SECOND ANNUAL GROUNDWATER MONITORING AND CORRECTIVE ACTION REPORT U.S. EPA COAL COMBUSTION RESIDUALS (CCR) RULE

Transcription

1 SECOND ANNUAL GROUNDWATER MONITORING AND CORRECTIVE ACTION REPORT U.S. EPA COAL COMBUSTION RESIDUALS (CCR) RULE DISPOSAL AREA 8 BRUNNER ISLAND STEAM ELECTRIC STATION EAST MANCHESTER TOWNSHIP YORK COUNTY, PENNSYLVANIA Prepared for: Brunner Island, LLC East Manchester Township, Pennsylvania Prepared by: West Chester, Pennsylvania and the Wayne, Pennsylvania Project No: January 31, 2019

2 TABLE OF CONTENTS PAGE NO.: 1.0 Introduction Purpose Area 8 Landfill Location and Design Groundwater Monitoring Network Geology Hydrogeology Regional Flow Groundwater Movement Water-Bearing Zones CCR Rule Monitoring Well Network Overview Groundwater Level Measurement CCR Groundwater Monitoring Data Collection For Statistical Analysis Statistical Analysis Method Results Alternate Source Demonstration Ongoing Detection Monitoring Corrective Actions Anticipated Upcoming Activities Certification References LIST OF TABLES TABLE 1 Monitoring Well Construction Overview 2 Groundwater Sampling Results i

3 TABLE OF CONTENTS (Continued) LIST OF FIGURES FIGURE 1 Site Location Map 2 General Site Layout 3 Schematic Conceptual Cross Section Local Geology 4 Schematic Cross Section Conceptual Regional Groundwater Movement - Vertical Component 5 Existing Groundwater Elevation Contours Active Discharge to Basin 6 6 Static Groundwater Elevation Contours If No Active Discharge to Basin 6 ii

4 1.0 INTRODUCTION 1.1 PURPOSE The United States Environmental Protection Agency (USEPA) published 40 CFR 257, Subpart D, Disposal of Coal Combustion Residuals from Electric Utilities (CCR Rule) on April 17, The CCR Rule regulates disposal of coal combustion residuals (CCRs) in CCR landfills and impoundments. Advanced GeoServices Corp. and the V.F. Britton Group, LLC (Advanced GeoServices) have prepared this Second Annual Groundwater Monitoring and Corrective Action (GWMCA) Report for Disposal Area 8 (DA8), a state-permitted Class II residual waste landfill, located at the Brunner Island Steam Electric Station (Brunner) in East Manchester Township, York County, Pennsylvania. Brunner is owned and operated by Brunner Island, LLC, a subsidiary of Talen Energy Corporation. The CCR Rule states the following requirements for the GWMCA Report (see 40 CFR ): (e) Annual groundwater monitoring and corrective action report. For existing CCR landfills and existing CCR surface impoundments, no later than January 31, 2018, and annually thereafter, the owner or operator must prepare an annual groundwater monitoring and corrective action report. For new CCR landfills, new CCR surface impoundments, and all lateral expansions of CCR units, the owner or operator must prepare the initial annual groundwater monitoring and corrective action report no later than January 31 of the year following the calendar year a groundwater monitoring system has been established for such CCR unit as required by this subpart, and annually thereafter. 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. For purposes of this section, the owner or operator has prepared the annual report when the report is placed in the facility s operating record as required by (h)(1). At a minimum, the annual groundwater monitoring and corrective action report must contain the following information, to the extent available: (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; 1-1

5 (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; (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; (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); and (5) Other information required to be included in the annual report as specified in through (f) The owner or operator of the CCR unit must comply with the recordkeeping requirements specified in (h), the notification requirements specified in (h), and the internet requirements specified in (h). This report has been prepared to satisfy these requirements. The sections of the report in which these requirements are met as shown in the table below: CCR Citation Requirement How Satisfied 40 CFR (e) (1) Map showing background and downgradient monitoring wells 40 CFR (e) (2) New wells installed or decommissioned during report year 40 CFR (e) (3) Assessment and detection monitoring data, summary of samples taken 40 CFR (e) (4) Discussion of groundwater monitoring status 40 CFR (e) (5) Items required through Sections , including status of Assessment of Corrective Measures Selection of Remedy Implementation of Corrective Action Figure 5 Section 3.3 Sections 2 and 3, and Table 2 Section 4 Not applicable to this CCR Unit, as described in Section 5 1-2

6 1.2 AREA 8 LANDFILL LOCATION AND DESIGN Brunner is an active electric generation facility located on the west bank of the Susquehanna River in East Manchester Township, York County, Pennsylvania as shown on Figure 1. Brunner is owned and operated by Brunner Island, LLC. DA8 is located in the central portion of Brunner Island southeast of the main generation area. DA8 is a Class 2 residual waste landfill that was constructed on top of closed Ash Basin 5 (Basin 5) as an overfill landfill. As shown on Figure 1, closed Basin 5 has a substantially larger footprint than DA8. Placement of material into DA8 began in 2009 and is currently on-going. The permitted area for DA8 is 20 acres; however, only 9 acres (Cell 1) have been constructed and only 7.19 acres (active area) of the constructed area are currently being used for disposal. Figure 2 also shows two additional areas (Cell 2 and Cell 3) which are proposed/permitted, but have not been constructed, to the northeast of Cell 1. The landfill is double-lined with a primary geosynthetic liner and a secondary underlying clay liner. A leachate detection zone exists between the geosynthetic liner and the underlying clay subgrade layer. No disposal has occurred in the inactive constructed portion of DA8 (1.81 acres, as shown on Figure 2). This inactive constructed portion of DA8 is graded and covered by temporary tarps to help direct stormwater runoff to a drainage channel outside the active portion of DA8. Figure 2 depicts the channel location and stormwater flow direction. Stormwater is ultimately directed to the Susquehanna River at NPDES Outfall # 010. Figure 3 is a schematic conceptual cross section of DA8, and shows the leachate detection zone which is located at the base of the landfill. The groundwater table, underlying closed Basin 5 ash, and general underlying geology are also depicted on the figure. 1-3

7 2.0 GROUNDWATER MONITORING NETWORK A detailed description and justification for the DA8 groundwater monitoring network is detailed in the report entitled Groundwater Monitoring System Plan (Advanced GeoServices, 2017a). DA8 has been monitored for numerous years in accordance with state permit requirements. There is a good understanding of the site characteristics, as described in the following sections. 2.1 GEOLOGY The DA8 area is generally underlain by the Triassic Age New Oxford Formation, which consists predominately of a shale unit. The local bedrock geology is evident based on outcrops along the roadway and railroad tracks west of Black Gut Creek. Several strike and dip measurements were collected from the outcrops to identify the bedrock structural orientation. Based on the measurements, the bedding of the New Oxford Formation has an average strike of N45 E and dips to the northwest approximately 12. Joint sets were evident in near vertical orientations perpendicular to the strike orientation. The native overburden material within the surrounding and underlying closed Basin 5 was excavated down to the top of the bedrock during the construction of closed Basin 5 and has since been backfilled with coal ash material to an average thickness of 36 feet above the bedrock. In areas outside the footprint of closed Basin 5, the bedrock is directly overlain by native overburden material. The overburden material consists of a native sand and gravel layer that is overlain by a silty clay material (see Figure 3). The perimeter berms of closed Basin 5 consist of compacted clay, silt, sand, and gravel and are situated directly on the top of the bedrock surface. 2.2 HYDROGEOLOGY Regional Flow Brunner Island (specifically the DA8/closed Basin 5 area) is located on an island, with the Susquehanna River bordering the east side of the island and a small tributary (Black Gut Creek) bordering the west side of the island (see Figure 1). Topographic highlands exist to the west of 2-1

8 Brunner Island with associated groundwater moving from the highland recharge zone to the east and discharging into the Susquehanna River (regionally) and Black Gut Creek (locally). Any westward groundwater movement from closed Basin 5 and DA8 is hydrogeologically prevented from reaching these topographic highlands. The regional flow characteristics result in an upward vertical groundwater gradient under the footprint of Brunner Island hindering the vertical migration of potential contaminants downward into the groundwater column. Figure 4 provides a schematic cross-section with the conceptual regional vertical groundwater movement associated with the closed Basin 5 area (and associated DA8) Groundwater Movement Basin 5 is closed; therefore, no plant discharge water is directed into closed Basin 5. However, plant discharge water is typically being discharged to Basin 6, which borders closed Basin 5 to the southeast. As a result, the groundwater mound caused by the active plant process water being directed into Basin 6 may have an impact on groundwater flow at closed Basin 5 and the associated DA8. Process water enters Basin 6 when the plant is fully operational. The water which discharges into Basin 6 creates a groundwater mound under Basin 6 with radial flow outward, including into the closed Basin 5 area. Figure 5 provides an average site groundwater elevation contour map for 2017, resulting under the closed Basin 5 (and DA8) with active discharge to Basin 6. This groundwater contour map was generated from the water level data collected during the June 2017 monitoring event. It is anticipated that in the near future, discharge of plant process water onto Basin 6 will cease and the groundwater mound will diminish in both closed Basin 5 and Basin 6. Therefore, groundwater flow conditions in the DA8/closed Basin 5 area may change. Figure 6 provides a groundwater elevation contour map which serves to predict the anticipated future groundwater elevation contours, based on historic water level measurements collected prior to the construction of the closed Basin 5 as documented in the 1984 PPL Drawing No. E This drawing represented the groundwater elevations at the time soil borings were advanced on the site prior to basin development and the contours shown are interpreted to represent past and future static water level conditions on the site. It should be noted that some minor river stage influence is observed 2-2

9 around the perimeter of closed Basin 5. Based on the anticipated future static conditions (i.e., no plant process water discharge to Basin 6), future groundwater elevations would stabilize within the ash material within closed Basin 5. Based on the current groundwater flow directions and the radial flow nature of the closed Basin 5 area, MW-8-3A and MW-8-12A are considered the upgradient monitoring points due to their location outside the potential impact area from contaminant migration from DA8. The average groundwater elevation is below the bottom of DA8. Although the groundwater elevation is within the ash material of closed Basin 5, it has no direct interaction with the material within DA Water-Bearing Zones The CCR rule requires monitoring of the upper-most aquifer under the CCR unit. As discussed above, closed Basin 5 is underlain by fractured bedrock. Outside the footprint of closed Basin 5, overburden material overlies the fractured bedrock. Piezometers installed and monitored proximate to closed Basin 5 were installed in both the overburden and the bedrock material. Based on water level data collected in these paired piezometers, it is evident that a slight upward vertical gradient exists typical of discharge zone hydraulics; a characteristic that would be expected in this area. Evaluation of this area suggests that the potentiometric surface observed in the overburden and bedrock wells are connected. Separate water-bearing zones do not exist. Based on published geologic data, it is apparent that the bottom of the aquifer can range from 100 to 400 feet below the ground surface where the fractures in the bedrock (secondary porosity) no longer transmit groundwater. Based on site-specific data collected from the area, the hydraulic conductivity of the bedrock zone is generally transitional with depth with approximate upper, middle, and deep values of 0.24, 7.54, and 0.91 feet per day, respectively. However, these values are not consistent over the entire Brunner Island area. Low hydraulic conductivity in the upper portion of the bedrock has been suggested within geologic publications to be the result of silt and 2-3

10 clay filling of the shallow rock fractures, which reduces hydraulic conductivity. Clay-filled fractures in the bedrock were generally not observed on the site. 2.3 CCR RULE MONITORING WELL NETWORK OVERVIEW As previously discussed, DA8 is built entirely within the footprint of closed Basin 5 (as an overfill landfill) as shown on Figures 1, 2, and 3, making the placement and sampling of wells within closed Basin 5 ash, for the purpose of water quality monitoring for DA8, problematic. The presence of the closed Basin 5 CCR material underneath and surrounding DA8 precludes the installation of wells at the DA8 boundary for a groundwater detection monitoring system. Therefore, the overfill design of the DA8 CCR landfill is a special situation which requires professional judgment to be utilized to meet the goal of developing a detection monitoring program. Wells MW-8-3A and MW-8-12A were selected as upgradient wells, since they are close to DA8 and likely to have less influence from the adjacent Basin 6 than other existing monitoring points closer to Basin 6 under current groundwater flow conditions (See Figure 5). The general downgradient wells selected are MW-8-4, MW-8-5A, MW-8-9A, and MW-8-11A. Table 1 provides the construction of these wells, and Figure 2 provides the well locations. The hydrogeologic conditions and rationale for the placement of these wells was described in the Groundwater Monitoring System Plan (Advanced GeoServices, 2017a). 2.4 GROUNDWATER LEVEL MEASUREMENT Groundwater level measurements were collected at the beginning of each groundwater sampling event. These measurements were performed by use of an electronic depth-to-water meter and measured to the nearest 0.01 feet from the indicated survey mark at the top (and the north side) of each inner PVC well casing for those wells identified in Table 1. This process allows a depth measurement from the survey mark to the groundwater table to be converted to a groundwater surface elevation. 2-4

11 3.0 CCR GROUNDWATER MONITORING 40 C.F.R (f) defines the statistical analysis methods to determine whether a statistically significant increase (SSI) of any Appendix III parameter has occurred. 40 C.F.R (h) (1) further instructs that the SSI for each parameter at each well will statistically be compared to background (or baseline) data. The sampling events required to commence the SSI analysis were completed in A Certification defining the Statistical Method, Selection of Statistical Method Certification Groundwater Monitoring and Analysis Program for Disposal Area 8 (Advanced GeoServices, 2017b), for evaluating possible SSIs in concentrations of Appendix III groundwater constituents, was placed on the Talen CCR Rule publicly-accessible website for Brunner. 3.1 DATA COLLECTION FOR STATISTICAL ANALYSIS Groundwater samples were collected in accordance with Talen procedures for low-flow sampling. In addition to the CCR Rule Appendix III constituents mentioned above, groundwater depth, field ph, field Redox, field turbidity, total alkalinity, and iron were analyzed. For every 10 or fewer groundwater sampling points collected during a CCR Rule sampling event at Basin 6, a duplicate sample was collected. Matrix spike and matrix spike duplicates were included in analytical batches per specific test method requirements to assess matrix effects on laboratory precision and accuracy. The results of laboratory testing are provided as Table 2. From April 2016 to July 2017, eight rounds of groundwater samples were collected and analyzed for Appendix III and Appendix IV parameters to characterize baseline conditions. The parameters, or constituents, associated with each appendix are: Appendix III Parameters Boron Calcium Chloride Fluoride ph Sulfate Total Dissolved Solids (TDS) Antimony Arsenic Barium Beryllium Cadmium Chromium Cobalt 3-1 Appendix IV Parameters Fluoride Lead Lithium Mercury Molybdenum Selenium Thallium Radium 226 & 228

12 In September 2017, a ninth round of groundwater samples was collected as an initial detection monitoring event. Samples were analyzed for Appendix III parameters only. The September 2017 detection monitoring event was used for the initial statistical evaluation described in Section 3.2. The 2018 detection monitoring sampling events were conducted in February and August. 3.2 STATISTICAL ANALYSIS Method A Certification defining the Statistical Method, Selection of Statistical Method Certification Groundwater Monitoring and Analysis Program Disposal Area 8 Landfill (Advanced GeoServices, October 2017b), for evaluating possible SSIs in concentrations of Appendix III groundwater constituents, was placed in the Talen CCR Rule operating record and Brunner s CCR website. The Certification indicated that the expected statistical method to be used was Analysis of Variance (ANOVA). Since the time of the Certification, the Prediction Limit method was selected instead, based on further evaluation of the options listed in the Certification. The method flexibility is described in Section 2.2 of the Certification and the recommendations of the USEPA s Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities: Unified Guidance (USEPA, 2009). The appropriate form of Prediction Limits (parametric or non-parametric) for each constituent are based on the statistical properties of the data. If data for all wells have equal variances for a given constituent and the residuals for each well are normally distributed, a parametric Prediction Limit is utilized. If the data could not be transformed to meet those conditions, a non-parametric Prediction Limit is utilized. 3-2

13 3.2.2 Results During the 2018 reporting period, the detailed analysis (Advanced GeoServices, 2018a) was performed using the statistical spreadsheet for DA8, with the resulting SSIs identified are identified below: INITIAL SSIs Appendix III MW-8-5A MW-8-9A MW-8-11A MW-8-4 Parameters West (Creek) Side East (River) Side Boron Calcium Chloride Fluoride ph Sulfate Total Dissolved Solids (TDS) = SSI identified In general, Chloride appears to have SSIs across multiple wells associated with DA8. Calcium, Fluoride, Sulfate, field ph, and TDS SSIs were identified in other select wells at the Site. 3.3 ALTERNATE SOURCE DEMONSTRATION 40 CFR (e)(2) allows the owner or operator to demonstrate that a source other than the CCR unit caused the apparent SSI(s) or that the apparent SSI(s) resulted from errors in sampling, analysis, statistical evaluation, or natural variation in groundwater quality. This demonstration is designated an Alternate Source Demonstration (ASD). Considering DA8 s proximity atop closed Basin 5, Advanced GeoServices reviewed the DA8 landfill liner system and compared the quality of the water in the leachate detection and collection layers with the groundwater to discern whether there were dissimilarities (Advanced GeoServices, 2018c). If dissimilarities were present, then the DA8 leachate could not be the source of the SSI in the groundwater. This analysis was completed and reported in April

14 The following four groundwater quality points are supporting evidence that DA8 leachate is not migrating into closed Basin 5: 1. The following three types of water were evaluated: i. Leachate generated from the materials placed in the landfill, ii. Water found in the Leachate Detection Zone of the landfill (beneath the primary liner and above the secondary clay liner), and iii. Groundwater sampled from downgradient wells. Each has distinct characteristics. These characteristics can be used to differentiate these three types of water and understand their sources and the probable influences on the water (e.g., the materials the water has infiltrated through). A summary of several key differentiating water characteristics, which helps to understand these influences, is provided below: Parameter Unit KEY WATER CHARACTERISTICS SUMMARY (First Quarter 2016 to Third Quarter 2018) Leachate Collection Zone Discharge Average Concentration Leachate Detection Zone Discharge Average Concentration * Downgradient Groundwater Average Well Concentration ph S.U Alkalinity Eq/L Chloride Sulfate Arsenic µg/l Cobalt µg/l * Some samples were diluted for analysis. When laboratories dilute samples, detection limits increase; however, the reported values typically remain representative and within the order of magnitude of the constituent detected. The collected leachate generated from the materials placed in DA8 has a distinct and consistent fingerprint which includes a relatively low ph (averaging 3.21), low Alkalinity (averaging 0.75 equivalents per liter (Eq/L)), elevated Sulfates (averaging milligrams per liter ()), and relatively low Arsenic (averaging 5.79 micrograms per liter (µg/l)) over the monitoring period. This water (leachate) is quite different from the water found in either the underlying 3-4

15 DA8 Leachate Detection Zone or the groundwater sampled from wells along the perimeter of DA8, as shown on Table A, above. 2. Further observations made regarding groundwater characteristics, include the following: The average Leachate Detection Zone water ph of 6.99 is similar to the average downgradient monitoring well ph of The average Leachate Detection Zone water Alkalinity of units is similar to the downgradient average downgradient Alkalinity of units. These characteristics suggest the water in the Leachate Detection Zone and the downgradient groundwater may have been exposed to similar materials. The contrast in the ph and Alkalinity characteristics of the Leachate Detection Zone water and downgradient groundwater, compared to the leachate provides a strong line of evidence that a release of the leachate from DA8 is not the source of the elevated concentrations of these characteristics in the downgradient groundwater. 3. The low concentration of Arsenic in the leachate and the Leachate Detection Zone water, compared to the elevated concentrations in the downgradient groundwater, provides a strong line of evidence that a release from DA8 is not the source of the elevated Arsenic concentrations found in the Leachate Detection Zone water or the downgradient groundwater. This means that an Alternate Source of CCR compounds is likely present. In summary, if the Arsenic is not present in the leachate, it is not likely that it would be released from DA8. 4. Cobalt is found in the leachate from DA8 at an average concentration of µg/l. However, it is only found in the Leachate Detection Zone water at a relatively lower average concentration of µg/l, and it is found in the downgradient plume at a concentration of µg/l. If there was a release of leachate from DA8, the concentration of Cobalt found in the leachate would be expected to be similar to the concentration found in Leachate Detection Zone, with a diluted downgradient plume. The lack of this expected pattern of similar elevated concentrations in the leachate, Leachate Detection Zone water, and a diffuse downgradient 3-5

16 plume is not observed. This is a line of evidence that the DA8 landfill materials, and leachate generated from them is not the source of Cobalt within the downgradient groundwater and an Alternate Source of the CCR compound Cobalt exists in the DA8 vicinity. Based on the data (evidence) discussed above (Advanced GeoServices, 2018c), it is Advanced GeoServices opinion that DA8 is not the source of the SSIs identified in downgradient monitoring wells. Therefore, assessment monitoring is not warranted and Disposal Area 8 should remain in detection monitoring. Further, no new monitoring wells were required. The existing groundwater monitoring network was, and continues to be, maintained for continued monitoring. Closed Basin 5 quarterly groundwater monitoring and associated activities are being overseen by the PADEP Residual Waste Program. 3-6

17 4.0 ONGOING DETECTION MONITORING Based on the ASD described in Section 3.3, DA8 remained in detection monitoring through In compliance with 40 CFR257.94(b) of the CCR Rule, semi-annual groundwater detection sampling events were performed in 2018, in February and August. After receiving these analytical results, Advanced GeoServices re-evaluated the dataset to determine whether the data continues to show SSIs, and whether the SSIs show any change (Advanced GeoServices, 2018d & 2018e). Advanced GeoServices compared results from 2018 semi-annual groundwater detection sampling events with the initial SSIs, to determine whether SSIs were identified at new well locations or for constituents not previously identified as having SSIs. For both sampling events in 2018, the SSIs were consistent with the initial SSI evaluation (of the September 2017 detection monitoring sampling event). For thoroughness, the SSIs were then compared again to the ASD to confirm that the ASD remains valid. The conclusions of the ASD revisit for the 2018 sampling events were described in Section 3.3. Since the data and SSI evaluation for the 2018 groundwater detection monitoring events are statistically comparable with the September 2017 initial groundwater detection monitoring event, there is sufficient evidence to demonstrate that there is a continued Alternate Source (as described in the April 13, 2018 Alternate Source Demonstration) for the SSIs of Appendix III constituents measured in the groundwater downgradient of DA8. Based on the foregoing, assessment monitoring is still not warranted and DA8 should remain in detection monitoring. 4-1

18 5.0 CORRECTIVE ACTIONS Further actions, if and as needed, regarding assessment and/or corrective action, will be described in future CCR-rule required documents. Area 8 remained in Detection Monitoring throughout

19 6.0 ANTICIPATED UPCOMING ACTIVITIES During the 2019 calendar year, the following activities are anticipated to occur relative to implementation of groundwater-related requirements of the CCR Rule: Continue semi-annual groundwater detection monitoring and testing. Continue to assess the groundwater monitoring data for SSIs and consistency with the previous SSI evaluation and ASD. Other actions may also be completed, if/as necessary, in accordance with the CCR regulations, depending on the results of the above analyses. 6-1

20 7.0 CERTIFICATION CCR Landfill Information Name: Disposal Area 8 Operator: Brunner Island, LLC Address: 1400 Wago Road, York Haven, PA Qualified Professional Engineer: Name: Christopher T. Reitman, P.E. Company: Advanced GeoServices Corp. I, Christopher Reitman, certify that this Second Annual Groundwater Monitoring and Corrective Measures Report for 2018 for Disposal Area 8 has been compiled to meet the requirements of the Coal Combustion Residual (CCR) rule 40 CFR (e). I am a duly licensed Professional Engineer under the laws of the Commonwealth of Pennsylvania. Print Name: Christopher T. Reitman Signature: Date: January 31, 2019 License Number: P.E My license renewal date is September 30, 2019 Qualified Professional Geologist: Name: Val F. Britton Company: V.F. Britton Group, LLC I, Val F. Britton, certify that this Second Annual Groundwater Monitoring and Corrective Measures Report for 2018 for Disposal Area 8 has been compiled to meet the requirements of the Coal Combustion Residual (CCR) rule 40 CFR (e). I am a duly licensed Professional Geologist under the laws of the Commonwealth of Pennsylvania. Print Name: Val F. Britton Signature: Date: January 31, 2019 License Number: P.G My license renewal date is September 30, 2019 G:\Projects\2015\ Brunner Detection Monitoring Systems\Work Documents\GW_Annual GWMCA Report\DA8\2019-For 2018\WIP\WIP_DA8_2nd Annual GWMCA ReportI_ docx 7-1

21 8.0 REFERENCES Advanced GeoServices Corp. (Advanced GeoServices, 2017a). Groundwater Monitoring System Plan, October, Advanced GeoServices Corp. (Advanced GeoServices, 2017b). Selection of Statistical Method Certification Groundwater Monitoring and Analysis Program for Disposal Area 8, October, Advanced GeoServices Corp. (Advanced GeoServices, 2018a). Groundwater Detection Monitoring Statistical Analysis for Disposal Area 8, January 15, Advanced GeoServices Corp. (Advanced GeoServices, 2018b). Initial Annual Groundwater Monitoring and Corrective Action Report for 2017, January 31, Advanced GeoServices Corp. (Advanced GeoServices, 2018c). Alternate Source Demonstration Disposal Area 8, April 13, Advanced GeoServices Corp. (Advanced GeoServices, 2018d). Groundwater Detection Monitoring February 2018, Statistical Analysis & Supplemental Alternate Source Demonstration, Disposal Area 8, June 14, Advanced GeoServices Corp. (Advanced GeoServices, 2018e). Groundwater Detection Monitoring August 2018, Statistical Analysis & Supplemental Alternate Source Demonstration, Disposal Area 8, January Pennsylvania Power & Light Company (PP&L, 1984), Drawing showing E showing 1984 Static Groundwater Elevation Map. United States Environmental Protection Agency (USEPA, 2009). Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities: Unified Guidance,

22 TABLES

23 January 2019 TABLE 1 MONITORING WELL CONSTRUCTION OVERVIEW Disposal Area 8, Brunner Island Steam Electric Station East Manchester Township York County, PA AGC Project No.: Project No Well NORTHING PA SOUTH NAD83 EASTING NAD83 PA SOUTH TOIC Elevation (Ft. MSL) NAVD88 Diameter (Inch) Total Depth (Ft. BGS) Screen Interval (Ft. BGS) Material Screened CCR Monitoring Role MW ' ' ' Bedrock Upgradient MW ' ' ' Alluvium & Bedrock Downgradient MW-8-5A ' ' ' Bedrock Downgradient MW-8-9A ' ' ' Bedrock Downgradient MW-8-11A ' ' ' Bedrock Downgradient MW-8-12A ' ' ' Bedrock Upgradient Note: Northings, Eastings, and TOIC developed by Kimball Surveying based on field date developed June 5-7 and July 18, 2017 for V.F.Britton G:\Projects\2015\ Brunner Detection Monitoring Systems\Work Documents\GW_2017 Annual GWMCA Report\DA8\2019\WIP\Tables\Table 1_Area 8_Well Data 1 of 1

24 January 2019 TABLE 2 GROUNDWATER SAMPLING RESULTS DISPOSAL AREA 8, BRUNNER ISLAND STEAM ELECTRIC STATION EAST MANCHESTER TOWNSHIP, YORK COUNTY, PA Project Background Down-gradient Sample Location MW-8-3A MW-8-12A MW-8-4 MW-8-5A MW-8-9A MW-8-11A Sample Name BR 8-3A BR 8-12A BR 8-4 BR 8-5A BR 8-9A BR 8-11A Lab ID Date Sampled 4/26/ :44 4/26/2016 8:15 4/26/ :07 4/26/ :54 4/26/2016 8:33 4/26/2016 9:47 Matrix Groundwater Groundwater Groundwater Groundwater Groundwater Groundwater EVENT ID Area 8 Round 1 Area 8 Round 1 Area 8 Round 1 Area 8 Round 1 Area 8 Round 1 Area 8 Round 1 Parameters Units Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL Conventional Chloride Fluoride Lab ph S.U H H H H H H 1.68 Sulfate Total Dissolved Solids Metals, Total Boron, Total µg/l Calcium, Total Metals, Dissolved Boron, Dissolved µg/l Calcium, Dissolved Field Parameters ph field reading S.U Notes: H- Analyzed out of hold time S.U.- Standard Units Q = Qualifier - Miligrams per Liter J- Results value is estimated NC- Analyte not certified in NELAC Scope of Accreditation ug/l- Micrograms per Liter DL = Detection Limit Advanced GeoServices Corp Page 1 of 11

25 January 2019 TABLE 2 GROUNDWATER SAMPLING RESULTS DISPOSAL AREA 8, BRUNNER ISLAND STEAM ELECTRIC STATION EAST MANCHESTER TOWNSHIP, YORK COUNTY, PA Project Sample Location Sample Name Lab ID Date Sampled Matrix EVENT ID Parameters Conventional Chloride Fluoride Lab ph Sulfate Total Dissolved Solids Metals, Total Boron, Total Calcium, Total Metals, Dissolved Boron, Dissolved Calcium, Dissolved Field Parameters ph field reading Units S.U. µg/l µg/l S.U. Background Down-gradient MW-8-3A MW-8-12A MW-8-4 MW-8-5A MW-8-9A MW-8-11A BR 8-3A BR 8-12A BR 8-4 BR 8-5A BR 8-9A BR 8-11A /13/2016 8:25 6/16/ :25 6/14/2016 8:01 6/14/2016 9:24 6/16/ :53 6/16/2016 8:26 Groundwater Groundwater Groundwater Groundwater Groundwater Groundwater Area 8 Round 2 Area 8 Round 2 Area 8 Round 2 Area 8 Round 2 Area 8 Round 2 Area 8 Round 2 Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL H H H H H H Notes: H- Analyzed out of hold time - Miligrams per Liter ug/l- Micrograms per Liter S.U.- Standard Units Q = Qualifier J- Results value is estimated NC- Analyte not certified in NELAC Scope of Accreditation DL = Detection Limit Advanced GeoServices Corp Page 2 of 11

26 January 2019 TABLE 2 GROUNDWATER SAMPLING RESULTS DISPOSAL AREA 8, BRUNNER ISLAND STEAM ELECTRIC STATION EAST MANCHESTER TOWNSHIP, YORK COUNTY, PA Project Sample Location Sample Name Lab ID Date Sampled Matrix EVENT ID Parameters Conventional Chloride Fluoride Lab ph Sulfate Total Dissolved Solids Metals, Total Boron, Total Calcium, Total Metals, Dissolved Boron, Dissolved Calcium, Dissolved Field Parameters ph field reading Units S.U. µg/l µg/l S.U. Background Down-gradient MW-8-3A MW-8-12A MW-8-4 MW-8-5A MW-8-9A MW-8-11A BR 8-3A BR 8-12A BR 8-4 BR 8-5A BR 8-9A BR 8-11A /19/2016 8:56 9/22/2016 9:36 9/22/2016 9:02 9/20/2016 8:00 9/22/ :03 9/22/2016 8:04 Groundwater Groundwater Groundwater Groundwater Groundwater Groundwater Area 8 Round 3 Area 8 Round 3 Area 8 Round 3 Area 8 Round 3 Area 8 Round 3 Area 8 Round 3 Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL U U U U H H H H H H Notes: H- Analyzed out of hold time - Miligrams per Liter ug/l- Micrograms per Liter S.U.- Standard Units Q = Qualifier J- Results value is estimated NC- Analyte not certified in NELAC Scope of Accreditation DL = Detection Limit Advanced GeoServices Corp Page 3 of 11

27 January 2019 TABLE 2 GROUNDWATER SAMPLING RESULTS DISPOSAL AREA 8, BRUNNER ISLAND STEAM ELECTRIC STATION EAST MANCHESTER TOWNSHIP, YORK COUNTY, PA Project Sample Location Sample Name Lab ID Date Sampled Matrix EVENT ID Parameters Conventional Chloride Fluoride Lab ph Sulfate Total Dissolved Solids Metals, Total Boron, Total Calcium, Total Metals, Dissolved Boron, Dissolved Calcium, Dissolved Field Parameters ph field reading Units S.U. µg/l µg/l S.U. Background Down-gradient MW-8-3A MW-8-12A MW-8-4 MW-8-5A MW-8-9A MW-8-11A BR 8-3A BR 8-12A BR 8-4 BR 8-5A BR 8-9A BR 8-11A /12/2016 9:27 12/14/ :56 12/14/2016 8:39 12/13/2016 8:02 12/14/2016 9:24 12/14/ :05 Groundwater Groundwater Groundwater Groundwater Groundwater Groundwater Area 8 Round 4 Area 8 Round 4 Area 8 Round 4 Area 8 Round 4 Area 8 Round 4 Area 8 Round 4 Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL H H H H H H R Notes: H- Analyzed out of hold time - Miligrams per Liter ug/l- Micrograms per Liter S.U.- Standard Units Q = Qualifier J- Results value is estimated NC- Analyte not certified in NELAC Scope of Accreditation DL = Detection Limit Advanced GeoServices Corp Page 4 of 11

28 January 2019 TABLE 2 GROUNDWATER SAMPLING RESULTS DISPOSAL AREA 8, BRUNNER ISLAND STEAM ELECTRIC STATION EAST MANCHESTER TOWNSHIP, YORK COUNTY, PA Project Sample Location Sample Name Lab ID Date Sampled Matrix EVENT ID Parameters Conventional Chloride Fluoride Lab ph Sulfate Total Dissolved Solids Metals, Total Boron, Total Calcium, Total Metals, Dissolved Boron, Dissolved Calcium, Dissolved Field Parameters ph field reading Units S.U. µg/l µg/l S.U. Background Down-gradient MW-8-3A MW-8-12A MW-8-4 MW-8-5A MW-8-9A MW-8-11A BR 8-3A BR 8-12A BR 8-4 BR 8-5A BR 8-9A BR 8-11A /7/ :22 3/9/2017 8:09 3/8/2017 8:24 3/7/2017 7:30 3/9/ :04 3/9/2017 8:04 Groundwater Groundwater Groundwater Groundwater Groundwater Groundwater Area 8 Round 5 Area 8 Round 5 Area 8 Round 5 Area 8 Round 5 Area 8 Round 5 Area 8 Round 5 Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL J H H H H H H X Notes: H- Analyzed out of hold time - Miligrams per Liter ug/l- Micrograms per Liter S.U.- Standard Units Q = Qualifier J- Results value is estimated NC- Analyte not certified in NELAC Scope of Accreditation DL = Detection Limit Advanced GeoServices Corp Page 5 of 11

29 January 2019 TABLE 2 GROUNDWATER SAMPLING RESULTS DISPOSAL AREA 8, BRUNNER ISLAND STEAM ELECTRIC STATION EAST MANCHESTER TOWNSHIP, YORK COUNTY, PA Project Sample Location Sample Name Lab ID Date Sampled Matrix EVENT ID Parameters Conventional Chloride Fluoride Lab ph Sulfate Total Dissolved Solids Metals, Total Boron, Total Calcium, Total Metals, Dissolved Boron, Dissolved Calcium, Dissolved Field Parameters ph field reading Units S.U. µg/l µg/l S.U. Background Down-gradient MW-8-3A MW-8-12A MW-8-4 MW-8-5A MW-8-9A MW-8-11A BR 8-3A BR 8-12A BR 8-4 BR 8-5A BR 8-9A BR 8-11A /24/ :37 4/26/ :39 4/24/ :42 4/25/2017 7:22 4/26/2017 9:08 4/26/ :51 Groundwater Groundwater Groundwater Groundwater Groundwater Groundwater Area 8 Round 6 Area 8 Round 6 Area 8 Round 6 Area 8 Round 6 Area 8 Round 6 Area 8 Round 6 Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL H H H H H H Notes: H- Analyzed out of hold time - Miligrams per Liter ug/l- Micrograms per Liter S.U.- Standard Units Q = Qualifier J- Results value is estimated NC- Analyte not certified in NELAC Scope of Accreditation DL = Detection Limit Advanced GeoServices Corp Page 6 of 11

30 January 2019 TABLE 2 GROUNDWATER SAMPLING RESULTS DISPOSAL AREA 8, BRUNNER ISLAND STEAM ELECTRIC STATION EAST MANCHESTER TOWNSHIP, YORK COUNTY, PA Project Sample Location Sample Name Lab ID Date Sampled Matrix EVENT ID Parameters Conventional Chloride Fluoride Lab ph Sulfate Total Dissolved Solids Metals, Total Boron, Total Calcium, Total Metals, Dissolved Boron, Dissolved Calcium, Dissolved Field Parameters ph field reading Units S.U. µg/l µg/l S.U. Background Down-gradient MW-8-3A MW-8-12A MW-8-4 MW-8-5A MW-8-9A MW-8-11A BR 8-3A BR 8-12A BR 8-4 BR 8-5A BR 8-9A BR 8-11A /6/2017 9:54 6/5/ :18 6/6/ :16 6/13/2017 7:28 6/5/ :00 6/5/ :01 Groundwater Groundwater Groundwater Groundwater Groundwater Groundwater Area 8 Round 7 Area 8 Round 7 Area 8 Round 7 Area 8 Round 7 Area 8 Round 7 Area 8 Round 7 Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL J H H H H H H Notes: H- Analyzed out of hold time - Miligrams per Liter ug/l- Micrograms per Liter S.U.- Standard Units Q = Qualifier J- Results value is estimated NC- Analyte not certified in NELAC Scope of Accreditation DL = Detection Limit Advanced GeoServices Corp Page 7 of 11

31 January 2019 TABLE 2 GROUNDWATER SAMPLING RESULTS DISPOSAL AREA 8, BRUNNER ISLAND STEAM ELECTRIC STATION EAST MANCHESTER TOWNSHIP, YORK COUNTY, PA Project Sample Location Sample Name Lab ID Date Sampled Matrix EVENT ID Parameters Conventional Chloride Fluoride Lab ph Sulfate Total Dissolved Solids Metals, Total Boron, Total Calcium, Total Metals, Dissolved Boron, Dissolved Calcium, Dissolved Field Parameters ph field reading Units S.U. µg/l µg/l S.U. Background Down-gradient MW-8-3A MW-8-12A MW-8-4 MW-8-5A MW-8-9A MW-8-11A BR 8-3A BR 8-12A BR 8-4 BR 8-5A BR 8-9 BR 8-11A /27/ :29 7/25/ :56 7/27/ :10 7/25/2017 7:32 7/25/2017 8:28 7/25/ :39 Groundwater Groundwater Groundwater Groundwater Groundwater Groundwater Area 8 Round 8 Area 8 Round 8 Area 8 Round 8 Area 8 Round 8 Area 8 Round 8 Area 8 Round 8 Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL H H H H H H Notes: H- Analyzed out of hold time - Miligrams per Liter ug/l- Micrograms per Liter S.U.- Standard Units Q = Qualifier J- Results value is estimated NC- Analyte not certified in NELAC Scope of Accreditation DL = Detection Limit Advanced GeoServices Corp Page 8 of 11

32 January 2019 TABLE 2 GROUNDWATER SAMPLING RESULTS DISPOSAL AREA 8, BRUNNER ISLAND STEAM ELECTRIC STATION EAST MANCHESTER TOWNSHIP, YORK COUNTY, PA Project Sample Location Sample Name Lab ID Date Sampled Matrix EVENT ID Parameters Conventional Chloride Fluoride Lab ph Sulfate Total Dissolved Solids Metals, Total Boron, Total Calcium, Total Metals, Dissolved Boron, Dissolved Calcium, Dissolved Field Parameters ph field reading Units S.U. µg/l µg/l S.U. Background Down-gradient MW-8-3A MW-8-12A MW-8-4 MW-8-5A MW-8-9A MW-8-11A BR 8-3A BR 8-12A BR 8-4 BR 8-5A BR 8-10 BR 8-11A /11/ /19/2017 9:30 9/20/2017 0:00 9/12/2017 0:00 9/19/2017 0:00 9/19/2017 8:34 Groundwater Groundwater Groundwater Groundwater Groundwater Groundwater Area 8 Round 9 Area 8 Round 9 Area 8 Round 9 Area 8 Round 9 Area 8 Round 9 Area 8 Round 9 Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL P P H H H, P H H H P P P P P P NC 4.96 P NC Notes: H- Analyzed out of hold time - Miligrams per Liter ug/l- Micrograms per Liter S.U.- Standard Units Q = Qualifier J- Results value is estimated NC- Analyte not certified in NELAC Scope of Accreditation DL = Detection Limit Advanced GeoServices Corp Page 9 of 11

33 January 2019 TABLE 2 GROUNDWATER SAMPLING RESULTS DISPOSAL AREA 8, BRUNNER ISLAND STEAM ELECTRIC STATION EAST MANCHESTER TOWNSHIP, YORK COUNTY, PA Project Sample Location Sample Name Lab ID Date Sampled Matrix EVENT ID Parameters Conventional Chloride Fluoride Lab ph Sulfate Total Dissolved Solids Metals, Total Boron, Total Calcium, Total Metals, Dissolved Boron, Dissolved Calcium, Dissolved Field Parameters ph field reading Units S.U. µg/l µg/l S.U. Background Down-gradient MW-8-3A MW-8-12A MW-8-4 MW-8-5A MW-8-9A MW-8-11A BR 8-3A BR 8-12A BR 8-4 BR 8-5A BR 8-9A BR 8-11A /12/ :35 2/19/ :25 2/12/2018 8:15 2/13/2018 7:57 2/12/ :00 2/19/2018 8:56 Groundwater Groundwater Groundwater Groundwater Groundwater Groundwater Area 8 Round 10 Area 8 Round 10 Area 8 Round 10 Area 8 Round 10 Area 8 Round 10 Area 8 Round 10 Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL H H H H H H NC 7.06 NC 5.09 NC 6.88 NC 7.22 NC 7.41 NC Notes: H- Analyzed out of hold time - Miligrams per Liter ug/l- Micrograms per Liter S.U.- Standard Units Q = Qualifier J- Results value is estimated NC- Analyte not certified in NELAC Scope of Accreditation DL = Detection Limit Advanced GeoServices Corp Page 10 of 11

34 January 2019 TABLE 2 GROUNDWATER SAMPLING RESULTS DISPOSAL AREA 8, BRUNNER ISLAND STEAM ELECTRIC STATION EAST MANCHESTER TOWNSHIP, YORK COUNTY, PA Project Sample Location Sample Name Lab ID Date Sampled Matrix EVENT ID Parameters Conventional Chloride Fluoride Lab ph Sulfate Total Dissolved Solids Metals, Total Boron, Total Calcium, Total Metals, Dissolved Boron, Dissolved Calcium, Dissolved Field Parameters ph field reading Units S.U. µg/l µg/l S.U. Background Down-gradient MW-8-3A MW-8-12A MW-8-4 MW-8-5A MW-8-9A MW-8-11A BR 8-3A BR 8-12A BR 8-4 BR 8-5A BR 8-9A BR 8-11A /22/ :08 8/19/ :32 8/23/ :21 8/15/2018 7:36 8/19/ :48 8/19/2018 8:58 Groundwater Groundwater Groundwater Groundwater Groundwater Groundwater Area 8 Round 11 Area 8 Round 11 Area 8 Round 11 Area 8 Round 11 Area 8 Round 11 Area 8 Round 11 Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL Result Q DL H H H H H H NC 7.25 NC 5.51 NC 6.85 NC 7.44 NC 7.58 NC Notes: H- Analyzed out of hold time - Miligrams per Liter ug/l- Micrograms per Liter S.U.- Standard Units Q = Qualifier J- Results value is estimated NC- Analyte not certified in NELAC Scope of Accreditation DL = Detection Limit Advanced GeoServices Corp Page 11 of 11

35 FIGURES

36 Engineering for the Environment. Planning for People. TM F:\Projects\2015\ Brunner Detection Monitoring Systems\Cad\Drawings\Disposal Area 8 Updated Figures.dwg

37 F:\Projects\2015\ Brunner Detection Monitoring Systems\Cad\Drawings\Disposal Area 8 Updated Figures.dwg A Engineering for the Environment. Planning for People. TM

38 F:\Projects\2015\ Brunner Detection Monitoring Systems\Cad\Drawings\Disposal Area 8 Updated Figures.dwg Engineering for the Environment. Planning for People. TM 1/04/2019

39 F:\Projects\2015\ Brunner Detection Monitoring Systems\Cad\Drawings\Disposal Area 8 Updated Figures.dwg Engineering for the Environment. Planning for People. TM

40 Engineering for the Environment. Planning for People. F:\Projects\2015\ Brunner Detection Monitoring Systems\Cad\Drawings\Disposal Area 8 Updated Figures.dwg 5 TM