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 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 MONITORING AND CORRECTIVE ACTION REPORT COAL COMBUSTION BYPRODUCT LANDFILL Hatfield s Ferry Power Station Greene County, Pennsylvania Prepared for: FirstEnergy 8 Cabin Hill Drive Greensburg, PA 1561 Prepared by: Tetra Tech, Inc. 4 Penn Center Boulevard, Suite 2 Pittsburgh, PA Phone: (412) Fax: (412) Tetra Tech Project No. 212C-SW-71

3 MONITORING AND CORRECTIVE ACTION REPORT COAL COMBUSTION BYPRODUCT LANDFILL HATFIELD S FERRY POWER STATION GREENE COUNTY, PENNSYLVANIA Prepared for: FirstEnergy 8 Cabin Hill Drive Greensburg, PA 1561 Prepared by: Tetra Tech, Inc. 4 Penn Center Boulevard, Suite 2 Pittsburgh, PA Phone: (412) Fax: (412) Tetra Tech Project No. 212C-SW-71

4 TABLE OF CONTENTS 1. INTRODUCTION Background and Site Characteristics Regulatory Basis Overview of Report Contents GENERAL INFORMATION Status Of The Groundwater Monitoring And Corrective Action Program Establishing a CCR Groundwater Monitoring Well System Development of a Groundwater Monitoring Plan Completion of Background Groundwater Sampling Selection of Statistical Methods Initial Detection Monitoring Sampling Event Problems Encountered/Resolved Transition Between Monitoring Programs (If Any) Key Activities Planned For The Upcoming Year DETECTION MONITORING INFORMATION Groundwater Analytical Results Summary TABLES FIGURES 212C-SW-71 iii

5 TABLES 2-1 CCR Rule Groundwater Monitoring System Well Summary 3-1 CCR Rule Groundwater Monitoring Analytical Results Summary FIGURES 2-1 CCR Rule Groundwater Monitoring System 212C-SW-71 iv

6 1. INTRODUCTION This 217 Annual Coal Combustion Residuals (CCR) Groundwater Monitoring and Corrective Action Report was prepared by Tetra Tech, Inc. (Tetra Tech) on behalf of FirstEnergy (FE), for the Coal Combustion Byproduct Landfill (CCBL or CCR unit ) at the Hatfield s Ferry Power Station (hereinafter referred to as the Station ). The Station is located in Greene County, Pennsylvania. The report was developed to comply with requirements of 4 CFR 257.9(e). 1.1 BACKGROUND AND SITE CHARACTERISTICS CCRs produced at the Station were placed in the facility s captive CCBL, which is located approximately one mile west-southwest of the Station. The landfill is an existing CCR unit that is regulated under Pennsylvania Department of Environmental Protection (PADEP) Solid Waste Permit No A PADEP groundwater monitoring program for the landfill has been in effect since Although CCR waste generation ceased when the Station closed in 213, a September 215 modification to the permit also allowed coal combustion wastes generated at other FirstEnergy facilities to be disposed at the Hatfield CCBL. However, no disposal from any other facilities has occurred to date. The original topography of the CCBL area has been altered by surface mining of coal that was performed during the 197s and 198s throughout much of the central portion of the site. Mine spoil, in some cases mixed with fly ash, was used as backfill for mined areas. The CCBL consists of three permitted disposal areas: Phase I (approximately acres), Phase II (approximately 2 acres), and Phase III (approximately 17 acres at full build-out). The Phase I and II areas are unlined but do include an underdrain blanket system and are largely overlain by the Phase III area, which has a Pennsylvania Class I Residual Solid Waste liner system that includes two geomembranes, a geosynthetic clay liner (GCL), a leachate collection system, and a leak detection zone. Disposal operations were performed in the Phase I and II areas until 21, at which time all operations were transitioned to the Phase III area. Between 29 and 213, the Phase III area was constructed in stages (referred to as Steps ): Steps 1, 2, and 3-1, which have a combined lined area of approximately 58 acres. Underdrain flows collected from the Phase I and II areas are routed to two concrete sumps where they are then pumped to a passive wetland treatment system located northeast of the Phase II disposal area. Surface water runoff and leachate collected from the Phase III area are routed to the landfill s Leachate Storage Impoundment (LSI), which is located east of the Phase II and Phase III disposal areas. Like the Phase III area, the LSI has a Class I liner system. 212C-SW

7 Groundwater in the CCBL area occurs primarily within the mine spoil and underlying fractured bedrock and flow is primarily controlled by topography and by the bedrock structure (i.e., dip). The uppermost aquifer in the CCBL area is the mine spoil/weathered bedrock aquifer (shallow aquifer) but some of the shallow groundwater also migrates to the underlying Uniontown sandstone aquifer. Within the footprint of the CCBL the mine spoil/weathered bedrock and Uniontown sandstone form a single interconnected flow unit, as the shallow mine spoil/weathered bedrock groundwater discharges/infiltrates directly into the Uniontown sandstone north of the outcrop of the Waynesburg coal. The Uniontown sandstone is directly underlain by a shale layer that serves as an aquitard to further vertical groundwater flow downward into other aquifers at the site. The mine spoil/weathered bedrock unit has been identified as the uppermost aquifer for CCR Rule groundwater monitoring under most of the CCBL area, with the underlying Uniontown sandstone considered the uppermost aquifer in those CCBL areas located north of the outcrop of the Waynesburg coal. Historic and recent groundwater level data indicate groundwater flow within the mine spoil/weathered bedrock aquifer is primarily to the north along the slope of the top of bedrock. A portion of the shallow groundwater in the eastern portion of the CCBL (northeast of the waste boundary) also flows eastward. Groundwater in the Uniontown sandstone aquifer migrates primarily to the northeast and east towards outcrop areas along major drainage features in the area. The historic and recent groundwater data also indicates that the groundwater flow patterns at the site exhibit very little seasonal and temporal fluctuations. A representative set of water level data from the current reporting period (217) were used for contouring groundwater flow patterns at the site as shown on Figure 2-1. A more detailed discussion of the site s geologic and hydrogeologic characteristics is provided in Section 2. of this report. 1.2 REGULATORY BASIS As required by 257.9(e), of the CCR Rule, Owners or Operators of existing CCR landfills and surface impoundments must prepare an Annual Groundwater Monitoring and Corrective Action Report no later than January 31, 218 and annually thereafter. According to the subject section, For the preceding calendar year, the annual report must document the status of the groundwater monitoring and corrective action program for the CCR unit, summarize key actions completed, describe any problems encountered, discuss actions to resolve the problems, and project key activities for the upcoming year. 212C-SW

8 This report has been developed to meet the general requirements above and the specific requirements of 257.9(e)(1) through (5), which include: (1) A map, aerial image, or diagram showing the CCR unit and all background (or upgradient) and downgradient monitoring wells, to include the well identification numbers, that are part of the groundwater monitoring program for the CCR unit (see Figure 2-1); (2) Identification of any monitoring wells that were installed or decommissioned during the preceding year, along with a narrative description of why those actions were taken (see Section 2.1.1); (3) In addition to all the monitoring data obtained under through , a summary including the number of groundwater samples that were collected for analysis for each background and downgradient well, the dates the samples were collected, and whether the sample was required by the Detection Monitoring or Assessment Monitoring programs (see Sections and and Table 3-1); (4) A narrative discussion of any transition between monitoring programs (e.g., the date and circumstances for transitioning from Detection Monitoring to Assessment Monitoring in addition to identifying the constituent(s) detected at a statistically significant increase over background levels) (see Section 2.3); and (5) Other information required to be included in the annual report as specified in through In addition, the Owner and Operator must place the report in the facility's operating record as required by (h)(1), provide notification of the report s availability to the appropriate State Director within 3 days of placement in operating record as required by (h)(1), and place the report on the facility s publically accessible website, also within 3 days of placing the report in the operating record. 1.3 OVERVIEW OF REPORT CONTENTS Section 1. of this report provided an overview of the CCR unit characteristics, regulatory basis, and a summary of the requirements for CCR Annual Groundwater Monitoring and Corrective 212C-SW

9 Action Reports. Section 2. summarizes the status of key actions pertaining to CCR groundwater monitoring completed during 217 for the CCBL and plans for the upcoming year. Section 3. presents Detection Monitoring results from groundwater sampling events completed in C-SW

10 2. GENERAL INFORMATION This section provides an overview of the status of the CCR groundwater monitoring program through 217 and key activities planned for STATUS OF THE GROUNDWATER MONITORING AND CORRECTIVE ACTION PROGRAM During calendar years 216 and 217, the following key actions were completed with regard to the CCR groundwater monitoring program for the CCBL Establishing a CCR Groundwater Monitoring Well System Tetra Tech was contracted by FirstEnergy to review existing groundwater monitoring system information and site hydrogeologic data for the CCBL to evaluate the suitability of the existing system, determine whether additional monitoring wells were needed, and to install and develop any new wells to establish a system that meets the applicable requirements and performance standards for groundwater monitoring under 4 CFR Upon completing this review, one additional groundwater monitoring well and one piezometer were installed in October of 216 to fill data gaps and to develop a network in compliance with CCR Rule requirements. The CCR monitoring well network consists of three upgradient (background) wells in the mine spoil/bedrock aquifer (MW-212A, -213A, and -215A), three upgradient (background) wells in the Uniontown sandstone aquifer (MW-212B, -213B, and - 215B), five downgradient wells to monitor the combined aquifer (MW-216A, -22A, -22B, -23B, and -24B), and one piezometer (PZ-221A), as summarized in attached Table 2-1 and shown on attached Figure 2-1. The piezometer will be used to evaluate groundwater flow patterns near the northwestern edge of the CCR unit, with provision to convert it to a CCR monitoring well if water level data indicates a flow component in the CCR uppermost aquifer from the CCR unit to the northwest. A CCR Groundwater Monitoring System Evaluation Report (Tetra Tech, Inc., October, 217), which discusses the basis for development of the monitoring well network and includes detailed information on the site geology, hydrogeology, and well completion records, was placed in the facility s Operating Record. As required by (f), the CCR groundwater monitoring well network was certified by a Professional Engineer to be in compliance with the applicable requirements of The subject certification was placed in both the facility s Operating Record and on the publically accessible website ( on October 17, C-SW

11 2.1.2 Development of a Groundwater Monitoring Plan On behalf of FE, Tetra Tech prepared a Groundwater Monitoring Plan to comply with applicable requirements of the CCR Rule. The document provides the sampling and analytical methodologies and procedures for collecting and reporting representative groundwater quality data from CCR monitoring wells at the CCBL. 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 Quality assurance (QA) and quality control (QC). In addition, the document includes the statistical plan describing the process for evaluating groundwater monitoring data developed from the CCR sampling and analysis program [ (f)] Completion of Background Groundwater Sampling To fulfill the applicable requirements of (b), eight independent rounds of background groundwater samples for analyzing all Appendix III and IV parameters from each of the CCR monitoring wells were collected prior to October 17, 217. The sampling events were conducted on the following dates: Sampling Event Dates 1 1/23 to 1/26/17 2 2/2 to 2/21/17 3 3/27 to 3/28/17 4 4/25 to 4/26/17 5 5/23 to 5/24/17 6 6/2 to 6/21/17 7 7/24 to 7/31/17 8 8/22 to 8/24/ Selection of Statistical Methods Based on the attributes of the data set from the eight rounds of background sampling, statistical methods were selected among the available methods referenced in (f) which met the performance standards referenced in (g). Data from the first eight rounds of groundwater 212C-SW

12 analytical results collected at the upgradient and downgradient CCR network wells at the site were evaluated in terms of percent non-detects and data distributions to select the appropriate statistical method for each parameter to identify any Statistically Significant Increases (SSIs) over background concentrations [ (h)]. As required by (f)(6), the statistical method selection was certified by a Professional Engineer as currently appropriate for evaluating the groundwater monitoring data for the CCBL at the Hatfield s Ferry Power Station and as meeting the applicable requirements of (f). The subject certification was placed in both the facility s Operating Record and on the publically accessible website on October 17, Initial Detection Monitoring Sampling Event In accordance with , FirstEnergy collected the first round of Detection Monitoring samples from the upgradient and downgradient CCR groundwater monitoring wells on October 12 and 13, 217 as summarized in the table below. The samples were analyzed for Appendix III parameters, with the laboratory analyses completed by October 25, 217. The laboratory results are discussed in Section 3. of this report. Monitoring Well Location Date Sampled Purpose MW-212A Upgradient/Background - 1/13/17 Detection Monitoring MW-213A Mine Spoil/Bedrock 1/12/17 Detection Monitoring MW-215A 1/13/17 Detection Monitoring MW-212B Upgradient/Background - Uniontown Sandstone 1/12/17 Not Sampled Insufficient Water MW-213B 1/12/17 Not Sampled Insufficient Water MW-215B 1/13/17 Detection Monitoring MW-216A Downgradient 1/12/17 Detection Monitoring MW-22A Mine Spoil/Bedrock 1/12/17 Detection Monitoring MW-22B Downgradient 1/12/17 Detection Monitoring MW-23B Uniontown Sandstone 1/12/17 Detection Monitoring MW-24B 1/12/17 Detection Monitoring 2.2 PROBLEMS ENCOUNTERED/RESOLVED During the eight background sampling events and the initial Detection Monitoring sampling event, insufficient recoverable volumes of groundwater from two of the pre-existing upgradient wells (MW-212B and -213B) was found to consistently be problematic. These wells have been part of 212C-SW

13 the PADEP groundwater monitoring program for several years and have been able to yield sufficient water even though they have historically exhibited low to moderate standing water column depths (typically between two and five feet). It s believed that the sampling frequency (approximately every four to six weeks) required to obtain the eight background and initial Detection Monitoring samples in time to meet the CCR groundwater compliance milestone date of October 17, 217 may have overstressed these particular wells. It s also believed that one or both of these wells may still be viable for use in the site s CCR groundwater monitoring system as the required sampling frequency under the CCR Rule (semi-annual) is now in effect. As such, and since the remaining CCR monitoring system still exceeds the minimum required number of upgradient wells, the water levels in MW-212B and -213B will be monitored on a quarterly basis during 218. This additional water level data will be used to determine the viability of using one or both of the wells as part of the site s CCR groundwater monitoring system and, if necessary, help establish the basis for preparing a demonstration - in accordance with (d) - that they must be sampled at a frequency between six months and one year in order to have recoverable groundwater volumes available. If such a demonstration needs to be prepared it will be placed in the landfill s operating record when complete, and included as part of the 218 CCR Groundwater Monitoring and Corrective Action Report. Other than the available groundwater sampling volumes for upgradient wells MW-212B and -213B noted above, there were no other significant problems (e.g., quality control issues) encountered during 217 with regard to the CCR groundwater monitoring program. 2.3 TRANSITION BETWEEN MONITORING PROGRAMS (IF ANY) During 216 and 217, the eight rounds of background sampling for all Appendix III and IV parameters were conducted followed by initiation of Detection Monitoring with collection of the first Detection Monitoring samples in October of 217. There was no transition between monitoring programs (e.g., Detection to Assessment Monitoring) during KEY ACTIVITIES PLANNED FOR THE UPCOMING YEAR The following are the key CCR groundwater compliance activities planned for 218: Complete the statistical evaluation of the initial round of Detection Monitoring data to determine if there are any Appendix III parameter concentrations in downgradient wells exhibiting SSIs above background. If there are no SSIs, then continue with Detection Monitoring by conducting two semiannual rounds of sampling and analysis for Appendix III constituents [per (c)]. 212C-SW

14 If any SSIs are identified, then 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 any SSI s are identified and an ASD indicates that an alternate source is not responsible for all the SSI s identified, then initiate Assessment Monitoring for Appendix IV constituents [per (e)(1)]. Obtain quarterly water levels in MW-212B and -213B to determine if one or both of the wells are viable for use in the CCR groundwater monitoring system and if they will require a sampling frequency of between six months and one year. Should it be determined that a demonstration for a modified sampling frequency is needed, it will be prepared in accordance with (d). 212C-SW

15 3. DETECTION MONITORING INFORMATION 3.1 GROUNDWATER ANALYTICAL RESULTS SUMMARY As referenced above, the CCR groundwater sampling and analysis program implemented through the end of 217 consists of the eight background sampling rounds conducted between January and August 217 for all Appendix III and IV parameters, and the initial Detection Monitoring round of sampling conducted in October 217 for all Appendix III parameters. Table 3-1 presents the analytical results for these events. As previously noted, statistical evaluation of the Appendix III Detection Monitoring data in Table 3-1 remains in-progress as of the end of the 217 reporting period (lab results were received in the fourth quarter of 217 and a 9 day period is allowed by the CCR Rule for statistical evaluation which falls in the first quarter of 218). If any Appendix III SSIs are identified, ASD or Assessment Monitoring activities will be undertaken as appropriate, and associated recordkeeping, notification, and reporting will be performed in accordance with the applicable requirements of 4 CFR , 95, 15, 16, and C-SW

16 TABLES

17 TABLE 2-1 CCR RULE GROUNDWATER MONITORING SYSTEM WELL SUMMARY HATFIELD S FERRY CCB LANDFILL 217 ANNUAL GROUNDWATER Well Year Installed Formation Monitored Ground Surface Elevation (ft MSL) Total Well Depth (ft bgs) Monitored Interval (ft bgs) Monitored Interval (ft MSL) Casing ID and Material Upgradient (Background) MW-212A 25 MW-213A 25 MW-215A 25 Mine Spoil/ Weathered Bedrock Mine Spoil/ Weathered Bedrock Mine Spoil/ Weathered Bedrock " - Sch. 4 PVC " - Sch. 4 PVC " - Sch. 4 PVC MW-212B 25 Uniontown SS " - Sch. 4 PVC MW-213B 25 Uniontown SS " - Sch. 4 PVC MW-215B 25 Uniontown SS " - Sch. 4 PVC Downgradient MW-216A 25 MW-22A 216 Mine Spoil/ Weathered Bedrock Mine Spoil/ Weathered Bedrock " - Sch. 4 PVC " - Sch. 4 PVC MW-22B 1993 Uniontown SS " - Sch. 4 PVC MW-23B 1993 Uniontown SS " - Sch. 4 PVC MW-24B 1993 Uniontown SS " - Sch. 4 PVC Piezometer PZ-221A 216 Mine Spoil/ Weathered Bedrock " - Sch. 4 PVC Notes: SS = sandstone MSL = mean sea level bgs = below ground surface ID = inside diameter PVC = polyvinyl chloride

18 TABLE 3-1 CCR RULE GROUNDWATER MONITORING ANALYTICAL RESULTS SUMMARY HATFIELD'S FERRY CCB LANDFILL ANNUAL GROUNDWATER SAMPLING EVENT NO. 2 WELL ID3 SAMPLE DATE BORON METALS MG/L APPENDIX III (all Chemical Constituents sampled as TOTAL RECOVERABLE) 1 APPENDIX IV (all Chemical Constituents sampled as TOTAL RECOVERABLE) 1 CALCIUM CHLORIDE FLUORIDE PH SULFATE TDS ANTIMONY ARSENIC BARIUM BERYLLIUM CADMIUM CHROMIUM COBALT METALS MISC MISC MISC MISC MISC METALS METALS METALS METALS METALS METALS METALS LEAD LITHIUM MERCURY MOLYBDENUM SELENIUM 1 MW-22B 1/24/ J U.54 J U.175 U.3 U U U.85 J. U.175 U.376 U MW-22B 2/2/ U.1 U U.175 U.3 U.423 J.52 U U.72 J. U.175 U.121 U.599 U 3 MW-22B 3/28/ J U.3 J J.175 U.3 U.473 J.52 U.1359 J-.4 U.95 J. U.175 U U 4 MW-22B 4/25/ J U.19 J U.175 U.3 U.436 J.52 U U.55 J. U.175 U.291 U.124 U 5 MW-22B 5/24/ J U.29 J U.17 U.3 U.493 J.52 U U.7 J. U.17 U U.527 U 6 MW-22B 6/2/ U.38 J U.17 U.3 U U U.56 J. U.17 U U 7 MW-22B 7/24/ U.24 J U.17 U.45 U U U.5 J. U.32 J.59 U.543 J 8 MW-22B 8/23/ U.3 J J.17 U.45 U U U.33 J. U.17 U.364 U (DM-1) MW-22B 1/12/ J MW-23B 1/26/ J U.45 J U.175 U.3 U.475 U.52 U U.285 U. U.175 U.328 U.77 U 2 MW-23B 2/2/ J U.1 U U.9 U.3 U.475 U.52 U U.285 U.3 J.175 U.178 U.54 U 3 MW-23B 3/28/ J-.89 J U.15 U U.175 U.3 U.475 U.52 U.335 J-.4 U.285 U. U.175 U.374 U.389 U 4 MW-23B (D) 4/25/ J U.24 J U.175 U.3 U.475 U.52 U U.285 U. U.175 U.641 U U 4 MW-23B 4/25/ J-.89 J J.25 J U.19 J.3 U.475 U.52 U U.43 J. U.175 U.346 U U 5 MW-23B 5/24/ J-.83 J U.19 J U.17 U.3 U.47 U.52 U U.45 J. U.17 U.172 U U 6 MW-23B 6/2/ J U.24 J U.17 U.3 U.47 U.52 U U.28 U. U.17 U -.1 U.36 U 7 MW-23B (D) 7/24/ J U.33 J U.17 U.45 U.8 J.52 U U.28 U.16 J.17 U.45 U.322 U 7 MW-23B 7/24/ J U.21 J U.17 U.45 U.47 U.52 U U.28 U. U.17 U.896 U.522 J 8 MW-23B 8/23/ J U.15 U UJ.17 U.45 U.47 U.52 U J.28 U. U.17 U.696 U (DM-1) MW-23B (D) 1/12/ J (DM-1) MW-23B 1/12/ J MW-24B 1/25/ J U.15 U J.175 U.3 U.67 J.52 U J.285 U. U.175 U.192 U.676 U 2 MW-24B 2/2/ U.1 U.2.1 U.175 U.3 U.48 J.52 U U.285 U.146 J.175 U.15 U.482 U 3 MW-24B 3/28/ J-.94 J U.15 U J.175 U.3 U.475 U.52 U.7859 J-.4 U.285 U. U.175 U U 4 MW-24B 4/25/ J-.83 J U.15 U U.175 U.3 U.475 U.52 U U.285 U.136 J.175 U.542 U U 5 MW-24B 5/24/ J-.81 J U.28 J U.17 U.3 U.5 J.52 U U.28 U. U.17 U.796 U.455 U 6 MW-24B 6/2/ J U.16 J U.17 U.3 U.47 U.52 U.39.4 U.28 U. U.17 U.7 U.168 U 7 MW-24B 7/24/ J U.15 U U.17 U.45 U.47 U.52 U U.28 U. U.17 U.415 U.724 J 8 MW-24B 8/23/ U U.15 U J.17 U.45 U.54 J.52 U U.28 U. U.17 U.462 U (DM-1) MW-24B 1/12/ J MW-212A (D) 1/26/ U.28 J U.175 U.3 U.475 U.52 U U.3. U.175 U.25 U.633 U 1 MW-212A 1/26/ U.29 J U.175 U.3 U.475 U.52 U U.12. U.175 U.276 U.652 U 2 MW-212A 2/21/ U.1 U U.175 U.3 U.475 U.52 U U.76. U.175 U.128 U.566 U 3 MW-212A 3/27/ J U.18 J U.175 U.3 U.475 U.52 U.6336 J-.4 U.152. U.175 U U 4 MW-212A 4/26/ U.24 J U.175 U.3 U.475 U.52 U U.717. U.175 U U 5 MW-212A 5/23/ U.37 J U.17 U.3 U.47 U.52 U J.62. U.17 U.131 U.968 U 6 MW-212A 6/21/ U.19 J U.17 U.45 U.47 U.52 U U.459 J. U.17 U U 7 MW-212A 7/25/ U.34 J U.17 U.45 U.47 U.52 U U.429 J. U.17 U.127 U.312 U 8 MW-212A 8/23/ U.28 J UJ.17 U.45 U.41 J.52 U U.314 J. U.17 U.472 U (DM-1) MW-212A 1/13/ J MW-213A 1/25/ U U.175 U.137 J.4 J.13 J.23 J.4 U U.175 U.28 U.687 U 2 MW-213A 2/21/ J U.2357 U U.175 U.44 J.475 U.52 U U U.175 U.163 U.58 U 3 MW-213A 3/27/ J U J.175 U.6 U.475 U.52 U.2897 J.4 U U.175 U.271 U.992 U 4 MW-213A 4/26/ J-.19 J U.175 U.3 U.475 U.52 U U U.175 U.19 U U 5 MW-213A (D) 5/23/ J U U.17 U.3 U.47 U.52 U J U.17 U.345 U.736 U 5 MW-213A 5/23/ J U U.39 J.3 U.47 U.52 U J U.17 U.74 U.93 U 6 MW-213A 6/21/ U U.17 U.45 U.47 U.52 U U U.17 U.679 U MW-213A 7/31/ U.17 U.45 U.47 U.52 U.2186 J.4 U.464. U.17 U.426 U MW-213A 8/23/ U J.17 U.45 U.47 U.52 U U J.17 U.773 U (DM-1) MW-213A 1/12/ MW-215A 1/24/ J U.2 J U.175 U.3 U.475 U.52 U J.285 U.126 J.175 U.339 U MW-215A (D) 2/21/ U.15 U.88.1 U.175 U.3 U.48 J.52 U U.285 U. U.175 U.158 U.486 U 2 MW-215A 2/21/ U.15 U U.175 U.3 U.475 U.52 U U.3 J. U.175 U.145 U.528 U 3 MW-215A 3/27/ J U.15 U J.175 U.3 U.48 J.52 U.1539 J-.4 U.33 J. U.175 U.785 U.236 U 4 MW-215A 4/26/ J U.15 U U.175 U.3 U.475 U.52 U U.285 U. U.175 U.691 U U 5 MW-215A 5/23/ U.21 J U.17 U.3 U.48 J.52 U J.28 U. U.17 U.413 U U 6 MW-215A 6/21/ U.15 U U.17 U.45 U.47 U.52 U U.36 J. U.17 U.756 U.539 U 7 MW-215A 7/31/ U.15 U U.17 U.45 U.6 J.52 U U.35 J. U.17 U.33 U -.28 U 8 MW-215A (D) 8/23/ U.15 U J.17 U.45 U.47 U.52 U U.28 U. U.17 U.466 U MW-215A 8/23/ U.15 U J.17 U.75 J.47 J.52 U U.28 U. U.17 U.184 U (DM-1) MW-215A 1/13/ J MW-215B 1/24/ J U.49 J U.175 U.71 J-.228 J.21 J J J.175 U.355 U.83 2 MW-215B 2/21/ U.15 U U.175 U.55 J.475 U.52 U U.472 J. U.175 U.212 U.5 U 3 MW-215B 3/27/ J U.21 J U.175 U.3 U.475 U.52 U.649 J-.4 U J.175 U.356 U.151 U 4 MW-215B 4/26/ J J U.15 U U.175 U.3 U.475 U.52 U U.363 J.156 J.175 U.315 U.787 U 5 MW-215B 5/23/ U.34 J U.17 U.3 U.47 U.52 U J.422 J. U.17 U.972 U.219 U 6 MW-215B 6/21/ U.15 U U.17 U.45 U.47 U.52 U U.267 J. U.17 U.349 U -.51 U 7 MW-215B 7/31/ U.15 U U.17 U.45 U.47 U.52 U U.27 J. U.17 U U 8 MW-215B 8/23/ U.15 U UJ.17 U.45 U.47 U.52 U.73.4 U.255 J. U.17 U.875 U (DM-1) MW-215B 1/13/ J MW-216A 1/25/ U J.175 U.3 U U J.4 J. U.175 U MW-216A 2/2/ U.9 U U.9 U.3 U U U.285 U. U.175 U.157 U.58 U 3 MW-216A 3/28/ J U J.175 U.3 U U J-.4 U.285 U. U.175 U METALS THALLIUM RADIUM-226 RADIUM-228 METALS METALS METALS METALS METALS RADIOCHEM RADIOCHEM MG/L MG/L MG/L S.U. MG/L MG/L MG/L MG/L MG/L MG/L MG/L MG/L MG/L MG/L MG/L MG/L MG/L MG/L MG/L PCI/L PCI/L Sheet 1 of 2

19 TABLE 3-1 CCR RULE GROUNDWATER MONITORING ANALYTICAL RESULTS SUMMARY HATFIELD'S FERRY CCB LANDFILL ANNUAL GROUNDWATER SAMPLING EVENT NO. 2 WELL ID3 SAMPLE DATE BORON METALS MG/L APPENDIX III (all Chemical Constituents sampled as TOTAL RECOVERABLE) 1 APPENDIX IV (all Chemical Constituents sampled as TOTAL RECOVERABLE) 1 CALCIUM CHLORIDE FLUORIDE PH SULFATE TDS ANTIMONY ARSENIC BARIUM BERYLLIUM CADMIUM CHROMIUM COBALT METALS MISC MISC MISC MISC MISC METALS METALS METALS METALS METALS METALS METALS LEAD LITHIUM MERCURY MOLYBDENUM SELENIUM METALS THALLIUM RADIUM-226 RADIUM-228 METALS METALS METALS METALS METALS RADIOCHEM RADIOCHEM MG/L MG/L MG/L S.U. MG/L MG/L MG/L MG/L MG/L MG/L MG/L MG/L MG/L MG/L MG/L MG/L MG/L MG/L MG/L PCI/L PCI/L 4 MW-216A 4/25/ J-.158 J U U.25 J.3 U U U.285 U.7 J.175 U MW-216A 5/24/ J-.91 J U U.27 J.3 U U U.28 U.124 J.17 U MW-216A 6/2/ J U U.17 U.3 U U U.28 U. U.17 U.662 U.287 U 7 MW-216A 7/24/ J U.83 J U.17 U.45 U U U.28 U.272 J.17 U J 8 MW-216A 8/24/ U.98 J J.2 J.45 U U U.28 U.275 J.17 U.787 U (DM-1) MW-216A 1/12/ J MW-22A 1/23/ J U U.175 U.3 U.8.52 U J.2 J. U.175 U.423 U.558 U 2 MW-22A 2/2/ J U J.175 U.3 U U U.94 J.17 J.175 U.169 U.544 U 3 MW-22A (D) 3/27/ J U J.175 U.3 U U.6826 J-.4 U.77 J. U.175 U U 3 MW-22A 3/27/ J U U.175 U.3 U U.7278 J-.4 U.79 J. U.175 U U 4 MW-22A 4/25/ J-.62 J U U.175 U.3 U U U.66 J. U.175 U.8.2 U 5 MW-22A 5/23/ J U U.17 U.3 U U J.68 J. U.17 U U 6 MW-22A (D) 6/2/ J U J.17 U.45 UJ.8153 J-.52 U.7296 J-.4 U.53 J. U.17 U.144 U -.89 U 6 MW-22A 6/2/ J U U.17 U.3 U U U.41 J. U.17 U U 7 MW-22A 7/24/ J U U.17 U.45 U U.72.4 U.28 U. U.17 U U 8 MW-22A 8/24/ J U J.17 U.91 J U U.28 U. U.17 U U 9 (DM-1) MW-22A 1/12/ J NOTES: 1 Lab analyses were completed by Beta Lab and TestAmerica Laboratories, Inc., both of which are accredited/certified laboratories: Beta Lab ISO/IEC 1725 Cert No (Exp ) and ISO/IEC 91 Cert. No IS7 (Exp ) and TestAmerica NELAP Identification Number: 2-416, EPA Region: 3, Expiration Date: Event Nos. 1 through 8 were background/baseline sampling events. Event No. 9 was the initial Detection Monitoring (DM-1) sampling event. 3 Field duplicate samples that were taken for Quality Control purposes are noted with a (D). DATA QUALIFER DEFINITIONS: The following definitions provide brief explanations of the validation qualifiers assigned to results in the data review process. U J The analyte was analyzed for, but was not detected at a level greater than or equal to the level of the adjusted method detection limit for sample and method. The analyte was positively identified and the associated numerical value is the approximate concentration of the analyte in the sample (due either to the quality of the data generated because certain quality control criteria were not met, or the concentration of the analyte was below the reporting limit). J+ The result is an estimated quantity, but the result may be biased high. J- The result is an estimated quantity, but the result may be biased low. UJ The analyte was analyzed for, but was not detected. The reported detection limit is approximate and may be inaccurate or imprecise. R The sample result (detected) is unusable due to the quality of the data generated because certain criteria were not met. The analyte may or may not be present in sample UR The sample result (nondetected) is unusable due to the quality of the data generated because certain criteria were not met. The analyte may or may not be present in sample. Sheet 2 of 2

20 FIGURES

21 FIGURE NUMBER 1 4 DRAWN BY: S. PAXTON 1/26/ CHECKED BY: B. BAKER/26/18 APPROVED BY: B. BAKER 1/26/ REVISION GREENSBURG, PENNSYLVANIA FIRSTENERGY CORPORATION CONTRACT NUMBER: 212C-SW Feet HATFIELD'S FERRY CCR RULE GROUNDWATER MONITORING SYSTEM CCB LANDFILL (U) MW-212B (165.5) MW-212A (U) MW-213B (U) MW-213A (U) 8 Topographic Contour (1-foot) Approximate Waste Boundary (15.98) Approximate Parcel Boundary Groundwater Elevation Contour (137.36) Groundwater Elevation May Uniontown Sandstone Pre-Existing Monitoring Well (6.3) MW-22A 7 (125.78) 2 1 MW-216A (U) New Piezometer Mine Spoil EASTING NORTHING ³ 1357 Coordi na tes a re i n NAD 1983 Sta te Pl a ne Penns yl va ni a South (feet) (956.72) R 5 New CCR Monitoring Well 5 Legend (138.1) 93 MW-23B (D) 1 (948.24) 9 1 WELL NO MW-22B (D) MW-23B (D) MW-24B (D) MW-212A (U) MW-212B (U) 92 MW-213A (U) MW-213B (U) MW-215A (U) MW-215B (U) MW-216A (U) MW-22A PZ-221A MW-215A (U) MW-22B (D) (N/A) MW-215B (U) R PZ-221A 1 7 (959.18) MW-24B (D) References: 1. Aerial photograph provided by ESRI's ArcGIS Online World Imagery map service ( 214 ESRI and its data suppliers). 98 from the Pennsylvania Spatial Data Access 2. Contours obtained (PASDA) website and from FirstEnergy Drawing No. C , Rev.. 3. Pre-Existing monitoring99well locations were obtained from FirstEnergy Drawing No. C , Rev.. 4. Approximate Waste Boundary lines were obtained from FirstEnergy Drawing Nos. C834825, Rev., C835358, Rev. C, C834821, Rev. 1 and C83482, Rev Approximate Parcel Boundary obtained from FirstEnergy Drawing No. C A, dated 8/31/5. 6. Monitoring well MW-22A and piezometer PZ-221A were installed by Tetra Tech, Inc. in well locations were 3 October 216. As-built Tetra Tech, Inc. on /22/216. obtained by field survey performed by PGH P:\GIS\FIRST_ENERGY\MAPDOCS\HATFIELDSFERRY_PROPOSED_MW_MAY217_CCR.MXD 1/26/18 SP