Disposal of Coal Combustion Residuals from Electric Utilities Rule ANNUAL GROUNDWATER MONITORING AND CORRECTIVE ACTION REPORT PREFACE

Transcription

1 Disposal of Coal Combustion Residuals from Electric Utilities Rule ANNUAL GROUNDWATER MONITORING AND CORRECTIVE ACTION REPORT Report Requirements PREFACE This report documents the status of the groundwater monitoring and corrective action program in place under the federal Coal Combustion Residuals (CCR) Rule. Containing data for the previous calendar year, it must be placed in the facility operating record by January 31 and posted publicly by March 2. It summarizes key actions completed, describes any challenges and how they were addressed, and projects key activities for the upcoming year. It must include a map or diagram depicting the CCR unit and all the wells in the monitoring network, identifying any that were decommissioned or installed in the previous year. In addition, it contains the monitoring data summary, a narrative discussing any transitions between detection monitoring and assessment monitoring and the reasons for those transitions. What the Report Is This report describes the first step in a phased, prescriptive process for monitoring groundwater near CCR storage facilities. It is a snap shot in time, showing how the data obtained during the report year compare to all the background data that have been obtained to date, and whether further monitoring for additional substances should be performed based on that comparison. What the Report Is Not The report does not make any determinations regarding potential environmental impact to or contamination of groundwater, and neither the raw data nor the initial statistical analysis should be independently or collectively interpreted in that way. Report Methodology Data comparison is done through a test to determine if monitoring results from wells adjacent to the CCR facility are statistically higher than background levels for that site. Therefore, as the data set increases over time, so does the confidence that any one result represents a statistically significant increase (SSI) over the background data. Groundwater moves slowly and both natural and man-made sources can impact groundwater. Therefore, the federal rule uses a phased approach with data verification steps in between. In this initial annual report, if a data result yields an SSI, the groundwater monitoring effort transitions from the detection program (measuring substances that move most rapidly in groundwater to identify a potential impact) to the assessment program (measuring substances that are of more concern including several that have regulatory standards).

2 ANNUAL GROUNDWATER MONITORING AND CORRECTIVE ACTION REPORT COAL COMBUSTION RESIDUALS (CCR) RULE W.H. SAMMIS POWER STATION JEFFERSON COUNTY, OHIO Prepared for: FirstEnergy Generation, LLC Greensburg Corporate Center 800 Cabin Hill Drive Greensburg, Pennsylvania January /29/2018

3 Section CONTENTS Page 1.0 INTRODUCTION Site Background ACTIVITIES SUMMARY Groundwater Evaluation Work Plan Certified Monitoring Well System Baseline Detection Monitoring Statistical Method Certification DATA EVALUATION Monitoring Well System Groundwater Flow Results Baseline Detection Monitoring Statistical Evaluation GENERAL INFORMATION Problems Encountered and Resolutions Actions Planned for REFERENCES... 6 Table List Table 1 Table 2 Table 3 Table 4 Summary of Monitoring Well Construction Analytical Summary Table Groundwater Elevations Groundwater Flow Rates List of Figures Figure 1 General Location Map Figure 2 Well Location Map List of Appendices Appendix A Groundwater Flow Maps i 1/29/2018

4 1.0 INTRODUCTION At the request of FirstEnergy Generation, LLC (FirstEnergy), AECOM Technical Services, Inc. (AECOM) prepared this Annual Groundwater Report for the FirstEnergy W.H. Sammis Power Plant (Sammis Plant), located near in Stratton, Ohio in accordance with the United States Environmental Protection Agency (USEPA) Final Rule 40 Code of Federal Regulations (CFR), Part Sub-Part (e) (Rule). The Rule was established to regulate the disposal of Coal Combustion Residuals (CCR) produced by electricity generating facilities (USEPA, 2015). This report summarizes all activities related to the CCR Rule groundwater monitoring program at the Sammis Plant through The following sections present a site background summary, a discussion of field activities performed, a summary of laboratory results, statistical evaluation findings, and conclusions regarding groundwater conditions in the aquifer system subject to monitoring under the CCR Rule. 1.1 Site Background The Sammis Plant is situated on the western shoreline of the Ohio River in Jefferson County, Ohio, immediately north of the town of Stratton. The United States Army Corps of Engineers (USACE) New Cumberland Lock & Dam Structure (NCLD) is located adjacent to the east. The Sammis Plant is a coalfired power plant and has been in operation since A general location map of the site is provided as Figure 1. There are two settlement ponds on-site that have been identified as surface impoundments subject to the CCR Rule because they are used for temporary storage of a CCR, namely sluiced bottom ash. The impoundments are adjacent to each other, separated by a 3-foot wide berm. For the purposes of the CCR rule, a single multi-unit groundwater system monitors both ponds. The impoundments are used in an alternating fashion such that when an impoundment is considered full, sluicing is switched to the other impoundment and the full unit is dewatered and the accumulated ash is excavated and disposed at a privately owned landfill. Prior to these investigation activities, no groundwater monitoring network existed at the subject site ACTIVITIES SUMMARY The following subsections describe the activities that were performed in 2016 and 2017 for the Sammis Plant related to the CCR Groundwater Monitoring Network. 2.1 Groundwater Evaluation Work Plan A Groundwater Evaluation Work Plan Coal Combustion Residuals (CCR) Rule, W.H. Sammis Power Station, (Work Plan) dated April 7, 2016 was prepared to comply with applicable requirements of the CCR Rule and placed in the operating record. This document provides the sampling and analytical methodologies and procedures for collecting and reporting representative groundwater quality data from CCR monitoring wells at the Sammis Impoundments. As required by (a), the document provides procedures and techniques for the following: Sample collection; Sample preservation and shipment; Analytical procedures; Chain-of-custody control; and /29/2018

5 Quality assurance (QA) and quality control (QC). 2.2 Certified Monitoring Well System Nine monitoring wells and two piezometers were installed between April 25, 2016 and June 1, 2016 by Frontz Drilling with oversight by AECOM. A complete report describing the well installation and details about the monitoring network entitled Monitoring Well Installation Report (WIR), Coal Combustion Residuals Rule, W.H. Sammis Power Station, Jefferson County, Ohio dated October 2017 has been placed in the operating record. Each well has a dedicated bladder pump system and tubing installed for sampling purposes. Locations are shown on Figure 2. Each well was installed into the upper portion of the uppermost usable aquifer underlying the site. At the Sammis Plant, the uppermost aquifer is encountered in unconsolidated sand and gravel. Table 1 contains information regarding well locations, pump depths, and construction details. Well lithologic and construction logs are included in the WIR Report.. The CCR monitoring network at the Sammis Plant was reviewed and certified by a Professional Engineer, as required by 40 Code of Federal Regulations (CFR) (e)(1). A copy of the Groundwater Monitoring System Certification document was placed in the operating record and public website for CCR Activities maintained by FirstEnergy. 2.3 Baseline Groundwater Eight Baseline groundwater sampling events were conducted at the Sammis Plant between July 2016 and July The following table summarizes the dates of each of the sampling events for the baseline period and the wells included in the events. Event Type Event Dates Wells Sampled Baseline Groundwater 1* July 13-14, 2016 MW-1, MW-2, MW-3, MW-4, MW-5, MW-6, MW-8, MW-9 2 September 20-21, November 29 December 1, February 14-15, 2017 MW-1, MW-2, MW-3, MW-4, MW-5, MW-6, 5 March 14-16, 2017 MW-7, MW-8, MW-9 6 May 2-3, June 6-7, July 5-6, 2017 *MW-7 was inaccessible during this event due to station construction activities Monitoring wells were sampled using low-flow sampling methods in accordance with the Work Plan dated April All wells were sampled for Appendix III and Appendix IV parameters in accordance with 40 CFR Results from the Baseline sampling events are included in Table 2. Monitoring wells MW-7 and MW-8 were used during the Baseline program to evaluate groundwater flow conditions and potential background influences. At the end of the baseline period these two wells were not considered necessary for ongoing groundwater quality monitoring in the vicinity of the CCR unit and were not included in the final CCR monitoring network. Both locations are planned for use as piezometers to assist in groundwater flow evaluations for future monitoring events /29/2018

6 2.4 Detection Monitoring The first Detection Monitoring sampling event took place between August 21 and August 22, Detection monitoring is conducted on a semi-annual basis per 40 CFR (b). The following wells were sampled during this event: MW-1 MW-2 MW-3 MW-4 MW-5 MW-6 MW-9 Monitoring wells were sampled using low-flow sampling methods in accordance with the Work Plan. All wells were sampled for Appendix III parameters in accordance with 40 CFR (a). Results from the detection sampling event are included in Table Statistical Method Certification In accordance with 40 CFR (f)(6) a statistical program for evaluating statistically significant increases (SSI) over baseline levels was developed and certified on October 17, The Statistical Methods Certification document describing the selected method was placed in the operating record and public website for CCR Activities maintained by FirstEnergy. 3.0 DATA EVALUATION The following sections present details about the monitoring system, groundwater flow, groundwater sampling results, and statistical evaluation for the Sammis Plant well network and datasets. 3.1 Monitoring Well System The CCR monitoring well system at the Sammis Plant contains two upgradient monitoring wells and five downgradient monitoring wells. Their locations are shown in Figure 2. Construction details for these monitoring wells are available in Table 1. MW-7 and MW-8 were used during the Baseline program to evaluate groundwater flow conditions and potential background influences. At the end of the baseline period these two wells were removed from ongoing groundwater quality monitoring in the vicinity of the CCR unit because MW-7 is located between the two ponds, which were combined into a multi-unit monitoring system and MW-8 was found to be outside the potential influence of the CCR units. 3.2 Groundwater Flow Prior to the collection of groundwater samples, all on-site monitoring wells, including piezometers P-1 and P-2, were gauged and a potentiometric surface map was created to confirm groundwater flow direction. A summary of groundwater measured elevations is included in Table 3 and groundwater flow maps for each event are included in Appendix A. Generally, groundwater flow at the Sammis Plant is south to southeast and appears to be most heavily influenced by the New Cumberland Lock and Dam (NCLD) directly adjacent to the east of the Sammis Plant on the Ohio River. Groundwater flow patterns were consistent throughout the duration of the baseline-sampling period. The presence of the NCLD results in a relatively steep groundwater gradient across the area occupied by the impoundments. Groundwater flow rate (i.e., velocity) estimates were calculated using the groundwater flow maps, estimated hydraulic conductivity and porosity values from the nearby production wells /29/2018

7 Estimated groundwater velocities range from 1.3 to greater than 20 feet per day. These upper and lower range values are based on estimated hydraulic characteristics from the wells, which are located to the south-southeast of the Sammis Plant and surface impoundments. These production wells are screened deeper in the Ohio River buried valley aquifer than the CCR monitoring wells at the Sammis plant. The groundwater velocity in the immediate vicinity of the ponds is likely in the lower end of the calculated ranges due to a relatively higher amount of fine materials likely present in the upper portion of the aquifer system. Table 4 contains groundwater flow rate calculations for each of the baseline and detection sampling events. 3.3 Results During 2016 and 2017 a total of eight Baseline Monitoring events and one Detection Monitoring event were completed. Discussion of the results from these sampling activities is presented in the following subsections Baseline During the Baseline period, all wells were sampled for Appendix III and Appendix IV parameter lists. Constituents from both parameter lists were detected in all of the monitoring wells in all groundwater sampling events conducted. Analytical results from the Baseline are displayed in Table 2. Complete analytical laboratory reports are included in Appendix E Detection Monitoring All CCR program monitoring wells were sampled for Appendix III parameters on August 27, 2017 as part of the first Detection Monitoring event at the Sammis Plant. Each Appendix III parameter was detected in all wells sampled for this event. Detection monitoring analytical results are displayed in Table Statistical Evaluation Upon receipt of the analytical results from the first Detection Monitoring event, a statistical evaluation was conducted to identify any SSIs over baseline concentrations for the Appendix III parameters. In accordance with 40 CFR (h)(2), a determination of whether there has been a SSI over background levels must be performed within 90 days of completing the detection monitoring laboratory sample analysis. Because analytical results from the first round of detection monitoring at Sammis were available in September 2017, the SSI determination was completed prior to January Statistical methods were chosen in accordance with 40 CFR (f)(1). Monitoring wells were evaluated using an interwell approach with monitoring wells MW-1 and MW-9 used as the background comparison. Both wells are located upgradient of the surface impoundments. A parametric prediction interval was used to evaluate for SSIs over baseline concentrations in each of the monitoring wells, for each of the constituents. Rationale behind why each method was selected is outlined in Statistical Methods Certification Document dated October 17, A copy of this document was placed in the operating record and public website for CCR Activities maintained by FirstEnergy. Constituents with SSIs identified during the first detection monitoring event include: Boron, calcium, and sulfate in MW-4 Boron, calcium, chloride, sulfate, and total dissolved solids (TDS) in MW-5 Boron, calcium, chloride, sulfate, and TDS in MW-6 All SSIs are highlighted in Table /29/2018

8 4.0 GENERAL INFORMATION The following sections summarize any problems encountered in the CCR program through 2017, any resolutions to those problems if needed and upcoming actions planned for Problems Encountered and Resolutions During the first Baseline event, damage to the flush-mount monitoring well cover at MW-7 prevented access to the well and the monitoring well was not sampled. Repairs were completed and the well was sampled during subsequent baseline monitoring events. (MW-7 was subsequently removed from the groundwater monitoring system and excluded from detection monitoring, however). 4.2 Actions Planned for 2018 The following are the key CCR groundwater compliance activities planned for 2018: Potentially conduct an Alternate Source Determination (ASD) [per (e)(2)] to determine if a source other than the CCR unit may be causing the SSIs. If the ASD indicates that an alternate source is responsible for all the SSI s identified, revert back to semi-annual detection monitoring for Appendix III constituents [per (c)] If an ASD indicates that an alternate source is not responsible for all the SSI s identified, then then establish an Assessment Monitoring Program [per (e)(1)] /29/2018

9 5.0 REFERENCES AECOM, October Coal Combustion Residuals Rule Groundwater Monitoring System Certification, W.H. Sammis Power Station, October 17, AECOM, October Coal Combustion Residuals Rule Statistical Methods Certification, W.H. Sammis Power Station, October 17, AECOM, April Groundwater Evaluation Work Plan Coal Combustion Residuals (CCR) Rule (Work Plan), W.H. Sammis Power Station, April 7, AECOM, October Monitoring Well Installation Report Coal Combustion Residuals (CCR) Rule, W.H. Sammis Power Station, October 17, United States Environmental Protection Agency, Part , Sub-Part (e) Coal Combustion Residuals Rule /29/2018

10 Tables

11 TABLE 1 FIRST ENERGY W.H. SAMMIS POWER PLANT NORTH AND SOUTH ASH IMPOUNDMENTS MONITORING WELL CONSTRUCTION SUMMARY CCR RULE MONITORING NETWORK Well ID Easting Northing Well Installation Date TOC Elevation (ft MSL) Ground Surface Elevation (ft MSL) Total Depth (ft BTOC) Bottom Elevation (ft MSL) Screen Length (feet) Top of Screen (feet BTOC) Bottom of Screen (ft BTOC) Top of Screen Elevation (ft MSL) Bottom of Screen Elevation (ft MSL) Pump Depth (ft BTOC) Well Casing Material Well Screen Material and Slot Size Groundwater Flow Location Program Use MW Apr Upgradient MW May Downgradient MW May Downgradient MW May Downgradient MW May inch 2-inch Schedule Downgradient MW May Schedule PVC and Downgradient MW May PVC inch slot Upgradient/Background MW-7* Apr Downgradient MW-8* May Downgradient P May Downgradient P Apr Upgradient Detection Water Level/Flow Evaluation TOC - Top of Casing ft MSL - feet above Mean Sea Level ft BTOC - feet below top of casing PVC - Polyvinyl Chloride *Excluded from CCR Network after Baseline (to be used for water levels only) W.H. Sammis Plant - CCR Program 1 of 1

12 Table 2 First Energy W.H. Sammis Power Station Analytical Data MW-2 MW-3 MW-4 MW-5 MW-6 Baseline Detection Baseline Detection Baseline Detection Baseline Detection Baseline Detection Analtyte Name units Boron Calcium Appendix III Constituents Chloride Fluoride ph S.U. Sulfate 7/14/ J D D D D UD D UD UD UD DJ U JD UD UD U 9/21/ J D UD D D UD UD UD UD UD UD U JD UD UD U 12/1/ J D UD JD DB UD UD UD UD UD UD JB JD UD UD U 2/14/ J 46.1 D 50.7 D UD JD D UD UD UD UD UD JD U JD UD UD /16/ J DB UD JD D UD UD UD UD UD UD U JD UD UD /3/ J D UD D D UD D JD UD UD UD U JD UD UD U 6/6/ J D UD D D UD UD UD UD UD UD U JD UD UD U 7/5/ J D UD JD D UD UD UD UD UD UD U JD JD UD U 8/22/ J D /13/ J D UD JD D UD D UD UD UD UD BJ JD UD UD U 9/21/ J D UD JD D UD UD UD UD UD UD U JD UD UD U 12/1/ J D UD JD DB UD UD UD UD UD UD JB JD UD UD U 2/14/ J D UD JD D UD UD UD UD UD UD U JD UD UD U 3/16/ J DB UD JD D UD UD UD UD UD UD U JD UD UD U 5/3/ J D UD UD D UD UD UD UD UD UD U JD UD UD U 6/6/ J D UD UD D UD UD UD UD UD UD U JD UD UD U 7/5/ J D UD JD D UD UD UD UD UD UD U JD UD UD U 8/22/ J D /13/ J D UD D D UD D UD UD UD UD JB JD UD UD U 9/21/ J D UD UD D UD UD UD UD UD UD U UD UD UD U 11/29/ J D JD JD D UD UD UD UD UD UD U JD UD UD /14/ J D UD JD D UD UD UD UD UD UD U UD UD UD U 3/14/ J D UD JD D UD JD UD UD UD UD U JD UD UD U 5/3/ J D UD D D UD UD UD UD UD UD U UD UD UD U 6/6/ J D UD UD D UD UD UD UD UD UD U UD UD UD U 7/5/ J D UD UD D UD UD UD UD UD UD U JD UD UD U 8/21/ J D /13/ J D D UD JD D UD D UD D UD DJ BU UD UD UD U 9/20/ J D D UD D D UD D JD D UD UD J UD UD UD U 11/29/ J D UD JD D UD UD UD JD UD UD U UD UD UD /15/ J D D UD JD D UD UD UD JD UD UD U UD UD UD /14/ J D D UD JD D UD JD UD JD UD UD U UD UD UD U 5/2/ J D D UD D D UD JD UD JD UD UD U UD UD UD U 6/6/ J D D D D D UD JD UD JD UD UD U UD UD UD U 7/5/ J D D UD JD D UD UD UD JD UD UD U UD UD UD /21/ J DB D 540 7/13/ J D J D UD D D UD D UD D J UD UD JB UD UD UD U 9/20/ J D J D UD D D UD D UD D J UD UD J JD D D U 11/29/ J D J D JD JD D JD JD UD D J UD UD U JD UD JD /15/ J D D UD JD D UD JD UD D UD UD U UD UD UD U 3/14/ J J D UD UD D UD JD UD D J UD UD U UD JD JD U 5/2/ J D J D UD D D UD JD UD D J UD UD U UD UD 0.0 UD U 6/7/ J 104 D 74.4 D J D UD D D UD JD UD D J UD UD U UD UD UD U 7/5/ J D J D UD JD D UD JD UD D J UD UD U UD JD UD /21/ J DB J D 692 TDS Antimony Arsenic Barium Beryllium Cadmium Downgradient Wells Chromium Appendix IV Constituents Cobalt Fluoride Lead Lithium Mercury Molybdenum Selenium Thallium Radium pci/l Sammis Page 1 of 2 1/29/2018

13 Table 2 First Energy W.H. Sammis Power Station Analytical Data MW-1 MW-9 Baseline Detection Baseline Analtyte Name units Boron Calcium Appendix III Constituents Chloride Fluoride ph S.U. Sulfate TDS Antimony Arsenic Barium Beryllium Cadmium Upgradient Wells Chromium Appendix IV Constituents Cobalt Fluoride Lead Lithium Mercury Molybdenum Selenium Thallium 7/14/ J D UD D D UD D UD UD UD UD U JD UD UD U 9/21/ J D UD D D UD UD UD UD UD UD UD JD UD UD U 12/1/ J D UD JD DB JD JD UD UD UD UD JB JD UD UD U 2/15/ J D UD JD D UD UD UD UD UD UD U JD UD UD U 3/16/ J DB UD JD D UD UD UD UD UD UD U JD JD UD U 5/3/ J D UD UD D UD UD UD UD UD UD U JD UD UD U 6/7/ J D UD D D UD UD UD UD UD UD U JD D UD U 7/5/ J D JD JD D UD JD UD UD UD UD U JD UD UD U 8/22/ J D /14/ J D UD D D UD D UD UD UD UD U D UD UD U 9/21/ J D UD D D UD UD UD UD UD UD U JD UD UD U 12/1/ J D UD JD DB UD UD UD JD UD UD JB JD UD UD U 2/15/ J D UD JD D UD UD UD UD UD UD U JD UD UD U 3/16/ J DB UD JD D UD UD UD UD UD UD U JD UD UD U 5/3/ J 38.7 D 31.9 D UD UD D UD UD UD UD UD UD U JD UD UD U 6/7/ J D UD UD D UD UD UD UD UD UD U JD UD UD /6/ J D UDB JD D UD UD UD UD UD UD J JD UD UD U Detection 8/22/ J D Upper Limit Confidence Leve Max Upgradient Value Max Concentration Min Concentration Radium pci/l Statistically significant increase (SSI) over baseline sampling using well specific and parameter specific statistical limits. TDS = Total Dissolved Solids NE = Not Established = milligrams per liter S.U. = Standard Units pci/l = picocurie/liter 0.2 = Concentration below the Reporting Limit B = Analyte detected in the associated blank D = Dilution J = Estimated value U = Analyte analyzed for but not detected = Value is the combined total of Radium 226 and 228 * = "U" flag for radionuclides is not detected above the minimum detectable concentration which differs from similar flag for aqueous results Sammis Page 2 of 2 1/29/2018

14 TABLE 3 FIRST ENERGY W.H. SAMMIS POWER STATION MONITORING WELL GROUNDWATER ELEVATIONS Date Event 1 Event 2 Event 3 Event 4 7/13/2016 9/20/ /28/2016 2/13/2017 Groundwater Elevation Groundwater Elevation Groundwater Elevation (feet, msl) DTW (feet) (feet, msl) DTW (feet) (feet, msl) DTW (feet) Groundwater Elevation (feet, msl) Well TOC Elevation (feet, msl) DTW (feet) P NM NA P MW MW MW MW MW MW MW NM NA MW MW NM = Not measured NA = Not applicable TOC = Top of casing DTW = Depth to water Sammis Page 1 of 2 1/29/2018

15 TABLE 3 FIRST ENERGY W.H. SAMMIS POWER STATION MONITORING WELL GROUNDWATER ELEVATIONS Date TOC Elevation Well (feet, msl) P P MW MW MW MW MW MW MW MW MW DTW (feet) Event 5 Event 6 3/14/2017 5/1/2017 Groundwater Elevation (feet, msl) DTW (feet) Groundwater Elevation (feet, msl) Event 7 Event 8 Event 9 6/5/207 6/29/2017 8/17/2017 Groundwater Elevation Groundwater Elevation (feet, msl) DTW (feet) (feet, msl) DTW (feet) Groundwater Elevation (feet, msl) DTW (feet) NM NA NM = Not measured NA = Not applicable TOC = Top of casing DTW = Depth to water Sammis Page 2 of 2 1/29/2018

16 Table 4 First Energy W.H. Sammis Power Station Groundwater Flow Rates Flow Path from P-2 to MW-5 Flow Path from MW-7 to MW-5 Flow Path from MW-1 to MW-4 Event Groundwater Flow Direction Minimum Conductivity (cm/sec) Maximum Conductivity (cm/sec) Gradient (dh/dl) DTW (upgradient) DTW (downgradient) Difference b/w head (ft) Effective Porosity Length (ft) Min. Velocity (cm/sec) Max velocity (cm/sec) E E E E E E E E-03 5 South, southeast % E E E E E E E E E E-02 1 NA NM NM NA NA NA E E E E E E-03 5 South, southeast % E E E E E E E E E E E E E E E E E E-03 5 South, southeast % E E E E E E E E E E-03 NM = Not measured NA = Not applicable cm/sec = Centimeters per second References: Zorbini, J., Zorbini D., Drinking Water Source Protection Plan for W.H. Sammis Plant 1 of 1 1/29/2018

17 Figures

18 Document Path: J:\Project\GIS\F\First_Energy\Sammis Power Station\HydroGeo Summary Report\Fig1_General Location Map (6-8-16).mxd PROJECT LOCATION (JEFFERSON COUNTY) ³ OHIO SAMMIS POWER STATION NORTH & SOUTH CCR IMPOUNDMENTS Copyright: 2013 National Geographic Society, i-cubed UNITED STATES DEPARTMENT OF THE INTERIOR GEOLOGICAL SURVEY KNOXVILLE QUADRANGLE WELLSVILLE QUADRANGLE (FROM ARCGIS ONLINE Copyright: 2011 National Geographic Society, i-cubed) 0 1,000 2,000 Feet ³ W.H. Sammis Station Jefferson County, Ohio FIGURE 1 SITE LOCATION MAP DATE: 7/5/2017 CREATED BY: CTM JOB NO Scale: 1 inch = 1,000 feet

19 Document Path: G:\Cincinnati\DCS\Projects\GIS\F\First_Energy\Sammis Power Station\Figure2_WellLocationMap_SHOWING_MW8.mxd! A MW-9! A.! P-2! A.!.! MW-1 MW-2 MW-7! A P-1 MW-3! A! A MW-6.!! A MW-5 MW-8 LEGEND:! A.! Monitoring Well Piezometer MW Feet (FROM ARCGIS ONLINE Copyright: 2011 National Geographic Society, i-cubed) ³ OSIP Imagery W.H. Sammis Station Jefferson County, Ohio FIGURE 2 WELL LOCATION MAP DATE: 1/26/2018 CREATED BY: TA JOB NO SCALE 1 inch = 300 feet

20 Appendix A Groundwater Flow Maps

21 Document Path: G:\Cincinnati\DCS\Projects\GIS\F\First_Energy\Sammis Power Station\EVENT_1_DRAFT_SAMMIS_GWE_July13_2016.mxd MW P P South Domestic Water Well 6A MW Production Well 3A MW MW-7 NM Production Well 2A Production Well 1A MW MW MW MW ODNR Well #1 ODNR Well #2 650 MW OSIP Imagery LEGEND: Monitoring Well / Groundwater Elevation - July 2016 Piezometer / Groundwater Elevation - July 2016 First Energy Production Well Production Well Inferred Direction of Groundwater Flow Groundwater Contour (ft, msl) Inferred Groundwater Contour (ft, msl) Groundwater Depression Contour (ft, msl) NM Not Measured (FROM ARCGIS ONLINE Copyright: 2011 National Geographic Society, i-cubed) ³ 1 inch = 300 feet Feet DATE: 1/16/2018 CREATED BY: SJJ JOB NO SPS CCR Compliance Site EVENT 1 GROUNDWATER ELEVATION CONTOUR MAP JULY 13, 2016 SCALE

22 Document Path: G:\Cincinnati\DCS\Projects\F\FirstEnergy\ CCR GW (SAMMIS-HR)\Data-Tech\GIS\EVENT_2_SAMMIS_GWE_Sept20_2016.mxd MW P P-1 NM South Domestic Water Well 6A MW Production Well 3A MW MW Production Well 2A Production Well 1A MW MW MW MW ODNR Well #1 ODNR Well #2 650 MW LEGEND: Monitoring Well / Groundwater Elevation - September 2016 Piezometer / Groundwater Elevation - September 2016 First Energy Production Well Production Well Inferred Direction of Groundwater Flow Groundwater Contour (ft, msl) Inferred Groundwater Contour (ft, msl) (FROM ARCGIS ONLINE Copyright: 2011 National Geographic Society, i-cubed) ³ Feet DATE: 1/16/2018 CREATED BY: SJJ JOB NO EVENT 2 GROUNDWATER ELEVATION CONTOUR MAP SEPTEMBER 20, 2016 OSIP Imagery W.H. Sammis Station Jefferson County, Ohio SCALE 1 inch = 300 feet

23 Document Path: G:\Cincinnati\DCS\Projects\F\FirstEnergy\ CCR GW (SAMMIS-HR)\Data-Tech\GIS\EVENT_3_DRAFT_SAMMIS_GWE_Nov28_2016.mxd MW P South Domestic Water Well 6A P MW Production Well 3A MW MW Production Well 2A Production Well 1A MW MW MW MW ODNR Well #1 ODNR Well #2 650 MW OSIP Imagery LEGEND: Monitoring Well / Groundwater Elevation - November 2016 Piezometer / Groundwater Elevation - November 2016 First Energy Production Well Production Well Inferred Direction of Groundwater Flow Groundwater Contour (ft, msl) Inferred Groundwater Contour (ft, msl) (FROM ARCGIS ONLINE Copyright: 2011 National Geographic Society, i-cubed) ³ Feet DATE: 1/16/2018 CREATED BY: SJJ JOB NO SPS CCR Compliance Site EVENT 3 GROUNDWATER ELEVATION CONTOUR MAP NOVEMBER 28, 2016 SCALE 1 inch = 300 feet

24 Production Well 3A MW Document Path: J:\Project\F\FirstEnergy\ CCR GW (SAMMIS-HR)\Data-Tech\GIS\DRAFT_SAMMIS_GWE_FEB_2017.mxd South Domestic Water Well 6A 655 P P MW MW MW Production Well 2A 656 Production Well 1A MW MW ODNR Well #1 653 MW MW ODNR Well #2 MW OSIP Imagery LEGEND: SPS CCR Compliance Site Monitoring Well / Groundwater Elevation - February 2017 Piezometer / Groundwater Elevation - February 2017 First Energy Production Well Production Well Inferred Direction of Groundwater Flow EVENT 4 GROUNDWATER ELEVATION CONTOUR MAP FEBRUARY 13, 2017 Goundwater Contour (ft, msl) Inferred Groundwater Contour (ft, msl) (FROM ARCGIS ONLINE Copyright: 2011 National Geographic Society, i-cubed) Feet DATE: 6/16/2017 CREATED BY: SJJ JOB NO SCALE 1 inch = 300 feet

25 Document Path: G:\Cincinnati\DCS\Projects\F\FirstEnergy\ CCR GW (SAMMIS-HR)\Data-Tech\GIS\EVENT_5_DRAFT_SAMMIS_GWE_March14_2017.mxd MW P South Domestic Water Well 6A P MW Production Well 3A MW MW Production Well 2A 654 Production Well 1A MW MW MW MW ODNR Well #1 ODNR Well #2 651 MW OSIP Imagery LEGEND: Monitoring Well / Groundwater Elevation - March 2017 Piezometer / Groundwater Elevation - March 2017 First Energy Production Well Production Well Inferred Direction of Groundwater Flow Groundwater Contour (ft, msl) Inferred Groundwater Contour (ft, msl) (FROM ARCGIS ONLINE Copyright: 2011 National Geographic Society, i-cubed) ³ 1 inch = 300 feet Feet DATE: 1/16/2018 CREATED BY: SJJ JOB NO SPS CCR Compliance Site EVENT 5 GROUNDWATER ELEVATION CONTOUR MAP MARCH 14, 2017 SCALE

26 MW Production Well 3A Document Path: J:\Project\F\FirstEnergy\ CCR GW (SAMMIS-HR)\Data-Tech\GIS\DRAFT_SAMMIS_GWE_May1_2017.mxd South Domestic Water Well 6A P P MW MW MW Production Well 2A Production Well 1A MW MW MW MW ODNR Well #1 ODNR Well #2 MW OSIP Imagery LEGEND: Monitoring Well / Groundwater Elevation - May 2017 Piezometer / Groundwater Elevation - May 2017 First Energy Production Well Production Well Inferred Direction of Groundwater Flow Goundwater Contour (ft, msl) Inferred Groundwater Contour (ft, msl) (FROM ARCGIS ONLINE Copyright: 2011 National Geographic Society, i-cubed) Feet DATE: 6/16/2017 CREATED BY: SJJ JOB NO SPS CCR Compliance Site EVENT 6 GROUNDWATER ELEVATION CONTOUR MAP MAY 1, 2017 SCALE 1 inch = 300 feet

27 Document Path: G:\Cincinnati\DCS\Projects\F\FirstEnergy\ CCR GW (SAMMIS-HR)\Data-Tech\GIS\EVENT_7_DRAFT_SAMMIS_GWE_June5_2017.mxd MW P South Domestic Water Well 6A P MW Production Well 3A MW MW Production Well 2A Production Well 1A MW MW MW MW ODNR Well #1 ODNR Well #2 650 MW OSIP Imagery LEGEND: Monitoring Well / Groundwater Elevation - June 2017 Piezometer / Groundwater Elevation - June 2017 First Energy Production Well Production Well Inferred Direction of Groundwater Flow Goundwater Contour (ft, msl) Inferred Groundwater Contour (ft, msl) (FROM ARCGIS ONLINE Copyright: 2011 National Geographic Society, i-cubed) ³ Feet DATE: 1/16/2018 CREATED BY: SJJ JOB NO SPS CCR Compliance Site EVENT 7 GROUNDWATER ELEVATION CONTOUR MAP JUNE 5, 2017 SCALE 1 inch = 300 feet

28 Document Path: G:\Cincinnati\DCS\Projects\F\FirstEnergy\ CCR GW (SAMMIS-HR)\Data-Tech\GIS\EVENT_8_DRAFT_SAMMIS_GWE_June29_2017.mxd MW P South Domestic Water Well 6A P MW Production Well 3A MW MW Production Well 2A Production Well 1A MW MW MW MW ODNR Well #1 ODNR Well #2 650 MW OSIP Imagery LEGEND: Monitoring Well / Groundwater Elevation - June 2017 Piezometer / Groundwater Elevation - June 2017 First Energy Production Well Production Well Goundwater Contour (ft, msl) Inferred Groundwater Contour (ft, msl) Inferred Direction of Groundwater Flow (FROM ARCGIS ONLINE Copyright: 2011 National Geographic Society, i-cubed) Feet ³ DATE: 1/16/2018 EVENT 8 GROUNDWATER ELEVATION CONTOUR MAP JUNE 29, 2017 CREATED BY: SJJ JOB NO SPS CCR Compliance Site SCALE 1 inch = 300 feet

29 Document Path: G:\Cincinnati\DCS\Projects\F\FirstEnergy\ CCR GW (SAMMIS-HR)\Data-Tech\GIS\EVENT_9_DRAFT_SAMMIS_GWE_August17_2017.mxd MW South Domestic Water Well 6A P P-1 NM MW Production Well 3A MW MW Production Well 2A Production Well 1A MW ODNR Well #1 649 MW MW MW ODNR Well #2 648 MW OSIP Imagery LEGEND: Monitoring Well / Groundwater Elevation - August 2017 Piezometer / Groundwater Elevation - August 2017 First Energy Production Well Production Well Inferred Direction of Groundwater Flow Goundwater Contour (ft, msl) Inferred Groundwater Contour (ft, msl) (FROM ARCGIS ONLINE Copyright: 2011 National Geographic Society, i-cubed) ³ Feet 1 inch = 263 feet DATE: 1/16/2018 EVENT 9 GROUNDWATER ELEVATION CONTOUR MAP AUGUST 17, 2017 CREATED BY: SJJ JOB NO SPS CCR Compliance Site SCALE