### EPA/OSWER/ORCR 

# CCR Dam age Case Database Technical Support Docum ent on Dam age Cases, Docket #

EPA-HQ-RCRA-2009-0640

**Alexander Livnat, Ph.D. 12/18/2014** 



### The enclosed excel spreadsheet summarizes the universe of Coal Combustion Residual (CCR) damage cases confirmed by EPA at the signature of the final rule. This database comprises three groups, each with its own tab: Proven Damage Cases, Potential Damage Cases, and Rejected Damage Cases. Subject to information limits, the database summarizes the following key data on CCR management units: type of unit (landfill, surface impoundment, structural fill), status and type of liners, waste unit’s commissioning year, categorization of the damage type (groundwater, surface water, ecological), first damage detection year, Contaminants of Concern and standard(s) exceeded, state actions in response to the impact, key litigation cases, remedial measures taken, and site-specific background information. Each entry in the database (40 proven, 113 potential, four undesignated, and 18 ‘newly rejected’



## Introduction to the database of CCR Damage Cases

The enclosed excel spreadsheet summarizes the universe of Coal Combustion Residuals (CCR) damage cases confirmed by EPA at the signature of the final rule.[1] This database comprises three groups, each with a corresponding tab: Proven Damage Cases, Potential Damage Cases, and Rejected Damage Cases.
The information pertaining to the great majority of these damage cases derives primarily from four reports: CCW DC Assessments, **[2]** 

### Out of Control , [3] 

### In Harm’s Way , [4]

### and Risky Business. **[5]** 

### A limited subset of the cases derives from additional sources. These include primarily stakeholder comments to the dockets of the June 21, 2010 proposed CCR rule - primarily EPRI's Evaluation of Coal Combustion Product Damage Cases ,[6] and the October 12, 2011 Notice of Data Availability (NODA); and data retrieved from EPA’s 2009-2014 CCR impoundment assessment reports [7]

### and EPA’s 2009 information
All the damage cases included in EPA’s 2007 report as well as the three cases included in the 2010 proposed CCR rule were reassessed against ‘test of proof’ criteria; all the ‘newly alleged’ and other candidate cases were assessed also against the same criteria.[9] For complete information on the methodology of these assessments, the reader is referred to Unit XI, Summary of Damage Cases, in the

### Each of the damage cases with sufficient information is accompanied by a case-specific module: these

modules are compiled into a compendium, an accompanying technical support document on damage cases.[10] The technical support document on damage cases comprises five individual volumes (i.e., electronic files): (1) Document I, for those of the cases that based on an assessment or a reassessment are now designated as ‘proven’ cases (case numbers PR01 to PR40); (2) Document IIa, for cases that based on a reassessment are now designated as ‘potential’ (case numbers PTa01 to PTa42); (3-4) Document IIb, for ‘newly alleged’ damage cases that based on an assessment are now designated as ‘potential.’ Due to its size, this document is split into two parts: Part One (case numbs PTb01 to PTb32); and Part Two (case numbers PTb33 to PTb55). Finally, (5) Document III, for those of the cases that

**Proven Damage Cases:**
Paraphrasing from EPA’s 2007 report, according to the 2000 Regulatory Determination, 65 FR 32224 and the Technical Background Document to the Report to Congress on Remaining Waste from Fossil Fuel Combustion: Potential Damage Cases (1999), classifying damage to groundwater as a proven
1) Scientific investigation: Damages that are found to exist as part of the findings of a scientific study. Such studies should include both formal investigations supporting litigation or a state enforcement action, and the results of technical tests (such as monitoring of wells). Scientific studies must demonstrate that damages are significant in terms of impacts on human health or the environment. For
2) Administrative ruling. Damages are found to exist through a formal administrative ruling, such as the conclusions of a site report by a field inspector, or through existence of an enforcement that cited
3) Court decision. Damages are found to exist through the ruling of a court or through an out-of-court

4) Fossil fuel combustion wastes must be clearly implicated in the damage observed.

The above definition does not limit proven damage cases only to those sites with a primary MCL exceedance(s) in ground water distant from the waste management unit (‘offsite’). A case still may be considered proven under the scientific investigation test if a scientific study demonstrates there is documented evidence of another type of damage to human health or the environment, e.g., ecological
Currently, there are 40 confirmed proven damage cases. They comprise (1) those that EPA confirmed through an assessment of ‘newly alleged’ damage cases submitted to the Agency by environmental advocacy groups in their three cited reports; (2) those that EPA confirmed through a re-assessment of the proven, potential and rejected damage cases in EPA’s 2007 report and in the 2010 proposed rule; (3) those brought to the Agency’s attention in the course of recent information collection campaigns waged shortly after the December 2008 TVA Kingston incident (i.e., the CCR impoundment assessment
Each of the 40 ‘proven’ damage cases is accompanied by a site-specific module in the damage casecompendium. A link to these ‘proven’ damage case modules (PR01 to PR40) is provided in the cross**Potential Damage Cases:**

### According to the May 2000 Regulatory Determination, 65 FR 3224, potential damage cases are those

with (1) documented exceedances of primary MCLs or other health-based 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. Currently, there are 113 confirmed potential damage cases. Similarly to the proven damage cases, these cases hail from the very same

resources. Finally, there are four additional, state-endorsed damage cases from Wisconsin. While EPA has insufficiently-detailed information (including the extent, if any, that the contaminants have
Ninety seven of the 113 ‘potential’ damage cases are accompanied by individual, site-specific modules in the damage case compendium. These modules can be recognized by their prefix: all those damage cases that are designated as ‘potential’ based on a reassessment of the inventory included in EPA’s 2007 report and in the 2010 proposed rule are included in document IIa (case numbers PTa01 to PTa42). All those damage cases that are designated as ‘potential’ based on an assessment of the ‘newly alleged’ damage cases included in the three reports by the environmental advocacy groups are included in the two-volume document IIb (case numbers PTb01 to PTb32 in Part One, and case numbers PTb33
**Rejected Damage Cases** :
This tab contains all those CCR damage cases that were included in the four reports cited above; some, such as those in EPA’s 2007 report, were designated as ‘rejected’ from the outset; the remainder have failed EPA’s renewed scrutiny. For a CCR damage case to be rejected, it has to fail at least one of the following criteria: (1) the disposal setting, and/or the original boiler combustion residue, and/or the generating sector of the CCR is out of scope of the final rule (e.g., disposal in open coal mine pits; and/or waste from oil-fueled boilers, and/or CCR from industrial- or other non-utility electrical facility boilers); (2) CCR has been commingled with other waste types (such as hazardous waste) to the extent that masks the role of CCR in the resulting contamination; (3) the information at hand is inadequate to
Cases from three distinct categories ended under this tab: (i) those of the original 18 cases designated in EPA's 2007 report as ‘rejected’ (cases #68-85) that are now re-designated as ‘potential’ or ‘proven’ based on new information obtained since that report was issued; (ii) those cases that were originally designated in the 2007 report as ‘potential’ or ‘proven’, but upon reassessment failed the scrutiny of EPA’s ‘test of proof’ criteria. These cases are re-designated as ‘rejected’; and (iii) the remaining damage cases, designated in the 2007 report as ‘rejected’, that in the wake of the reassessment have retained
The ‘rejected’ cases that are referenced to the three environmental advocacy group reports have been submitted to EPA among a total of 90 ‘newly alleged’ damage cases. Upon assessment of all these cases, EPA decided they do not qualify as confirmed damage cases for one or more of the reasons discussed above, and consequently designated them as ‘rejected’. For details, see the information
Fifteen of the ‘rejected’ damage cases are accompanied each by a site-specific module in the damage case compendium of the technical support document on damage cases. A link to these ‘rejected’ damage case modules (R01 to R15) is provided in the cross-walk column of the ‘rejected’ tab of the spreadsheet

.

### Similar links are also provided in the crosswalk column for those cases that while originally designated as ‘rejected’ are now re-designated as ‘proven’ or ‘potential’ (e.g., PR08, re-designated as

### Abbreviations:GW- groundwater; SW - surface water; Ecol - ecologic; LF - landfill; SI - surface

impoundment; S&G - sand and gravel; WU - waste unit; BU - beneficial use; CCW – coal combustion waste; RTC – Report to Congress; FFC – fossil fuel combustion; UST – underground storage tank; DC – damage case; OU- Operational Unit; TCLP – toxicity characteristic leaching procedure; COC – Contaminant of Concern; TDS = total dissolved solid; TSS - total suspended solid; Sf - sulphate; NOV - Notice of Violation; NOD – Notice of Deficiency; CO - Consent Order; COA - Consent Order Agreement; CCA – Compliance Commitment Agreement; ROD - Record of Decision; RI - Remedial Investigation; FS - Feasibility Study; MCL - Primary Maximum Concentration Level; SMCL - Secondary Maximum Concentration Level; ES - Enforcement Standard; PAL - Preventive Action Level; WQS - Water Quality Standard; AWQC - Ambient Water Quality Criteria; PDWS - Primary Drinking Water Standard; SDWA - Secondary Drinking Water Standard; CCC - Chronic Criterion Concentration; LHA - Life Health Advisory;
**Standard Symbols:** COCs/GW and COCs/Surface Water columns: **Ni**(or any other monitored constituent) – a reported exceedance; **(Ni)**(or any other monitored constituent) – an exceedance thatindustry rejects, claiming the alleged exceedance is due to one of the following: an outlier, a nonAction columns on the right hand side end of each tab (e.g., NOV, CO/Admin Order, etc.): **Y**– the measure associated with this column’s header was or is being implemented; (**Y**) – the measure is yet to

[1] Prior to the June 2010 propose CCR rule, EPA used the term Coal Combustion Waste (CCW) in lieu of CCR. [2] EPA (2007): 2007 Coal Combustion Waste Damage Case Assessments: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2006-0796-0015 [3]Out of Control: Mounting Damages from Coal Ash Waste Sites; Environmental Integrity Project, EarthJustice; February 24, 2010: http://www.environmentalintegrity.org/news_reports/news_02_24_10.php [4] 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, http://www.environmentalintegrity.org/news_reports/08_26_10.php [5] Risky Business: Coal Ash Threatens America’s Groundwater Resources at 19 More Sites. Environmental Integrity Project Report, Dec. 13, 2011; also: EPA-HQ-RCRA-2011-0392-0259. http://www.environmentalintegrity.org/documents/121311EIPThirdDamageReport.pdf [6] A key source for industry’s perspective on damage cases is: Evaluation of Coal Combustion Product Damage Cases, Volumes 1 and 2: 1020554, EPRI Final Report, September 2010. http://www.epri.com/search/Pages/results.aspx?sq=1&k=Evaluation%20of%20Coal%20Combustion%20Product%20Damag e%20Cases [7] http://www.epa.gov/osw/nonhaz/industrial/special/fossil/surveys2/index.htm [8] http://www.epa.gov/osw/nonhaz/industrial/special/fossil/surveys/index.htm [9] A major part of the assessment and reassessment of the damage cases record was performed by ICF International. The following documents are included in the docket of the final rule (EPA-HQ-RCRA-2009-0640):

Assessment of Previously Identified Proven Damage and Recently Alleged Damage Cases. ICF International. Prepared for U.S. EPA, Office of Resource Conservation and Recovery, EPA Contract No. EP-W-07-003, Work Assignment No. 3-88. October Appendix A: Reassessment of Previously Identified Proven Damage Cases (EPA 2007 and proposed rule). Appendix B: Assessment of February 2010 Alleged Damage Cases (Out of Control). Appendix C: Assessment of August 2010 Alleged Damage Cases (In Harm’s Way).[10] Volumes 1-5 of the technical support document on damage cases (Compendium) are included in the docket to the final

rule (EPA-HQ-RCRA-2009-0640).**No. Crosswalk**  **Facility Location**  **State References**  **Waste Unit Type**

1 PR01 Plant Bowen, Georgia

Power Cartersville,

Bartow Co. GA CCW DC Ass #8 One Primary, unlined SI; and an ash stack.

2 PR02 Eagle Valley Station,

Illinois Power & Light Martinsville IN Response to U.S. EPA l04(e) Information Request, 2009 Five unlined

impoundments

3 PR03 Gibson Generating

Station Plant, Duke Energy Princeton IN Out of Control #6 2 LFs (one of which is unlined - implicated), 4 Primary SIs (implicated) and 2 settling/decant basins, and a-3,500 acre Cooling Reservoir (implicated).4 PR04 NIPSCO Yard 520 Pines IN CCW DC Ass #19 LF & BU

5 PR05 BBSS S&G Quarries,

Constellation Energy Gambrills MD CCR Proposed Rule, 6/2010 2 S&G pits

6 PR06 Morgantwon Faulkner

Offsite Landfill, PEPCO (Mirant, GenOn, NRG) Morgantown,

Charles Co. MD CCW DC Ass #5 and MDE Notice of Intent to Sue Mirant , January 3, 2011 3 LFs & 3 associated sets

of stormwater/ leachate management ponds (implicated); artificial wetland.

7 PR07 Range Road Landfill,

Detroit Edison East China

Township MI EPA-HQ-RCRA-2009- 0640-6815, Attachment 5. An offsite LF

8 PR08 JR Whiting Generating

Plant, CMS/Consumers Energy Erie MI CCW DC Ass #76 6 Primary Sis; SIs #3, #4, and #5 are implicated.9 PR09 North Lansing Landfill, Lansing Board of Water & Light North Lansing MI CCW DC Ass #18 and EPA-HQ-RCRA-2009- 0640-6815, Attachment 5. S&G pit

10 PR10 Colstrip Power Plant,

PPL Montana Colstrip MT Out of Control #10 14 active ponds (including evaporation ponds), 5 inactive ponds, 2 ponds that are capped and/or reclaimed, and a 160-acre Cooling Lake. Both Primary and Secondary Ponds implicated.

11 PR11 Reid Gardner

Generating, Nevada Energy Moapa NV Out of Control #18 Originally: 3 SIs, 5 evaporation ponds; LF, Both dry and wet disposal WUs implicated. Recently: 8 evaporation ponds (zero discharge cooling system).

12 PR12 Cayuga Coal Ash

Disposal Landfill, AES Lansing NY In Harm's Way #22 (Table C) LF (implicated) and

Leachate Pond (possibly implicated)

13 PR13 Don Frame Trucking

Fly Ash Landfill Pomfret NY CCW DC Ass #3 Offsite LF, preceded by a structural fill.14 PR14 Belews Lake Station, Duke Energy Stokes,

Rockingham, Guilford, and Forsyth counties. NC CCW DC Ass #11 SI discharge into cooling reservoir.

15 PR15 Dan River Steam

Station, Duke Energy Eden NC NC DENR, Feb. 2014 2 contiguous SIs (one Primary and one Scondary)

16 PR16 Hyco Lake Roxboro NC CCW DC Ass #7 SI discharge into cooling reservoir.

17 PR17 Swift Creek Structural

Fill Site ReUse Technology Rocky Mount NC Out of Control #14 Struct Fill18 PR18 Conesville FGD Landfill, AEP Conseville OH CCW DC Ass #63; EPRI (1984) FGD sludge (Poz-O-Tec)

LF associated with an FGD emergency sludge pond (implicated), a closed (1988) LF; and 4 SIs: Fly Ash Storage, Fly Ash Pond, Bottom Ash Pond, and Clearwater Pond. SIs are dredged and contents transferred to LF.

19 PR19 Bruce Mansfield

Power Station, First Energy Shippingport PA In Harm's Way #29 One, very large disposal SI

**No. Crosswalk**  **Facility Location**  **State References**  **Waste Unit Type**

20 PR20 Fern Valley Landfill,

Orion Power Holdings Elrama PA Out of Control #22 LF (implicated) with a leachate collection/storm water pond.21 PR21 Hatfield's Ferry Power Station, Allegheny Energy Masontown PA In Harm's Way #30 LF (Phases 1, 2, and 3).

22 PR22 Martins Creek Power

Plant, PPL Mt Bethel

Township PA CCR Proposed Rule, 6/2010 4 SI: two closed (# 2 &3);

one retired during the spill and partially closed since 1999, and completely closed afterwards (# 1, implicated in GW impact), and one active during spill (# 4, implicated in dike breach) subsequently decommissioned. 23 PR23 Canadys Plant, SCE&G Walterboro SC CCW DC Ass #10 2 Primary SIs. Old pond deactivated 1989 and a new one kicked in (both implicated). Also, waste water treatment ponds (i.e., Coal pile runoff basins #1 and #2, coal pile runoff detention basin, low-volume waste ponds A, B, and C, and spray pond.

24 PR24 Savannah River DArea, DOE Savannah River SC CCW DC Ass #12 SIs: two (Primary) settling basins and a drainage swamp - all implicated. In 2001, switched to a LF, with cells being closed/ capped as they fill up.25 PR25 Urquhart Station, SCE&G Beech Island SC Out of Control #26 LF & SIs (2 Settling basins, receiving only small amount of fly ash and stormwater, and dredged every 12-18 months - implicated). Also, wastewater treatment ponds (i.e.,metals pond, lowvolume waste pond, ashlandfill runoff basin, lowvolume waste polishing pond, and stormwater runoff pond.)

26 PR26 Kingston Fossil

Station, TVA Harriman TN CCR Proposed Rule, 6/2010 **Before 12/2008:**Several

SIs (implicated in spill) and stacking area - Main Ash Pond, Stilling Pond, Fly Ash Stacking Area (Dredge Cells 1 and 2 & Emergency Dredge Cell),and Stack RunoffLeachate Pond. **Post spill:** all pond areas (with the exception of the stilling pond) converted to ash stacking areas, and a new gypsum dewatering facility (implicated).

27 PR27 Oak Ridge Y-12 OU# 2,

DOE Oak ridge TN CCW DC Ass #9 Ash retention SI and an abandoned (Lst.?) quarry. Presently LF (not implicated). 28 PR28 CCW Landfill, Trans

Ash Inc. Camden TN Out of Control #29 Gravel Pit serving as an Offsite Landfill/Structural Fill 29 PR29 Pirkey Power Plant

Brandy Branch Reservoir, SW Electric Power Marshall TX CCW DC Ass #20 SI discharge into cooling reservoir30 PR30 Martin Lake Power Plant, Texas Utilities Electric Tatum, Rusk and

Manola counties. TX CCW DC Ass #22 Cooling Reservoir (5020 acre) receiving unpermitted stormwater discharge from SIs

31 PR31 Welsh Reservoir,

Southwestern Electric Power Mount Pleasant TX CCW DC Ass #21 SI discharge into cooling reservoir

32 PR32 Clinch River Power

Plant (Carbo powerplant), AEPAppalachian Power Cleveland VA In Harm's Way #36 2 SI (only Area 1 is active - implicated in spill; Bottom Ash Pond Area 2 was closed in 1998) and LF.

33 PR33 Glen Lyn Plant,

AEP/Appalachian Power Glen Lyn VA In Harm's Way #37 SIs (2): a fly ash pond(since 1965) and a multiunit bottom ash pond (1963) - implicated. Also (not implicated) a LF (1980?-2007?) and a structural fill (2007- ) on the New River.34 PR34 Chisman Creek, VEPCO Yorktown VA CCW DC Ass #6 4 (now abandoned) sand and gravel pits and three man-made ponds.

35 PR35 John Amos Power

Plant, AEP/Appalachian Power Co. Winfield/St.

Albans WV Out of Control #30 6 SIs (One large - fly ash - implicated in surface water impact; five, smaller - bottom ash, one of which is closed); 3 LFs.

36 PR36 Cedar Sauk Ash

Landfill, WEPCO Cedarburg WI CCW DC Ass #16 S&G pit

37 PR37 Columbia Energy

Center, Alliant Energy Pardeeville WI In Harm's Way #38 3 SIs (apparently - all implicated): primary ash pond, secondary ash pond, and a small polishing pond; also a cooling pond and a LF stormwater pond.38 PR38 Highway 59, We Energies Waukesha WI CCW DC Ass #14 S&G pit

39 PR39 Oak Creek Power

Plant, Wisconsin Energy/Wisconsin Electric Power Co. Oak Creek 

### WI EPA R5 cleanup bulletins and general media. Old Structural Fill

(implicated). Also: 3 LFs (two closed and one - Caledonia - active).

40 PR40 E.J. Stoneman,

Dairyland Power Grant Co. WI CCW DC Ass #13 Primary SI

**No. Crosswalk**  **Facility Location**  **State References**  **Waste Unit Type**



### Abbreviations: GW- groundwater; SW - surface water; Ecol - ecologic; LF - landfill; SI - surface impoundment; S&G - sand and gravel; WU - waste unit; BU - beneficial use; CCW – coal combustion waste; RTC – Report to Congress; FFC – fossil fuel combustion; UST – underground storage tank; DC – damage case; OU- Operational Unit; TCLP – toxicity characteristic leaching procedure; COC – Contaminant of Concern; TDS = total dissolved solid; TSS - total suspended solid; Sf - sulphate; NOV - Notice of Violation; NOD – Notice of Deficiency; CO - Consent Order; COA - Consent Order Agreement; CCA – Compliance Commitment Agreement; ROD - Record of Decision; RI - Remedial Investigation; FS - Feasibility Study; MCL - Primary Maximum Concentration Level; SMCL - Secondary Maximum Concentration Level; ES - Enforcement Standard; PAL - Preventive Action Level; WQS - Water Quality Standard; AWQC - Ambient Water Quality Criteria; PDWS - Primary Drinking Water Standard; SDWA - Secondary Drinking Water Standard; CCC - Chronic Criter**Liner Year Commissioned**  **Year Damage Noted**  **Failure Mode COCs/GW** 

Originally: No; at a later stage, lined with geosynthetic clay liners (GCL) or HDPE liners, and/or clay soil liners. 1968 2002 (sinkhole); 2008 (dry ash pile collapse) SW, Sediment,

Ecologic

No 1956; reconfigured in 2003. 2007, 2008 SW

SIs: No; LF: partial 1970s SW: 2003; GW: 2007 GW (mounding

conjectured), SW/Ecol (Elevated Se in fish and fish mortality; elevated hatching mortality of endangered Least Tern) **Primary MCL** (onsite):

As; **EPA Child Health Advisory**  **(HAL**; Offsite): B; **Drinking Water Advisory**  : Na; **SMCL** (onsite): Fe, Mn.Clay - below the South LF;

none beneath the North LF. North: 1966; South: 1983. 2000 GW, Soils, SW **Health-based standards** (in offsite water wells): B, Mo, As, Pb, Se; **SMCL**: Fe, Mn, Sf

Compressed Fly Ash 1995 1998 GW, Fugitive Dust **MCL**: As, Cd, Pb, Tl, Be, Ni; **SMCL**: Al, Mn, Sf, Li

No 1970; 1979; 1989 1991 GW & SW; Ecol (veget. Damage) **MCL**: Cd; **SMCL**: Fe, pH

(onsite: Al, Cl, Mn, Fe, Sf, TDS)

No Early 1950s 1995 GW & SW **State's health-based standards**  : B, Li, Mn

No 3 Implicated ponds: 1959 and 1974; the other 3 ponds: 1952, 1980. 2008? SW/Ecol SedimentsNo 1980 1993 GW **MCL**(Onsite): Pb, Se; **State standard** : Li; **SMCL**: Mn, B, Sf

Originally unlined or claylined. Progressively lined with a single or double geosynthetic liner(s), some w/leachate detection/collection system(s). Plant switched to high-density paste slurry system. 1975-76 (2); 1975; 1983 (2); 1988 (1); 1992 Early 1980s GW & SW **MCL**: Se, As; **WHO Drinking Water MCL**  : Mo; **SMCL**: B, Cl, Sf, TDS

SIs: No LF: No. Recent 8 evaporation ponds have double (HDPE geomembrane) liners and leak detection/ collection systems. 1976 1997 GW, SW, Fugitive Dust **MCL**(offsite GW): As;

**MCL**(onsite GW): As, Cr, Nitrate, Se, V; **SMCL**: Mo, B, Cl, Mg, Mn, Ti, Na, Sf, TDS

LF Phase I: No; LF Phase II: Composite 1980s 2000 GW & SW **MCL** (Offsite ): Pb, Se; **MCL**(Onsite): As, Cd, Se; **SMCL**(Offsite): Fe, TDS; **SMCL**(Onsite): Al, Mn, Sf, TDS; **State's GW Standards**  : As, Se. **Unspecified drinking water standards:**  Ba, B, Na, Ammonia

No 1971 1989 GW, SW/Sediments, Soils **MCL**: Pb; **SMCL**: Mn, Fe

TDS, SfNo 1970s 1974 SW/Ecol

No 1956; raised in 1968/69 and 1976/77, reconfigured 1976/77. 2014 SW

No 1964 1974 SW/Ecol

No 1991 2004 GW **MCL**(onsite and offsite): As, Pb; **State's groundwater quality**  **standard (2L)**(onsite and offsite): SfLF and SIs: No. The

emergency sluge pond: No (1977-1978), then a Poz-O-Tec liner that was frequently disrupted by dredging. The later (1993) LF expansion: composite liner. SIs: 1950s ;LF: 1/1977 1979/80 GW **PDWS**(Onsite and offsite): Pb, Cr; **PDWS** : (Onsite): As, Cd, Cr, Se; **SDWS**(Onsite): Ca, Mg, Sf, Fe, TDS

No 1977 1993 GW & SW **MCL** (Offsite & Onsite): As, Cd, Pb, F, Ba; **SMCL** (Offsite and Onsite): B, Cl, Sf, Fe, Mn, Na, Al, pH, TDS, TSS

**Liner Year Commissioned**  **Year Damage Noted**  **Failure Mode COCs/GW** 

3' Poz-O-Tec over bottom ash and drain system. Landfilling might have diverged outside the lined

area. 1979 (?) or 1989 1995 GW, SW, ecologic **MCL** (Onsite): As; **SMCL/Health Advisories** (Onsite): B, Cl, Sf, TDS;Phases 1 & 2 LF: No, but

w/leachate collection system. Phase 3 LF (2009): composite (double synthetic) liner system and a lined leachate storage impoundment. Until 2001, leachate and wastewater were discharged directly to an unlined SI; since then - into an artificial wetland. Since 2007, an FGD disposal system: equalization basin, 4 wetland cells, 5 rock drain cells, and a sedimentation pond. 1984 2001 GW, SW, ecologic **MCL**(Onsite): As; **EPA's HAL** : B; **EPA's RAL**: Mo; **SMCL**: Mn,Sf, Al, TDS.

No. 1: No; Nos. 2 & 3: unknown; No. 4: lined with a 36-mil, synthetic, reinforced-rubber (Hypalon) liner system. During breach of No. 4, Plant's ash was diverted temporarily to No. 1. 1955 2005 GW, SW **MCL** (Onsite): Se, (Cr); **SMCL**(Onsite): (Fe).

Old pond: No; New (1989- ) pond: Bentonite slurry wall. Slurry wall failed. 1974 1988 1982 2008 GW **MCL** (Offsite): As, Ni; (Onsite): Se.

No 1950s Mid 1970s SW/Ecol, SedimentsNo LF: Late 1980s to mid1990s; settling basins: 1977 1989; 2007 GW, Soil **MCL**(Offsite and Onsite): As; **State's DWS** (Onsite): Ni.

Old WUs: No; The Gypsum dewatering (2010): initially - clay, replaced by an HDPE liner after impacted by a sinkhole. 1950s 2008 GW, SW/Sediments, Soils, ecology **MCL**: Se; **Life Health**

**Advisory (LHA)** : Mn; **Federal health-based guidelines**  : Co; **SMCL**: Sb, Al, Ammonia.

No 1955 1989 SW/Ecol, GW **SMCL**: Al, Mn, Fe, Zn;

0.25" geosynthetic, partial and improperly installed 2002 2005 GW & SW, Sediment **MCL** (Offsite) Hg;

(Onsite): As, Cr, Pb, Hg.

No 1983 1986 SW/EcolNo 1974 1978 SW/Ecol

Apparently No 1976 1981 SW/Ecol

No 1954-55 1967 SW/Ecol

Fly ash pond: 1-3" clay. Bottom ash pond: No. 1963, 1965 Late 1970s SW/EcolNo 1957 1980 GW & SW **MCL**: Ni, V, Se; **SMCL**: Sf

SIs: No; LF - ? 1971 1974 SW/Ecol

No 1969 Early 1980s GW, Ecol **MCL**: Se; **SMCL**: Sf; **State standard (WQS)** : B

SIs: No; LF storm pond: HDPE. 1974 1977 SW/Ecol, GW **SMCL**: B, Na, SfNo 1969 1988 GW **State Preventive Action Level (PAL** , Offsite): As; **State Enforcement Standards (ES** , Offsite): B, Mo, Mn, Fe, Cl, Sf. **State PAL** (Onsite): Se, Cl; **State ES**(Onsite): B, Mn, Fe,Sf; **SMCL**: TDS.

2 Inactive LFs: probably No; Active LF: Clay (Phase I); Composite w/ leachate collect (Phase II). Structural Fill: No 1960s & 1974; Fill from 1950s to late 1960s 2002 or

earlier; Fill's partial collapse: 10/31/11 SW: Fill collapsed

into Lake Michigan

No 1950 1976 GW **MCL**(Offsite): Cd; SMCL (Offsite): B, Fe, Mn, Sf; **MCL**(Onsite): Cd, Cr; **SMCL**(Onsite): Ba, Sf, Mn, Fe

**Liner Year Commissioned**  **Year Damage Noted**  **Failure Mode COCs/GW** 



### Abbreviations: GW- groundwater; SW - surface water; Ecol - ecologic; LF - landfill; SI - surface impoundment; S&G - sand and gravel; WU - waste unit; BU - beneficial use; CCW – coal combustion waste; RTC – Report to Congress; FFC – fossil fuel combustion; UST – underground storage tank; DC – damage case; OU- Operational Unit; TCLP – toxicity characteristic leaching procedure; COC – Contaminant of Concern; TDS = total dissolved solid; TSS - total suspended solid; Sf - sulphate; NOV - Notice of Violation; NOD – Notice of Deficiency; CO - Consent Order; COA - Consent Order Agreement; CCA – Compliance Commitment Agreement; ROD - Record of Decision; RI - Remedial Investigation; FS - Feasibility Study; MCL - Primary Maximum Concentration Level; SMCL - Secondary Maximum Concentration Level; ES - Enforcement Standard; PAL - Preventive Action Level; WQS - Water Quality Standard; AWQC - Ambient Water Quality Criteria; PDWS - Primary Drinking Water Standard; SDWA - Secondary Drinking Water Standard; CCC - Chronic Criter**COCs/SW Regulatory Action**  **Current Status Comments** 

**EPA Region IV ecological sediment screening**  **values (ESVs)** : As, Cd, Cr, Pb, Hg, Ni, Cu State/CO, requiring, among others, a fine and corrective action. Active/modified **2002** : Sinkhole developed, releasing slurry to creek (2.25 million gallons of ash/water mixture was released to a tributary of the Euharlee Creek, containing 281 tons of ash); elevated Se and Cd in invertabrate fauna. **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. ~ 40 tons of ash was released with ~ 2 tons of ash reaching Euharlee Creek. ~ 14 offsite properties in the neighborhood were affected. CERCLA cleanup ensued.

No data State/CO (2008). IDEM assessed IPL a $23,800 civil penalty, required IPL to study the site, submit its findings to IDEM, implement repairs, and follow up with regular inspections. Active Two pond dike breaches, w/30 million gl of spilled slurry each. IPL submitted a root causal analysis associated with the second levee breach and levee repair recommendations to IDEM and initiated external qualified professional inspections of all of its levees in June 2008.
**EPA’s recommended Criterion Continued**  **Concentration (CCC) in water: Se** ; Unspecified standard: As, B None. Voluntary closing of cooling lake to fishing. Duke supplying (voluntarily) bottled drinking water to homes w/affected/closed wells; no enforcement action by the State. IDEM considers the surface impoundments as temporary CCR storage areas that are exempt from solid waste regulations. Active Closed loop water system (no NPDES). CCR is periodically scooped out of the SIs and sent to an on-site CCR LF. Gibson Lake and wetlands are part of a designated Important Bird Area (IBA) and are vital habitat and migration grounds for numerous bird species. From 2003-2008, the cooling lake discharged into the Cane Ridge Wildlife Management Area, a 463-acre section of the Patoka River National Wildlife Refuge, contaminating the water, soil and biota with selenium levels that posed a high hazard to wildlife.**Largely exceeded**

**background values** : B, Ammonium. State/AOC Inactive Groundwater mounding beneath the North Landfill. Soil: Crvi, As. **A Superfund Alternative site.**  Remediation included a clay barrier between the South and North sectors of the LF, and a 2-stage closure of the LF (including a clay capping), and a Supplemental Closure Plan for contiguous areas. Two AOCs, Human health and ecological risk assessments and a draft remediation feasibility study; and an ongoing radiation survey/study. State/CO, $1 million penalty;supply of alternative water. Outof-court settlement of $54 million. Inactive/2007 Pump and Treat; mitigation plan in place.

Water quality standards: Cd, Cu, Pb, Se; **elevated TSS (>30 mg/l):** TDS;**chronic national non priority pollutant water**  **quality standard** : Cl; Fe; pH (2.65 - 4) State/CO; State and citizens' lawsuit in Federal court Closed (2010) Protracted history of violations and remediation efforts. Liners in newer units ('93); slurry wall ('94-'95); closure and clay-bentonite capping of older units ('97); a leachate collection and treatment system in expanded LF; artificial wetland (2002). CO (2013) requires cap and seal of all closed cells in the LF and install liner systems in all leachate and stormwater collection ponds, perform a study to characterize the levels of contamination at the Site, and develop and implement a plan to control fugitive CCR dust.

**State's health-based standards**  : B, Li, Mn RI/FS; slurry wall installation; leachate collection; hydrological monitoring and Remedial studies. Active (Cuthbertson to Livnat, 11/9/2010 email). One of the three associated plants retired (2001), and another one is on the verge of retirement. Leachate migrating off-site in GW and

reaching 2 small ponds (no drinking water source affected).

Elevated As, Se, Br (in Oligochates); **several time toxic threshold**  : Se; Br, Co, Ni, Cr (in Fish and their natural feedstock); As, Co, se, Ni (in Sediment) State: Final closure of the implicated ponds was approved in 2005 and is nearing completion. Some Active, some not In recent years, fly ash disposal at the

plant has been minimal, with most being sold for reuse by cement manufacturers; the rest is landfilled. Plant was a candidate for retirement by the end of 2015, but retirement date deferred to April 2016.Groundwater mounding. State/Remedial Action Plan Response action plan, RI/FS to determine the extent of contamination, and the development of a Remedial action Plan, to address the release. A soil-bentonite slurry wall was constructed around the perimeter of the facility in 2008.

**Recommended threshold for cattle**  : Sf State issued, in 8/2012 a CO. Previous corrective action involved installing hundreds of monitoring wells, lining the more recently installed SIs with a rubber-like liners, introduction of a pump-and-treat system, seepage capture trenches, and forced evaporation. Some active, some not Designed as Zero Liquid Discharge (ZLD)

facility. Leaking ponds have been either retrofitted or closed, and in 2004 the Plant switched to a low-water, paste slurry system.

**Excessive' (no standard specified):** As, Cd, Ba, B, Fe, Mg, Mn, Mo, Al, Cl, Sf, TDS 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 GW at the Site. Some active, some not Closure of some of the unlined ponds.

Three of the Plant's four generation units (Units 1-3) are slated to close by the end of 2014, with the fourth generation unit (Unit 4), to close in 2017.

**Federal WQCs. Standard for protection of human**  **health from surface water ingestion and fish**  **consumption:** As**; Acute toxicity standard for**  **aquatic life:** Cd **; Chronic toxicity standard for**  **aquatic life:** Se; **Unspecified standards** (in sediment): Cr, Zn State/NOV for excess disposal Inactive (Phase I), Active (Phase II)

**Higher levels than control streams, but no**  **exceedances:**Mn, Sf State required remedial action, court order to cease receiving wastes. Inactive/1988. Dunkirk Steam Station mothballed in 3/2012. An 1975-77 study provides early

information on composition of leachate/shallow GW in onsite wells and surface water ponds, and bioaccumulation of iron and manganese in biota residing there.**Draft freshwater**

**Chronic Criterion Concentration (CCC):** Se in fish State/CO, Fish advisory. State required operating changes to mitigate contamination. Active/modified



### Surface Water **Standard:**As, Cu, Fe, Al Failure of a 48" diameter metal storm sewer line that runs under the inactive ash pond released about 27 million gallons (between 30,000-39,000 tons) of CCR slurry into the Dan River. NC DENR issued two NOV (2/2014), and NC DHHS issued an advisory against eating fish and shellfish from the Dan River downstream of the spill. Plant retired April 2012, but implicated pond still contained water when the 2/2014 failure/release occurred. Duke permanently plugged the

breached sewer pipe and stopped the ash slurry’s flow into the Dan River in about six days. In mid-July 2014, Duke Energy completed the cleanup (suction dredging of 3,000 ton of CCR) of the Dan River. In a March 12, 2014 letter to NC’s Governor and DENR, Duke Energy committed to clean-close the plant’s inactive ash ponds 'within 24 to 30 months once the destination for the ash is determined and the necessary permits secured.'

**Health Advisory standard**  : B; **Draft freshwater Chronic**  **Criterion Concentration (CCC)**  : Se in fish; **HAL:**B State/Fish advisory; stopped temporarily wet handling and introduced wastewater treatment. The NC DEWQ is requiring long-term monitoring of the lake. On March 3, 2014, DENR issued to the Roxboro Steam Plant a Notice of Violation for failing to secure a storm water permit. Active

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. ) Inactive Three of the five coal-fueled plants still operating; one coverted to biofuel, and one decommissioned.State/LF capped by a 2’ clay cap with 6” topsoil cover in 1988. The utility voluntarily monitored GW starting in the late 1970s (55 wells reported in 2002); no monitoring is presently required. Post-closure inspections continue. Inactive/1988 Generation Units 1 and 2 (125 MW capacity each), were shut in 2005 due to corrosion fatigue. Unit 3 (162 MW), slated for retirement by end of 2012.

**State's WQC** : As, Sb, Cd, Hexavalent Cr, Pb, Tl; **State's Chronic Water Quality Standards**  : Se, B; **Health Advisory** : Mo. State/settlement Agreement; 2 NOVs (dust). A remedial plan for the impacted springs. Settlement agreement (6/1994) for GW contamination: FirstEnergy was required to provide an alternative water supply to a private residence. Contaminated private property buyouts by FirstEnergy. Active Closure to start 2017 and proceed for 12 years.

**COCs/SW Regulatory Action**  **Current Status Comments** 

**State's CCC** : Se. 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. Inactive/2007 FGD, one of the disposed-off materials, might have blocked infiltration and contributed to mounding of perched GW inside the LF, thus affecting so called up-gradient monitoring wells. PADEP attributes exceedances to AMD from an up-gradient, abandoned surface coal mine and leachate from the side-gradient, unlined Clairton MSW landfill.**NPDES Violations** : Tl, Al,

Mn; **State's CCC** : Cr, B, Se; **Federal Water Equivalent**  : Mo; **SMCL**: pH, TDS State/COA. PADEP does not deny exceedances of B, Mn, sulfate and TDS, but attributes them to AMD associated with past coal mining activities in the landfill’s watershed. Some Active, Some Not. The Plant closed at the end of 2013. PADEP attributes exceedances to AMD

associated with past coal mining activities in the landfill’s watershed. Artificial wetland fails to properly treat for B, Se, and Mo.

**Pennsylvania's WQC** (Offsite): As, Pb, Cu, Al; **New Jersey's WQC** (Offsite): As, Pb State/NOV, CO All four basins are inactive. Plant's 2 coal-fired units closed 2007 (demolished 2009) due to air pollution impacts on New Jersey. Karstic terrain. **Dike failure; release of**

**100 million gallons of coal ash slurry**

. Subsequent actions included closure of the SI and suction dredging for removal of the fly ash from the Delaware river bottom and the other impacted areas. The part of the Delaware River on which the Martins Creek plant is located was designated by Congress as the Lower Delaware Wild and Scenic River in 2000.

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. Inactive since Plant's closure (Nov. 2013) Operator was allowed to buy

neighboring property under State policy. In 1996, DHEC approved a mixing zone and compliance boundaryto accommodate plume from old (pre1989) pond. Mixing zone/compliance boundary expanded to include the new (1989-), active SI. Vertical extent of plume was limited by a confining geologic unit 15-30' below the property.

**Acute WQC** : Cd, Cr, Cu, Hg, Se, Zn; **Acute and Chronic WQC**  : Al, Fe. State/Federal: ROD, capping, and institutional control. Some active, some not Final remediation of the site is expected

to begin in 2015, concurrent with closure of the coal-fired power plant.Soil (**Source and**

**standards unknown** ): As, Ba, Cr, Co, Hg, Ni, Zn, Mn. None as of the start of 2010. 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 As from ash basins. Active Arsenic plume affects only the shallow, unconfined aquifer. DHEC entered into a Consent Agreement with SCE&G for the closure of the landfill and in 6/2011, approved the closure plan. Generation Unit 3 - the last coal-fueled unit at Urquhart - was converted to burn natural gas in 2012. The Plant's remaining two units would be retired by 2018.

**Fish threshold of toxicity for reproduction**  **and growth** : As; (Sediment); **Residential Superfund soil screening**  (soil): As, Co, Tl, Fe. (Sediment pore waters) **toxic level for sensitive benthic invertebrates**  : As State/CO, Fish advisory; Federal/CERCLA, impact studies. District judge established that TVA is legally responsible for the December 2008 incident and that TVA would have to pay unspecified damages to more than 800 plaintiffs (8/2012). In response to the appearance of the sinkhole in the FGD landfill, on December 17, 2010, TDEC issued an Enforcement Order for Corrective Action for KIF’s violation of both the State’s Water Quality Control Act and the State’s Solid Waste Disposal Act. Active Dike failure (12/2008) and contamination of GW due to a sinkhole (12/2010).

**Max concentration for protecting aquatic life**  : As;**Fish tissue toxicity level**  : Se, As, Tl (?). State/Federal: **NPL**, RI, Remedial Action. Inactive Remedial Action completed 1997. Due to 'unclean closure', site is being monitored and under institutional control. **Unknown standards** : SW: Hg (?); Sediment: Hg State/Order, 3 NOV (in one case, $160,000 penalty) Active Expansion, with GW monitoring, recently approved. Groundwater mounding. **Toxicity level:** Se in fish State/Fish advisory; Fish Se study Active USWAG claims that the Pirkey plant's SI system was designed as self contained, and that runoff from lignitic coal has contaminated the cooling resrvoir.**Toxicity level:** Se in fish State/Fish advisory, Fish Se study. State required operating changes to mitigate contamination: (i.e., increasing freeboard capacity of the CCR management ponds, lining ponds with synthetic membranes, installing leak detection systems, monitoring ground- and surface water, and biomonitoring of fish). Discharge of ash-pond decant water to the cooling reservoir was eliminated. Active

**Toxicity level:** Se in fish State/Fish advisory, fish Se study. State required operating changes to mitigate contamination. Active Generation Unit 2 of the Welsh Plant (528 MW; one of three generation units), slated to retire by December 31, 2014. **EPA's WQC** : Cu, Al, pH None Some Active, some not. Generation Unit 3 (235 MW) to retire by end of 2014; and Units 1 and 2 (470 MW total) would be refueled with natural gas with a capacity of 422 MW by end of 2014. Dike failure; release of 130 million

gallons of coal ash slurry. Subsequent actions included closure of the SI, a cement bentonite-fly ash cutoff wall within the perimeter dike of Ash Pond 1 (1990), and a wastewater treatment plant (1993). All coal-fueled units are slated for closure at the end of 2014.

**State's WQS** : Cd, Cr, Se, As, Zn, pH. **Steep bioaccumulation in**  **duckweed** : Cd, Ni, Cu None (In its comment to the docket, VADEQ Characterizes this incident as a not recent case and a legacy issue which is not an accurate picture of VA's current regulatory program.) Since 2009, fly ash is dry-disposed at the New River Structural Fill. Inactive. Plant is slated to close by end of December 2014. Effluent discharges from the ponds in

the mid- to late 1970s impacted the biota in the stream, reducing the taxon richness and diversity, particularly for macro-invertebrates and fish and impacting microbial measures of aquatic ecosystem function and overall health. Site is karst-susceptible.**WQC** : V, Ni, Sf State/CO Federal/NPL. ROD for OU1 included capping the disposal pits, GW and leachate collection for treatment and to lower the water table beneath the pits, replacement water supply wells to 55 homes with contaminated well water, and post-closure monitoring. ROD for OU2 included relocation of a 600- foot portion of the tributary to minimize contact with the fly ash disposal areas, diversion of surface runoff, and long-term monitoring for the ponds, tributary, and estuary. Inactive/1974. One(out of two) coalfired unit would likely close by 2015 and a second unit would likely be converted to natural gas. Nearby shallow residential wells

became contaminated with nickel, selenium, and vanadium, leachaed from coal ash and petcoke.

**State’s Acute and Chronic water quality**  **standards for the protection of aquatic**  **life** : Se, Hg, As, Cu. State/Compliance Schedule; NOV (2/2009) due to inadequate LF stormwater control resulting in deposition of fly ash in adjacent wetland. Consent Decree (8/1/2014) between citizens groups and APCo to comply with NPDES effluent limitations for Se and Hg in Outlet 003. Active A compliance schedule to meet end-ofpipe chronic toxicity limitations on this discharge in the most recent NPDES permit (7/2007).

**Excessive contents in impacted vegetation**  : B State: Extraction pumping, GW monitoring, and two-phase site capping Inactive/1977 Impact on GW and vegetation damage in wetland.

**Ambient Water Quality Criteria (AWQC)**  : Cd, Cu; **Levels toxic to aquatic life**  : As, Se, Pb, Mn; **Elevated tissue levels in Crawfish (accompanied**  **by impaired metabolic rates)**  : Se, Zn, Fe State/CO Acive Series of impoundments - sulfuric acid added to reduce the pH from over 10 to 8 or lower, as required by the discharge permit. Construct a sanitary wastewater treatment plant.State: Remediation plan, capping, alternative water source to residents. Inactive/1978 Elevated GW Table.

**State's WQC** : Cr, As, TCE, diesel Collapse impact study was a multiagency effort. Structural fill: Inactive Collapse of old structural fill used for

the staging of adjacent Plant expansion landed ~23,000 cu yd in the Lake and in two coastal settlemt ponds. On November 8, 2011, The Sierra Club filed a notice of intent to sue WE.
State/Admin Order for long-tem GW monitoring, closure. Inactive. Plant recently convertedinto a biomassfueled facility. Groundwater displays periodic

mounding. Leachate migrating off-site in GW and reaching 2 small ponds (no drinking water source affected). Since 1989, coal ash has been managed in a double-lined landfill, with leachate collection.
**COCs/SW Regulatory Action**  **Current Status Comments** 



### Abbreviations: GW- groundwater; SW - surface water; Ecol - ecologic; LF - landfill; SI - surface impoundment; S&G - sand and gravel; WU - waste unit; BU - beneficial use; CCW – coal combustion waste; RTC – Report to Congress; FFC – fossil fuel combustion; UST – underground storage tank; DC – damage case; OU- Operational Unit; TCLP – toxicity characteristic leaching procedure; COC – Contaminant of Concern; TDS = total dissolved solid; TSS - total suspended solid; Sf - sulphate; NOV - Notice of Violation; NOD – Notice of Deficiency; CO - Consent Order; COA - Consent Order Agreement; CCA – Compliance Commitment Agreement; ROD - Record of Decision; RI - Remedial Investigation; FS - Feasibility Study; MCL - Primary Maximum Concentration Level; SMCL - Secondary Maximum Concentration Level; ES - Enforcement Standard; PAL - Preventive Action Level; WQS - Water Quality Standard; AWQC - Ambient Water Quality Criteria; PDWS - Primary Drinking Water Standard; SDWA - Secondary Drinking Water Standard; CCC - Chronic Criter**NOV CO/Admin**  **Order Study**  **Extended- or Assmt**  **Monitoring Remedial** 

**Action Lawsuit/Petitio** 

**n/Consent Decree**  **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 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** 

**NOV CO/Admin** 

**Order Study**  **Extended- or Assmt**  **Monitoring Remedial** 

**Action Lawsuit/** 

**Petition/ Consent**  **Decree Fish Advisory/** 

**Fishing Ban Provide** 

**Drinking Water** 



### Y **Y**

### Y **Y Y**  **Y Y** 

**Y Y**  **Y Y**  **Y Y** 

**CO 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**  **Y**

### Y **Y Y**  **Y**

**Y Y** 

**Y Y**  **Y**

**NOV CO/Admin** 

**Order Study**  **Extended- or Assmt**  **Monitoring Remedial** 

**Action Lawsuit/** 

**Petition/ Consent**  **Decree Fish Advisory/** 

**Fishing Ban Provide** 

**Drinking Water** 


### Abbreviations: GW- groundwater; SW - surface water; Ecol - ecologic; LF - landfill; SI - surface impoundment; S&G - sand and gravel; WU - waste unit; BU - beneficial use; CCW – coal combustion waste; RTC – Report to Congress; FFC – fossil fuel combustion; UST – underground storage tank; DC – damage case; OU- Operational Unit; TCLP – toxicity characteristic leaching procedure; COC – Contaminant of Concern; TDS = total dissolved solid; TSS - total suspended solid; Sf - sulphate; NOV - Notice of Violation; NOD – Notice of Deficiency; CO - Consent Order; COA - Consent Order Agreement; CCA – Compliance Commitment Agreement; ROD - Record of Decision; RI - Remedial Investigation; FS - Feasibility Study; MCL - Primary Maximum Concentration Level; SMCL - Secondary Maximum Concentration Level; ES - Enforcement Standard; PAL - Preventive Action Level; WQS - Water Quality Standard; AWQC - Ambient Water Quality Criteria; PDWS - Primary Drinking Water Standard; SDWA - Secondary Drinking Water Standard; CCC - Chronic Criter**Other (Closure) Basis for Consideration** 

Converted to a dry stack operation Scientific & Administrative

Breached dike repaired following each failure. Eagle Valley to retire and be replaced by 2017 by combined cycle gas turbine. Administrative

In the process of switching from wet to dry disposal. ScientificScientific and Administrative

Penalty; out of court settlement Scientific and Administrative

Lawsuit by state Scientific and Administrative

Scientific and Administrative

**Closure** Scientific**Closure** Scientific and Administrative

Lining of SIs. Citizens' suit - out of court settlement Administrative

Scientific and Administrative

Scientific

**Closure** Scientific and AdministrativeState req'd operating

changes (wet to dry; and ash-basin decant water, which continued to receive minor selenium contributions from power plant bottom ash, being discharged into the nearby Dan River) Scientific and Administrative

Administrative

State req'd operating changes Scientific and Administrative

Administrative**Closure** Scientific

Settlement Agreement (1994). Consent Decree (12/2012) and Impoundment Closure Permit (4/2014). Scientific and Administrative

**Other (Closure) Basis for Consideration** 

**Closure.** Plant slated for retirement by March 2014. Scientific and AdministrativeLF Phases 1 & 2

Closed. Scientific and Administrative

Two coal-fueled units (150 MW) permanently closed 2007, but oil/gas - fueled units (1690 MW) still operate. Scientific and Administrative

**Closure.** One of three coal-fired units at the Plant (Unit #1) was retired in late 2012, and the two others - Nov. 2013. Scientific and Administrative

**Closure** Scientific and Administrative**Closure** Scientific

**CERCLA cleanup** Scientific and Administrative

**NPL** Scientific and Administrative

**Penalty** Scientific and Administrative

Scientific and AdministrativeState req'd operating

changes. Scientific and Administrative

State req'd operating changes Scientific and Administrative

**None** ('pre-regulatory era') Scientific

**None** Scientific**NPL/**Capping. Scientific and Administrative

Compliance schedule Scientific

**Closure.** The Plant's four coal-fueled units were replaced with two (545 MW each) natural-gas fueled units in 2005 and 2008. Scientific and Administrative

Scientific and Administrative**Closure** 

### in 1999. In

3/2014, WE Energies was granted permission to convertthe plant from coalfueled to natural gas fueled facility. Scientific and Administrative

**CERCLA cleanup** Scientific and Administrative

**Closure** Scientific and Administrative

**Other (Closure) Basis for Consideration** 



### Abbreviations: GW- groundwater; SW - surface water; Ecol - ecologic; LF - landfill; SI - surface impoundment; S&G - sand and gravel; WU - waste unit; BU - beneficial use; CCW – coal combustion waste; RTC – Report to Congress; FFC – fossil fuel combustion; UST – underground storage tank; DC – damage case; OU- Operational Unit; TCLP – toxicity characteristic leaching procedure; COC – Contaminant of Concern; TDS = total dissolved solid; TSS - total suspended solid; Sf - sulphate; NOV - Notice of Violation; NOD – Notice of Deficiency; CO - Consent Order; COA - Consent Order Agreement; CCA – Compliance Commitment Agreement; ROD - Record of Decision; RI - Remedial Investigation; FS - Feasibility Study; MCL - Primary Maximum Concentration Level; SMCL - Secondary Maximum Concentration Level; ES - Enforcement Standard; PAL - Preventive Action Level; WQS - Water Quality Standard; AWQC - Ambient Water Quality Criteria; PDWS - Primary Drinking Water Standard; SDWA - Secondary Drinking Water Standard; CCC - Chronic Criter

### Abbreviations: GW- groundwater; SW - surface water; Ecol - ecologic; LF - landfill; SI - surface impoundment; S&G - sand and gravel; WU - waste unit; BU - beneficial use; CCW – coal combustion waste; RTC – Report to Congress; FFC – fossil fuel combustion; UST – underground storage tank; DC – damage case; OU- Operational Unit; TCLP – toxicity characteristic leaching procedure; COC – Contaminant of Concern; TDS = total dissolved solid; TSS - total suspended solid; Sf - sulphate; NOV - Notice of Violation; NOD – Notice of Deficiency; CO - Consent Order; COA - Consent Order Agreement; CCA – Compliance Commitment Agreement; ROD - Record of Decision; RI - Remedial Investigation; FS - Feasibility Study; MCL - Primary Maximum Concentration Level; SMCL - Secondary Maximum Concentration Level; ES - Enforcement Standard; PAL - Preventive Action Level; WQS - Water Quality Standard; AWQC - Ambient Water Quality Criteria; PDWS - Primary Drinking Water Standard; SDWA - Secondary Drinking Water Standard; CCC - Chronic Criter

### Abbreviations: GW- groundwater; SW - surface water; Ecol - ecologic; LF - landfill; SI - surface impoundment; S&G - sand and gravel; WU - waste unit; BU - beneficial use; CCW – coal combustion waste; RTC – Report to Congress; FFC – fossil fuel combustion; UST – underground storage tank; DC – damage case; OU- Operational Unit; TCLP – toxicity characteristic leaching procedure; COC – Contaminant of Concern; TDS = total dissolved solid; TSS - total suspended solid; Sf - sulphate; NOV - Notice of Violation; NOD – Notice of Deficiency; CO - Consent Order; COA - Consent Order Agreement; CCA – Compliance Commitment Agreement; ROD - Record of Decision; RI - Remedial Investigation; FS - Feasibility Study; MCL - Primary Maximum Concentration Level; SMCL - Secondary Maximum Concentration Level; ES - Enforcement Standard; PAL - Preventive Action Level; WQS - Water Quality Standard; AWQC - Ambient Water Quality Criteria; PDWS - Primary Drinking Water Standard; SDWA - Secondary Drinking Water Standard; CCC - Chronic Criter

### Abbreviations: GW- groundwater; SW - surface water; Ecol - ecologic; LF - landfill; SI - surface impoundment; S&G - sand and gravel; WU - waste unit; BU - beneficial use; CCW – coal combustion waste; RTC – Report to Congress; FFC – fossil fuel combustion; UST – underground storage tank; DC – damage case; OU- Operational Unit; TCLP – toxicity characteristic leaching procedure; COC – Contaminant of Concern; TDS = total dissolved solid; TSS - total suspended solid; Sf - sulphate; NOV - Notice of Violation; NOD – Notice of Deficiency; CO - Consent Order; COA - Consent Order Agreement; CCA – Compliance Commitment Agreement; ROD - Record of Decision; RI - Remedial Investigation; FS - Feasibility Study; MCL - Primary Maximum Concentration Level; SMCL - Secondary Maximum Concentration Level; ES - Enforcement Standard; PAL - Preventive Action Level; WQS - Water Quality Standard; AWQC - Ambient Water Quality Criteria; PDWS - Primary Drinking Water Standard; SDWA - Secondary Drinking Water Standard; CCC - Chronic Criter

### Abbreviations: GW- groundwater; SW - surface water; Ecol - ecologic; LF - landfill; SI - surface impoundment; S&G - sand and gravel; WU - waste unit; BU - beneficial use; CCW – coal combustion waste; RTC – Report to Congress; FFC – fossil fuel combustion; UST – underground storage tank; DC – damage case; OU- Operational Unit; TCLP – toxicity characteristic leaching procedure; COC – Contaminant of Concern; TDS = total dissolved solid; TSS - total suspended solid; Sf - sulphate; NOV - Notice of Violation; NOD – Notice of Deficiency; CO - Consent Order; COA - Consent Order Agreement; CCA – Compliance Commitment Agreement; ROD - Record of Decision; RI - Remedial Investigation; FS - Feasibility Study; MCL - Primary Maximum Concentration Level; SMCL - Secondary Maximum Concentration Level; ES - Enforcement Standard; PAL - Preventive Action Level; WQS - Water Quality Standard; AWQC - Ambient Water Quality Criteria; PDWS - Primary Drinking Water Standard; SDWA - Secondary Drinking Water Standard; CCC - Chronic Criter

### Abbreviations: GW- groundwater; SW - surface water; Ecol - ecologic; LF - landfill; SI - surface impoundment; S&G - sand and gravel; WU - waste unit; BU - beneficial use; CCW – coal combustion waste; RTC – Report to Congress; FFC – fossil fuel combustion; UST – underground storage tank; DC – damage case; OU- Operational Unit; TCLP – toxicity characteristic leaching procedure; COC – Contaminant of Concern; TDS = total dissolved solid; TSS - total suspended solid; Sf - sulphate; NOV - Notice of Violation; NOD – Notice of Deficiency; CO - Consent Order; COA - Consent Order Agreement; CCA – Compliance Commitment Agreement; ROD - Record of Decision; RI - Remedial Investigation; FS - Feasibility Study; MCL - Primary Maximum Concentration Level; SMCL - Secondary Maximum Concentration Level; ES - Enforcement Standard; PAL - Preventive Action Level; WQS - Water Quality Standard; AWQC - Ambient Water Quality Criteria; PDWS - Primary Drinking Water Standard; SDWA - Secondary Drinking Water Standard; CCC - Chronic Criter**No. Crosswalk**  **Facility Location**  **State**

**1** 

### PTa02 Widows Creek Fossil Fuel Plant, TVA Stevenson AL

2 

### PTa01 Colbert Fossil Fuel Plant, TVA Tuscumbia, Colbert Co. AL

3 

### PTb01 Flint Creek Power Plant, SWEPCO Gentry AR

4 

### PTb02 Independence Steam Station – Entrgy/AP&L Newark AR5 

### PTa03 Cholla Steam electric Generating Station - Arizona Public Service Co. Joseph City, Navajo County AZ

6 

### PTb03 Montville Generating Station - NRG

Energy/Montville Power Montville CT

7 

### PTb04 Indian River Power Plant Burton Island – NRG Energy Millsboro DE

8 

### None Crist Plant Ash Landfill - Gulf Power (Southern

Company) Pensacola FL

9 

### PTa04 Lansing Smith Plant - Florida Power & Light Bay Co. FL10 

### PTb07 Curtis Stanton Energy Center - Orlando Utility Commission Orlando FL

11 

### PTb08 Seminole Generating Station – Seminole Electric

Cooperative Palatka FL

12 

### PTb05 Big Bend Station – Tampa Electric Co. Apollo Beach FL

13 

### PTb06 CD McIntosh Jr. Power Plant – City of Lakeland Lakeland FL

14 

### PTb13 Lansing Station Ash Ponds and Landfill –

Alliant/Interstate Power and Light Company (IP&L) Lansing IA15 

### None Fair Station Ash Landfill - Central Iowa Power Cooperative Montpelier IA

16 

### PTa19 Muscatine County Landfill Montpelier IA

16 PTb14 George Neal Station North Landfill - MidAmerican

Energy Sergeant Bluff/Sioux City IA

17 

### PTb15 George Neal Station South Ash Monofill -

MidAmerican Energy Salix IA

18 

### None Prairie Creek Generating Station Ash Landfill -

Interstate Power and Light (Alliant) Cedar Rapids IA19 

### None Joppa Steam Plant Ash Ponds - Ameren (Electric Energy) Joppa IL

20 

### None Meredosia Power Station Ash Ponds - Ameren

Energy Generating Company Meredosia IL

21 

### None Dallman Station Ash and FGD Ponds - City Water,

Light and Power Springfield IL

22 

### PTa09 Powerton Plant Mahoney Landfill and Ash Ponds -

Midwest Generation (Commonwealth Edison) Pekin, Tazewell Co. IL

23 

### PTa05 Duck Creek Station - Central Illinois Light Co.

(Ameren, Dynegy) Canton, Fulton Co. IL24 

### PTa07 Hennepin Power Station - Illinois Power Co. (Dynegy) Hennepin, Putnam Co. IL

25 

### PTa06 Havana Power Plant - Illinois Power Co. (Dynegy) Havana, Mason Co. IL

26 

### PTa10 Vermillion Power Station - Illinois Power (Dynegy

Midwest) Oakwood, Vermillion Co. IL

27 

### PTa08 Hutsonville Power Station - Central Illinois Public

Service Co. (Ameren) Hutsonville, Crawford Co. IL

**No. Crosswalk**  **Facility Location**  **State**28 

### PTa12 Wood River Power Station - Illinois Power Co. (Dynegy Midwest) Alton, Madison Co. IL

29 

### None Waukegan Generating Station Ash Ponds - Midwest

Generation (Edison International) Waukegan IL

30 

### PTa11 Coffeen/White & Brewer Trucking Fly Ash Landfill Coffeen, Montgomery Co. IL

31 

### PTb09 Joliet Generating Station 9 Lincoln Stone Quarry

Landfill - Midwest Generation Joliet IL

32 

### None Joliet 29 Generating Station Ash Ponds - Midwest

Generation (Edison International) Joliet IL33 

### None Pearl Station Ash Pond - Prairie Power (Soyland Power Coop.) Pearl IL

34 

### PTb10 Marion Plant - Southern Illinois Power Cooperative

(SIPC) Marion IL

35 

### PTb11 Venice Power Station – Union

Electric/Ameren/AmerenUE Venice IL

36 

### PTa16 Michigan City Site, NiSource Michigan City IN

37 

### PTa13 Bailly Generating Station, NiSource Chesterton IN38 

### PTa18 R.M. Schahfer Generation Station, NiSource Wheatfield, Jasper Co. IN

39 

### PTa14 A.B. Brown Generating Station - Southern Indiana

Gas & Electric Co. (Vectren) Mt. Vernon, Posey Co. IN

40 

### PTa17 Petersburg Generating Station - Indianapolis Power

& Light Petersburg, Pike Co. IN

41 

### PTa15 Merom Generating Station CCW Landfill - Hoosier

Energy Sullivan IN

42 

### PTb12 Clifty Creek Station, Indiana-Kentucky Electric

Corporation Madison IN43 

### PTa20 East Bend Scrubber Sludge Landfill - Cinergy (Duke Energy) Rabbit Hash, Boone Co. KY

44 

### PTb16 Mill Creek Station – Louisville Gas & Electric Louisville KY

45 

### None Paradise Fossil Plant Ash Ponds, TVA Paradise KY

46 

### PTb17 Shawnee Fossil Plant, TVA Paducah KY

47 

### PTb18 Spurlock Power Station - Eastern Kentucky Power

Cooperative Maysville KY48 

### PTb19 Big Cajun II Power Plant – NRG/Louisiana Generating New Roads LA

49 

### PTb20 Dolet Hills Power Station - CLECO Power Mansfield LA

50 

### PTb21 Rodemacher Power Station - CLECO Power Lena LA

51 

### PTa21 K.R. Rezendes Main Street Ash Landfill, PG&E Freetown MA

52 

### PTb22 Brandywine Coal Ash Landfill – Mirant Mid-Atlantic Brandywine, Prince George's County MD53 

### PTb23 Mirant Dickerson’s Generation Station’s Westland Disposal Site Dickerson, Montgomery Co. MD

54 

### PTb24 Karn/Weadock Generating Facility – Consumer

Energy Saginaw MI

55 

### PTb25 Pine Hill Landfill - Marquette Board of Light & Power Negaunee Township MI

56 

### PTb26 Presque Isle Power Plant - We Energies Marquette MI

57 

### PTb27 Muskegon County Type III Landfill Muskegon Co. MI58 

### PTb28 John Warden Ash Site L'Anse, Baraga Co. MI

59 

### PTb29 BC Cobb - Consumers Energy Muskegon Co. MI

60 

### PTb30 J.H. Campbell, West Olive - Consumers Energy Ottawa Co. MI

**No. Crosswalk**  **Facility Location**  **State**

61 

### PTa22 Xcel Energy/Southern Minnesota Municipal Power

Agency (Sherco) Generating Plant Becker, Sherburne Co. MN62 

### PTa26 Allen Steam Generating Plant - Duke Power Gaston Co. NC

**63** 

### PTb37 Sutton Steam Plant – Progress Energy Wilmington NC

64 

### PTb36 Lee Steam Plant – Progress Energy Goldsboro NC

65 

### PTb34 Cape Fear Steam Plant – Progress Energy Moncure NC

66 

### PTb33 Belews Creek Steam Station - Duke Energy Belews Creek NC67 

### PTb32 Asheville Steam Electric Plant - Progress Energy Arden NC

68 

### PTb35 Dan River Steam Station - Duke Energy Eden NC

69 

### PTa28 R.M. Heskett Station - Montana-Dakota Utilities Mandan, Morton Co. ND

70 

### PTa29 W.J. Neal Plant - Basin Electric Velva, McHenry Co. ND

71 

### PTa27 Coal Creek Station - Great River Energy Underwood ND72 

### PTb38 Leland Olds Station - Basin Electric Power Cooperative Stanton ND

73 

### PTb31 Sheldon Station – Nebraska Public Power District Hallam NE

74 

### PTa24 Weber Ash Disposal Site - AES Creative Resources Fenton, Broome Co. NY

75 

### PTa23 Danskammer Waste Management Facility, NY -

Central Hudson Gas & Electric Corporation Newburgh NY

76 

### PTa25 C.R. Huntley Flyash Landfill Tonawanda NY77 

### PTa31 Miamiview Landfill - Cincinnati Gas & Electric Co. Hamilton Co. OH

78 

### None Stuart Station Impoundments - Dayton Power &

Light Adams Co. OH

79 

### PTa30 Beckjord Station - Cinergy W.C. New Richmond OH

80 

### PTb39 Cardinal Fly Ash Reservoir (FAR) 1 & 2 – AEP Brilliant OH

81 

### PTb40 General James M. Gavin Power Plant – AEP/Ohio

Power Cheshire OH82 

### PTb41 Muskingum River Plant – AEP/Ohio Power Beverly OH

83 

### PTb42 Northeastern Station Ash Landfill, AEP/Public Service

Co. of Oklahoma Oologah OK

84 

### PTb45 Mitchell Power Station, Allegheny Energy Courtney PA

85 

### PTb43 Phillips Power Plant – Duquesne Light Co. Crescent Tonshp PA

86 

### PTb47 Seward Generating Station – RRI Energy, Inc. New Florence PA87 

### PTb44 Hunlock Power Station – UGI Development Co. Hunlock Creek PA

88 

### PTb46 Portland Generating Station’s Bangor Quarry Ash

Disposal Site – RRI Energy, Inc Bangor PA

89 

### None McMeekin Station Ash Landfill and Ponds - South

Carolina Electric & Gas Company (SCANA) Columbia SC

90 

### PTb49 Wateree Station – South Carolina Electric & Gas Eastover SC

91 

### None Cross Generating Station Ash Landfill and Ponds -

South Carolina Public Service Authority (SCPSA; Santee Cooper) Pineville SC92 

### PTb48 Dolphus M. Grainger Generating Station - South Carolina Public Service Authority Conway SC

93 

### None Winyah Generating Station Ash and FGD Ponds -

South Caroline Public Service Company (Santee Cooper) Georgetown SC

**No. Crosswalk**  **Facility Location**  **State**

94 

### None Allen Fossil Plant Ash Ponds, TVA Memphis TN

95 

### PTa32 Bull Run Steam Plant, TVA Oak Ridge TN96 

### PTb52 John Sevier Fossil Plant, TVA Rogersville TN

97 

### PTb50 Cumberland Steam Plant, TVA Cumberland City TN

98 

### PTb51 Gallatin Fossil Plant, TVA Gallatin TN

99 

### PTb53 Johnsonville Fossil Plant – TVA New Johnsonville TN

100 

### None Coleto Creek Power Station - International Power Fannin TX101 

### PTb54 Fayette Power Project (Sam Seymour) – Lower Colorado River Authority Le Grange TX

102 

### None Parish Generating Station - Texas Genco II (NRG

Energy) Thompsons TX

103 

### PTa33 Battlefield Golf Course - Dominion Power Chesapeake VA

104 

### PTa41 Rock River Ash Disposal Facility - Alliant (WP&L) Beloit, Rock Co. WI

105 

### PTa36 Edgewater 1-4 Ash Disposal Site - Alliant Sheboygan WI**106** 

### PTa40 Pulliam ash Disposal Site - Wisconsin Power Supply Co. Green Bay WI

107 

### PTa35 Alma On-site Fly Ash Landfill - Dairyland Power Buffalo Co. WI

108 

### PTa34 Alma Off-site Fly Ash Landfill - Dairyland Power Alma, Belvidere Township WI

109 

### PTa38 Nelson Dewey Ash Landfill, Cassville Grant Co. WI

110 

### PTb55 Oak Creek Power Plant Caledonia Landfill –

Wisconsin Energy/Wisconsin Electric Power Oak Creek WI111 

### PTa39 Druecker Quarry Fly Ash Site - WEPCO Port Washington Facility Ozaukee Co. WI

112 

### PTa37 Lemberger Landfill, Wisconsin Whitelaw, Franklin Township, Manitowoc County WI

113 

### PTa42 Dave Johnston Power Plant, WY Glenrock, Converse Co. WY

114 

### None Pleasant Prairie Landfill, WEPCO Kenosha Co. WI

115 

### None Highway 32 Landfill, WEPCO Ozaukee Co. WI116 

### None Woodfield Landfill - NSP (Northern States Power) Bayfield Co. WI

117 

### None Weston #3 Ash Disposal Landfill - WPSC (Wisconsin

Public Service Co.) Marathon Co. WI

**No. Crosswalk**  **Facility Location**  **State References**  **Waste Unit Type Liner**  **Year Commissioned**

2007 DC Ass #32 3 major SIs (ash pond, gypsum pond, and gypsum settling pond) and several minor (de-minimis) ponds. 3 SIs: No Main Ash Pond: 1950; Gypsum Stack: early to mid-1980s.

2007 DC Ass #33 2 SIs (one for CCR, one runoff pond), & 2 LFs (one of which is closed); a (no longer used) chemical pond is apparently GW contamination source. SIs: None; Chemical pond: Clay; LFs: None SI: 1972 LF: 1975, 1984

In Harm's Way #1 LF (implicated in impact); and 2 SIs: one Primary and one Secondary (implicated in impact; both unregulated, because they are dredged periodically for BU). Also, 500 acres cooling lake. LF: No (till 1994); 6" Clay liner thereafter. SIs: No All: 1978

In Harm's Way #2 LF; 2 wastewater recycle ponds & 1 surge pond. Along with CCR, the surge pond and the recycle ponds handle various process wastewaters. Apparently, all WUs are implicated. LF: 90% - no liner; half of the most recent cell was built with 18” of compacted clay, max. hydraulic conductivity of 1 x 10-5 cm/sec. 1983, 19902007 DC Ass #67 Two primary SIs (one fly ash, theother bottom ash) and 2 small deminimis (ash contact) wastewater ponds: a Sedimentation Pond and a Retention Pond (Zero discharge facility); also, a cooling lake. Fly Ash pond assoc. w/impact. 2 Primary SIs: No SIs: 1978; cooling lake: 1961.

In Harm's Way #3 Several primary coal ash settling ponds and disposal lagoon (active until 1971, when plant switched to oil) - implicated; and 3 unregulated, off site dumping

areas. No 1919

Out of Control #1 An island-sited Primary 'SI' and mainland-sited LF: all implicated. SI: No; LF-I: No 1957; 1980

EPA-HQ-RCRA-2011-0392- 0259 (Risky Business #1) Fly ash and bottom ash storage areas (SW of the plant) and 2 gypsum storage areas (NE of the plant). Both WUs implicated. ? ?

2007 DC Ass #36 A Primary SI (with 3 cells) No 1965Out of Control #2 Active LF; 3 CCR and coal storage area runoff ponds, a recycled water pond (zero-discharge facility), and a plant wastewater pond. Both LF and ash ponds implicated. Yes 1981

Out of Control #3 Active, unlined FGD LF (implicated); 3 lined process wastewater ponds; and 2 unlined storm water runoff ponds. LF: No; 3 process wastewater ponds: Yes; 2 storm water runoff ponds: No. 1984

Out of Control #4 Three economizer fly ash ponds, 2 bottom ash ponds, 2 wastewater recycling ponds, one FGD gypsum settling pond; bottom ash dry storage unit, and waste disposal management unit. waste disposal management unit clearlyimplicated, but apparently wetdisposal units are also a source LF – Yes; FGD Storage Area: No (but liner to be implemented 2013-2015); 8 SIs: Yes (in 3 of the ponds - first installed in 2001). Five ponds have compacted structural fill and 60 mil HDPE liners; the remaining 3 - compacted structural fill Bottom ash ponds and LF - late 1960s -early 1970s?; Economizer ponds: 1984; settling-recycle ponds: 2009.

In Harm's Way #4 2 LFs (implicated); FGD sludge dewatering area, process wastewater ponds (implicated); artificial wetland. LFs: Originally - No; presently - a double liner(?). SIs: One pond has a double liner (?). Other ponds: unknown. 1981

In Harm's Way #7 LF; 2 Ash Ponds (Primary and Polishing). LF: No; Ponds: No LF: 1985. Ponds: ~ 1975.EPA-HQ-RCRA-2011-0392-

0259 (Risky Business #3) Ash monofill ? 1974

2007 DC Ass #64 LF (now closed) assoc w/impact. Also an active LF. Both LFs: No 1964; 1975

In Harm's Way #5 One LF (two closed sections), in a former S&G Pit (implicated); 3 unlined SIs. LF; No; SIs: No LF: 1978; 2 SIs: 1972; 1 SI: 1975

In Harm's Way #6 LF in a former S&G Pit. Apparently No Early 1980s

EPA-HQ-RCRA-2011-0392- 0259 (Risky Business #4) LF (implicated), in a former limestone quarry. 12 small (each less than an acre) SIs, 10 of which receive CCR and 2 receive coal pilerunoff. Facility permit No. 57-SDP35-04. ? LF: ? 11 Sis: 1965; one of the coal pile runoff ponds: 2009.EPA-HQ-RCRA-2011-0392-

0259 (Risky Business #8) 2 SIs, one active, other inactive and capped. Also runoff/settlement pond and sewage lagoon. No Inactive: mid-1950s; Active: 1973 (modified 1985); sewage lagoon: 1995

EPA-HQ-RCRA-2011-0392- 0259 (Risky Business #9) 2 active SIs (Fly Ash pond and Bottom Ash pond); three inactive Sis (Fly Ash, Bottom Ash, ?). No Active: Fly Ash: 1968; Bottom Ash: 1972. Old Fly Ash and Old Bottom Ash established: 1948? Capped in 1970s.

EPA-HQ-RCRA-2011-0392- 0259 (Risky Business #6) 2 active Sis (implicated); FGD LF (Facility operates under IEPA Permit IL0024767.) No Sis: ?; FGD LF: 1986

Mahoney LF: 2007 DC Ass#40; Ash Ponds: EPA-HQRCRA-2011-0392-0259 and Risky Business #11 (EIP, 2011). IEPA Permit IL0002232. 2 LFs (one - in abandoned S&G pit, both now closed) and 3 ponds: Ash Basin, Secondary Basin, and Bypass/ Stormwater Basin. Also, a 1,426 acres Powerton (cooling) Lake (closed-loop cooling system). Both dry- and wet-disposal implicated. LFs: Poz-O-Pac (ash w/lime, with a tendency to crack upon shrinkage); 2 ash ponds (Ash Basin & Secondary Basin): Yes; stormwater retention basin: No. Powerton Lake: 1971; Old LF: 1972; 'New' LF: 1978. SIs: apparently in the 1970s.

2007 DC Ass #47 2 Primary SIs (slated for closing in 2010), Recycle Pond, and an 1,800 acre cooling pond. Primary SIs: No; Recycle Pond: Clay. 1976, 1985, 1985.2007 DC Ass #48 2 Primary SIs in a pre-existing gravel pit (both implicated; closed since 1996); an extinct (originally, a gravel pit) LF, overbuilt by a SI; several currently active (lined) SIs; and a recently completed, lined fly ash LF. 2 Inactive SIs: No; Old LF: No; Active SIs: Composite. New LF: Synthetic. SIs: 1952; 1958; 1997.

2007 DC Ass #49 3 multi-cell Primary SIs - one active, two closed in 1994. Impact associated w/one of the closed SIs. Active SI: composite (clay & geomembrane); two other SIs: apparently No. Active SI (4 cells): 1990- 2003; Inactive SI (2 cells): 1947; closed SI: 1977.

2007 DC Ass #52 3 multi-cell Primary SIs - oneactive, two closed (one in the mid1970s and the other converted, in 1988, into a stormwater pond); and a cooling pond. Impact associated w/at least one of the two closed SIs. 2 SIs: No; 3rd SI: contradictory information. Mid-1950s; mid-1970s; and 1988.

2007 DC Ass #53 Five Primary SIs, one of which (Pond D) is assoc. w/impact (closed in 2000, partially replaced by a LF). 3 SIs (A, B, C): geomembrane; bottom ash pond: probably No; Pond D: No. LF: unknown. A: 1986; B and C: 2000; Bottom Ash: 1940; and D: 1968.

**References Waste Unit Type**  **Liner Year Commissioned** 2007 DC Ass #54 2 Primary ponds, one of which (West Pond - WAP - closed in 2000) is assoc. w/impact. Original ponds redesigned, w/Bottom Ash handled in 2 ponds and, beginning in 1999, all fly ash has been managed by dry-handling. WAP: Originally No, but in 1997, one cell received double clay liner w/leachate collection, and the EAP - a composite liner (45-mil HDPE/clay). Precursor to both ponds: 1952. Evolved into the West Ash Pond (WAP): 1977 (and earlier) and the East Ash Pond (EAP): 2006.

EPA-HQ-RCRA-2011-0392- 0259 (Risky Business #12) 2 SIs and a LF (Facility operates under IEPA Permit IL0002259). SIs: Yes; LF: ? ?

2007 DC Ass #56 2 inactive LF cells (assoc. w/impact, closed between 1980- 1997); one active LF w/leachate + stormwater pond; and two recycle SIs (one for boiler slag and one for FGD gypsum). Also, a cooling lake. LFs: No; Recycle Pond: No; FGD Pond: HDPE. LF: 1977 or earlier; Recycle Pond: 1979; FGD Pond: 2009.

In Harm's Way #8 Primary Pond (defined as 'LF') in former quarry, assoc. w/impact; 2 Primary SIs. No 1962

EPA-HQ-RCRA-2011-0392- 0259 (Risky Business #7) 3 active SIs (Facility operates under IEPA Permit IL0064254.) Two: HDPE; One: geocomposite ?EPA-HQ-RCRA-2011-0392-

0259 (Risky Business #10) Clay Yes 1968

In Harm's Way #9 1 LF; 11 SIs (most are Primary, for fly ash and FGD gypsum; two - for bottom ash/boiler slag and a connected Polishing Pond). SIs are implicated. Also, a cooling lake (Lake of Egypt). LF: No; 6 SIs: No; 1 SI: Yes; remaining ponds: unknown. SIs: 7 were commissioned in 1976, one – in 1988, one- in 1992, and 3 – in 1996.

In Harm's Way #10 3 Primary SIs (implicated; stopped receiving CCR in 1977, but kept receiving process wastewater till 2005), closed 2010. No 1950s

2007 DC Ass #43 2 historic, Primary SIs (assoc. w/impact; closed 2007); presently: 3 Primary SIs (two- for fly ash, one - for bottom ash) and 3 polishing ponds: two 'secondary' ponds and one 'final settling' pond. Also, pre-1973 areas of unregulated structural fill. All six SIs: No 1974

2007 DC Ass #44 Several unpermitted 'LFs' (discontinued 1979-1986) and several SIs: two Primary and 2 or 3 Secondary (one closed 1979). Remaining ponds were retrofitted (1980-81). Apparently, all old WUs assoc. w/impact. Presently: 2 Primary ponds, 2 Secondary ponds, one bottom ash pond, and All waste units were originally unlined. However, between 1979 and 1981, the SIs were dredged then ‘composite’ lined (HDPE over clay). 1962-1970s2007 DC Ass #55 3 Primary Ponds and 4 de-minimis ponds; one LF; and two former dry-staging areas (one for ash, the other - for FGD gypsum). Impact assoc. apparently with all old, unlined WUs. LF Phases I and II: No; LF Phases III and IV: Composite liner w/leachate collection. SIs: No information (Dam Assm't Report withheld under CBI). LF commissioned 1984. Ponds: 1976 (large, Final Settling basin); 1982 (3Primary and one deminimis pond); 1983 (FGD stormwater Pond); and 1999 (Yard Drain Stormwater Pond). Two dry (retired) waste units: 2007 DC Ass #57 One unlined LF assoc. w/impact; two unlined (bottom ash) SIs (not implicated). LF: initially - No, Clay -in expansion; SIs: No. LF: 1979 (expanded: 1992); SIs: 1978 and 2003- 07.

2007 DC Ass #59 Site associated with old abandoned surface and underground coal mines. One unlined LF assoc. w/impact; 4 unlined SIs (two active, two inactive, constructed between 1964 and 1986) are not implicated. LF: No (planned LF expansion will have a liner consisting of 1' of clay and 2' of Poz-o-Tec); SIs: No LF: 1976 (expanded: 1967, 1969, 1977, 1986). SIs: 1964-1986, modified: 1999.

2007 DC Ass #60 One active (lined) and one closed (unlined) LF, associated with several auxiliary sedimentation-, wastewater treatment, and emergency basins, all lined. LF #1 (unlined) impact GW, basins impact cooling reservoir. LF Area 1: No; Area 2A: Clay. Auxiliary basins: all lined (clay or synthetic). LF: 1982; 1994.

Out of Control #7 Type III LF & 2 SIs (one is Primary, for Boiler slag, and the other was formerly Primary, for fly ash, but is currently used only for stormwater management.) An ulined Class III LF sited over the former fly ash SI (Overfill); in 2009/10 it was redesigned as Class I LF for FGD and fly ash. LF and SIs: No SI: 1955; LF: 1992. Type I LF permitted in 2002 but subject to legal petitions for improved environmental controls.2007 DC Ass #35 3 unlined, Primary SIs and one LF (older cells - unlined). Both LF and SIs implicated. 3 SIs: No; LF: mostly NO, but 2 recent cells have a composite geomembrane/ geosynthetic clay liner with leachate collection. LF: 1981; 3 SIs: 1980

In Harm's Way #11 3 LF phases (one of which is inactive; only one of the two active ones is lined); 1 Primary CCR SI and 4 FGD process ponds. WU culpability unresolved. 2 LFs: No; 1 LF: Composite; Ash SIs: No; FGD ponds: ? 1972

EPA-HQ-RCRA-2011-0392- 0259 (Risky Business #13) Three ash disposal areas: 3 SIs (a scrubber sludge pond and a slag pond in an abandoned strip mine pit adjacent to the Green River; and Peabody Ash Pond next to Jacob’s Creek, S of the plant). FGD disposal area (LF?) SW of the plant. No Scrubber Sludge pond: 1985/86; Slag Pond: Mid 1960's; Peabody Ash Pond: 1997.

In Harm's way #12 2 unlined LFs & 2 SIs; one of the LFs is an overfill (built over a closed SI). Dry ash stacking area implicated. LFs: No; SIs: No SIs: 1950s and 1971; LFs: 1984 and 2007.

In Harm's Way #13 LF (unlined, since 1979; clay-lined expansion in 1996; LF implicated); and a Primary (Bottom Ash) SI. LF (1996 expansion): 2' compressed clay; SI: Clay liner. LF: 1979; SI: 1976In Harm's Way #14 5 SIs: 2 Primary (one- fly ash, one - bottom ash), two wastewater treatment ('Primary' and 'Secondary'), and a Surge Pond. Impact assoc. with Primary Treatment Pond, the Surge Pond, and the Bottom Ash pond. 3 SIs: clay; 2 SIs: 'naturally occurring clay'. 1980

In Harm's Way #15 1 LF & 9 SIs: 3 bottom ash ponds, 3 surge ponds (FGD and ash), a metal cleaning waste pond (fly ash), a plant discharge collection pond, and a limestone runoff pond. One Surge Pond and Metal Cleaning Pond (both contain ash) implicated. LF: ?; 2 ash ponds: clay; 7 SIs: ?; site underlain by low permeability clay. 1986

In Harm's Way #16 1 LF with a leachate collection pond; 7 SIs: two Primary (one- fly ash and one -bottom ash), 2 metal cleaning waste ponds, a coal sedimentation pond, and unpermitted clarifier sludge sedimentation pond. All WUs implicated. LF: apparently No; 2 ash ponds: clay; 5 leach & wastewater ponds: 60-mil HDPE LF: 1980s (overfill); SIs: 1982; Leach ponds: 2009

2007 DC Ass #25 Unlined, offsite monofill in a former S&G Pit (actually, a structural fill). Use discontiued in 2001, but closing might be still ongoing. No 1976

Out of Control #8 LF, 4- leachate ponds (implicated), wastewater ponds. LF: No – all but one pit (Composite liner since 2007); Ponds: Yes 1970; 1971MDE Notice of Intent to

Sue Mirant , January 3, 2011 1 LF (comprising one closed and one active phase); 2 settling/ leachate treatment ponds. Pond 2: unlined; Pond 3: lined w/synthetic liner only in 2010, connected to active LF by an unlined ditch. 1959; 1962

Out of Control #9 2 Primary SIs (implicated), transformed into corresponding Class III (fly ash) LFs in 1986 and 1992. Sluicing of fly ash stopped in 2009. Bottom ash still handled in ponds. No 1940s to 1970s.

EPA-HQ-RCRA-2009-0640- 6815, Attachment 5. Sanitary Landfill Receiving Fly Ash No 1985

EPA-HQ-RCRA-2009-0640- 6815, Attachment 5. Type III off-site Industrial Landfill Implicated LF: No; two later, non-implicated LFs: Yes, with leachate collection systems. 1979

EPA-HQ-RCRA-2009-0640- 6815, Attachment 5. Type III fly ash off-site monofill No 1980EPA-HQ-RCRA-2009-0640-

6815, Attachment 5. Type III industrial landfill No 1974

EPA-HQ-RCRA-2009-0640- 6815, Attachment 5. Inactive SI (regulated as Type III industrial LF). Also, ten additional, active SIs. Implicated pond: No 1970

EPA-HQ-RCRA-2009-0640- 6815, Attachment 5. Inactive SI (regulated as Type III industrial LF). Also, four active ponds and seven active LF cells. Implicated pond: No 1962

**References Waste Unit Type**  **Liner Year Commissioned** 

2007 DC Ass #41 4 Primary ponds w/overflow to a recycle/stoemwater basin (Ponds #1 and #2 are closed - they are assoc. w/impact); one LF and a leachate collection basin. Ponds #1, #2, and Bottom Ash: Clay; Pond #3 and Recycle Basin: Composite; LF: Yes, w/leachate collection; Leachate collection pond: geomembrane. Pond #1, Bottom Ash Pond and Recycle Pond: 1975; Fly Ash/FGD Pond (#2): 1984; Fly Ash/FGD Ponds: 2004 (#3N) and 2010 (#3S); LF and leachate collection pond: 1986.2007 DC Ass #34 2 Primary SIs: one closed (1973), converted into a lined LF ('overfill'), the other (unlined, 4 cells - 3 primary and one 'polishing') is active. 2 SIs: No; LF: double liner w/leak detection system. SIs: 1957; 1973; LF: 2009/10

Out of Control #11 2 Primary SIs: one (unlined) closed (1985), the other (clay-lined )active, both implicated; and a Secontaminated cooling lake. 1971: No; 1984: Clay; Cooling lake: No 1971, 1984; Cooling lake: 1970s.

Out of Control #12 One Primary, active SI (prior to Plant's retirement - implicated), 4 inactive (but not yet closed) ponds; and a cooling lake. No Inactive: 1950s and 1960s (last closed 1980). Active: 1980; cooling lake: 1961.

Out of Control #13 5 unlined SIs: one Primary (active until plant's retirement); two ponds for stormwater management; and 2 inactive ponds. Inadequate info to pin point down specific source term. No 1956; 1963; 1970; 1978; 1985

Out of Control #15 2 active, lined LFs and one unlined (inactive since 2007); one unlined SI, and a small chemical washdown pond. All WU implicated. Also, a 3,700-acre cooling lake. One LF: geosynthetic with leach collection; FGD LF: Composite; SI: No; Chemical Washdown Pond: apparently No. LFs: 1974, 2007, 2008; SI: 1974; Chemical Washdown Pond: 1972- 74; cooling lake: 1973.Out of Control #16 2 Primary SIs: one active, and one inactive (part of it serves as a constructed wetland). Both implicated; also, a Chemical Metal Cleaning Treatment System, a FGDS wet scrubber wastewater treatment system, and a 320-acre cooling lake. 2 SIs: No (another source claims that the 1964 pond had a geonet installed there). 1964; 1982. Cooling lake: 1963.

In Harm's Way #18 2 contiguous SIs (one Primary and one Scondary), both implicated; unlined LF (closed 2005), and a new, replacement LF thereafter. SIs: No; Old LF: No; Post 2005 LF: Unknown. Old LF: 1949; New LF: 2005 (?); SIs: 1956; raised in 1968/69 and 1976/77, reconfigured 1976/77.

2007 DC Ass #66 Unlined monofill (discontinued/closed 1989-90) - implicated; an active LF with a leachate evaporation pond. Old LF: No; active LF: some cells - clay, others - composite. 1954

2007 DC Ass #23 Unlined Primary SI, closed since late 1980s. No 1951

2007 DC Ass #24 2 Primary ponds, 4 ash-contact evaporation ponds (Zero discharge facility), a recycle pond, an extended basin for cooling water storage, a river water basin for storage of raw water; and 5 special CCR landfills (storage for BU). Only Ponds are assoc. w/impact. 2 Primary Ponds: originally lined with compacted soil, then - clay lined, finally - 1979 to 1982 - composite lined + leachate collection.Auxiliary and watermanagement Units: Unknow. LF: Originally No liner; between 2005-2008, a 2 Primary SIs: 1979; LF: First cell - 1989, other cells - later.In Harm's Way #20 5 Primary SIs: three active bottom ash ponds and two closed fly ash ponds (ponds implicated). Since 1994, plant switched from wet - to dry disposal of fly ash, which is minefilled. SIs 1-3: No; SIs 4-5: Probably No; Mine LF: 2' Clay. 1966; 1975 (2); 1985; 5th pond - unspecified date.

In Harm's Way #21 1 LF (closed 1999; implicated) and several active LFs. Closed LF: No (but rather natural clay substrate); active LFs: Clay liner 1989

2007 DC Ass #27 Offsite LF w/liner and leachate collection w/a leachate/sedimentation basin (closed since 2001). LF and Leachate Basin implicated in impact. LF: 20 mil PVC/leach collection. Leachate collection basin: unknown. 1978-80

2007 DC Ass #28 Old LF (1959-63) implicated. 'New' LF has two combined leachate collection and stormwater basins. Old LF: unlined; 'New' LF Phase I: Unknown; Phases II and III: double liner w/leachate collection system. 1959

2007 DC Ass #29 4 LFs inactive, unlined - implicated in impact - and one active LF; one Primary pond and five secondary ponds. 4 Closed LFs: No; Phase II LF: Synthetic w/leachate collection. Primary Pond: No; two (of the 5) secondary ponds: No; two (of the 5) secondary ponds: asphalt; and one (of the 5) secondary pond: Clay. LF: Early 1970s; Ponds: Primary - prior to 1976; Secondary: 1977 (two) and 1984 (two).2007 DC Ass #58 Offsite LF in a S&G Pit. Clay 1983

CCW DC Ass #82; EPA's 2009 Dam Assessment Report. 2 LFs and 5 Ash Ponds. Also, wastewater and acid wash basin and stormwater basin. LFs: ?; 4 of the impoundments have clay liner; one (the oldest): none. LFs: ?; Ponds: 1975, 1977, 1978, 1977/81, and 2001.

2007 DC Ass #61 3 Primary (unlined) SIs, one of which is active. No 1956, 1963, 1966.

In Harm's Way #23 2 Primary fly ash ponds: one closed and one active (both implicated); a 'pond complex' comprising 1 Primary Bottom Ash Pond, a Recirculation Pond, and polishing pond; and one FGD LF - an overfill. LF: Synthetic; SIs: No SIs: 1973 & 1987; LF: Post2000

In Harm's Way #24 6 LFs (three closed and 3 active) and 3 small LF stormwater/leachate ponds; and 2 Primary SIs (one active - for bottom ash, and one inactive - for fly ash). Also, 4 shallow storm water runoff collection ponds around the perimeter of the coal pile. Apparently, LF is implicated. LFs: Composite (1.5' clay and 30-mil PVC); LF leachate/stormwater: Geosynthetic; 1 bottom ash and 1 fly ash SIs: No; shallow stormwater/coal pile - ? SIs: 1974; LFs: 1994, 1996, 1998In Harm's way #26 4 Primary, ulined SIs - one is implicated. No 1968

In Harm's Way #27 LF (unlined: implicated) and an unlined Primary (bottom ash) SI. LF: No; SI: No LF: 1978; SI: 1979

Out of Control #19 Unlined LF; 2 Wastewater lagoons w/'soil liner'. Lagoons implicated, but ultimate source might be the up-gradient LF. LF: No 2 wastewater lagoons: compacted soil/bottom ash ?

Out of Control #20 LF (FGD); 2 (unlined) wastewater treatment lagoons (implicated). All WUs closed (the ponds were clean-closed). LF: No; Leachate collection; SIs: No 1969

Out of Control #21 2 unlined, unpermitted LFs (closed); Co-disposal coal ash/coal refuse pit (closed). Apparently, all WUs implicated. No 1954Out of Control #23 2 unlined SIs, operated until Plant's decommissioning (2010), implicated. Only on inner slope of embankments, in situ clay Early 1960s

Out of Control #24 LF in a quarry, lined above existing ash only in 1999 (implicated); 2 Secondary Ponds: Stormwater sedimentation pond & leachate collection pond (NPDES-regulated outfalls) LF: 60-mil LLDPE geomembrane over 6" fly ash sub base. Ponds: unknown. Pre-1995

EPA-HQ-RCRA-2011-0392- 0259 (Risky Business #16) LF and 3 SIs. ? ?

Out of Control #25 2 unlined SIs in formerly River S&G open pit mining (implicated); additional WUs (not-implicated): Class III FGD and ash LF; one coal pile runoff and LF leachate pond; and 2 small wastewater treatment ponds. No 1970

EPA-HQ-RCRA-2011-0392- 0259 (Risky Business #15) LF and 3 SIs. Bottom Ash 1: Clay (4" soilbentonite); Bottom Ash 2: Geosynthetic Clay; GypsumPond: Clay (4" soilbentonite); all 1x10-7 cm/sec. Bottom Ash 1: 1983; Bottom Ash 2: 1995; Gypsum Pond: 1983.Out of Control #27 2 Primary, unlined SIs, one of which had been converted (1977) into dry ash storage area prior to the recent retirement of the Plant. At least one of the SIs is implicated. No 1966 & 1977

EPA-HQ-RCRA-2011-0392- 0259 (Risky Business #17) 6 Sis: Ash Pond A; Ash Pond B; South Ash Pond; West Ash Pond; Unit 3 & 4 Slurry Pond; and Unit 2 Slurry Pond. No. Two (A & B) in 1975; one (Unit 2 Slurry) in 1977; and three (South Ash, West Ash, and Unit 3 & 4) in 1980.

**References Waste Unit Type**  **Liner Year Commissioned** 

EPA-HQ-RCRA-2011-0392- 0259 (Risky Business #18) 2 Sis; Active East ash pond and inactive (since 1992) West ash pond. The inactive west pond implicated (OIG, 2011). No West Pond: 1950's; East Pond: 1969.

2007 DC Ass #31 3 Primary SIs: bottom ash, fly ash, and gypsum (an overfill), several dry stacked areas, and a closed LF. Two of the 3 Primary ponds implicated. No 1967Out of Control #28 1 SI converted into dry stacking (implicated); 1 active Primary bottom ash SI. Auxiliary ponds include the Waste Stabilization Pond (WSP) and two Metal Cleaning Treatment Ponds (MCTPs). Runoff from the Dry Fly Ash Disposal area first drains to the sediment pond, then to a Originally - No; partial geocomposite liner w/leachate collection installed in 2008-09 over active LF. 1955; 1979

In Harm's Way #32 1 active SI, gypsum storage (both implicated), ash stack, and two former SIs that served as a basis for overfills. SIs: No; Gypsum sorage and ash stack: probably No. 1969

In Harm's Way #33 3 Primary SIs: two active (one each for bottom ash and fly ash) and one closed (- implicated), and 3 stilling ponds. No 1959

In Harm's Way #34 One active, Primary SI; also, 2 closed Primary SIs (one of which was used before closure for dry stacking) & one closed LF. All unlined WUs implicated. Active SI: No; 1 SI, later used for dry stacking: Clay; 1 closed SI and 1 closed LF: No. 1952

EPA-HQ-RCRA-2011-0392- 0259 (Risky Business #19) 2 SIs (“primary” and “secondary”) receive fly ash and bottom ash. One coal pile runoff pond; and one evaporation pond. Also, a “Dry Product Storage Area” of 130 acres N of the ponds. Compacted Clay “primary” and “secondary” SIs: 1980. Other 2 ponds: 1980?In Harm's Way #35 2 Primary SIs (at least one implicated), coal pile runoff pond, 2,400-acre cooling lake, 1 CCR (FGD) LF and 1 Class II Sanitary LF. 2 SIs: Clay; coal pile runoff pond and cooling pond: Apparently No; LF: Unknown. 2 SIs: 1979 & 1988; FGD LF: 1988

EPA-HQ-RCRA-2011-0392- 0259 (Risky Business #20) LF (Bottom & Fly) and clay-lined FGD Emergency Pond LF: ?; FGD pond: Clay. FGD pond: 1980/82

CCR Proposed Rule, 6/2010 Structural Fill No 2002-2007

2007 DC Ass #42 4 Primary ponds (discontinued in 2000, but not yet closed). No Unclear whether 1954 or 1978.

2007 DC Ass #45 Five unlined SIs: 2 Primary (Slag and the twofold A) and 3 Secondary (B, C, and F); a LF and a ‘CCR landfill contact pond' (receiving sediments and storm runoff from the LF). Apparently, all implicated. None lined. 1969 (2), 1977 (2), 1984 (2)2007 DC Ass #46 LF No 1971

2007 DC Ass #50 LF (closed 1986). No 1947

2007 DC Ass #51 One Primary SI, converted to LF in 1995. The current, lined LF not implicated. Original SI and LF Phases 1- III: Clay; Current LF (IV): Geosynthetic w/leachate collection. SI: 1983; converted to LF: 1995 (Phase I); Phase IV: 2007

2007 DC Ass #15 Coal ash pond (established 1959) and slag pond (established 1976), both permitted 1979 under RCRA). Old ash pond implicated in impact (closed 2001). No 1959, 1976.

In Harm's Way #39 3 LFs (two closed, one active), and a structural fill. 2 Inactive LFs: probably No; Active LF: Clay (Phase I); Composite w/leachate collection (Phase II); structural fill: No 1960s & 19742007 DC Ass #17 Unpermitted fill of a former S&G Pit and an abandoned limestone quarry. No 1948

2007 DC Ass #62 Sand and Gravel Pit used as a ‘Dual’, MSWLF and an Off-Site Industrial Waste LF. Located next to the Lemberger Transport Site (LTR), a licensed industrial LF which recieved primarily liquid waste, and was active between 1970 and 1976. No. Open dump from 1940 to 1969. Lemberger Landfill, Inc. operated the site as a sanitary landfill under a license from WDNR from 1969 to 1976. From 1976 to 1977,received fly ash from Manitowoc Public Utilities to serve as daily cover. Located about 2007 DC Ass #65 Three LFs (one active and two inactive), implicated in impact; also (non-implicated) eight ponds. A spill into the N. Platte River (1/2009) from a Secondary Pond. 3 LFs: No; 2 Primary SIs: Flexible Membrane, and 2 others: composite liner; 4 Secondary Ponds: No liner. Ponds: 1959 and 1972. LFs: Unknown (but pre 1985).

EPA-HQ-RCRA-2009-0640- 6416, Table 2 LF (License #2786) ? ?

EPA-HQ-RCRA-2009-0640- 6416, Table 2 LF (License #2801) ? ?EPA-HQ-RCRA-2009-0640-

6416, Table 2 LF (License #3233) ? ?

EPA-HQ-RCRA-2009-0640- 6416, Table 2 LF (License #2879) ? ?

**References Waste Unit Type**  **Liner Year Commissioned** **Year Damage**

**Noted Failure Mode**  **COCs/GW COCs/SW** 

Early 1990s GW (SW: 1/2009

gypsum pond spill killed fish; $9.2 million in cleanup; declared FONSI). **MCL Action Level:**Pb;

**SMCL or Health-Based Guidelines:** Co, B, Fe, Mn, Al, Sf

1984 GW **MCL**: Cd, Sb, As, Cr, Pb, Nitrate; **SMCL**: Sf, Al, Fe, Mn; **Health advisories** : B, Mo, Co, Li.

GW: 1994; SW: 1996 GW & SW **MCL**: Se, Ag, (Ba, Cd, Pb - contested by utility); **SMCL**: Fe, Mn, Sf, pH, TDS Only leachate (seepage) samples recorded.

Early 1990s GW **MCL**: (As, Cd, Pb - contested by ADEQ); **SMCL**: Fe, Mn, Sf, Cl, TDS, pHPre-1999 GW and ecological **SMCL**: Sf, Cl, F, TDS Elevated selenium in fish (?)

SW: Late 1960s GW & SW; Soil **MCL**: As, Be; **SMCL**: Mn, Fe, pH **State's industrial/commercial**  **Direct Exposure Criteria (DEC)**  : As, Be; **State's Surface Water Protection**  **Criteria (SWPC) and Pollutant Mobility Criteria**  **(PMC) for Class GA**  **designated areas** : Cd, Pb, 2005 GW, SW, Sediments, Ecologic (?), Fugitive Dust (?) **MCL**: (As), Se, (Cr), Tl **AWQS** : (Al, Fe); **State Uniform Risk-Based**  **Standards (URS) in surface water and sediments**  : As, Al, Ba, Fe; **Unknown standard**  : Cd, Cr, Cu, Pb, Hg, Ni, Zn (Sediments)

? GW **MCL**: As, Cd; **HAL:**Mn, Cr?; DWA: Na, Sf; **SMCL:** Al, Cl, Fe, pH, TDS N/A

Pre-1985 GW **PDWS** : Cd, Cr, F, Ra-226 & 228; **SDWS** : Cl, Sf, Mn, Fe, Al, Na, TDS. Most constituents contested by utility as tracable to seawater or natural sources (local phosphates).2003 GW & SW **MCL**: Gross Alpha, Ra226; **State's Groundwater Clean-up**  **Target Levels (CTLs)** : Al, Fe, Mn, V, Cl, Na, Sf, TDS, pH **State's Freshwater Clean up Target levels**  : Al, Na, Cl, Sf, Gross Alpha; **SMCL**: Fe, Mn, TDS, pH

1999 GW & SW **MCL**: As, Pb; **State's Groundwater Clean-up**  **Target Levels (CTLs)/SMCL** : B, Fe, Cl, Sf, TDS **FDEP benchmark':**As; **HAL**: B; **State's Class III fresh surface water**  **Cleanup Target Levels (CTLs)**  : Al; **SMCL:**Cl, Sf, Na, TDS

2000 GW & SW; Vegetation damage **MCL**: As, Tl; **State's**

**Protection Groundwater Clean-up Target Levels**  **(CTLs)** : Mn, Sf, Al, Mo, Cl, F, Na, Gross Alpha, TDS; **HAL**: B **State surface water standards guidance**  **criteria:**(B, Fe)

1997 GW **MCL**: As, Pb, Se, Cd, Nitrate; **SMCL**: Fe, Mn, V, Fe, Sf, TDS, pH

2002 GW **MCL:**As; **SMCL:**Fe, Sf, Mn; **LHA:**Mn1995 GW **MCL**: Se; **health-based guideline**  : Mn, Sf; **SMCL**: Mn, Sf, Fe. N/A

Pre-1987 GW MCL: (Se); SMCL: Sf

2001 GW (LF) **MCL**: (As); **SMCL**: Fe, Mn, Sf

2000 GW MCL: (As); Up-gradient Control Limits (UCLs): Ba, Se, Zn; SMCL: Fe, Mn, Sf

2008 GW **MCL**: As; **health-based guideline**  : B, Mn, Sf; **SMCL**: Fe, Mn, Sf. N/A2010 GW **MCL:**Pb; **health-based guideline:** Cr, Co, B, Mn, Sf; **State GW standard:** Pb, B, Fe, Mn, Sf;**SMCL:** TDS. N/A

2010 GW **MCL**:As; **health-based guideline:**  B, Mn, Cr?; **State GW Standard:** As, B, Mn; **SMCL:**Mn, Sf, TDS. N/A

2010 GW **MCL:**As; **health-based guideline**  : Cr, Na; **State GW Standard**  : B, Mn, Fe; **SMCL**: Sf, TDS. N/A

LF: Pre-1985; Ponds: 2010. GW & SW **LF: MCL:**As, Se, Pb, Cr, Nitr; **SMCL:**Fe, Mn, Sf, TDS. **Ponds: MCL** : As, Pb; **Health-based guideline:** Cr, Mn;**IL GW Standard** : Pb, B, Mn; **SMCL**: Mn, Fe, TDS. **SDWS** : Mn

1999 GW **SMCL**: Mn, Fe, Cl, Sf, TDS, B1989 GW **SMCL**: (Fe, Mn), B, Sf, TDS

1997 GW **SMCL**: (Mn), B, Sf

Pre-2000 GW **SMCL**: B, Sf, TDS, Fe, Mn, Cl

Pre-2000 (as early as mid-1980s) GW **SMCL**: (Mn), Sf, TDS; **HAL**: B

**Year Damage Noted**  **Failure Mode COCs/GW**  **COCs/SW**1989 GW **SMCL**: (Fe, Cl), B, Sf, TDS; Illinois Class I groundwater standard: (Mn)

2010 GW **MCL**: As, Sb; **health based guideline**  : B, Mn, Sf; **IL GW Standard** : As, Sb, B, Mn, Sf, TDS; **SMCL**: Mn, Fe, Sf, TDS. N/A

GW: Pre-1993; SW: 1995 GW & sediment/ soil;

Vegetation stress **MCL**: Cd, Cr, Tl, Be; **HAL**:

B; **SMCL**: Mn, Sf, Ni, TDS **Unspecified standards (Sediments/Soil)**  : Cr, Ba, Mn, Fe, Ni, Zn, Al, Na

1994 GW **MCL**: As, (Se, Cd, Ba); **Applicable Groundwater Quality Standards**  **(AGQSs)** : (B), Sf, Mo, Ammon, TDS, pH; **SMCL**: Cu

2010 GW **MCL:** Sb; **health-based guideline** exceedances: Mn, Sf; **IL GW Standard** : Sb, Mn, Sf, Cl, TDS; **SMCL**: Mn, Sf, Cl, TDS. N/A2010 GW **MCL**: As; **EPA health based guideline**  :Cr, B, Mn, Sf; **IL Groundwater Standard**  :Pb,B, Mn, Sf, Cl, Fe, TDS; **SMCL**: Mn, Cl, Fe, Sf, TDS. N/A

1997 GW & SW **Illinois Class I GW Standard/MCL** : Cd; **Illinois Class I GW Standard/SMCL** : (Fe), Sf, B **AWQC** : Al, TDS; **EPA’s criteria for sensitive crop**  **irrigation** : B

1996 GW **Illinois Class I GW standards/MCL** : (As), Cd; **Illinois Class I groundwater**  **standards/SMCL**: Fe, Mn, (B), TDS

Pre-1982 GW **MCL**: As, (Pb)

1976 GW and Soil **MCL**: Cd, As Boron-adversely impacts vegetationPre-1993 GW **SMCL**: Fe, Mn, Mo, Sf, Cl, Na;**HAL**: B

Pre-1987 GW **MCL**: As; **SMCL**: Sf, Na, Cl, TDS, pH; **HAL**: B

1997 GW **SMCL**: (Sf), TDS

1987; 1990 GW & SW; Fugitive

Dust MCL: Ba, Cr, Cd, Pb;

**SMCL**: Sf, Na, Cl Elevated Se in fish caused deformities and decline in fish population.

2002 GW **HAL**: B; **SMCL**: (Mn, Mg, Fe), Sf1981 GW **SMCL**: Fe, Mn, Sf, Cl, TDS

1994 GW **MCL**: (As); **SMCL**: Sf, TDS, Cl

1980s; then (newly installed wells): 2011. GW **MCL**: As; **health-based guideline**  : B, Cr, Co, Mn. N/A

1980s GW & SW **MCL**: As, Se, Be; **HAL**: B; **SMCL**: Co, Ni, Mo, V, Sf, Mn, TDS, pH Reddish Leachate

2005 GW **MCL**: (As); **SMCL**: Sf, TDS1989 GW **MCL**: Se, Ba, As; **SMCL**: TDS

1992 GW **MCL**: As, Pb, Se; **SMCL**: Fe, Cl, Sf, TDS, pH

1983 GW **MCL**: As, Pb; **SMCL**: Cl, TDS, pH, Sf

1998 GW **MCL**: Se, As(?)

GW: 2002; SW: 2006 GW & SW; Fugitive

Dust (?) **MCL**: Cd; **SMCL**: Fe, Al,

Mn, Sf, Cl, TDS **WQC** : Cd, Pb, Se2005

(unauthorized discharges) GW & SW **MCL**: As; **SMCL**: Cu, An, Al, Mn, Fe, Sf, Cl, TDS **Maryland WQC** : Se, As, Ba, Cr; **Maryland Secondary WQC**  : Co, Cu, Fe, Zn, Sf, Cl, Hardness

1982 GW **MCL**: (As); **HAL**: B; **State's health-based standard**  : Li

Early 1990s GW State Health Based Standards: B, Li; Elevated Na

1989 GW State Health Based Standards: B, Li, Mo, Se, Na, and Sf.

Mid-1990s (?) GW State's health-based standards: B, Mn.? GW & SW State's health-based standards: B, Li. State's health-based standards: B, Li.

? GW State Health Standards: B, Li, Mn, Sf, Ammonia

? GW & SW/Potential

for ecologic damage State Health Based

Standards: Se, B, Li, Sb; Unknown Federal & State Standards: pH, Cd, Cr, Fe, Pb, Va, Al, Ni, Tl, Mn, Zn. State Based Health Standards: Se, B, Li, Sb

**Year Damage Noted**  **Failure Mode COCs/GW**  **COCs/SW**

1985 GW **MCL**: As, Se, Cd, Pb; **SMCL**: Sf, B1985 GW **SMCL or EPA Lifetime Health Advisory (LHA)**  : Mn, Fe, Ni, nitrate, pH

2006 GW, SW, Ecologic **MCL**: As, Tl, Sb, Se, Pb; **SMCL/HAL**: Fe, Mn, B, Sf, TDS Se in fish causing elevated morbidity and mortality

2007 GW **MCL**: (Pb, Cr), As; **State's water quality standard**  **(2L)/SMCL**: B, Mn, Fe, pH

2007 GW MCL: (Pb, Cr), Se; **State's water quality standard**  **(2L)/SMCL**: (Fe, Mn), B, Sf

2005 GW & SW **MCL, State's water quality standard (2L)**  : As, Se, Cr, (Pb);**State's water quality standard (2L),**  **SMCL**: B, Sf, Nitrate,pH, (Fe, Mn) (Bromide)2007 GW & SW **MCL/State's water quality standards (2L)**  : Cr, Tl, Se, Nitrate. **SMCL**: B, Fe, Mn, Cl, Sf, pH, TDS. **CCC** : Se, Cd; **MCL**: As, Sb, Tl.

1993 GW **MCL**: {Pb), As; **State's water quality standards**  **(2L)** : Cr, Sb, (Ag); **SMCL**: Fe, Mn, Sf, B, TDS, pH.

1998 GW **MCL**: Cd, Se, nitrate; **SMCL**: B, Sf

1982 GW & SW; Sediments **MCL**: Cd, Pb, As, Cr; **SMCL**: Zn, Al, **Unspecified standard:** As

1987 GW **MCL**: As, Se, Cr; **SMCL**: Fe, Sf, B, Na, Cl, TDS1985 GW **MCL**: As, (Pb); **SMCL**: Sf, B

1999 GW **MCL**: (Se); **SMCL**: (Sf)

1991 GW **SMCL**: Sf, Mn, Fe, Al, TDS, pH

? GW **SMCL**: Fe, Mg, Mn, Na, B, Sf, sulfide, TDS, pH

1987 GW & SW **MCL**: As, Cd, Ba, Pb; **SMCL**: Fe, Mn, Sf, TDS **Unspecifies standards**(at discharge outfall): Fe, TSS1994 GW **SMCL**: (Mn), Sf

Sometimes between 1973- 1986. GW **SMCL:**TDS, Sf, Fe.

1985 GW **MCL**: Se; **SMCL**: Sf

1993 GW & SW **MCL**: As; **HAL**: B; **EPA Lifetime Health Advisory**  **(LHA)** : Mo **Unspecified standards**( **No limts in NPDES)**  : As, Mo

1974 (ecologic); 1994 GW & SW; Ecologic **MCL**: (As, Ba, Cd, Pb, Gross Alpha); **SMCL**: (Mn, Cl, TDS); **EPA Lifetime Health Advisory (LHA)**  : (Mo) **NPDES permit criteria** : B, Cu, Sf; **Acute or Chronic exposure WQC**  : Al, Ni, Zn2005 GW **MCL**: Ba, Gross Alpha; **SMCL**: Fe, Sf, (TDS)

2008 GW **MCL**: As, Ba, Cr, Pb, Se, Tl; **SMCL**: Sf, pH; **State health-based standards**  : V

1998 GW **MCL**: As; **SMCL**: B, Mo, Ni, Mn, Fe

SIs: Late 1980s; LF: mid-1990s GW & SW **MCL**: As, F; **SMCL**: Al, Mn, Cl, TDS **CCC** : As

2004 GW & SW **MCL**: Sb, As, Cd, Cr, Pb, Se; **SMCL**: Al, Fe, Mn, Ni, Zn, Cl, Sf, TDS **WQC for fish and aquatic life (CCC)**  : (Al, Ni, Zn); **NPDES permit** : Fe, Mn, pH1999 GW **MCL**: As;**SMCL**: Fe, Mn

GW: 2001; SW: 2006 GW & SW **MCL**: F; **SMCL**: Al, Fe, Mn, Sf, TDS **Criteria Continuous Concentration (CCC)**  : (Cr hex., Se, Cd, B)

2005 GW **MCL**: Cr, Pb (in turbid samples); **health advisory** : Cr, Sf; **SMCL**: Sf, Fe, TDS. N/A

1997 GW & SW; Potential ecologic damage (As in fish) **State's Water**

**Classifications and Standards for GB-class**  **groundwater** : As; **MCL**: Cr, Cd, Pb **MCL**: As;**SMCL**: Fe

2009 GW **MCL**: As, Cd; **health based guideline**  : Cr, Na, Sf, Fe;**SMCL**: Al, Cl, Fe, Sf, TDS. N/A1996 GW & SW **MCL**: As; **SMCL**: pH **MCL:**As

2009 GW **MCL**: As; **health-based guideline**  : Cr, Sf, Fe; **SMCL**: Sf, Cl, Fe. N/A

**Year Damage Noted**  **Failure Mode COCs/GW**  **COCs/SW**

2006 or earlier GW **MCL:**As; **health-based guideline:** Mn; **SMCL:** TDS. N/A

1974 GW, SW **MCL**: As, Cd, (Co);**SMCL**: Sf, Al, Ca, Fe, B, Mn, Mo, Ni Fe2006 GW & SW; Dam Failure (1973) **MCL**: Cd; **SMCL**: Al, Sf;

**HAL**: B, Sr; **Regional Screening Level for tap**  **water** : Mn **Chronic and Acute EPA Water Quality Criteria**  **(WQC) levels for freshwater aquatic life**  : Cd; **Chronic WQC** : As, Se, Cr hex., Al, Mn

2008 GW & SW **State's GWPS/MCL** : As, Se; **State's GWPS** : V; **HAL**: B; **SMCL**: Al, Fe, Mn, Cl, Sf, TDS **WQC for Fish and Aquatic Life and DWS**  : Se

2008 GW **MCL/GWPS** : As, Cd, Hg, (Be); **HAL**: B; **State GWPS** : Ni, V; **SMCL**: Co, Fe, Mn, Sf, TDS

1986 GW **MCL**: As, Cd, Pb, Cr; **HAL**: B, Mo; **SMCL**: Al, Fe, Mn, Co, Sf, TDS

Pre-1985 (?); 2010 GW **MCL:**As, Pb; **health based guideline:** B, Co, Ni, V. N/A2005 GW **State's Residential & Commercial Protective**  **Contamination Levels (PCLs)**  : Co; **Residential PCL/HAL** : Mo; **MCL/PCL** : Se; **SMCL**: Al, Mn, V, Sf, Cl, TDS

2009 GW **MCL**: As, Se, Ba;**health based guideline**  : B, Cr, Co, Mn, Mo, Sf. N/A

2008 GW & SW **MCL** (onsite only): As, Cr, Pb; **SMCL**: V, Cu, (Mn, Fe); **HAL**: B (drinking water wells offsite) **Unspecified standards** (Offsite): Al, Fe, Mn; **Unspecified standards** (Onsite): Tl, Cr, Pb, Al, Fe, Mn

1976-1977 GW **State Enforcement Standard (ES = MCL)**  : As, (Hg), Se; **ES (= SMCL)** : B, Fe, Sf, TDS

1980s GW **State ES HAL**: B; **State ES** : Fe, Sf, TDS; **State PAL**: Cl; **MCL**: As, Se1986 or 1994 GW **Enforceable Standard (ES)**  : Sf, Mn; **Preventative Action Level (PAL)**  : Fe; **SMCL**: (B, Zn, Al, Cl, TDS, pH)

1975 GW **State Enforcement Standard (ES)**  : Mn, Sf

Pre-1993 GW **State Enforcement Standard (ES)**  : Mn, Sf, (Fe); State PAL: B; MCL: Se, (Cd)

Pre-1979 GW **State PAL**: As, Se, Cd (?); **State ES** : B, Sf, F, Mn

2002 or earlier GW **State Enforcement Standard (ES)/EPA's**  **Lifetime Health Advisory (LHA)**  : Mo; **State PAL**: As, F, Hg, B; **State ES** : Mn, Sf1980 GW **State PAL**: Se; **State ES** : B, Sf

1980 GW & SW VOC and inorganic constituents. **MCL:** CVOCs, As, Ba, Cr, Cd, Pb. Unknown standard(s): VOCs, Cd, Pb.

Pre-1985 GW & SW **MCL**: (Cd); **SMCL**: (Mn), Sf, B Unknown

? GW ? B, Se, Hg, Sf

? GW ? As? GW ? As, Pb, Mn

? GW ? As, Se, Pb, Mn

**Year Damage Noted**  **Failure Mode COCs/GW**  **COCs/SW Regulatory Action**  **Current Status**

None. CO recommended (1993); 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. Active

In karst active area; sinkhole treated and capped. Some Active, some not

ADEQ ordered assessment monitoring (2005) due to SSI in Se, sulfate and TDS. Notice of Deficiency (NOD) in 2008. Active

None. Since no primary MCL exceedances noted in the recent years, the State has not responded because it does not enforce SMCLs. ActiveNone Active

EPA's RCRA Corrective Action investigations at the site identified 14 Areas of Concern (AOCs). CTDEP and USEPA made final determination that migration of contaminated GW is under control (2001). The facility is working towards a RCRA Final Remedy. RCRA Closure/Post-Closure work continues on site. NRG has completed an Ecological Risk Assessment. Inactive (Plant switched fuel to oil)

CO for RI and remediation of the Burton Island (SI) area; DNREC issued No Further Action remedy for off-site sediment and off-site surface water. The Final Remedial Plan for OU1 (construction of erosion controls) and for OU3 (No Further Action) was approved in 8/2008. A Final remedial Plan for OU2 (targeted soil cover with land use controls) was approved in 10/2013. Some Active, some not. Based on a Consemt Decree, and with the exception of Generation Unit #4, all generation units retired between 2011 and ? Active

None; impact restricted to ZOD. ActiveState required upgrades, additional

monitoring of LF, determination of waste type, and bottom-liner systems for any future disposal units at the LF. Active

State required Interim Remedial Action Plan (GW capture system and remedial monitoring). The groundwater monitoring is ongoing since 2004 with results reported quarterly to FDEP. Active

CO (2001) for repair/replacement of liner systems on waste management units; A Remedial Action Plan and GW monitoring plan approved 2007; closure of a SI impacting vegetation. Some Active, some not. Closed the unlined DA-2 Disposal Area in 2005.

FDEP issued a Consent Order (2001) because of impacts to GW and required additional on-site monitoring and ~ $180,000 in civil penalties. Active

IDNR required (in 2009) that MW11 be evaluated to determine why it has been difficult to obtain GW samples and to replace it if it continues to remain dry. A replacement well (MW-11R) was installed in 2010. Following the exceedances of As, Mn and Fe in MW-11R, IDNR required an assessment monitoring. IPL submitted a GW Assessment Workplan, including the installation of additional monitoring wells, and, for two rounds of assessment Active? Active

Capping and seeding; GW monitoring/study. No further state remediation action. Some Active, some not

MidAmerican Energy submitted a risk evaluation for arsenic to IDNR in 2006, and IDNR requested more data to support the study's conclusion attributing the high concentrations of arsenic to off-site sources or the submission of a plan to address the arsenic plume. Issue is still under consideration. A new composite lined cell constructed in 2009 and the older cells are Some Active, some not. Generating boilesr 1 & 2 to retire 4/2016 due to violations of CAA.

IDNR requested (2005) that future GW reports from MidAmerican discuss potential for GW mounding under LF, evaluate if listed wells are truly ”upgradient,” and discuss potential for migration and possible receptors. The Utility’s 2008 GW report did not address these questions. Active

? LF inactive (1987); final cover in 1992.A hydrogeologic assessment plan has been

submitted and approved. IEPA met with Electric Energy to discuss elevated levels of contaminants at the site and appropriate remedial alternatives (IEPA, Oct. 2011). Some active, some inactive

Hydrogeologic assessment plans approved and implemented, GW monitoring results received and under review (IEPA, Nov. 2011). Some active, some inactive

A hydrogeologic assessment received and is currently under review. CWLP met with the IEPA to discuss potential impact to theadjacent stream and the potential for offsite movement of contaminants. CWLP will be doing further investigation to better define GW impacts at the site (IEPA,Oct. 2011). Active

Waste units sited over highly permeable fluvioglacial deposits. The large, older LF has been closed after ceasing operation in 1978 with 2' of soil cover. There is no information on whether the newer, smaller LF has been also closed since ceasing operation in 1982. Old LF closed/1978; Another LF closed/1982. Ponds: Active

Plant area underlain by fluvioglacial and aeolian deposits, and by mine spoil. Closure of unlined SIs, including dewatering; overhaul of monitoring well system. Switched to offsite dry disposal. Remedial action under development. Some Active, some not. Recyclingpond cleanclosed/2011, as well as the two SIs. CCRs disposed in offsite LF.Located on glaciofluvial deposits. CO by

State. Old SI closed in 1996, replaced with a lined SI and LF. Some Active, some not. In July 2013, Dynegy notified the EPA about its intent to close the Hennepin west ash pond system.

Located on glaciofluvial deposits. Consent Order; pond closing by State/2009. Some Active, some not

Study; GW monitoring program, Plant retired in 12/2011. Inactive

Two shallow aquifers separated by a confining layer. CO to close unlined SI and replace w/2 synthetically-lined SIs. GW program in effect. Ameren conducted a human health risk assessment and an ecological risk assessment in support of the closure of Pond D. Plant retired end of 2011. Closure of Pond D completed 1/2013.

**Regulatory Action Current Status** CO (in 1999, switched to dry handling; GW

monitoring program). Approved GMZ. Active/ modified

NOV W-2012-00056 (6/11/2012), violations in MW-1, MW-2, MW-3, MW-4, and MW-5. In the quarterly monitoring samplings between 10/2010 to 3/2012, exceedances of As, Sb, B, Fe, Mn, Sf, Cl, TDS, and pH. Compliance Commitment Agreement (CCA), 10/24/2012. On 10/3/2012, the Environmental Law Policy Center (ELPC), along with other environmental organizations, filed a complaint against MWG before the IPCB, alleging that MWG caused or contributed to the contamination of GW via open dumping. Active

IEPA acknowledged damage to vegetation by seeps and GW impact (1995-1996); Leaking cells capped; GW monitoring in effect. Area declared GMZ. Culprit LF is Inactive.

In 1996 the LF became exempt from Illinois Class I GW Protection standards and IEPA applied relaxed standards (Applicable Groundwater Quality Standards, AGQSs) to a number of contaminants. 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 GW”, identifying 50 Active

Hydrogeologic assessment plans approved, GW monitoring results received and under review (IEPA, Feb. 2010). Hydrogeologic assessment plans approved (27 parameters are reported quarterly). GW sampling results have been received indicating potential GW impacts. Additional sampling data is being collected to establish background water quality at the site (IEPA, Oct. 2011). **NOV**(6/11/2012); **Compliance Commitment Agreement (CCA)** 
, ActiveA hydrogeologic assessment plan has been

submitted and approved. Preliminary GW sampling results received indicating potential GW impacts. Additional sampling data is being collected to establish background water quality at the site (IEPA,Oct. 2011). Active

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. Active

None, but proposed closure of the SIs through capping and a GMZ. The well inventory required by IEPA and completed by Ameren confirms that there is no use of groundwater for potable or industrial uses down-gradient of the impoundments. The contaminated GW will slowly discharge into the river by subsurface seepage at levels that are presumably protective of huma Inactive. Plant retired.

Two rows of steel slurry wall down-flow from the disposal site for protection from Lake storms and for improved structuralstability. In 1999, Plant switched to drydisposal of fly ash. Impoundments capped in 2007. Fly ash from the Michigan City (and Bailly) Stations is transported for disposal offsite (Schafer Generating Station.) Active

RCRA EPA Corrective Action, monitoring wells, Baseline Ecologic Risk Assessment; NIPSCO required to investigate whether contamination from the site is affecting soil, GW or Lake Michigan. LFs: Inactive (1976, 1986); SIs: ActiveNo Consent Order and/or other

state/federal action. Original unlined cells capped; switched to dry handling; GW monitoring in effect. Active/ modified

A slurry wall was installed in the NE corner of the original LF in late 1987; Leaking cells capped; GW monitoring in effect. Some Active, some not

None Active

State: Corrective Action and GW monitor for GW impacts. Federal: Consent Decree for emission violations. Some Active, some not

Citizen groups appealed the Type I Restricted waste landfill permit, requesting additional monitoring and installation of a liner during future construction. IKEC and IDEM rejected the requested changes, and the appeal has been subject to multiple judicial reviews since 2003. IDEM claimsthat the boron SMCL exceedances in downgradient GW monitoring wells do not ActiveGW mounding is probable. A revised GW

assessment plan that also included a risk assessment was submitted to the KPDES in 12/2009. Active

KY has discretion, under 401 KAR 45:160 Sect.1, to require or not require a GW corrective action. The O/O is currently not required to perform a corrective action. Assessment monitoring for sulfate is currently required, and KDEP is currently evaluating the information on Cl exceedance. Active

? Active

A GW assessment was performed at the site in the 1980s; no KDWM enforcement action since. KDWM permitted (2007) the expansion of the LFs without a liner (as “special waste landfills”), over old, unlined ash ponds. Some Active, some not. Shawnee Units 1 and 4 either will be converted to biomass-fuel, controlled by adding scrubbers and selective EKPC has been directed by the KDWM toconduct an assessment in MW-2A & MW3A, to determine the cause of the detection of arsenic in MW-3 at a concentration exceeding the permit limit . The Commonwealth of Kentucky did require a Remedial Action Plan (RAP) under its regulations; the plan has been approved and EKPC has implemented it. The RAP ActiveLDEQ 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. Resampling recommended to verify high levels of Ba and As detected in 2010. Active

LDEQ required (Dec. 2008) on-site assessment monitoring, but in Feb. 2010, LDEQ allowed a return to detection monitoring. Active

LDEQ required (2008) on-site assessment monitoring. Active

CO, a partial cap. About 80% of the LF area has been capped. Most of the remaining 20% of uncapped LF will be brought to grade with clean fill as part of the proposed Payne's Crossing development project. Inactive 2001

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. A $1.9 million settlement was reached 1/2013. Active. Plans for either switching from coal to oil at the Chalk Point Plant or having itretired in mid2017. This will significantly reduce theMDE filed notices of intent to sue Mirant

Mid-Atlantic LLC in federal court (1/2011) for alleged water pollution violations. For additional lawsuits/settlemnt agreement, see under Comments. Active. NRG, new owner, plans to switch the Dickerson Plant from coal to oil or have it retired in mid-2017.

Consent Decree requires slurry walls to be built to stop leakage, and monitoring of GW/surface water interface. While a slurry wall was constructed at the Weadock site, recently, the slurry wall proposition for the Karn site has been scrapped due to slope instability of the site. Active. Consumers Energy announced plans to demolish Weadock plant in April 2016 pending approval of the Michigan Public Service Commission and Feseability Study; Remedial Action Plan.

Inactive 1995 Consent Orders (1993 and 1995); Restrictive covenant in place to restrict installation of water supply wells; and groundwater monitoring (suspended in 2009). Inactive (capped) 1993-1994.

Feasibility Study and Remediation Action Plan (RAP) since 1998 required groundwater interceptor trench, rapid infiltration and treatment. Inactive 2001Consent order (1993): remediation

investigation suggested no active GW extraction. Ash redistribution and removal, grading, and capping w/synthetic membrane, surface water drainage, and remedial leachate collection. Supplemental Remedial Investigations (1995), amended Remedial Action Plan (1997), and a 30-year post-closure GW monitoring. Inactive 1993

Consent Order, Remedial Investigation and Feasibility Study, followed by a Remedial Action Plan (RAP). Restriction on new drinking water wells. Construction of a bentonite slurry wall around the entire SI; FML cap covered by 30 inches of soil and topsoil; Closure (2008); and 30-year post closure monitoring. Inactive 1982

Two Remedial Action Plans. Restrictive deed covenant. GW extraction (can be suspended if criteria are met), and mixing zone criteria for B, Li, and Se. Inactive 1998

**Regulatory Action Current Status** 

None(?); not clear whether Ponds' #1 and #2 capping/closing and active dewatering are in response to state requirements. Some Active, some not.Based on NC DENR directions, compliance

monitoring wells were constructed at the Compliance Boundaries of the CCR SIs in 12/2010. Due to Fe, Mn, and Ni exceedences between 2011-2013, NC DENR’s submitted a lawsuit against Duke Energy Progress (8/2013); DWR staff is working with the Defendant to determine if these exceedances are naturally occurring Some Active, some not

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 re-designated as "No Further Remedial Action Planned". However, multiple-constituent violations above 2L GW Standards have been measured in 8 compliance wells between Inactive: Plant closed 11/2013. Clean-closing of SI being considered.

NC DENR’s lawsuit against Duke Energy Progress alleges that based on GW monitoring data from 12/2010 through 7/16/2013, there are GW exceedances of the 2L GW Standard at or beyond the compliance boundary of the Plant’s SIs. A consortium of citizens groups sued Duke (9/3/2014) alleging violation of the NPDES Permit and of the CWA. One Active, 3 inactive (prior to Plant's retirement, 9/2012).

Minor GW mounding next to the River. NC DENR’s lawsuit against Duke Energy Progress (8/2013) indicates that based on GW monitoring data since 9/2010, GW had exceedances of the 2L GW Standard at or beyond the compliance boundary of the Plant’s ash ponds. A consortium of citizens groups sued Duke (9/3/2014) alleging violation of the CWA. Some Active, some not (prior to Plant's retirement in 10/2012).

GW Corrective Action Plan and Closure of the Pine Hall Rd. LF, but not for the other two LFs. Pine Hall Road Landfill capped with a drainage geonet overlain by a 40 mil LLDPE geomembrane and 2' of soil cover. DWQ has sent a letter to Progress Energy, directing them to place wells at their Compliance Boundaries. New monitoring wells were installed (10/2010), per DNER Some Active, some notMounded GW around the active ash basin.

DWQ has sent a letter to PE, directing them to place wells at their Compliance Boundaries. Monitoring wells placed in 2010 & 2011. Since 2006, Progress Energy took several actions to maintain and upgrade the SIs and associated components of its wastewater treatment system at the Asheville Plant. Following a contamination Active

Until 2013, State stated it will not require action until contamination is outside the ”compliance boundary.” On August 16, 2013 NC DWQ filed a lawsuit against Duke Energy. The lawsuit indicates that based on GW monitoring data from 1/2011 through 7/2013, GW exceedances from the 2L GW Standard, at or beyond the compliance boundary of the Plant’s ash ponds, include Inactive. Plant retired on April 1, 2012.

State required corrective action: Old LF site capped and closed; GW monitoring in effect. Some active, some Inactive

State issued a special use disposal permit to allow disposal to continue, but required continued monitoring and site closure. A preliminary assessment (PA) in 1990 and a Site Inspection (SI) in 1995, both under CERCLA. According to the 1999 RTC, "Site closed and capped and pending NFRAP (“No Further Remedial Action Planned”). The GW monitoring wells were approved for Inactive (closed) 1989/90.

State required relining of SIs in 1990; GW monitoring in effect. ActiveNone. Some Active, some not (Pond 4 and Pond 5 were decommissioned and capped between 1992 and 1996).

NDEQ required the Utility to install additional wells and extended post-closure GW monitoring period from 10 to 15 years due to evidence of contamination. Some Active, some not

CO (1999). Site Investigation, closing and capping, and GW monitoring. Closure completed 2001, and GW monitoring system in operation. Inactive (2001)

Corrective Measure Assmt. As of 2010, Phase I of the LF (1987-1994) was closed and fully capped; Phase II (1992-2005) was closed and 70% capped, and Phase III has operated since 2006 till Plant's retirement. Active (current permit to expire 8/2018).

As of June 2011, seven CWA violations have been recorded, including a State Administrative Penalty Order (oil leak, July 2006), incurring a penalty of $500. Some Active, some not (current operational permit to expire 1/2023).Closed and capped (1996); GW monitoring

is no longer required. Inactive

Unknown Active (?)

GW investigation and remediation performed, monitoring wells in effect. A sinkhole Investigation and Repair Plan letter was followed by sinkhole repair (1999). Active/ modified

AEP asserts that GW contamination was due to previous mining. The OH EPA placed (2004) 4- GW monitoring wells under “assessment monitoring” due to evidence of CCR contamination. In 2009, AEP submitted a 2nd Assessment Monitoring Report to OH EPA based on the results of the expanded GW monitoring program, which included wells Groundwater Some Active, some not

OH EPA required assessment monitoring onsite to determine extent and rate of contamination and to address the contamination. OHEPA claims that several coal mines and oil/gas wells that are either within the LF’s footprint or adjacent to the LF’s and SIs’ footprints are the culprits: in fact, the fly ash SI serves to collect and treat the surrounding acid mine drainage prior to Some Active, some notOH EPA mandated AEP (2004) to implement

a GW monitoring plan and install 15 GW monitoring wells, 4 GW elevation monitoring wells, and 5 piezometers. However, OH EPA does not support the conclusion that the PP has demonstrated an indication of an impact on GW quality. Active. Generation Units 1-4 to retire by Dec. 31, 2014, while Unit 5 might be then switched to natural gas.

ODEQ required AEP (9/2007) to establish a GW 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. Active. One of the two generation units to retire by 2017.

None (State law does not require state response for onsite exceedances of secondary MCLs); (NOV for fugitive dust) Inactive. The Plant was deactivated at the end of 2013.

Consent Order and Agreement (COA) was signed in 1990 providing several options to remediate contamination source; included $50,000 penalty for discharge violations. Inactive; early and late-1990s. Plant decommissioned 2002, demolished 2011/2012.

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. In May 2010, four environmental groups announced that they intend to sue Seward’s owners for about 12,000 violations of the federal CWA, the Pennsylvania Clean Streams Law, and the InactivePADEP ordered GW 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. Inactive. As of 5/22/2010, the Hunlock PP is no longer operative, including all associated disposal activities.

None. PADEP claims that State law does not require state response for onsite exceedances of SMCLs; surface discharges are regulated through a NPDES permit, and Reliant has not been in violation of their permit. Active. Plant slated to close in January 2015.

? Active

CO (2001) in response to monitoring well violations of As seeping from the SIs. It established a GW Mixing Zone, with waivers for As (3,000 ppb), sulfate, Pb, Cr and Cd. According to a Settlement filed 8/17/2012 (U.S. District Court for the District of SC) with Catawba Riverkeeper Foundation, SCE&G will decommission the Wateree’s Station CCR storage ponds by removing One SI is inactive; all other WUs - Active

? ActiveSC DHEC required a proposal (2009) for

stabilizing Arsenic exceedances in 3 monitoring wells or a corrective action plan. DHEC also indicated that no remediation of the SIs is being conducted, and no violations or orders have been issued to the site owner. Inactive: the Plant shut down operation in May 2012.

? Active

**Regulatory Action Current Status** 

? Active

None, assuming dilution by the Clinch River. Phase III, then Phase II GW Assessment Monitoring. In May 2012, citizens’ groups petitioned the Tennessee Water Quality Control Board, contending that the State of Tennessee NPDES Permit, which authorizes BRF to discharge 19 million gl/d of CCR effluents from its settling pond directly into Melton Hill Reservoir on the Clinch River, ActiveNone. Apparently, state law does not

require a response to onsite exceedances. The Plant has been under Phase II Ground Water Assessment Monitoring since April 2007. Between 1998 and recently, TVA installed a leachate collection system ~ 2,500 feet in length adjacent to the Holston River, and during 2008-2009, TVA installed a geocomposite liner system and leachate Inactive. Plant retired from service December 31, 2012.

None. Apparently, state law does not require a response to onsite exceedances. Groundwater Assessment Plan required by TDEC. Some Active, some not

GW Assessment Plan in place since 4/2011. A coalition of environmental groups filed with the Tennessee Water Quality Control Board an appeal of a pollution permit issued for Gallatin (July 2012). Two ponds active, one closed (1998)

Both New Johnsonville and the City of Camden intake their municipal water supplies from the Tennessee River near the PP’s outfalls. Despite evidence of surface water quality impacts from the PP’s CCR disposal, the State has not required the PP to limit its discharge, monitor CCR disposal areas more frequently, or take any corrective action. The PP stopped Some Active, some not. Six of the Plant's 10 generating units to close no later than by end of 2015, and the four other generation units - no later than by ? ActiveTCEQ required (2005) a Se assessment at

one of the SIs as the likely source of Se; investigations remain underway. Assessment monitoring, capping/closure of leaking SI, and notification of residents in adjacent properties. Pond closed; LF Active

? Active

Among the CoC (arsenic, boron, chromium,copper, lead, and vanadium) in GW from onsite monitoring wells, only boron has been detected in about 25 residential drinking water wells. In response to the City of Chesapeake’s requested, EPA conduct site inspection under CERCLA. Dominion Power undertook installing public water to the two closest communities. Several lawsuits by Inactive

Biennial GW Reports. Inactive (decommissioned: 2000)

State required upgrade of GW monitoring, studies, and remediation. WDNR required a series of investigations from 1988 to 1997. The investigations found that cessation of ash sluicing and capping of the LF had effectively controlled the contamination of GW and no additional remedial actions were required. The ‘LF contact pond’ closed with clay cap in 1986 after construction of a Some active (new LF and SIs); Old LF w/contact pond - Inactive. One generation unit slated for closure by the end of 2015, and a second, possibly toThe LF was closed and capped in 1986. In

1994, WDNR required investigation of GW contamination and upgrade of monitoring network to reflect concentrations outside the screened ash zone intervals. Inactive 1986

AOC; requirement for additional monitoring wells; ultimately-site closure. Now, under post-closure monitoring. Inactive 1986. Three of the Plant's 5 generating boilers closed end of 2011, and the remaining two - to be retired early in 2015. Analysis of LF performance, better liner and mitigation study. Phase II final cap was placed in 2000 and Phase I/III final cap - in 2007. Some Active, some not

The State required an investigation of GW contamination, capping and closing of old ash pond (permitted as LF). Some Active, some not. Plant to retire by the end of 2015.

WDNER has been investigating (as of 6/2010) to better establish local background and gradients to determine if CCRs are source of exceedances. Strong indication for past extensive, unregulated CCR dumping might explain Mo upgradient from designated LFs. WE has been purchasing impacted properties. Some Active, some notInvestigation Report (1994) and Remedial

Report (2007). The property with the quarryand impacted private well that had preremediation boron and sulfate exceedances was purchased by the utility and retired. Engineered cap (2007/08) and partial removal of the fly ash to form a 1-acre wetland. Inactive 1971. Coalfueled generation unit closed 2004.

Designated as an NPL site in 1986 due to GW contamination. RI/FS performed in 1991. PRPs entered into a consent decree with U.S.EPA in 1992 to perform design and remedy implementation activities. Remediation, completed 9/1996, included waste relocation; landfill capping; slurry wall construction; leachate collection and GW treatment system installations; and implementing GW monitoring and use Inactive: Both LL and LTR, the adjacent industrial waste LF, stopped operating in 1976 (1977?). Wate relocated in 1996.

No Reg. action on GW impact. A Jan. 2009 release of 14,400 gallons of coal ash from the Blowdown Canal. Corrective action addressed the spill. Some Active, some not

? Closed (in ?); now being mined.

? Active? Active

? Closed (in ?); another cell active (License #3067)

**Regulatory Action Current Status** **Comments NOV**  **CO/Admin Order**  **Study**

Plant situated on a karst terrain. Groundwater mounding inferred from radial flow pattern. A January 2009 gypsum pond spill incident was resolved as Finding of No Significant Impact (FONSI). The removal of the gypsum from the triangle area was completed June 2009. **Y**(EA to document the spill emergency response actions)

Groundwater mounding. **Y**

Plant's area designated (2007) as an “Important Bird Area” (IBA). An intermediate liner (i.e., over existing CCR fill) and leachate collection system would be placed over the ash currently in the landfill to minimize infiltration into the lower ash body. **Y**

Mounding beneath the Surge Pond.Baseline GW quality was worse than that of the contaminant plume.

‘Zero discharge facility’, high evaporation rates result in high Na and Cl levels in the ash ponds, as well as in salty seeps.

The Thames River close to the PP 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 GW contaminated in excess of SWPC would adversely impact the River **Y**

RI studies for OUs 1, 2, and 3 determined that GW contamination pathways to residential wells are impeded by the prevalence of brackish water, and that fugitive dust dispersion complies with NAAQS. The RI of OU2 determined that if landfill erosion is controlled, there is no ecological hazard from exposure to sediment through food web interactions; and there is possible, but not probable potential for adverse effects on benthic invertebrates due to arsenic and barium in sediment. Citizens claim that Indian River arsenic data in fish and shellfish for 1998- 08 exceed 1x10-5 human health risk estimate. **Y Y** 

The plant is located in quaternary alluvium of the Escambia River. GW appears to have a naturally low pH. GW mounding in the area of the ash LF. GW monitoring data from 5 sampling events from 5/2008 to 11/2010 show that contamination from a coal ash LF and gypsum storage areas at the Plant have caused multiple exceedances of MCLs for As and Cd in a compliance monitoring well. An expanded monitoring program that began in 2010 added testing for Tl. The first round of monitoring found levels that are 85% of the Tl MCL in a detection monitoring well. Other health-based guidelines were also exceeded. Data for 5 GW sampling ? ? ?

According to the Utility, GW impacts are reported to occur within the approved FDEP ZOD, so they are in compliance with FDEP GW regulations.A Zero Discharge facility. State claims that the problem is completely

contained on-site. **Y**

A Zero Discharge facility. LF - stabilized FGD. State claims impact within Zone of Discharge (ZOD). Utility claims that surface water samples were taken from ditches adjacent to the FGD LF, where surface water qualitystandards are not applicable because they are part of an NPDES MultiSector General Permit treatment system. **Y**

A Zero Discharge facility. The unlined Gypsum Management Area is one of the sources of contaminants. State claims impact limited to Zone of Discharge (ZOD). Thallium primary EPA MCL exceedance on a property offsite, which was subsequently purchased by TECO. Plant is co-located with The Tampa Bay Seawater Desalination Plant, from which it receives its cooling water. **Y**

Built on top of abandoned phosphate mine, which likely has some influence on GW flow under the site. Impacts confined to the Zone of Discharge. Lakeland has prepared and implemented a Best Management Plan (BMP), a permanent Waste Management Plan (WMP), and a modified groundwater Monitoring Plan (GWMP) for the power plant. **Y**

The Lansing PP was constructed in 1948, with generation units added in 1957 and 1976. “The flow of the regional aquifer is N-NW toward the Mississippi River. However, the potentiometric map of the area does not appear to take into account the localized, more westerly flow in shallow GW in the alluvium of the valley in which the CCR LF and impoundments are located. The alluvium, which is generally more permeable than the fine-grained sandstones of the bedrock aquifer, probably represent a near-surface GW system that creates a preferential flow path for contaminants to the W-NW. The presence of contaminants in MW11 is consistent with this interpretation." Originally rejected as a damage case (ICF, 10/2010, Appendix C, #7, p. 14 ) due toInadequate Information:Monofill located on alluvial sand, silts and clays adjacent to the flood

plain of Pine Creek, which enters the Mississippi River 0.5 mile SW of the monofill. Over most of the site shale is found at depths of 15' below the original ground surface or less. GW monitoring data from 1995 to 2008 indicate that the monofill has contaminated underlying GW. The LF has 1 downgradient well where the average level of Se since 1995 has exceeded the MCL (max. 713 ppb, 14 times the MCL) and the average since 1995 has been 71.3 ppb (1.4 times the MCL). Health-based guidelines have been exceeded in 5 downgradient wells. ? ? ?

Not certain that the active LF is co-located with the closed (1973) LF. Limited-size LF and plume with no down-gradient recipients. An 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.” **Y**

Mounded GW underneath the monofill. The Utility suggested that the upgradient As contamination was due to up-gradient sources and is not CCRrelated. In Harm’s Way counters that some of the up-gradient wells are improperly classified because GW does flow from the monofill towards these wells due to mounding. **Y**

There are indications that the only “up-gradient” monitoring point (MW4) has been affected by CCR constituents as a result of GW mounding within the LF. **(Y)**

The shallow GW flow system includes shallow bedrock in the S part of the site, the saturated portion of the fill, and shallow unconsolidated deposits near a creek at the N edge of the LF. 18 monitoring wells, not all active. GW monitoring data (1994 - 2009) show As levels in 2 downgradient wells steadily increasing, exceeding the MCL in 2008 and 2009 (max.: 18.3 & 28.9 ppb). The Iowa GW standard of 1.0 ppm for B has been exceeded in 10 wells (Max. 37.1 ppm). Sulfate, in 10 downgradient wells (max. 5,300 ppm) and other SMCLs also exceeded. ? ? ?One of more than a dozen plants in Illinois with coal ash ponds where

GW monitoring was not required by IEPA prior to the TVA Kingston ash spill in TN. The first round of GW sampling of monitoring wells at 2 ash ponds was in 2010. The Pb MCL was exceeded in 2 wells (Max. 27.4 ppb, 1.8 times the MCL). As levels may be above the MCL, but this cannot be confirmed as the detection limit for arsenic was 2.5 times higher than the MCL . In response to IEPA’s new monitoring program, 7 wells (G101, G111, G112b, G113, G151, G152 and G153) were sampled on 8/17/2010. Whereas a well location map was not available for review, none of the ? ? ?

One of more than a dozen plants in Illinois with coal ash ponds where GW monitoring was not required by IEPA prior to the TVA Kingston ash spill in TN. The first round of GW sampling of 5 downgradient wells occurred in 2010. Arsenic exceeded the MCL in 2 wells (Max. 148 ppb, 14.8 times the MCL). EPA health-based guidelines were also exceeded. In response to this program 5 wells (APW1 to APW5) were sampled on 12/13/2010. A well location map was not available for review. Although no exceedances were found in APW1 and APW5, the presence of B at 0.117 ppm and 0.118 ppm in these 2 wells suggests that all wells have been impacted by ash ponds. ? ? ?

One of more than a dozen plants in Illinois with coal ash ponds where GW monitoring was not required by Illinois EPA prior to the TVA Kingston ash spill in TN. The first round of GW sampling, of 5 downgradient wells at the ash pond and 3 downgradient wells at the FGD pond in 2010 (May or June sampling), showed exceedances of the As MCL at 3 ash pond wells (Max. 93.6 ppb, 9.4 times the MCL) and 1 FGD well (14.8 ppb). In response to IEPA’s new monitoring program, 4 temporary piezometers were installed at the periphery of the ash pond area (AP1 to AP4, GW ~ 4- 6’ below ground surface) and another well, AW3, at a further distance downgradient from the ash pond. There are also 3 FGD monitoring wells ? ? ?

On 6/11/2012, IEPA issued a NOV for GW contamination after testing of wells showed numerous exceedances of heavy metals including As and Se. On 10/24/2012, a Compliance Commitment Agreement (CCA) signed between Midwest Generation (MWG) and IEPA. In 10/2012 citizen groups filed a complaint with Illinois Pollution Control Board, calling MWG to stop disposing ash in the ponds, start hauling the ash to a LF in a closed system and remediate the site to remove all contaminants. **Y Y** 

On 2/4/2013, Illinois Attorney General filed a complaint with the Illinois Pollution Control Board alleging that Ameren Energy Resources Generating Co. illegally disposed of 180,000 tons of coal ash (from another PP) at the Duck Creek power plant for use as fill material for a railroad embankment (no impact reported). **Y**Groundwater mounding under each of the two impoundments (east &

west) while they were active. An approved GMZ (1997). **Y**

Groundwater monitoring Zone (GMZ). Citzens' group appeal to the Illinois Pollution Control Board to revise the Plant's upcoming NPDES permit remains pending. **Y**

Utility claims contamination related to coal mining.

CIPS petitioned the Illinois Pollution Control Board (IPCB) in the mid1980s to establish site-specific water-quality standards for GW at the site; petition rejected by the IPCB, and rejection upheld by the Illinois Supreme Court. Ultimately, although contamination migrated offsite, such a special designation was approved by the IPCB towards the closure of Pond-D. **Y Y** 

**Comments NOV**  **CO/Admin Order**  **Study**In 1997-1998, ash was excavated from two unlined cells and lined cells

were constructed in those areas. **Y**

Satellite images indicate that the waste units are located on shore sediments of Lake Michigan. According to IEPA's Oct. 2011 report, GW flow appears to be highly dependent on the water level in the ash ponds. Due to the potential for off-site movement, Midwest Generation has been instructed to complete some additional investigations to more fully evaluate contaminant movement. Illinois EPA’s Ash Impoundment Strategy, developed in response to the TVA Kingston ash spill, identified the ash ponds at Waukegan as a Priority 2 site for hydrogeologic assessment (IEPA, 2010). 5 wells (MW1 to MW5) were sampled on 10/25/2010. A well location map was not available for review. MW5 is identified as an upgradient well, but very high levels of B (28 ppm), Sf, and TDS, in addition to As and Se detections, indicate that it is in fact contaminated by coal ash. 

### Y Y Y

In a 2011 draft NPDES permit, IEPA proposed changes to some of the outfalls and the addition of metals as constituents to be monitored.

GW flow shifts caused by quarrying activities to the LF's southeast necessitated additional monitoring wells. After encountering Boron exceedances in 8 of the 18 drinking water wells sampled south of the quarry, MG offered to either buy out the properties or drill new, deeper wells for the affected residences. MG contends that Boron was merely used as a 'fingerprint' tracer isotope in the study and that no residential wells were impacted by the LF. IEPA approved two Ground Water Management Zones (GMZs) designation for the LF area (with a potential for allowing off-site contamination of GW within the GMZs). **Y**

Illinois EPA’s Ash Impoundment Strategy, developed in response to the TVA Kingston ash spill, identified the ash ponds at Joliet 29 as a Priority 1 site for hydrogeologic assessment (IEPA, 2010). 11 wells (MW1 to MW11) were sampled on December, 6-7, 2010. Based on ash constituents being detected in all wells, all sampled wells are presumed to be downgradient. Sb MCL was exceeded in one well (12 ppb, twice the MCL). 5 parameters exceeded Illinois Class I GW Standards, including Sb (1 well), Cl (4 wells), Mn (3 wells), Sf (1 well), and TDS (2 wells). EPA health-based guidelines were also exceeded for Mn (2 wells, up to 3.7 times the LHA) and Sf (1 well, 3.2 times DWA). 

### Y Y ?Illinois EPA’s Ash Impoundment Strategy, developed in response to the

TVA Kingston ash spill, identified the ash pond at Pearl Station as a Priority 1 site for hydrogeologic assessment (IEPA, 2010). 12 wells (MW1 to MW12) were sampled on 5/27/2010. Based on ash constituents detected in all wells, all wells are presumed to be downgradient. As MCLwas exceeded in 5 wells (Max. 48 ppb, 4.8 times the MCL). EPA healthbased guidelines were exceeded for B in 7 wells (Max. 16 pm, 5.3 times the CHA), Mn in all wells (Max. 18 ppm, 60 times LHA), and Sf in 5 wells (Max. 1,400 ppm, 2.8 times DWA). 7 parameters exceeded Illinois Class I ? ? ?

SIPC obtained a boron-adjusted water quality standard in the 1990s from the Illinois Pollution Control Board (IPCB) for a long segment of the receiving stream. Still, SIPC apparently does not meet the boron permit limits dictated by the adjusted standard every month. Further assessment of GW impacts is underway. **Y**

Reversals in direction of GW flow with river's flood stage. A storm water and wastewater treatment system built in 2005: as a result, all discharges into the ash pond system were eliminated, the ash pond system has been completely isolated, and the water table beneath the ponds and the amount of saturated ash has dropped considerably since that time. 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. **Y**

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 Pb exceeding the PDWS was detected also in several up-gradient wells, it is not clear whether it is related to the CCR.

Seepage from the pre-1981, ulined settling ponds, estimated to be at least 2 million gallons per day, resulted in GW mounding. Near the Indiana National Lakeshore on Lake Michigan. In 1978, the SIs were dredged then lined with a composite liner (HDPE over clay). Fly ash from the BGS (and Michigan City) Stations is transported offsite for disposal (Schahfer Generating Station.) **Y Y** Phase III & IV have composite liner w/leachate collection.

FGD solids LF; Compacted clay liner in expanded LF area.

IDEM accepted Utility's claim that impacts are due/inseparable from those caused by coal mining activities.

5' clay liner (1x10-6hydraulic conductivity). Also: “Poz-O-Tec” (processed ash and FGD waste). **Y**

State and Utility claim that the GW flow discharges to the Ohio River and does not risk any drinking water resourcesIn 1999 the state required the facility to: (1) expand its list of semi-annual

monitoring parameters, (2) prepare a GW assessment plan to address GW degradation, and (3) establish the rate and direction of migration of contaminants in GW. **Y**

The Utility claims there is no significant potential for adverse impacts on local water supplies: GW 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. **Y**

The area around the Paradise plant has been severely disturbed by strip mining. A Lisman Fm. aquifer 6 to 22' beneath the surface has been substantially removed by mining, and where it remains it is in direct contact with ash disposal areas. Of great concern is the long-term impact on GW and possible ecological impacts to local surface water (TVA, 1989: “Any impacts to GW will be localized, with increased fluxes to the Green River and/or Jacob’s Creek.”). Monitoring in the 1980s, reported in a 1989 Draft EA for development of a dredged coal ash disposal area, revealed contamination at this site that included Be, Cd, and Pb above ? ? ?

Geohydrologic mounding underneath the dry stack area. GW has been assessed onsite; however, no offsite GW data are available. Metal 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 GW flow at the site because it does not require that a potentiometric surface map be submitted with GW reports. In its comment to the docket, KDEP states that there only appears to be one residential well down-gradient from the LF within the 2-mile radius. This well needs to be investigated for its actual use, as it appears it may be on plant property. Remedial Action Plan prepared for the LF.The higher GW elevations in pond area wells suggest GW mounding

beneath the ponds due to leakage, causing localized reversal of GW flow to the west, away from the Mississippi River. **Y**

Rodemacher Station submitted a request for a major permit modification of the coal ash management area to construct a Type I LF, which included a request for a 60' height increase in the existing CCR disposal unit, use of coal ash as protective cover, and use of an alternate liner.

In early 2001, MADEP issued a consent order, requiring modifications to the site’s GW monitoring program and surface water sampling, and evaluation of GW discharge to the adjacent Assonet Bay. In 2008, designated for development as a shopping mall (Payne's Crossing). **Y**

Under the proposed consent decree filed in Jan. 2013 in the U.S. District Court for the District of Maryland, GenOn MD Ash Management would cap and seal all closed cells in the landfill and install liner systems in all leachate and stormwater collection ponds; perform a study to characterize the levels of contamination at the Site; and develop and implement a plan to control fugitive coal dust, which can be released from the ponds. **Y (Y)** Bioreactor wastewater system installed in 2009/10 but failed. 1/2011:

MDE filed Intent to Sue in Federal court. 12/2012: settlement between MDE/coalition citizen groups with the Utility: penalty ($1.9 m); properly cap & seal all closed LF cells; install liner systems in all leachate/ stormwater ponds; study to characterize levels of onsite contamination; and control fugitive dust. 1/2013: coalition of citizens groups has filed an Intent to Sue for wastewater discharge violations. 6/2013: MDE filed a water pollution lawsuit to address unpermitted wastewater release into the Potomac River. A settment is under negotiations. **(Y)**

Geohydrologic mounding. In 2004, MDEQ developed tighter leachate and GW venting standards for surface waters at the GW/Surface Water Interface (GSI). Evaluations of data are complicated by the natural background concentrations of parameters such as As and Hg and likely low-level contamination coming from (non-CCR) dredge spoils piles. MDEQ recently claimed that under the revised “mixing zone” standards, and State revisions for B and As standards ‘based on new science’, these LFs' discharge levels comply with criteria. MDEQ concedes that whereas as of late in 2009 there were no known violations, there was also a lack **Y Y**  **Y**

Restrictive covenant blocking new water wells or use of drinking water within aquifer or any aquifer within 0.5 miles of the site; landfill closed and covered in 1993-95. Post-closure monitoring was required for ten years. **Y**

Plant slated for decommissioning in 2/2014 but was compelled by regulator to keep operating due to impact to power reliability. **Y Y** 

BC Cobb plant, the LF's customer, slated for decommissioning by April 2016. The LF was closed and capped as part of a settlement to a class action suit brought by neighbors. Under post-closure monitoring. **Y**Wet municipal solid waste underneath the ash. **Y Y** 

Originally closed by the state in 1984 with the standard earthen final cover required at the time, but closure later brought to par with stricter Type III closure requirements. Plant due for retirement by 4/2016. **Y Y** 

Selenium concentrations in fish from the lower Pigeon River and Pigeon Lake, in the vicinity of the fly ash disposal ponds, were significantly greater than Se concentrations at the up-stream Pigeon River site and were greater than published background Se concentrations in fish in the Great Lakes region. Se concentration in some species of fish from the lower Pigeon River and Pigeon Lake exceed dietary lowest observable adverse effect concentrations (LOAECs) associated with toxic effects in wildlife and laboratory animals.

**Comments NOV**  **CO/Admin Order**  **Study**

Hydrologic mounding is plausible. According to the Utility, As, Ba, Cl -, Cu, F -, Pb, Sulfate, and Zn 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 site has been the subject of several EPA investigations under Superfund (CERCLIS # NCD000830646). In 2008, NC DENR issued NOV and requested corrective action. Progress Energy is performing corrective action work voluntarily. Monitoring wells were installed at several phases (2004, 2006, 2008, 2010), with exceedances triggering a site assessment study (2008), a complaint in Wake County Superior Court, filed by SELC (1/2013) on behalf of several conservation groups, then sued Duke Energy, requiring cleanup of GW contamination around the Plant's unlined coal ash ponds; a federal judge decided (6/2014) that the lawsuit **Y Y**  **Y**

Originally, the State had no plans of taking regulatory action until GW contamination reaches the compliance boundary. This posture has changed once newly sited monitoring detected impact outside the ponds' compliance zone. Unpermitted dicharge is also alleged.

Originally, the State had no plans of taking regulatory action until GW contamination reaches the compliance boundary. This posture has changed once newly sited monitoring wells detected impact outside the ponds' compliance zone. Unpermitted dicharge is also alleged.

State and industry claim that Fe and Mn are due to background levels, and no remediation was required for any of the contaminants because exceedances are located inside the state’s Compliance Boundary. This very PP was associated with the Belews Lake ecologic DC. In 2014, Duke Energy agreed to assist Madison and Eden financially to upgrade their water-treatment systems, to make them capable of scrubbing water clean of bromide without producing unsafe levels of trihalomethane (The Plant's bromide discharges into the Dan River are unbridled by state or federal regulations: bromide, when interacting with chlorine in drinkingOriginally, the State has no plans of taking regulatory action until GW

contamination reaches the compliance boundary. In 2012, Duke Energy Progress retained SynTerra Corp. to evaluate GW data and prepare a site conceptual model. In 5/2013, NC DENR filed a complaint amending its March 2013 filing against Duke Energy over leaks and contamination at its Asheville Plant. Duke Energy and NC DENR have tentatively reached a settlement, a proposed consent order has been filed in two state superior courts and public comments are being sought. Following the February 2, 2014 spill into the Dan River, NC DENR rescinded the **(Y) Y** 

The LF has been capped and is inactive since 2005; the PP was retired 4/2012. **Y**

The site was operated without any control of surface waters from the SI. A tributary to the marsh and a nearby creek formerly flowed through the ash disposal areas. As late as 1989, surface water ran directly off the site from the SI dike into the marsh. Facility decommissioned in 1985. Unclear whether an impacted drinking water well was located on-site or off-site (if the latter, this Potential DC. should be redesignated as a Proven DC) **Y**

All ponds were relined with composite geosynthetic/clay liners. This site is a possible candidate for redesignation as a Proven DC. **Y**Groundwater has been evaluated onsite; however, no offsite assessment

or monitoring has been required. State claims it was instrumental in LOS' conversion to dry handling of fly ash in 1996.

NDEQ argues that Se 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 PP activity.

**Y Y** 

Owned by Dynegy’s Northeast Generation Inc. Following extensive damage during Hurricane Sandy, auctioned (12/2012) for demolition. In April 2014, petition to NY Public Service Commission to restore the facility as a peak power generator plant. **Y**

Phase II LF not implicated **Y Y** Property is utilized as a model airplane flying field.

Originally Rejected (EPA 2007 DC Ass. Report) due to inadequate information : "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. However, reinstated as apotential DC based on Ohio EPA's comment to the Oct. 2011 NODA, EPAHQ-RCRA-2011-0392-0163: “JM Stuart Station, Adams County, Ohio. At this time, there is evidence indicating the quality of GW beneath the J.M. Stewart Station has been impacted. Samples collected at the J.M. Stewart (sic) Station, well #2, between 1973 and 1986 by Ohio EPA staff indicates a rising level of total dissolved solids, sulfate, calcium, iron and magnesium. Ohio EPA continues to monitor GW to determine if this trend continues and rises to a level where a full assessment is warranted.”
Issue w/sinkholes. Ash sluicing ceased in 1985. An interceptor well was installed in 1993 to prohibit a sulfate plume from reaching off-site public water supply wells. NOVs (EPA) for emission/PM violations in the late 1990s.

The Tidd-Dale Subdivision, ~ 2000’ from the FAR 2 dam, relies on private drinking water wells (at least 9 private wells). The latest potentiometric map of the PP suggests that this Subdivision is in the direct path of GW flow from FAR 2. OH EPA has not required any sampling of these wells.

OH EPA increased the plant’s allowable daily max. concentration for B 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. In 1994, AEP switched to a dry ash handling system, reducing Se inputs to Stingy Run and Kyger Creek.Probable groundwater mounding. Local aquifer has high 'baseline' TDS.

Groundwater mounding. AEP has submitted a proposal to construct a slurry wall and grout curtain barrier along the length of the LF facing the Verdigris River; a proposal to ensure rainwater infiltration into the LF proper is minimized/ eliminated; and AEP is designing an intermediate liner and leachate collection system for the LF, to be submitted for ODEQ’s approval.

Presumably, groundwater mounding. State claims that elevated levels of Fe and Mn and sporadic low levels of As and B 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 aquifersrather than drinking water MCLs. The Pennsylvania MSCs for nonresidential, non-use aquifers have not been exceeded. EPA identifies As as released from the plant's WUs. PADEP claims that the decommissioning of the SIs was due to closing of the PP and not required by legal action. **Y Y** 

PADEP and the PP claim that is the legacy of the original Seward Power Station that has been demolished; and the neutrailzation of old coalrefuse with FBC ash used for the foundation of the newly constructed CoGen plant. **Y**Groundwater mounding under the central and western portions of the

site. Clean closure is either underway or has been completed.

RRI claims that there are no permit limits stipulated for discharges of B, Cd and Se into Brushy Meadow Creek from Outfall 002. As to unpermitted discharges of B, Cd, Crvi, and Se 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 current GW monitoring program was established in 2005 and was supposed to have 7 monitoring wells in the vicinity of the ash LF, south of the Saluda River (MW3B, MW13, MW14, MW15R, MW16R, MW17, and MW18), and 3 monitoring wells north of the Saluda River (MW30, MW31 and MW32). Between 2005 and 2010, MW13, MW14 and MW15 were only sampled in May, 2005, and no data were found for MW15R and MW18. Monitoring programs omit some CCR signature parameters: Sb, Be, Pb, Hg, Se, and Tl. Interpretation of Cr in GW sampling results is complicated by the fact that pH shows considerable variation in the same ? ? ?

The site is upstream of the Congaree National Park, one of the largest contiguous sections of floodplain forest in N. America. Fish living in the Wateree River in close proximity to the plant were found to have elevated tissue levels of arsenic in comparison to upstream and downstream populations. Neighboring landowners' lawsuits (2009) to stop contamination from reaching their properties has been overturned based on DHEC's 2001 arsenic waiver. Based on a settlement with SELC, SCE&G is now removing the 2.4 million tons of coal ash from its two SIs to an offsite LF, with full removal expected by 2021. The agreement also **Y**

GW elevation indicates flow from the ash pond to the NE toward Lake Moultrie, about 0.5 mile away. One apparent upgradient well (PM1), and 17 downgradient monitoring wells (CAP1 to 14, PM2, PM4, and PM6), were sampled in Jan. and July of 2009 and 2010. Well PM1 does not appear to be affected by ash and provides a good basis for comparison. The only coal ash constituent that appears to be naturally high in PM1 is Fe (16 ppm). PM1 had non-detects for heavy metals and the following concentrations for other parameters: Al <0.05 ppm, Cl 15.8 ppm, Na 5.99 ppm, Sf 6.86 ppm, and TDS 270 ppm. The following CCR signature MCL ? ? ?Nov. 2013 Consent Agreement requires semi-annual GW monitoring to

continue up to 2 years past the full removal of ash, a clean closure plan, and reporting any discharge and dike breach to DHEC and citizen groups. Santee Cooper sued by citizen groups in federal & State courts; lawsuits withdrawn following a Nov. 2013 Consent agreement for clean closure by Dec. 2023. **(Y)**

GW monitoring data go back to 1995. The monitoring programs omits many CCR signature several MCL parameters (Sb, Be, Hg, and Tl) and many health-based standard parameters. Pb added as a parameter in the most recent sampling event: it was detected in 6 wells at 2.98 to 10.2 ppb. GW monitoring data from 2009 and 2010 show As above the MCL (3 wells, Max. 180 ppb, 18 times the MCL). Health-based guidelines were exceeded for Sf (4 wells, Max. 1,163 ppm) and Fe (2 wells, Max. 88.7 ppm, 3.4 times the tapwater RSL). Total chromium was detected in 1 well at pH levels where all or most is likely to be Cr (+6). Data for 12 ? ? ?

**Comments NOV**  **CO/Admin Order**  **Study**

The aquifer beneath Allen Station interacts with adjacent Lake McKellar, causing flow reversals which render upgradient/downgradient well locations questionable. Also, there is mounding beneath the ponds. TDEC was not aware of the As exceedances at the ash ponds prior to a 2011 TVA Office of Inspector General (OIG) Report (TVA, 2011). Having no permitted LFs, TDEC does not require GW monitoring of the Plant’s ash disposal sites, but voluntary monitoring took place from 2004 to 2008. ? ? ?

Switched to dry handling of fly ash (mid-1980s). Toxicity study indicated potential for ecologic damage to introduced species; no data, however, to indicate impacts to native species. **Y**On May 27, 2011, a consortium of citizens groups submitted a petition

for statutory appeal to the Tennessee Water Quality Control Board concerning the intent of TDEC’s Division of Water Pollution Control to renew TVA JSF’s NPDES Permit TN 0005436. A modified permit was issued in Dec. 2012.

The construction of 2 CCR storage-disposal areas on top of earlier SIs and on top of a former creek channel, have created conditions conducive to GW contamination. Groundwater mounding, with one node each underneath the ash pond and underneath the gypsum stack. In 2/1997, bypass of Outfall 001 occurred when during about ten minutes, between 1/2 to 1 million gallons of gypsum wastewater spilled from the Gypsum Disposal Area into Wells Creek (oversurge due to heavy rainfall).

Adjacent to the Cumberland River, in Karstic terrain, with a history of active sinkholes. Closed pond subject to post-closure, quarterly monitoring sampling campaigns.

One of the PP’s disposal units - an 87-acre unlined CCR SI - is located on an island in the Tennessee River. In May 2011, JOF developed Preliminary Closure Plan for the Active Ash Pond. This Plan is deemed lacking by citizens groups and their professional consultant.

According to the TCEQ, “multiple aquifer levels are accessed in the region,” and “numerous private water wells are located around and adjacent to the facility with reported uses such as irrigation, household, and private drinking water.” (TCEQ, 2009). There are 19 drinking water wells within a mile of the Plant and its ash ponds (Aecom, 2009). TCEQ claims, however, that these wells are either upgradient or isolated from the Plant’s GW by Coleto Creek Reservoir, the Plant’s cooling water supply, which flanks the south and east boundaries of the site (Aecom, 2010). The response to the FOIA request for data from Coleto Creek ? ? ?The PP is located on Lake Fayette, serving as a cooling reservoir, and is

also a popular recreational lake for fishing and boating. Half of the CCR SI was closed down in 1988; the remaining part to be closed by 2012 and convert to dry handling. **Y**

Fishing is prohibited in the 2,140 acre Smithers Lake, immediately north of the Plant, which is owned and operated by NRG as a cooling water lake for the plant. The response to the FOIA request for data from Parish Station was received too late to develop a detailed description of contamination at this site. 27 wells sampled in 2009 and 2010 (two sampling events each year, four total). As was measured in 10 wells above the MCL (Max. 125 ppb); Ba, in 1 well above the MCL (2.15 ppm), and Se, in 2 wells above the MCL (Max. 242 ppb). ? ? ?

Course filled w/1.5 million yd3 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 w/o a liner as long as the fly ash was placed at least 2’ above GW and covered by an 18” soil cap. **Y**

Plant switched to natural gas in 2000. Closure of impoundments possibly underway. **Y**

Groundwater mounding. Ongoing monitoring at the site (including monitoring of the private wells) includes boron, sulfate, and arsenic. Previous monitoring included selenium, iron, fluoride, and chloride. **Y**Groundwater mounding. Ongoing monitoring at the site includes

indicator parameters plus boron, selenium, manganese, and iron. **Y**

Site is in the Mississippi floodplain and ash fill may have been placed below the water table/surface water elevation. Transient GW flow gradient reversals under high-river stage. Ongoing monitoring at the site includes indicator parameters plus manganese and boron. **Y**

**Y**

Site is in the Mississippi floodplain and due to GW mounding, ash fill has been placed close to the water table. **A drinking water well was impacted by SMCL exceedances.**  **Y Y** 

12 offsite private wells found exceedances of Mo and B. A consultant to WE determined that Mo in the private wells was not coming from CCR in the LFs. WE started supplying (as of 8/2009) bottled water to several dozen residents in the area w/o claiming responsibility for the contamination; however, shortly after WDNR relaxed the State’s molybdenum GW quality enforcement standard from 40 ppb (the federal HAL) to 90 ppb (in August 2013), WE stopped supplying water to affected residents (end of 2013). **Y**Operated from 1948-1971. A well located ~ 250’ south of the old quarry

was contaminated by very high levels of boron (the State did not have a health-based standard for B at the time of the exceedances). **Y**

Most of the residential wells found to be affected by the LL contamination in 1985 were screened near the top of the dolomite rock and were replaced with wells screened starting at about 250 feet below ground surface. Following citizens’ complaints about drinking water in 1985, WDNR sampled nearby residential wells, and replaced seven wells with much deeper wells. Twenty three private wells are sampled as part of continuing site activities. None of the metals exceeded MCLs in private well samples; one well had a VOC concentration exceeding an MCL. **Y Y** 

The testing documented in the 1988 RTC suggests uncertainty as to the cause of the impacts to downgradient GW because Cd, Mn, and sulfate were also found in upgradient wells. The utility reports that a follow-up investigation found that the Cd and Mn were naturally-occurring. **Y Comments**  **NOV CO/Admin**  **Order Study** **Extended or**

**Assmt Monitoring**  **Remedial**

**Action Lawsuit/** 

**Petition/ Complaint**  **Fish Advisory/**

**Fishing Ban Provide** 

**Drinking Water**  **Other (Closure,**

**switch to dry disposal)** 

**Y** (spill cleanup) **Y** Generation units 1- 6 and 8, to retire by 2015.

**Y Y** 

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**Action Law** 

**suit/Petition Fish** 

**Advisory/fishi ng ban**  **Provide**

**drinking water**  **Other (Closure,**

**switch to dry disposal)** **Y Y**  **Y**



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**drinking water**  **Other (Closure,**

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**Y**

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**Y Y**  **Y*** **Y Y**  **Y Y**  **Y Y:** Progress Energy purchased (on 12/10/2010) neighboring property, which relocated the Compliance Boundary such that well CB-3 (Tl **Y (Y)**  **Y Y** 

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

? ? ? ? ? ?**(Y) (Y)**  **Y (Y)** 

? ? ? ? ? ?

**Extended or Assmt**  **Monitoring Remedial** 

**Action Law** 

**suit/Petition Fish** 

**Advisory/fishi ng ban**  **Provide**

**drinking water**  **Other (Closure,**

**switch to dry disposal)** 

? ? ? ? ? ?

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

**Y**

**Y Y**  **Y**

**(Y)**

? ? ? ? ? ?**Y Y**  Pond Closure

? ? ? ? ? ?

**Y Y**  **Y**

**Y (Y)** 

**Y Y** **Y Y** 

**Y Y** 

**Y Y** 

**Y Y** 

**Y Y**  **Y Y** 

**Y Y**  **Y Extended or** 

**Assmt Monitoring**  **Remedial**

**Action Law** 

**suit/Petition Fish** 

**Advisory/fishi ng ban**  **Provide**

**drinking water**  **Other (Closure,**

**switch to dry disposal)** 

### No. **Crosswalk Facility**  **Location State**  **References/Pre-Existing Designation**  1 PR08 JR Whiting Generating

Plant, CMS/Consumers Energy Erie MI CCW DC Ass #76; 'rejected'

2 PR32 Clinch River Cleveland VA CCW DC Ass #71; 'rejected'

3 PTa21 Copicut Road Monofill Freetown MA CCW DC Ass #72; 'rejected'

4 PTb39 Cardinal PFBC Monofill Brilliant OH CCW DC Ass #69; 'rejected'

5 PTb39 Cardinal Fly Ash Reservoir

II Impoundment Brilliant OH CCW DC Ass #70; 'rejected'

6 PTb40 Gavin Impoundments Cheshire OH CCW DC Ass #74; 'rejected'

7 PTb41 Muskingum River Power

Plant Impoundments Beverly OH CCW DC Ass #77; 'rejected'

8 None Stuart Station

Impoundments - Dayton Power & Light Adams Co. OH CCW DC Ass #82; EPA's 2009 Dam Assessment Report.

9 R1 Florida Power & Light P.L.

Bartow Plant St. Petersburg, Pinellas Co. FL CCW DC Ass #39; 'potential'

10 R2 Florida Power & Light

Plant Port Everglades FL CCW DC Ass #37; 'potential'

11 R3 Florida Power & Light

Plant Port Riviera FL CCW DC Ass #38; 'potential'

### 12 R4 Rocky Acres Coal Combustion By-Product Disposal Site – Bunge North America Corp., (Also: Grays Siding) Oakwood, Vermillion County IL Out of Control #5

13 R5 New England Power Brayton Point MA CCW DC Assmt #26; 'potential'

14 R6 Salem Acres Site Salem MA CCW DC Ass #1; 'proven' - ICF (10/2010), Appendix A, P. 1

15 R7 Vitale Fly Ash Pit Beverly MA CCW DC Ass #2; 'proven' - ICF (10/2010), Appendix A, P. 2
16 R8 Four Corners Power Plant Fruitland NM Out of Control # 17; 'proven' - ICF (10/2010), Appendix B, #17, p. 33

17 R9 Antelope Valley Station -

Basin Electric Power Cooperative Beulah, Mercer County ND In Harm's Way #19

18 R10 Industrial Excess Landfill

Superfund Site Uniontown OH In Harm's Way #25; ICF (10/2010), Appendix C, #25, p.

52

19 R11 Boardman Plant –

Portland General Electric uniontown OR In Harm's Way #28; ICF (10/2010), Appendix C, #28, p.

58

**Crosswalk Facility**  **Location State**  **References/Pre-Existing Designation** 

### 20 R12 Big Stone Power Plant – Otter Tail Power Big Stone City SD In Harm's Way #31; ICF (10/2010), Appendix C, #31, p.

64

21 R13 Reliant Energy Elrama

Plant Union Township, Washington Co. PA CCW DC Assmt #30; 'potential'

22 R14 VEPCO Possum Point VA CCW DC Ass #4; 'proven'. ICF (10/2010), Appendix A, P. 4

23 R15 Mitchell Generating

Station Moundsville WV CCW DC Ass #31; 'potential'. ICF (10/2010), Appendix B, #31, p. 62

24 None Turris Coal Company

Elkhart Mine Elkhart IL CCW DC Ass #84; 'rejected'

25 None Dixie Caverns County

Landfill Roanoke Co. VA CCW DC Ass #73; 'rejected'

26 None Former CSX Rail Corridor Bloomington IN EPA-HQ-RCRA-2011-0392-0259 (Risky Business #5)

27 None Georgia Power (Southern

Company) Yates Generating Plant, FGD Landfill Newnan GA EPA-HQ-RCRA-2011-0392-0259 (Risky Business #2)

28 None NV Energy and Idaho

Power North Valmy Generating Station Ash Ponds Valmy NV EPA-HQ-RCRA-2011-0392-0259 (Risky Business #14)

29 None Star Coal Company #6

Landfill Monroe Co. IA CCW DC Ass #80; 'rejected'

30 None Star Coal Company #14

Landfill Monroe Co. IA CCW DC Ass #81; 'rejected'

### 31 None Thompson Landfill Thompson MI CCW DC Ass #83; 'rejected'

32 None Ohio Valley Electric Corp.

Kyger Creek Power Plant Impoundments Gallipolis OH CCW DC Ass #75; 'rejected'

33 None Muskogee Environmental

Conservation Company Fly Ash Disposal Site Muskogee OK CCW DC Ass #78; 'rejected'. EPA-HQ-RCRA-2003-0796-0019

34 None Public Service Co Fly Ash

Disposal Site (Northeastern Station?) Oologah (?) OK CCW DC Ass #79; 'rejected'. EPA-HQ-RCRA-2003-0796-0019

35 None Western Farmers

Electrical Fly Ash Site Chactaw Co. OK CCW DC Ass #85; 'rejected'

36 None American Coal

Corporation #5 Landfill Marion County IA CCW DC Ass #68; 'rejected'

**Crosswalk Facility**  **Location State**  **References/Pre-Existing Designation** 

### Current

**Designation/Rationale Comments** 

**Re-designated**as a proven damage case In CCW DC Ass, case is referred to as 'Lake Erie, Ohio'. Superseded by In

Harm's Way Case #17, JR Whiting Generating Plant - CMS/ Consumers Energy

. **Re-designated**as a proven damage case Superseded by In Harm's Way #36:Clinch River Plant, American Electric

Power d/b/a Appalachian Power – Cleveland, VA

**Re-designated**as a potential damage case Double counted': Superseded by CCW DC Ass Case #25, K. R. Rezendes

South Main Street Coal Ash Landfill (a Potential DC).

**Re-designated**as a potential damage case Superseded by In Harm's Way #23: Cardinal Plant, American Electric

Power – Brilliant, OH

**Re-designated**as a potential damage case Superseded by In Harm's Way #23: Cardinal Plant, American Electric

Power – Brilliant, OH

**Re-designated**as a potential damage case Superseded by In Harm's Way #24: Gavin Power Plant, American Electric

Power d/b/a Ohio Power Company – Cheshire, OH

**Re-designated**as a potential damage case Superseded by In Harm's Way #26: Muskingum River Plant, American

Electric Power d/b/a Ohio Power Company – Beverly, OH

**Re-designated**as a potential damage case Originally Rejected (EPA 2007 DC Ass. Report) due to inadequate

information : "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. However, reinstated as apotential DC based on Ohio EPA's comment to the Oct. 2011 NODA, EPAHQ-RCRA-2011-0392-0163: “At this time, there is evidence indicating the quality of GW beneath the J.M. Stewart Station has been impacted. Samples collected at the J.M. Stewart (sic) Station, well #2, between 1973 and 1986 by Ohio EPA staff indicates a rising level of total dissolved solids, sulfate, calcium, iron and magnesium. Ohio EPA continues to monitor GW to determine if this trend continues and rises to a level where a full assessment is warranted.”

**Rejected:**Out of Scope One of nine sites managing oil combustion wastes that have groundwater

contamination identified for the 1999 RTC.

**Rejected:**Out of Scope One of nine sites managing oil combustion wastes that have groundwater

contamination identified for the 1999 RTC. **Rejected:**Out of Scope One of nine sites managing oil combustion wastes that have groundwater

contamination identified for the 1999 RTC.

### Rejected:Out of

Scope/Non-Utility coalfired boiler CCR is from a non-utility coal-fired boiler (dry corn mill operation)

**Rejected:**Out of Scope One of nine sites managing oil combustion wastes that are associated with

largest coal- and oil-powered generating station in New England.

**Rejected:**CCRs commingled with other waste "Contribution of FFC wastes to damage not separable from other wastes.”

"“The co-managed wastes contributed metal contamination indistinguishable from CCRs." **Rejected:**CCRs commingled with other waste “Non-CCR wastes primarily USTs were focus of MADEP remediation."

**Rejected:**CCRs commingled with other (coal mining) waste ”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.”

**Rejected:**Out of Scope/Minefilling Landfill located in a mined out lignite pit.

**Rejected:**CCRs commingled with other waste; also, CCR from industrial boilers. ”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 addition, the source of the coal ash was from industrial boilers in the Akron/Canton area.

**Rejected:**Inadequate information Inadequate Information to 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.”

**Current Designation/Rationale**  **Comments**

### Rejected:CCRs

commingled with other waste ”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.”

**Rejected:**CCRs commingled with other (coal mining) waste Landfill in an abandoned coal mine.

**Rejected:**CCRs commingled with other waste “Co-Managed CCR wastes without clear implication of CCR wastes in

damages.”

**Rejected:**CCRs commingled with other (coal mining) waste ”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.”

**Rejected:**Out of Scope/Minefilling "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." **Rejected:**Out of Scope "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. **Rejected:**Out of Scope CCR commingled with non-CCRs; from a non-utility source. A rail-to-trail

project, railroad right-of-way soils ('Beneficial Use'). Coal ash and clinkers from train engine boilers used for ballast for railroad tracks bed.

**Rejected:**Inadequate information to determine source of metal contaminants "well screens are within soils derived from weathering of the Waresville

Schist which contains abundant nickel, chromium and cobalt." Georgia Power challenges allegations because: (i) "TCLP leaching concentrations from gypsum are lower than those in GW"; (ii) The settling pond and gypsum stacks are lined; and (iii) "Naturally occurring soils are one possible source of the metals.

**Rejected:** Inadequate information to determine source of metal contaminants The Utility claims that the high As, Fl, and Mn levels are naturally occurring

due to the unique geology of the area; the author of the report states that upgradient or background monitoring would be required to confirm this possibility. **Rejected:**Inadequate information "No information available."

**Rejected:**Inadequate information "No information available."

### Rejected: Inadequate

information "There is insufficient information available to identify the extent of ground

water contamination, or to positively identify the source of the contamination." **Rejected:**Inadequate information; lack of verification by state regulator "Ohio EPA staff are unaware of any issues related to this pond." No

subsequent new information.

**Rejected:**Inadequate information "There is insufficient information available to identify the extent and

nature of damages present and attribute them to fossil fuel combustion wastes."

**Rejected:** Inadequate information "There is insufficient information available to identify the extent and

nature of damages present and attribute them to fossil fuel combustion wastes."

**Rejected:**Inadequate information "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. **Rejected:**No Information No Information.

**Current Designation/Rationale**  **Comments**