State/CO, Fish advisory. State required operating changes to mitigate contamination. State/Fish advisory; stopped wet handling. The NC DEWQ is requiring long-term monitoring of the lake. State/NOV, CO (NOV in 2002 for failure to bring the fill area into compliance with an original plan for waste placement. A CO, in 2006, included a fine and a requirement to delineate the nature and extent of GW and surface water contamination. ) State/AOCs - 1997 and 2008: continue with environmental contaminant characterization activities and for the identification of corrective actions and/or clean-up measures for the soil and groundwater at the Site. State required remedial action, court order to cease receiving wastes State/NOV for excess disposal State/LF capped by a 2’ clay cap with 6” topsoil cover in 1988. The utility voluntarily monitored groundwater in the 1980s, no monitoring is presently required. Post-closure inspections continue. State/NOV, CO State/settlement Agreement; several NOV for exceedance of NPDES permits; remedial plan for collection of impacted spring water; NOI to sue by citizen groups (5/2012); a CO requiring impact studies, closure of the Little Blue Run SI at the end of 2016; and measures to control fugitive dust; 2 NOVs (fugitive dust). State/COA

### State/NOVs: Due to placement of waste outside of the permitted LF boundaries and failure to report

monitoring data, PADEP issued several noticed of violation in 2002. Water quality assessments have been required and will continue through 2017 in response to citizen and regulatory concerns. Actions and responses by the operator have satisfied regulators resulting in no further corrective regulatory actions. State/CO; slurry wall around old and new SIs; dewatering of old SI and contents' removal towards clean closure; extended monitoring well system. Mixing/compliance zone established. State/Federal: ROD, capping, and institutional control. None (Utility ia assessing the nature and extent of the contamination associated with the SIs. According to DHEC, no offsite monitoring has been required since results in wells near the river have not exceeded drinking water standards; these activities are considered to be “informal” actions, and no violations or orders have been issued to the owner. Informal state actions have been required, including listing site on GW Contamination Inventory (2008) for arsenic from ash basins. State/CO, Fish advisory; Federal/CERCLA, impact studies State/Federal: NPL, RI, Remedial Action. State/Order + penalty State/Fish advisory; Fish selenium study State/Fish advisory, fish selenium study. State required operating changes to mitigate contamination. State/Fish advisory, Fish Se study. State required operating changes to mitigate contamination. State/CO Federal/NPL None None (In its comment to the docket, Virginia DEQ characterizes this incident as a not recent case and a legacy issue which is not an accurate picture of VA's current regulatory program.) State/Admin Order for long-tem groundwater monitoring, closure. State: Remediation plan, capping, alternative water source to residents. State: monitoring and site capping State/CO WDNER has been investigating (as of 6/2010) to better establish local background and gradients to determine if CCRs are source of exceedances. Collapse cleanup was a multi-agency effort. Containment efforts included 1,500’ of linear boom on the Lake to contain the debris and fuel. An early January 2012 joint NOAA/Coast Guard report established that the ash that ended in the Lake would be so dispersed that it would not have any significant environmental impact. However, some long term, sub-lethal impacts on local fish and raptor populations cannot be totally ruled out. State/Compliance Schedule; NOV (2/2009) due to inadequate LF stormwater control resulting in deposition of fly ash in adjacent wetland.

### Current Status **NOV CO/Admin Order**  **Study**

Active/modified Y

Inactive Y Active Inactive/2007 Y Some active, some not Y Inactive/1997

Active Active (email, Cuthbertson to Livnat, 11/9/2010) Y

Some active, some not Proposed 2/2010, due in 2012 (?) Active/modified Y Active Inactive Y Y Some active, some not Y Y Inactive/1988 Inactive (Phase I), Active (Phase II) Y Inactive/1988 Active (Basin 4), Inactive (Basin 1) Y Y Active Y Y Y
Active Y

### Inactive/2007 Y

Some active, some not CO Some active, some not Active

Active Y Y Inactive Y Active Y Active Y Y Active Y Y Active Y Y Inactive/1974 Y Some Active, some not Inactive Inactive Y Inactive/1978 Inactive/1979 Inactive Y Some Active, some not Y, (Y)*

Active Y

### Assmt Monitoring **Remedial Action Law Suit**  **Fish Advisory/ Fishing Ban**  **Provide Drinking Water** Y

Y Y Y Y Y

Y

Y Y Y Y Y Y

Y Y

Y Y Y Y

### Y

Y Y

Y

Y Y Y Y Y

Y Y Y Y Y

### Other (Closure)

Fine

None Penalty; out of court settlement CERCLA cleanup

Closure

Lining of SIs. Citizens' suit - out of court settlement State req'd operating changes State req'd operating changes

Closure Settlement Agreement (1994); Closure required by the end of 2016.

### Closure

Closure None

CERCLA cleanup NPL Penalty State req'd operating changes State req'd operating changes NPL None ('pre-regulatory era') None Closure Closure Closure CERCLA cleanup

Compliance schedule

### Comments

2002: Sinkhole developed, releasing slurry to creek. 2008: extreme rain event collapsed a dry ash stockpile; storm water overwhelmed perimeter ditching in the ash pond and carried ash off of plant property to the north to a storm water conveyance and across several adjacent properties where it was deposited in a sediment pond. From the sediment pond, some of the ash reached Euharlee Creek. About 40 tons of ash was released with about 2 tons of ash reaching Euharlee Creek. About 14 offsite properties in the neighborhood were affected. CERCLA cleanup ensued. Soil: Hexavalent chromium, arsenic. A Superfund Alternative site. CCR is periodically scooped out of the SIs and sent to an on-site CCR landfill. IDEM considers the SIs to be temporary CCR storage areas and not subject to solid waste regulations. Curtis Pit is slated for closure; protracted history of violations. 2002: Sinkhole developed, releasing slurry to creek. 2008: extreme rain event collapsed a dry ash stockpile; storm water overwhelmed perimeter ditching in the ash pond and carried ash off of plant property to the north to a storm water conveyance and across several adjacent properties where it was deposited in a sediment pond. From the sediment pond, some of the ash reached Euharlee Creek. About 40 tons of ash was released with about two tons of ash reaching Euharlee Creek. About 14 offsite properties in the neighborhood were affected. CERCLA cleanup ensued. Leachate migrating off-site in groundwater and reaching two small ponds (no drinking water source affected).Note: this site is not included in the 6/15/11 statistic analysis, nor in the interim damage case summary tables that are based on ICF's 10/2010 study. For a location map and capacity data (as of the late 1990s), see: http://www.cis.stclaircounty.org/downloads/04_sw_plan_ii_1_through_30.pdf

Soil: Hexavalent chromium, arsenic.

EPA-HQ-RCRA-2009-0640-6815, Attach. #5 Curtis Pit is slated for closure; protracted history of violations. Dike failure

### Dike failure

EPA-HQ-RCRA-2009-0640-6815, Attach. # 5

Dike failure. Subsequent actions included closure of the SI and a wastewater treatment plant (1993) Leachate migrating off-site in GW and reaching 2 small ponds (no drinking water source affected). This site is not included in the 6/15/11 statistics. Elevated GW table Twelve offsite private wells found exceedances of molybdenum and boron. A consultant to WE determined that molybdenum in the private wells was not coming from CCR in the LFs. WE has been supplying (as of 8/2009) bottled water to several dozen residents in the area without assuming responsibility for the contamination. Collapse of old structural fill used for auxiliary facilities landed about 25,000 cubic yards in the Lake and in two coastal settlemt ponds.Note: This site, re-categorized from potential to proven damage case following the 10/2011 collapse, is included in the 6/15/11 statistical analysis as a potential, rather than a proven damage case. Dike failure; a compliance schedule to meet end-of-pipe chronic toxicity limitations on this discharge in the most recent NPDES permit (7/2007).**Facility**

TVA Widows Creek Fossil Fuel Plant TVA Colbert Fossil Fuel Plant Flint Creek Power Plant, SWEPCO (American Electric Power) Independence Steam Station – Entrgy/AP&L Arizona Public Service Co. Cholla Steam electric Generating Station Power Montville Generating Station - NRG Energy, Indian River Power Plant – NRG Energy, Burton Island Florida Power & Light Lansing Smith Plant CD McIntosh Jr. Power Plant – City of Lakeland Curtis Stanton Energy Center, Orlando Utility Commission Seminole Generating Station – Seminole Electric Cooperative Big Bend Station – Tampa Electric Co. Muscatine Co. LF George Neal Station North Landfill - MidAmerican Energy George Neal Station South Ash Monofill - MidAmerican Energy, Commonwealth Edison Powerton Plant – Mahoney LF Ameren (formerly: Central Illinois Light Co.) Duck Creek Station Dynegy Midwest (formerly: Illinois Power Co. Hennepin Power Station Dynegy Midwest (formerly: Illinois Power Co.) Havanna Power Plant Dynegy Midwest (formerly: Illinois Power) Vermillion Power Station Ameren (formerly: Central Illinois Public Service Co.) Hutsonville Power Station Dynegy Midwest (formerly: Illinois Power Co.) Wood River Power StationAmeren Coffeen/White & Brewer Trucking Fly Ash LF

Venice Power Station – Union Electric/Ameren/AmerenUE Joliet Generating Station 9 – Lincoln Stone Quarry Landfill - Midwest Generation

Marion Plant - Southern Illinois Power Cooperative NiSource (formerly: NIPSCO) Michigan City Site NiSource (formerly: NIPSCO) Bailly Generating Station R.M. Schafer Generation Station Southern Indiana Gas & Electric Co. A.B. Brown Generating Station Indiana Power & Light Petersburg Generating Station Hoosier Energy Merom Generating Station CCW LF Clifty Creek Station, Indiana-Kentucky Electric Corporation Cinergy East Bend Scrubber Sludge LF Mill Creek Station – Louisville Gas &Electric

Shawnee Fossil Plant - TVA Spurlock Power Station - Eastern Kentucky Power CooperativeBig Cajun 2 Power Plant – NRG/Louisiana Generating

Dolet Hills Power Station - CLECO Power Rodemacher Power Station - CLECO Power K.R. Rezendes South Main St Ash LF, PG&E (compare with CCW DC Ass #72, 'Copicut Road', and footnotes #135 and #141 therein) Mirant Dickerson’s Generation Station’s Westland Disposal Site Brandywine Coal Ash LF – Mirant Mid-American Marquette Board of Light & Power Pine Hill We Energies Presque Isle Power Plant Muskegon County Type II LF John Warden Ash Site Consumers Energy J.H. Campbell Consumers Energy BC Cobb Karn/Weadock Generating Facility – Consumer Energy
Xcel Energy/Southern Minnesota Municipal Power Agency (Sherco) Generating Plant Duke Power Allen Steam Generating Plant Dan River Steam Station - Duke Energy Sutton Steam Plant – Progress Energy Lee Steam Plant – Progress Energy Cape Fear Steam Plant – Progress Energy Belews Creek Steam Station, Duke Energy Asheville Steam Electric Plant, Progress Energy
Basin Electric, W.J. Neal Plant Great River Energy Coal Creek StationMontana-Dakota Utilities R.M. Heskett Station

Leland Olds Station - Basin Electric Power Cooperative Sheldon Station – Nebraska Public Power District
AES Creative Resources Weber Ash Disposal Site Central Hudson Gas & Electric Corp. Danskammer Waste Management Facility, , NY C.R. Huntley Flyash LF Cincinnati Gas & Electric Co. Miamiview LF Cinergy W.C. Beckjord Station Cardinal Fly Ash Reservoir (FAR) 1 & 2 – AEP General James M. Gavin Power Plant – AEP/Ohio Power Muskingum River Plant – AEP/Ohio Power Northeastern Station Ash LF, AEP/Public Service Co. of Okla Mitchell Power Station, Allegheny Energy

Phillips Power Plant – Duquesne Light Co. Seward Generating Station – RRI Energy, Inc., Hunlock Power Station – UGI Development Co. Portland Generating Station’s Bangor Quarry Ash Disposal Site – RRI Energy, IncWateree Station – South Carolina Elctric & Gas

Grainger Generating Station South Carolina Public Service Authority
TVA Bull Run Steam Plant, Cumberland Steam Plant – TVA Gallatin Fossil Plant – TVA Johnsonville Fossil Plant – TVA

John Sevier Fossil Plant – TVA Fayette Power Project (Sam Seymour) – Lower Colorado River Authority Dominion Virginia Power’s Battlefield Golf Course

Dewey Ash Landfill (Wisconsin Power & Light/ Alliant Nelson) WEPCO Port Washington Facility/Druecker Quarry Fly Ash Site Wisconsin Power and Light Alliant (WP&L) Rock River Ash Disposal Facility (Wisconsin Power and Light Co.) Alliant Edgewater 1-4 Ash Disposal site Wisconsin Power Supply Co. (WEPSCO) Pulliam ash Disposal Site Dairyland Power Alma Cooperative On-site Fly Ash LF
Dairyland Power Cooperative Alma Off-site Fly Ash LFOak Creek Power Plant – Wisconsin Energy/Wisconsin Electric Power (Caledonia): SEE #38 UNDERPROVEN

PacifiCorp Energy’s Dave Johnston Power Plant, WY

Note:**(Y)***: plan submitted for future action, or ongoing.**Location State**  **Key Reference(s)**

Stevenson AL CCW DC Ass #32 Colbert County AL CCW DC Ass #33 Gentry AR In Harm's Way #1 Newark AR In Harm's Way #2 Joseph County AZ CCW DC Ass #67 Montville CT In Harm's Way #3 Millsboro DE Out of Control #1 Bay County FL CCW DC Ass #36 Lakeland FL In Harm's Way #4 Orlando FL Out of Control #2 Palatka FL Out of Control #3 Apollo Beach FL Out of Control #4 IA CCW DC Ass #64 Sergeant Bluff/Sioux City IA In Harm's Way #5 Salix IA In Harm's Way #6
Pekin, Tazewell Co. IL CCW DC Ass #40 Canton IL CCW DC Ass #47 Hennepin IL CCW DC Ass #48 Havanna IL CCW DC Ass #49 Oakwood IL CCW DC Ass #52 Hutsonville IL CCW DC Ass #53 Alton IL CCW DC Ass #54Coffeen, Montgomery County IL CCW DC Ass #56

Venice IL In Harm's Way #10 Joliet IL In Harm's Way #8

Marion IL In Harm's Way #9 Michigan City IN CCW DC Ass #43
Chesterton IN CCW DC Ass #44 IN CCW DC Ass #55 IN CCW DC Ass #57 IN CCW DC Ass #59 IN CCW DC Ass #60 Madison IN Out of Control #7
Rabbit Hash KY CCW DC Ass #35 Louisville KY In Harm's Way #11

Paducah KY In Harm's way #12 Maysville KY In Harm's Way #13New Roads LA In Harm's Way #14

Mansfield LA In Harm's Way #15 Lena LA In Harm's Way #16 Freetown MA CCW DC Ass #25 Dickerson, Montgomery County MD BNA, 1/5/2011 Brandywine, Prince George's County MD Out of Control #8 Marquette MI EPA-HQ-RCRA-2009-0640-6815, Attach #5 Marquette MI EPA-HQ-RCRA-2009-0640-6815, Attach #5 Muskegon Co. MI EPA-HQ-RCRA-2009-0640-6815, Attach #5 Baraga MI EPA-HQ-RCRA-2009-0640-6815, Attach #5 MI EPA-HQ-RCRA-2009-0640-6815, Attach #5 MI EPA-HQ-RCRA-2009-0640-6815, Attach #5 Saginaw MI Out of Control #9
Becker, Sherburne Co. MN CCW DC Ass #41 Belmont NC CCW DC Ass #34 Eden NC In Harm's Way #18 Wilmington NC Out of Control #11 Goldsboro NC Out of Control #12 Moncure NC Out of Control #13 Belews Creek NC Out of Control #15
Arden NC Out of Control #16

Velva ND CCW DC Ass #23 Underwood ND CCW DC Ass #24ND CCW DC Ass #66

Stanton ND In Harm's Way #20 Hallam NE In Harm's Way #21

NY CCW DC Ass #27 Newburgh NY CCW DC Ass #28 Tonawanda NY CCW DC Ass #29 OH CCW DC Ass #58 New Richmond OH CCW DC Ass #61
Brilliant OH In Harm's Way #23 Cheshire OH In Harm's Way #24 Beverly OH In Harm's way #26 Oologah OK In Harm's Way #27 Courtney PA Out of Control #19

Crescent Township PA Out of Control #20
New Florence PA Out of Control #21 Hunlock Creek PA Out of Control #23 Bangor, Northapmton County PA Out of Control #24Eastover, Richland County SC Out of Control #25

Conway SC Out of Control #27 Oak Ridge TN CCW DC Ass #31 Cumberland City TN In Harm's Way #32 Gallatin TN In Harm's Way #33 New Johnsonville TN In Harm's Way #34
Rogersville TN Out of Control #28 Le Grange, Fayette County TX In Harm's Way #35 Chesapeake VA CCR Proposed Rule, 6/2010

Cassville, Grant County WI CCW DC Ass #15

WI CCW DC Ass #17 Rock County WI CCW DC Ass #42 Sheboygan WI CCW DC Ass #45 Green Bay WI CCW DC Ass #46 Grant County WI CCW DC Ass #50
Belvidere, Buffalo County WI CCW DC Ass #51Oak Creek WI In Harm's Way #39

Glenrock WY CCW DC Ass #65**WU Type Liner** 

SIs 3: No 2 SIs & 2 LFs SIs: Clay LFs: ? LF & 2 SIs LF: No LF; 3 wastewater recycle & surge ponds No 2 SIs and 2 ash contact wastewater ponds (Zero discharge facility) 2 SIs: No SIs; Ash storage area No SI & LF SI: No; LF-I: No SI No 2 LFs; Sludge dewatering area, process wastewater ponds; artificial wetland (?) LF: No LF; 3 Ruoff Ponds Yes LF; 5 Ruoff and process Ponds LF: Yes; 3 SIs: Some Yes LF, 4 SI, FGD storage Area LF – Yes; FGD Storage Area: No; SIs: ? 2 LFs 2: No
LF & 3 SIs LF: No; SIs: No LF ?

LF Poz-O-Pac (ash w/lime) SI No SIs 2: No 2 SIs 1: No 2 SIs No SI No SI NoLF No

3 SIs No LF in former quarry; 2 SIs No

1 LF; 7 SIs LF: No; 6 SIs: No; 1 SI: Yes 2 SIs 2: No
2 SIs, 2 LFs 2 LFs and 2 SIs: No LF No LF No LF No 2 LFs Area 1: No; Area 2A: Clay LF & SI (Boiler slag) No
SIs; LF 3 SIs: No LF:? 3 LFs; 1 Ash SI; 4 FGD process ponds 2 LFs: No; 1 LF: Yes; Ash SIs: No; FGD ponds: ?

2 LFs & 2 SIs LFs: No; SIs: No LF & SI LF (1996 expansion): 2' compressed clay; SIs: ?5 SIs & Surge treatment ponds 3 SIs: clay; 2 SIs: ?

1 LF & 9 SIs LF: ?; 2 ash ponds: clay; 7 SIs: ? 1 LF; 1 leach pond; 2 ash SIs; 4 other ponds 2 ash ponds: clay; 5 leach & wastewater ponds: 60-mil HDPE S&G Pit; structural fill No 1 LF; 4(?) ash settling and leachate treatment ponds 'Inadequately lined' LF, 4- leachate ponds, wastewater ponds LF: No – all but one pit (Composite liner since 2007); Ponds: Yes LF No LF No LF No LF No SI No? LF No 2 SIs No
4 SIs, 1 LF, recycling basin 2 SIs: Clay SIs 2: No 2 SIs & LF No
2 SIs 1972: No; 1982: Clay SI No 5 SIs (one of which is active) No 3 LFs & 1 SI 3 LFs: geosynthetic; SI: No 2 SIs (one of which serves as a constructed wetland) 2 SIs: No

SI No SIs and ash contact evaporation ponds (Zero discharge facility) 2: YesLF/Ash Pile No

5 SIs SIs 1-3: No; SIs 4-5: Probably No 1 LF (closed) No

LF & SI 20 mil PVC/leach collect LF No 4 LFs 4 Closed: No Phase II: Yes S&G Pit Clay SI No LF (FGD) & 2 SIs LF: Synthetic; SIs: No 6 LFs & 2 SIs LFs: Composite; SI: Geosynthetic

SI No

LF No LF; 2 Wastewater lagoons LF: No; 2 wastewater lagoons: compacted soil/bottom ash
LF (FGD); 2 SIs LF: Yes? Leachate collection; SIs: No 2 unpermitted LFs; Co-disposal coal ash/coal refuse pit No 2 SIs Partial, in situ clay LF in a quarry; Stormwater sedimentation & leachate collection ponds 60-mil LLDPE geomembrane over 6" fly ash sub base.2 SIs in former S&G open pit in river bed;

additional, non-implicated WUs No

2 SIs No
3 SIs No 2 SIs (one of which is active) & Ash stack SIs: No 3 SIs No 2 SIs & 1 LF 1 SI: Clay; 2 SIs: No; LF: no
1 SI converted into dry stacking; 1 SI No 2 SIs & 1 LF (FGD) SIs: Clay; LF: ? Structural Fill No

2 SIs, 1 LF No
S&G Pit No SIs (ash disposal area and 4 settling basins); LF (closed?) No 4 SIs No LF No SI No
SI, converted into LF Clay3 LFs, 1 (inactive) structural fill 2 Inactive LFs: No; Active LF: Clay (Phase I); Composite w/leachate collection (Phase II) 3 LFs 3: No**Year Started Year Damage Noted**  **Failure Mode** 1950 Early 1990s GW SI: 1972 LF: 1984 ? GW 1978GW: 1994; SW: 1996 GW & SW 1983 Early 1990s GW
1978 Pre-1999 GW 1919SW: Late 1960s GW & SW; Soil 1957; 1980 2005 GW, SW, Sediments, Ecologic (?), Fugitive Dust (?) 1965 Pre-1985 GW 1981 1997 GW 1981 2003 GW & SW 1984 2004GW & SW 1968 2000GW & SW; damaged vegetation 1964; 1975 Pre-1987 GW
LF: 1978; 2 SIs: 1972; 1 SI: 1975 2001 GW (LF) Early 1980s 2000GW
1972 Pre-1985 GW & SW 1976 1999 GW 1952; 1958 1989 GW 1947 1989 GW 1989 Pre-2000 GW 1968 2000GW 1978 1989 GW1977 or earlier GW: 1984; SW: 1995 GW & SW; stressed vegetation

1950s 1995 GW 1962 1994GW

1963 1994GW & SW 1974 Pre-1982 GW
1962-1970s 1976GW, SW; Ecologic (?) (stressed vegetation) 1984 Pre-1993 GW 1979 Pre-1987 GW 1976 1997 GW 1982; 1994 1987; 1990 GW & SW; Fugitive Dust SI: 1955; LF: 1991 2002 GW
1980 1981 GW 1972 1994GW

SIs: 1950s and 1971; LF: 1984 1980s GW & SW LF: 1982; SI: 1976 2005 GW1980 1989 GW 1986 1992 GW SIs: 1982; Leach pond: 2009 1983 GW 1976 2001 GW 1959; 1962 2010 (?) GW & SW 1970; 1971 2002 GW & SW; Fugitive Dust (?) 1985 ? GW 1979 ? GW 1980 ? GW 1974 ? GW & SW 1962 ? GW & SW/Potential for ecologic damage 1970 ? GW 1959; 1961 1982 GW

1975 Pre-1985 GW 1957; 1973 1985 GW LF: 1949; SIs: 1956 & 1976 1993 GW
1972; 1982 2006GW 1951 2007 GW 1956; 1963; 1970; 1978; 1985 2007 GW LFs: 1974, 2007, 2008; SI: 1974 2005 GW & SW
1964; 1982 2007 GW

1950s 1982 GW & SW; Sediments 1978; 1979 1979 GW1954 1998GW

1966; 1975 (2); 1985; unspecified date 1985 GW & SW 1989 1999 GW

1978-80 1991 GW 1959 ? GW Early 1970s ? GW, SW 1983 1994GW 1956 1985 GW
SIs: 1973 & 1987; LF: Post-2000 1993 GW & SW SIs: 1974; LFs: 1994, 1996, 1998 1994GW & SW; Ecologic

1968 2005 GW & SW
1978 2008GW 1963 1998GW Fugitive Dust

1969SIs: Late 1980s; LF: mid-1990s GW
1954 2004GW & SW 1959 2000GW & SW; Soil Pre-1995 GW: 2001; SW: 2006 GW & SW1970 1997 GW & SW; Potential ecologic damage (arsenic in fish)

1966 & 1977 1996GW
1965 1974GW, SW 1969 2008GW 1959 2008GW 1952 1986GW & SW

1955; 1979 ? GW & SW; Dam Failure (1973) SIs: 1979 & 1988; LF: ? 2005 GW 2002-2007 2008GW & SW

Early 1960s 1986GW
1948 1990s or earlier GW 1954 1976-1977 GW 1969 (2), 1977 (2), 1985 (2) 1980s GW 1971 1994GW 1947 1975 GW

1983 1991 GW1969, 1976 2002 or earlier GW, SW

Late 1960s; 1988 Pre-1985 GW, SW**COCs/GW COCs/SW** 

Pb, Cd, Cr Sf, Cr, Se, Cd, Al, Fe, Sb, As, Cr, Pb, B, Mn, Mo, Nitrate. Se, Fe, Mn, As, B, Mo, pH, Sulfate, TDS Ba, B, Cr, Pb, Se, Sf, TDS, pH As, Cd, Pb, Fe, Mn, Sf, TDS, pH
Sf, Cl, F, TDS As, Be, Pb, Mn, pH Cd, Cu, Ni, Zn, As, Be, Fe, Sf, TDS; As, Be, Pb (Soils) As, Se, Cr, Tl SW: Al, As, Ba, Fe; Sediments: As, Cd, Cr, Cu, Pb, Hg, Ni, Zn Cd, Cr, F, Cl, Sf, Mn, Fe As, Pb, Se, Mn, Cd, V, Fe, Sf, Nitr, TDS Gross Alpha, Ra-226, Al, Fe, Mn, V, Cl, Na, Sf, TDS, pH Al, Na, Cl, Sf, Gross Alpha As, Pb, B, Fe, Cl, Sf, TDS As, B, Al As, Tl, Mn, Sf, Cl B, Fe, TSS Se, Sf
As, Fe, Mn, Sf As, Fe, Mn, Sf, Ba, Se, Zn
Pb, Fe, Mn, Ca, Nitr, Sf Pb, Fe, Mn, Ca, Nitr, Sf Mn, Fe, Cl, Sf, TDS Fe, Mn, B, Sf, TDS Mn, B, Sf Sf, TDS Mn, B, Sf, TDS Mn, Fe, B, Cl, Sf, TDSCd, Ni, Tl, Mn, Fe, B, Ba, Sf, TDS B, Sulfate, Ni, TDS, Mn, Fe, Zn, Cr

As, Cd, Fe, Mn, B, TDS As, Se, Cd, Ba, Cu, B, Mo, Sf, Ammon, TDS, pH

Cd, Fe, Sf, B Al, B As, Pb(?) As, Pb, (Cd?), Al, B, Mn, Mo SW: B, Mn; Sediment/Soil: Cd, As, Se, B, Mo, Al, Cr Fe, Mn, Mo, B, Sf, Cl, Na Al, Sf, Cl, TDS, pH Sf, TDS Ba, Cr, Cd, Pb, Sf, Cl SW: Se B, Mn, Fe, Sf
Fe, Sf, TDS As, Sf, TDS

As, Se, Cr, Pb, Be, Co, Ni, Mo, V, Sulfate, TDS, B, pH Reddish Leachate As, Sf, TDSSe, Ca, TDS

As, Pb, Se, Sf, Ca, TDS, pH, Alkalin, Sp. Conduct. As, Pb, Cl, TDS, pH, Sf, Sp. Conduct. Se, Sf, Mn, Fe, Al, TDS Al, As, Ba, Cd, Cr, Co, Cu, Fe, Pb, Mg, Mn, Ni, Se, Zn, Cl, Sf Al, As, Ba, Cd, Cr, Co, Cu, Fe, Pb, Mg, Mn, Ni, Se, Zn, Cl, Sf, pH, TSS Cd, Fe, Al, Mn, Sf, Cl, TDS Cd, Pb, Se B, Li, Na B, Li, Na B, Mn B, Li Se, B, Li, Sb Se, B, Li, Sb B, Li As, B, (Hg, Li)
As, Cd, Cr, F, Pb, Cu, Fe, Mn, Zn, Cl, Sf, Nitr Mn, Fe, B, pH Pb, Cr, Ag, Fe, Sf
As, Fe, Mn, B As, B, Mn, Fe, pH Pb, B, Cr, Fe, Mn, Sf Pb, As, Se, B, Mn, pH, Sf, Nitr B, Fe, Mn, Sf, TDS Fe, Mn, B, pH (Cr, Pb, As, TDS)
Cd, Pb, Zn, Al, As, Cr As, Se, Sf, B, Fe, Na, Cl, TDSSe, B, Mn, Sf

As, Pb, Se, B, TDS (Se, B) Se, Sf, Cl
Sf, Mn, Fe, Al, TDS, pH As, Se, Fe, Mg, Mn, Na, B, Sf, Sulf, TDS, pH As, Fe, Mn, Sf, TDS Fe, TSS Mn, Sf Se, Sf
As, B, Mo As, Mo As, Ba, Cd, Pb, Mn, Mo, Gross Alpha, Cl, TDS B, Al, Ni, Zn Ba, Fe, Sf, Gross Alpha, TDS As, Ba, Hg, Sf As, Ba, Cr, Pb, Se, Tl, V, Sf, pH As, B, Mo, Ni, Mn, Fe

Al, Mn, Cl, F, TDS
Sb, As, Cd, Cr, Pb, Se, Al, Fe, Mn, Ni, Zn, Cl, Sf, TDS Al, Ni, Zn, Fe, Mn, pH As, Fe, Mn, Li, Ba, B SW: As; Soil: As, Se Al, Mn, Fe, F, Sf, TDS Cr +6, Se, Cd, BAs (Cr, Cd, Pb) As

As, pH Sf, Al, Ca, Fe, As, B, Mn, Mo Sf, Al, Ca, Fe As, Se, B, Al, Fe, Mn, Cl, Sf, TDS Cd, Hg, Be, B, Ni, Co, V, Fe, Mn, Sf, TDS As, Cd, Pb, B, Mo, Al, Fe, Mn, Sf, TDS, Co Mn, Fe, Al
Cd, Al, Mn, Sf Cd, As, Mn Se, Co, Mo, Al, V, Mn, Sf, Cl, TDS As, Cr, Pb, V, Cu, B Tl, Cr, Pb, Al, Fe, Mn

As, Se, B, Mn, Sf, F, TDS, pH
Se, B As, Hg, Fe, Sf, B, Ba, Al, TDS As, B, Fe, Sf, Cl, TDS B, Mn, Fe, Sf, TDS Mn, B, Sf, pH
Cd, Cr, Mn, Fe, B, Sf, TDS, conductanceMo, B, Mn, As, Hg, Sf, F As, Cr, TCE, diesel

Cd, Mn, Sf, B**Reg Action**

None. CO recommended; No Administrative Action was taken by the state; no remediation was performed because contamination in an up-gradient well was attributed to an off-site source. Sinkhole treated and capped. ADEQ ordered assessment monitoring (2005) due to statistically significant increase in selenium, sulfate and TDS. Notice of Deficiency (NOD) in 2008. None. Since no primary MCL exceedances noted in the recent years, the state has not responded because it does not enforce SMCLs. None USEPA made final determination that migration of contaminated groundwater is under control (2000). CO for RI and remediation of the Burton Island (SI) area; New LF (II) permit granted while presumably incompatible with several State regulations None; impact restricted to ZODFDEP issued a Consent Order (2001) because of impacts to groundwater and required additional onsite monitoring and about $180,000 in civil penalties. State required upgrades, additional monitoring of LF, determination of waste type. EIP claims that OUC has not fully addressed FDEP’s requests. State required Interim Remedial Action Plan (groundwater capture system and remedial monitoring) CO; A Remedial Action Plan and groundwater monitoring plan; closure of a SI impacting vegetation Capping and seeding; groundwater monitoring/study. No further state remediation action. IDNR requested MidAmerican to provide more evidence for their claim that arsenic contamination comes from an offsite source. Issue is still under consideration. IDNR requested (2005) that future groundwater reports from MidAmerican discuss potential for groundwater mounding under the LF, evaluate if listed wells are truly ”upgradient,” discuss potential for migration and possible receptors. The Utility’s 2008 groundwater report did not address these questions. ? Closure of unlined SIs, including dewatering; overhaul of monitoring well system. Remedial action under development. CO by State. Old SI closed in 1996, replaced with a lined SI. Consent Order; Closing by State/2009. Study; groundwater monitoring program. CO to close unlined SI and replace w/2 synthetically-lined SIs. Groundwater program in effect. CO (switched to dry handling; groundwater monitor program). An approved GMZ.Leaking cells capped; groundwater monitor in effect. A 5/1995 memo documents areas of dead

grass on-site, due to groundwater seepage; and a 7/1996 memo discusses IEPA’s recognition of contamination to groundwater as a result of ash disposal operations at the site. None, but proposed closure of the SIs through capping and a GMZ. IEPA issued a NOV (8/2009) for ”failure to operate a leachate collection and management system that assures the protection of Class I potable resource groundwater”, identifying 50 exceedances of groundwater standards in 10 wells. IEPA approved a corrective action of pumping wells in the SE area in 2009; the power plant implemented the corrective action in 2010; in 2011 IEPA approved an expanded corrective action along the southern boundary along with a GMZ. The GMZ in the SE corner of the facility is limited to the area of contamination. The corrective action has two-fold purpose: to control the source (and reintroduce an inward gradient required by the IPCB) and to mitigate impacts in the south of the LF. IEPA asked the Utility for and approved a “hydrogeologic assessment plan” to determine the source and extent of elevated Fe and Cd contamination at the site, including an upgrade and extension of the monitoring well system. Located on highly permeable sands on the shore of Lake Michigan, w/GW flow towards the Lake. Steel slurry wall down-flow from the disposal site. RCRA EPA Corrective Action, monitoring wells, Baseline Ecologic Risk Assessment; NIPSCO required to investigate whether contamination from the site is affecting soil, groundwater, or Lake Michigan. Original unlined cells capped; switched to dry handling; groundwater monitoring in effect. A slurry wall was installed in the NE corner of the original LF in late 1987. Leaking cells capped; groundwater monitor in effect. None State: Corrective Action and groundwater monitor for groundwater impacts. (Federal: Consent Decree for emission violations) Assessment Monitoring. IDEM claims that the parameters that are detected in the monitoring program are reflective of the active total chemistry of the formation, including levels of manganese, magnesium, and iron that exceed secondary MCLs in some cases. Extended monitoring, groundwater studies and a Risk Assessment. KY has discretion, under 401 KAR 45:160 Sect.1, to require or not require a groundwater corrective action. The O/O is currently not required to perform a corrective action. Assessment monitoring for sulfate is currently required. A groundwater assessment was performed at the site in the 1980s; no KDWM enforcement action since. KDWM permitted (in 2007) the expansion of the LFs without a liner (as “special waste landfills”), over old, unlined ash ponds. EKPC has been directed by the KDWM to conduct an assessment in wells MW-2A & MW-3A, to determine the cause of thedetection of arsenic in MW-3 at a concentration exceeding the permit limit. The Commonwealth of Kentucky did require a Remedial Action Plan under its regulations and, as noted above, the plan has been approved and the cooperative has implemented it.LDEQ issued a Notice of Deficiency (NOD) during permit renewal regarding inadequacy of

monitoring well system and required that 10 additional downgradient wells be installed. No other regulatory corrective action or administrative ruling. LDEQ required (2008) on-site assessment monitoring. LDEQ required (2008) on-site assessment monitoring. CO, a partial cap. MDE filed notices of intent to sue Mirant Mid-Atlantic LLC in federal court (1/2011) for alleged water pollution violations. In 4/2010, MDE filed suit in federal court maintaining that the disposal site was leaching pollutants in violation of the CWA and state law ? ? ? ? ? ? Consent Decree requires slurry walls to be built to stop leakage, and monitoring of groundwater/surface water interface. Due to the ongoing site investigation, and the determination that the water under the SIs has been determined to be GW not in an aquifer, the DNRE has not listed this site as a proven damage case at this time. None(?); not clear whether the capping/closing and active dewatering of Pond #1 are in response to state requirements. None: NC DENR does not require groundwater monitoring; has no record of groundwater monitoring; no indication that violations or enforcement actions occurred. State will not require action until contamination is outside the ”compliance boundary.” Additional GW monitoring wells were installed at the Compliance Boundary in 2/2011, and DWQ is evaluating GW monitoring data to determine if any additional action is required A NOV (1987) and request for corrective action; a CO (2004) was terminated by the company(2007) following a "Site Reassessment Report" by NCDENR which recommended the site be redesignated as "No Further Remedial Action Planned". None. NC DENR has not required any corrective action: DWQ has sent a letter to PE, directing them to place wells at their Compliance Boundaries. None. NC DENR has not required any corrective action: DWQ has sent a letter to PE, directing them to place wells at their Compliance Boundaries. Groundwater Corrective Action Plan and Closure of the Pine Hall Road LF, but not for the other two LFs. DWQ has sent a letter to PE, directing them to place wells at their Compliance Boundaries. Detection monitoring at all the 3 LFs 'is moving toward assessment monitoring'. None. DWQ has sent a letter to PE, directing them to place wells at their Compliance Boundaries.
State issued a special use disposal permit to allow disposal to continue, but required continued monitoring and site closure. State required relining of SIs in 1990; groundwater monitoring in effect.State required corrective action: site capped and closed; groundwater monitoring in effect.

None NDEQ required the Utility to install additional wells and extended post-closure groundwater monitoring period from 10 to 15 years due to evidence of contamination. In December 2010 additional wells were installed in the down gradient direction from the LF. The facility will conduct six semi-annual sampling events of all groundwater monitoring wells around the facility and perform statistical analysis of these results. CO. Closed and capped; groundwater monitoring in operation. Corrective Measure Assessment. In 7/2006, State Administrative Penalty Order ($500) for oil leak in discharge. Closed and capped. Groundwater investigation and remediation oerformed, monitor wells in effect. Ohio EPA encouraged the facility to install an interceptor well, but there was no formal compliance action. The one public water supply well that was located on site has been abandoned. Remediation has been performed. The OH EPA placed (2004) four Groundwater monitoring wells under “assessment monitoring” due to evidence of CCR contamination. OH EPA required assessment monitoring onsite to determine extent and rate of contamination and to address the contamination. OH EPA mandated AEP (2004) to implement a groundwater monitoring plan and install 15 Groundwater monitoring wells, four groundwater elevation monitoring wells, and five piezometers. However, OH EPA does not support the conclusion that the Power plant has demonstrated an indication of an impact on groundwater quality. ODEQ required AEP (9/2007) to establish a groundwater monitoring program at the LF (26 wells). Concerned about the karstic milieu and the proximity to the Verdigris River, ODEQ required further investigation and possible remedial action. None (State law does not require state response to onsite exceedances of secondary MCLs); NOV for fugitive dust.
Consent Order and Agreement was signed in 1990 providing several options to remediate contamination source; included $50,000 penalty for discharge violations. CO (1982) for closing of unpermitted pits and $308,000 fine for violating SWM Act. COA (2000); several COAs to cease discharge from coal ash/coal refuse pit. PADEP ordered groundwater assessment (2008) to delineate source and extent of contamination. As of early in 2010, PADEP was assessing monitoring data for well network adequacy to determine the scope of abatement necessary under closure. None (State law does not require state response for onsite exceedances of secondary MCLs). PADEP states that the exceedances in the surface water are also present in the up-gradient surface water sample. Unless demonstrated that the intermediate and down-gradient surface water samples show change in parameter concentration that are indicative of impact from the site, no action would be initiated against the facility.CO (2001) in response to monitoring well violations of arsenic seeping from the SIs. It established a

Groundwater Mixing Zone, with waivers for arsenic (3000 ppb), sulfate, lead, chromium, and cadmium.On 10/14/2011, SCE&G signed a private, legally non-binding Memorandum of Agreement (MOA) with DHEC. The MOA sets out an anticipated timeline in which SCE&G would transition to dry handling of fly ash by 12/31/2011; transition to dry handling of bottom ash by 12/31/2012; and complete its removal of ash from the SIs by 1/1/2022. SC DHEC required a proposal (2009) for stabilizing arsenic exceedances in three monitoring wells or a corrective action plan. DHEC also indicated that no remediation of the SIs is being conducted, that ongoing assessment activities are “informal,” and no violations or orders have been issued to the site owner. None, assuming dilution by the Clinch River. NOV for fugitive dust. None. Apparently, state law does not require a response to onsite exceedances. Groundwater Assessment Plan in place since 4/2011. None. Both New Johnsonville and the City of Camden intake their municipal water supplies from the Tennessee River near the power plant’s outfalls.Despite evidence of surface water quality impacts from the power plant’s CCR disposal, the state has not required the power plant to limit its discharge, monitor CCR disposal areas more frequently, or take any corrective action. The power plant quit monitoring in 1994. None. Apparently, state law does not require a response to onsite exceedances. TCEQ required (2005) a selenium assessment at one of the SIs as the likely source of selenium; investigations remain underway. Assessment monitoring, capping/closure of leaking SI, and notification of residents in adjacent properties. In response to the City of Chesapeake’s request, EPA conduct site inspection under CERCLA. Dominion Power undertook installing public water to the two closest communities. Lawsuit brought by citizens against the power plant and the gulf course owners. Dominion claims that the two lawsuits alleging groundwater contamination filed by residents of the neighboring community were dismissed by the Court based on the lack of factual or scientific support. The State required an investigation of groundwater contamination, capping and closing. The property with the quarry and impacted private well that had pre-remediation boron and sulfate exceedances was purchased by the utility and retired. Landfill was capped in 2007, included 2’ of soil with 6” topsoil cover. Remediation has been performed, and a groundwater monitoring program is in effect (producing biennial groundwater reports). State required upgrade of groundwater monitoring, studies, and remediation. State required upgrade of GW monitoring and studies. AOC; requirement for additional monitoring wells; ultimately-site closure, now under post-closure monitoring. Analysis of LF performance, better liner and mitigation study.WDNER has been investigating (as of 6/2010) to better establish local background and gradients to

determine if CCRs are source of exceedances. No Information on State response. Studies indicate that cadmium and manganese are naturally occurring.**Current Status**

Active Some Active, some not Active Active
Active Inactive Some Active, some not Active Active Active Active Some Active, some not Some Active, some not
Some Active, some not Active Inactive/1982 Some Active, some not Some Active, some not Some Active, some not Active Some Active, some not Active/ modifiedInactive

Inactive Active

Active Active LFs: Inactive (1976, 1986); SIs: Active Active/ modified Some Active, some not Active Some Active, some not Active
Active Active

Some Active, some not ActiveActive

Active Active Inactive 2001 Active Active Inactive 1995 Inactive 1993 Inactive 2001 Inactive 1993 Inactive 1998 Inactive 1982 Active

Some Active, some not. Some Active, some not Some Active, some not
Active Active Some Active, some not Some Active, some not
Active

Inactive 2000 ActiveInactive

Some Active, some not Some Active, some not

Inactive 2001 Active Some Active, some not Inactive Active/ modified
Some Active, some not Some Active, some not
Active
Active Active

Inactive; early and late-1990s
Inactive Inactive ActiveActive

Active
Active Some Active, some not Some Active, some not Some Active, some not

Active Active Inactive

Inactive 2001
Inactive 1971 Active Active Inactive 1986 Inactive

Some Active, some notSome Active, some not

Some Active, some not**Comments**

Landfill is a stacking operation; two sinkhole collapses induced switch to dry handling. Operational change (abandonment of sinkhole-prone WUs). The landfill permit issued in 2002 required that GW samples be collected to monitor 28 heavy metal and indicator parameters, and that statistical analyses of increases in concentrations should serve as a basis for corrective actions. AP & L has recently stopped sampling 26 wells at the surge pond and plant areas without objection from ADEQ, but eight wells around the landfill keep operating. Baseline groundwater quality (sulfate, chloride, fluoride, and TDS) was worse than that of the contaminant plume. ‘Zero discharge facility’, high evaporation rates result in high sodium and chloride levels in the ash ponds, as well as in salty seeps. The Thames River close to the power plant is saline, classified as unsuitable for shellfish harvesting, or as a fish/ shellfish habitat. Due to its high base flow, it is highly unlikely that groundwater contaminated in excess of SWPC would adversely impact the River. OU #2 (LF, land areas, berms) is currently under RI including ecological risk assessment and natural resource damage assessment. According to the Utility, groundwater impacts are reported to occur within the approved FDEP ZOD, so they are in compliance with FDEP's groundwater regulations. Built on top of abandoned phosphate mine, which likely has some influence on groundwater flow under the site. Contamination is still within the ZOD. Landfill - stabilized FGD. State claims impact is limited to the Zone of Discharge (ZOD). The unlined Gypsum Management Area is one of the sources of contaminants. State claims impact is limited to the Zone of Discharge (ZOD).Not certain that the active landfill is co-located with the closed landfill. Limited-size landfill and plume with no downgradient recipients. A 1987 scientific article concluded that “the pollution potential for this small upland LF appears limited to a small area, and is unlikely to adversely affect any water supplies utilized by humans in the near future.”The Utility suggested that the up-gradient arsenic contamination was due to up-gradient sources and is not CCRrelated.In Harm’s Waycounters that some of the up-gradient wells are improperly classified because groundwater does flow from the monofill towards these wells due to mounding. There are indications that the only “up-gradient” monitoring point (MW4) has been affected by CCR constituents as a result of groundwater mounding within the landfill. MidAmerican and IDNR claim that the background levels of arsenic naturally exceed the MCL at the site.
An approved GMZ. Utility claims contamination related to coal mining. A GMZ application, and a Corrective Action Plan (including a Closure Work Plan) to deal with contamination issues at the site was due 4/1/2012. SI removed from service in 2000. In late 1990s, two cells were lined: one-double clay w/leachate collect, one composite (45-mil HDPE/clay)An approved GMZ; as of 10/2011, further assessment is underway.

As part of the plan for final closure of the SIs, AmerenUE proposed (3/2010) final capping and a “Groundwater Management Zone” to contain contaminant plumes within the property. MG offered to either buy out the properties or drill new, deeper wells for the affected residences. There are presently two Ground Water Management Zones (GMZs) designation for the landfill area (with a potential for allowing off-site contamination of groundwater within one of the GMZs).

While no wells were placed off-site, Dames & Moore concluded that a steel slurry wall downflow from the disposal site, in addition to natural attenuation, mitigated and limited the contaminant plume. Because lead exceeding the PDWS was detected also in several up-gradient wells, it is not clear whether it is related to the CCR. Near the Indiana National Lakeshore on Lake Michigan. In 1978, the SIs were dredged then lined with a composite liner (HDPE over clay). Phase III & IV have composite liner w/leachate collection. An FGD solids landfill; compacted clay liner in expanded landfill area. IDEM accepted Utility's claim that impacts are due/inseparable from those caused by coal mining activities A 5' clay liner (1x10-6hydraulic conductivity). Also: “Poz-O-Tec” (processed ash and FGD waste). State and Utility claim that the as of 10/2011 flow discharges to the Ohio River and does not risk any drinking water resources. KDWM required a risk evaluation and river sampling to demonstrate that the effects of CCR management at the site would not negatively affect human health or water quality in the Ohio River. The findings of these studies confirmed no impacts to human health or the environment. In addition, groundwater flow for the location is in the direction of the Ohio River and there are no residential wells (or non-company owned properties) between the plant and the River. All local households are connected to public water supplies. Groundwater has been assessed onsite; however, no offsite groundwater data are available. Metal constituent monitoring started only in 9/2008. The Kentucky Division of Waste Management is unable to determine the location of any well or the direction and rate of groundwater flow at the site because it does not require that a potentiometric surface diagram be submitted with groundwater reports. In its comment to the docket, KDEP states that there only appears to be one residential well down-gradient from the landfill within the two-mile radius. This well needs to be investigated for its actual use, as it appears it may be on the power plant's property.The higher groundwater elevations in the pond area wells suggest groundwater mounding beneath the ponds due

to leakage, causing localized reversal of groundwater flow to the west away from the Mississippi River.

Operations at the landfill ended in 2001 as the result of a bylaw passed by the Town of Freetown. The bylaw bans the disposal of coal combustion wastes within the town.

Exceedances of the state's health-based standards for boron and lithium. Exceedances of the state's health-based standards for boron and lithium. Exceedances of the State's health-based standards for boron and manganese. Exceedances of the state's health-based standards for boron and lithium. Exceedances of the state's health-based standards for selenium, boron, lithium, and antimony, and release to Pigeon River: J. M. Besser et al., Ecotoxicology & Envir Safety 35, 7-15 (1966). Exceedances of the state's health-based standards for boron and lithium. MDEQ recently claimed that under the revised “mixing zone” standards, and State revisions for boron and arsenic standards ‘based on new science’, the discharge levels of these landfills comply with criteria. The US/Canada Joint International Commission (for shared water resources) designated the discharge area of the Saginaw River into the Bay as anArea of Concerndue to multiple sources of contamination. According to the Utility, arsenic, barium, chloride, Copper, fluoride, lead, sulfate, and zinc were only detected in samples collected from wells screened in the CCP pond. Past study showed high levels of Fe and Mn in background soils, as well as exceedences of SMCLs for Fe and Mn in background GW and the river/lake up-gradient and upstream of the site, at levels similar to those seen in the wells immediately adjacent to the ash ponds. The landfill has been capped and is now inactive; the rest of the power plant is to be soon decommissioned. The site has been the subject of several EPA investigations under Superfund (CERCLIS # NCD000830646). The State has no plans of taking regulatory action until groundwater contamination reaches the compliance boundary. The State has no plans of taking regulatory action until groundwater contamination reaches the compliance boundary. State and industry claim that iron and manganese are due to background levels. This very power plant was associated with the Belews Lake ecological damage case. The State has no plans of taking regulatory action until groundwater contamination reaches the compliance boundary. In the wake of EPA's followup on citizen complaints in public hearings, additional groundwater monitoring wells were installed at the Compliance Boundary in 2/2011, and DWQ is evaluating groundwater monitoring data to determine if any additional action is required under State Rules 15A NCAC 2L.01006(d). Unclear whether an impacted drinking water well was located on-site or off-site. All ponds were relined with composite geosynthetic/clay liners. This case is a possible candidate for categorization as a proven damage case.Groundwater has been evaluated onsite; however, no offsite assessment or monitoring has been required.

NDEQ argues that selenium and sulfate exist as naturally occurring minerals throughout the region. In evaluation of the site, the natural occurrence of both substances is being considered, as well as the possibility of a localized discharge of cooling tower water used for fire suppression or similar power plant activity. Currently, owned by Dynegy’s Northeast Generation Inc. Phase II landfill not implicated [NOVs (EPA) for emission/PM violations in the late 1990s.] The Tidd-Dale Subdivision, about 2000’ from the FAR 2 Dam, relies on private drinking water wells (at least nine wells). The latest potentiometric map of the power plant suggests that this Subdivision is in the direct path of groundwater flow from FAR 2. OH EPA has not required any sampling of these wells. OH EPA increased the plant’s allowable daily maximum concentration for boron in 2009 so it no longer exceeds NPDES requirements; it has also set water quality criteria for Kyger Creek for several metals that are all much higher than for the Ohio River; this results in significant mortality rate of the fathead minnow next to the outfalls’ mixing zone.
AEP has submitted a proposal to construct a slurry wall and grout curtain barrier along the length of the LF facing the Verdigris River, as well as a proposal to ensure rainwater infiltration into the LF proper is minimized/ eliminated. State claims that elevated levels of iron and manganese and sporadic low levels of arsenic and boron are attributed to AMD created by past mining of the Pittsburgh Coal Seam upgradient of the site. USWAG claims that the data should be more appropriately compared to Pennsylvania Statewide Health Standards of medium specific concentrations (MSCs) for non-residential, non-use aquifers rather than drinking water MCLs. The Pennsylvania MSCs for non-residential, non-use aquifers have not been exceeded. In the late 1980s, several water supply wells of the Cresswell Heights Joint Municipal Water Supply in Beaver County, Pennsylvania were contaminated with high levels of TDS from the two coal ash ponds. PADEP claims that the decommissioning of the SIs was due to closing of the power plant and not required by legal action. PADEP and the power plant claim that is the legacy of the original Seward Power Station that has been demolished; and the neutrailzation of old coal refuse with FBC ash used for the foundation of the newly constructed Co-Gen plant. As of 5/22/2010, the Hunlock power plant is no longer operative, including all the associated disposal activities. RRI claims that there are no permit limits stipulated for discharges of boron, cadmium, and selenium into Brushy Meadow Creek from Outfall 002. As to unpermitted discharges of boron, cadmium, hexavalent chromium, and selenium into Brushy Meadow Creek from Outfall 001, RRI claims that the CCC is not an end of the pipe standard, but rather a standard used in modeling of allowable downstream levels of a pollutant.The site is upstream of the Congaree National Park, one of the largest contiguous sections of floodplain forest in

North America. Neighboring landowners filed lawsuits (2009) to stop contamination from reaching their properties.

Toxicity study indicated potential for ecologic damage. The construction of two CCR storage-disposal areas on top of earlier SIs and on top of a former creek channel, have created conditions conducive to groundwater contamination. Adjacent to the Cumberland River, in Karstic terrain. One of the power plant’s disposal units - an 87-acre unlined CCR SI - is located on an island in the Tennessee River.

The power plant is located on Lake Fayette. The Lake serves as a cooling reservoir and is also a popular recreational site for fishing and boating. Half of the CCR SI was closed down in 1988; the remaining part is to be closed by 2012 and switch to dry handling. The golf course is filled w/1.5 million cubic yards of fly ash, amended with 1.7% to 2.3% cement kiln dust. Virginia’s Administrative Code allowed the use of fly ash as fill material without a liner as long as the fly ash was placed at least 2’ above groundwater and covered by an 18” soil cap. The Barge Company (CRT) potable water well (located between the fly ash basin and the landfill) has been rendered unsuitable for drinking, due to contamination by sulfate, boron, fluoride, and TDS. SI capped and closed once the plant switched to dry handling. Soil at the site - unconsolidated, high-permeability glacial outwash (between about 10-2cm/sec and 10-5cm/sec). Operated from 1948-1971. A well located about 250’ south of the old quarry was impacted by very high levels of boron (the state did not have a health-based standard for boron at the time of the exceedances). The power plant switched to natural gas in 2000. Ongoing monitoring at the site (including monitoring of the private wells) includes boron, sulfate, and arsenic. Previous monitoring included selenium, iron, fluoride, and chloride. Landfill in a diked area built on a former shallow wetland. The site borders a significant water body (Green Bay) and fly ash may have been placed below the water table and/or surface water elevation. Site is in the Mississippi River's floodplain and ash fill may have been placed below the water table/surface water elevation. WDNR issued administrative order in 1975 for a groundwater study and if found necessary, for ultimate closure . Closure plan, approved in 1981, included groundwater monitoring. In 1986 WDNR required additional monitoring wells. A groundwater monitoring program is in effect. Ash was originally sluiced to this landfill. The facility switched to dry CCR handling in 1995.Twelve offsite private wells found exceedances of molybdenum and boron. A consultant to WE determined that

molybdenum in the private wells was not coming from CCR in the landfills. WE has been supplying (as of 8/2009) bottled water to several dozen residents in the area without assuming responsibility for the contamination. The testing documented in the 1988 RTC suggests uncertainty as to the cause of the impacts to downgradient groundwater because cadmium, manganese, and sulfate were also found in upgradient wells. The utility reports that a follow-up investigation found that the cadmium and manganese occur naturally.**NOV CO/Admin Order**  **Study Assmt or other**  **Monitoring Remedial Action**  **Law Suit**

Y Y Y

Y Y Y Y Y

Y Y Y Y Y Y

Y

Y Y Y Y Y Y Y (Y)* Y Y YY

Y Y Y Y Y

(Y)* Y Y

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y (y)*y y y y Y Y (Y)* Y

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Y Y Y

(Y)*Y Y

Y (Y)* (Y)*

Y

Y Y Y

Y Y Y Y Y Y Y Y Y

Y YY**Fish Advisory/**

**Fishing Ban Provide Drinking Water**  **Other (Closure; Design or Operational change)** 

Y

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Y Y (Y)*

Y Y Y (Y)* (Y)* YY

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(Y)*

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### Facility **Location State** 

American Coal Corporation #5 Landfill Cardinal PFBC Monofill Brilliant OH Cardinal Fly Ash Reservoir II Impoundment OH Clinch River VA Copicut Road Monofill Freetown MA Dixie Caverns County Landfill Roanoke Co. VA Gavin Impoundments Cheshire OH Kyger Creek Power Plant Impoundments OH Lake Erie, Ohio Muskingum River Power Plant Impoundments Beverly OH Muskogee Environmental Fly Ash Disposal Site OK Public Service Co Fly Ash Disposal Site OK Star Coal Company #6 Landfill Monroe Co. IA Star Coal Company #14 Landfill Monroe Co. IA Stuart Station Impoundments/Dayton Power & Light Stuart Station OH Thompson Landfill MI Turris Coal Company Elkhart Mine IL Western Farmers Electrical Fly Ash Site Chactaw Co. OK Salem Acres Site Salem MA Vitale Fly Ash Pit Beverly MA VEPCO Possum Point VA Mitchell Generating Station Moundsville WV Four Corners Power Plant Fruitland NM

### Lansing Station Ash Ponds and Landfill – Alliant/IP&L Lansing IA

Industrial Excess Landfill Superfund Site Uniontown OH

Boardman Plant – Portland General Electric Boardman OR

Big Stone Power Plant – Otter Tail Power Big Stone City SD
New England Power Brayton Point MA Elrama Plant PA Florida Power & Light Plant Port Everglades FL Florida Power & Light Plant Port Riviera FL Florida Power & Light P.L. Bartow Plant FL

### References **Status/Rationale**

CCW DC Ass #68 Rejected: No Information. CCW DC Ass #69 Superseded byIn Harm's Way#23 (a Potential DC). CCW DC Ass #70 Superseded byIn Harm's Way#23 (a Potential DC). CCW DC Ass #71 Superseded byIn Harm's Way#36 (a Proven DC). CCW DC Ass #72 Double count': Superseded by CCW DC Ass Case #25, K. R. Rezendes South Main Street Coal Ash Landfill (a Potential DC). CCW DC Ass #73 Rejected: "The fly ash disposed at the site is emission control dust from an electric arc furnace, not fossil fuel combustion waste." No subsequent new information. CCW DC Ass #74 Superseded byIn Harm's Way#24 (a Potential DC). CCW DC Ass #75 Rejected: "Ohio EPA staff are unaware of any issues related to this pond." No subsequent new information. CCW DC Ass #76 Superseded byIn Harm's Way Case #17, 'JR Whiting generating Plant - CMS/ Consumers Energy' (a Proven DC). CCW DC Ass #77 Superseded byIn Harm's Way#26 (a Potential DC).CCW DC Ass #78; EPAHQ-RCRA-2003-0796- 0019 Rejected: "There is insufficient information available to identify the extent and nature of damages present and attribute them to fossil fuel combustion wastes."CCW DC Ass #79; EPAHQ-RCRA-2003-0796- 0019 Rejected: "There is insufficient information available to identify the extent and nature of damages present and attribute them to fossil fuel combustion wastes." CCW DC Ass #80 Rejected: "No information available." CCW DC Ass #81 Rejected: "No information available." CCW DC Ass #82 Rejected: "This site is categorized as a case without documented evidence of proven or potential damage to human health or the environment." No subsequent new information. CCW DC Ass #83 Rejected: "There is insufficient information available to identify the extent of ground water contamination, or to positively identify the source of the contamination." CCW DC Ass #84 Rejected: "An underground mine that disposes of coal processing waste and coal combustion waste in a diked surface lagoon...insufficient information to identify the extent of the contamination or confirm the source of the contamination." CCW DC Ass #85 Rejected: "There is insufficient information available to identify the extent and nature of damages present and attribute them to fossil fuel combustion wastes." No new information. CCW DC Ass #1; ICF (10/2010), Appendix A, P. 1 Rejected: "Contribution of FFC wastes to damage not separable from other wastes.” "“The co-managed wastes contributed metal contamination indistinguishable from CCRs." CCW DC Ass #2; ICF (10/2010), Appendix A, P. 2 Rejected: “Non-CCR wastes primarily USTs were focus of MADEP remediation." CCW DC Ass #4; ICF (10/2010), Appendix A, P. 4 Rejected: “Co-Managed CCR wastes without clear implication of CCR wastes in damages.” CCW DC Ass #31; ICF (10/2010), Appendix B, #31, p. 62 Rejected: ” The site is reported to co-manage CCR and unspecified “coal mining wastes”; therefore the claim does not specifically implicate CCRs as a cause of damage to human health or the environment.” Out of Control # 17; ICF (10/2010), Appendix B, #17, p. 33 Rejected: ”CCR is managed alongside mining wastes on the site, and the studies presented do not specifically implicate CCRs as a cause for contamination. The onsite water sample from a “well” in the CCR disposal area which had arsenic above the primary EPA MCL and boron above the EPA Child Health Advisory is arguably not a groundwater sample, but more representative of an ash pore water sample.”

### In Harm's Way #7; ICF

(10/2010), Appendix C, #7, p. 14 Rejected:Inadequate Informationto uphold it as a damage case:”Groundwater exceedances of the primary MCL for arsenic and the EPA SMCLs for iron, sulfate, and manganese have been found onsite in only one well (MW11) during limited rounds. However, the ability of this well to provide representative groundwater samples is in question as it has been dry for all but three of the past 11 sample collection rounds. Therefore, there is inadequate information to determine if the observed sporadic groundwater contaminant concentrations are attributable to CCRs.” In Harm's Way #25; ICF (10/2010), Appendix C, #25, p. 52 Rejected: ”Although there are numerous exceedances of primary and secondary EPA MCLs in both onsite and offsite groundwater, high incidences of cancer in the surrounding neighborhoods, and several regulatory actions, there are no explicit indications that CCRs are solely responsible for the damages. Large quantities of other non-CCR wastes have been co-managed at the landfill since the 1960s.” In Harm's Way #28; ICF (10/2010), Appendix C, #28, p. 58 Rejected:Inadequate Informationto uphold it as a damage case: ”Groundwater exceedances of primary and secondary EPA MCLs have been found onsite but at distance and upgradient from CCR materials. There is inadequate information to determine whether exceedances are site- related, from offsite sources, or from on-site but non-CCR sources. There has not been any assessment of groundwater or surface water offsite and there are no other impact or damage claims.” In Harm's Way #31; ICF (10/2010), Appendix C, #31, p. 64 Rejected: ”Although there are exceedances of primary EPA MCLs, EPA Lifetime Health Advisories, and EPA SMCLs in onsite groundwater, the exceedances generally occur near the brine ponds and are possibly related to the water softening and treatment process: CCRs cannot be directly implicated as a source of the contamination.” CCW DC Ass #26 Rejected: One of nine sites managing oil combustion wastes that are associated with largest coal- and oil-powered generating station in New England. CCW DC Ass #30 Rejected: Landfill in an abandoned coal mine. CCW DC Ass #37 Rejected: One of nine sites managing oil combustion wastes that have groundwater contamination identified for the 1999 RTC. CCW DC Ass #38 Rejected: One of nine sites managing oil combustion wastes that have groundwater contamination identified for the 1999 RTC. CCW DC Ass #39 Rejected: One of nine sites managing oil combustion wastes that have groundwater contamination identified for the 1999 RTC.

### Comments

No Info Re-categorized as a damage case Re-categorized as a damage case Re-categorized as a damage case Re-categorized as a damage case Out of Scope Re-categorized as a damage case Lack of verification by state regulator Re-categorized as a damage case Re-categorized as a damage case Inadequate information Inadequate information Inadequate information Inadequate information Inadequate information Inadequate information Minefilling Inadequate information CCRs commingled with other waste CCRs commingled with other waste CCRs commingled with other waste CCRs commingled with other (coal mining) waste CCRs commingled with other (coal mining) waste

### Inadequate information

Inadequate information

CCRs commingled with other waste
Out of Scope CCRs commingled with other (coal mining) waste Out of Scope Out of Scope Out of Scope

### References:

(1) Coal Combustion Waste Damage Case Assessments, USEPA Office of Solid Waste, July 9, 2007:http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2006-0796-0015 (2) The preamble to the June 21, 2010 proposed rulemaking (Disposal of Coal Combustion Residuals from Electric Utilities Proposed Rule, 75 FR 35128): (3) Michigan’s comment to the proposed CCR rule’s docket:http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2009-0640-6815 (Attachment 5) (4) Wisconsin’s comment to the proposed CCR rule’s docket:http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2009-0640-6416 (Appendix – Section D: Groundwater Impacts from Coal Combustion Ash Disposal Sites in Wisconsin, Table 2) (5) Out of Control: Mounting Damages from Coal Ash Waste Sites, Thirty-one New Damage Cases of Contamination from Improperly Disposed Coal Combustion Waste (6) In Harm’s Way: Lack of Federal Coal Ash Regulations Endangers Americans and Their Environment, Thirty-nine New Damage Cases of Contamination from Improperly Disposed Coal Combustion Waste. (7) Assessment of Previously Identified Proven Damage and Recently Alleged Damage Cases. ICF International. Unpublished report prepared for U.S. EPA, Office of Resource Conservation and Recovery, EPA Contract No. EP-W-07-003, Work Assignment No. 3-88, October 2010.

### http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2006-0796-0015 (2) The preamble to the June 21, 2010 proposed rulemaking (Disposal of Coal Combustion Residuals from Electric Utilities Proposed Rule, 75 FR 35128):http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2009-0640-0352 http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2009-0640-6815 (Attachment 5) http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2009-0640-6416 (Appendix – Section D: Groundwater Impacts from Coal Combustion Ash Disposal Sites in Wisconsin, Table 2) (5) Out of Control: Mounting Damages from Coal Ash Waste Sites, Thirty-one New Damage Cases of Contamination from Improperly Disposed Coal Combustion Waste. Environmental Integrity Project and EarthJustice, February 24, 2010. http://www.environmentalintegrity.org/news_reports/documents/OutofControl-MountingDamagesFromCoalAshWasteSites.pdf (6) In Harm’s Way: Lack of Federal Coal Ash Regulations Endangers Americans and Their Environment, Thirty-nine New Damage Cases of Contamination from Improperly Disposed Coal Combustion Waste.Environmental Integrity Project, EarthJustice and Sierra Club, August 26, 2010. http://earthjustice.org/sites/default/files/files/report-in-harms-way.pdf (7) Assessment of Previously Identified Proven Damage and Recently Alleged Damage Cases. ICF International. Unpublished report prepared for U.S. EPA, Office of Resource Conservation and Recovery, EPA Contract No. EP-W-07-003, Work Assignment No. 3-88, October 2010.

### http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2009-0640-0352 http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2009-0640-6416 (Appendix – Section D: Groundwater Impacts from Coal Combustion Ash Disposal Sites in Wisconsin, Table 2) . Environmental Integrity Project and EarthJustice, February 24, 2010. http://www.environmentalintegrity.org/news_reports/documents/OutofControl-MountingDamagesFromCoalAshWasteSites.pdf Environmental Integrity Project, EarthJustice and Sierra Club, August 26, 2010. http://earthjustice.org/sites/default/files/files/report-in-harms-way.pdf (7) Assessment of Previously Identified Proven Damage and Recently Alleged Damage Cases. ICF International. Unpublished report prepared for U.S. EPA, Office of Resource Conservation and Recovery, EPA Contract No. EP-W-07-003, Work Assignment No. 3-88, October 2010.

### . Environmental Integrity Project and EarthJustice, February 24, 2010. http://www.environmentalintegrity.org/news_reports/documents/OutofControl-MountingDamagesFromCoalAshWasteSites.pdf Environmental Integrity Project, EarthJustice and Sierra Club, August 26, 2010. http://earthjustice.org/sites/default/files/files/report-in-harms-way.pdf

### Abbreviations:

AMD Acid Mine Drainage AOC Administrative Order of Consent BNA Bloomberg Bureau of National Affairs CCC Criteria Continuous Concentration CO Consent Order COA Consent Order and Agreement COC Contaminant of Concern FBC Fluidized Bed Combustion FGD Flue Gas Desulphurization GMZ Groundwater Mixing Zone GW Groundwater HDPE High-density Polyethylene IPCB Illinois Pollution Control Board LF Landfill LLDPE Linear Low-Density Polyethylene NOD Notice of Deficiency NOV Notice of Violation NPDES National Pollutant Discharge Elimination System NPL National Priority List O/O Owner/Operator OU Operational Unit PDWS Primary Drinking Water Standard PM Particulate Matter RI Remedial Investigation ROD Record of Decision RTC Report to Congress S&G Sand and Gravel SI Surface Impoundment SW Surface Water SWPC Surface Water Protection Criteria USWAG Utility Solid Waste Activities Group WU Waste Unit ZOD Zone of Discharge