Annual Groundwater Monitoring and Corrective Action Report Year Ending December 31, 2017

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1 City Water, Light & Power Coal Combustion Residuals Surface Impoundments Annual Groundwater Monitoring and Corrective Action Report Year Ending December 31, 2017 January 2018 Prepared for: City Water, Light & Power 201 E. Lake Shore Drive Springfield, Illinois Prepared by: 3300 Ginger Creek Drive Springfield, IL Tel:

2 TABLE OF CONTENTS 1. INTRODUCTION GROUNDWATER MONITORING PROGRAM CFR (e): KEY ACTIONS, PROBLEMS ENCOUNTERED, AND KEY ACTIVITIES FOR Key Actions Problems Encountered Key Activities for Upcoming Year (2018) CFR (e)(1) (5) CONCLUSION... 3 FIGURES FIGURE 1: FIGURE 2: SITE LOCATION GROUNDWATER MONITORING SYSTEM TABLES TABLE 1: NOVEMBER 2017 DETECTION MONITORING RESULTS Andrews Engineering, Inc. i City Water, Light and Power

3 1. INTRODUCTION In accordance with 40 CFR (e), provided herein is the Annual Groundwater Monitoring and Corrective Action Report for year ending December 31, Given the regulatory timelines, this is the first annual report required for groundwater monitoring and corrective action. City Water, Light and Power (CWLP) owns and operates two (2) existing coal combustion residual (CCR) surface impoundments. The CWLP CCR surface impoundments are located north and east of the former Lakeside Power Generating Station and Dallman Power Generating Station in the Eastern ½ of Section 12, Township 15 North, Range 5 West, in Springfield, Illinois (see Figure 1). These CCR surface impoundments are identified as the Lakeside Ash Pond and the Dallman Ash Pond (see Figure 2). The former Lakeside Power Generating Station and Dallman Power Generating Station are situated on the northwestern bank of Lake Springfield in Springfield, Illinois. The Lakeside Ash Pond is immediately south of Spaulding Dam at the northern end of Lake Springfield. The Dallman Ash Pond is immediately northwest of the Lakeside Ash Pond. Placed into service prior to 1958, the Lakeside Ash Pond is primarily a diked embankment. The Lakeside Ash Pond consists of four separate ponds (i.e., three lime softening ponds and a settling pond) totaling approximately 35.0 acres. The Lakeside Ash Pond ceased receiving ash in The Dallman Ash Pond was placed into service in approximately 1976 and is also a diked embankment. The Dallman Ash Pond is approximately 34.5 acres. Fly ash and bottom ash are sluiced to the Dallman Ash Pond with raw lake water. 2. GROUNDWATER MONITORING PROGRAM As required by 40 CFR (b), the facility developed a Groundwater Sampling and Analysis Program by October 17, 2017 and placed it in the facility operating record. The detection monitoring program was initiated with the first sampling event on November 9, The monitoring network includes two upgradient wells (wells AP-4 and AP-5) and four downgradient wells (AP-1, AP-2, AP-3, and AW-3). The well locations are depicted in Figure 2. Pursuant to 40 CFR (a), the Detection Monitoring Program includes, at a minimum, groundwater monitoring for all constituents listed in Appendix III to Part 257, including boron, calcium, chloride, fluoride, ph, sulfate, and total dissolved solids (TDS). The long-term monitoring frequency for the Appendix III constituents under 40 CFR (b) will be semiannual during the active life of the CCR unit and the post-closure period. Pursuant to 40 CFR (b), eight (8) independent samples were collected from each background and downgradient well and analyzed for the constituents listed in Appendix III to Part 257 including boron, calcium, chloride, fluoride, ph, sulfate, and total dissolved solids (TDS); and for the constituents listed in Appendix IV to Part 257 including antimony, arsenic, barium, beryllium, cadmium, chromium, cobalt, fluoride, lead, lithium, mercury, molybdenum, selenium, thallium, and radium 226 & 228 combined. The initial 8 independent sampling events were completed over the second quarter 2015 through first quarter 2017 (40 CFR (b)). This schedule allowed the capture of seasonal variability in quality and potentiometric surface conditions. Pursuant to 40 CFR (f)(3), a prediction interval procedure has been selected in order to evaluate any changes in groundwater during detection monitoring. Andrews Engineering, Inc. 1 City Water, Light and Power

4 The following sections of the report address the annual groundwater monitoring and corrective action report requirements outlined in 40 CFR (e) CFR (e): KEY ACTIONS, PROBLEMS ENCOUNTERED, AND KEY ACTIVITIES FOR Key Actions Key actions that occurred in 2017 include the initiation of the groundwater monitoring program and statistical analysis plan. Both plans were completed by October 17, 2017 and placed in the facility operating record. The first detection monitoring semiannual event was completed on November 9, Problems Encountered No problems were encountered with the groundwater monitoring program in Key Activities for Upcoming Year (2018) Based on exceedances of the statistical limits identified as part of the November semiannual sampling event, derivation and implementation of an Assessment Monitoring Program pursuant to 40 CFR is anticipated in the first half of Given that no further information is available at this time, no additional activities can be detailed CFR (e)(1) (5) Additional requirements for the Annual Groundwater Monitoring and Corrective Action Report are detailed in 40 CFR (e)(1)-(5). Each of the requirements is reproduced below along with the response. (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. A map of the key features required above is provided as Figure 2 to this annual report. (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. No new monitoring wells were installed during 2017 as part of the monitoring program. Additionally, no wells were decommissioned. (3) All data collected as part of the detection or assessment monitoring programs in Detection monitoring data collected from the initiation of the groundwater monitoring program on November 9, 2017 is provided in Table 1. Andrews Engineering, Inc. 2 City Water, Light and Power

5 (4) Discussion of any transition between monitoring programs including the dates of the transition and the identification of the constituent(s) that necessitated the initiation of assessment monitoring. Only one set of detection monitoring data has been collected to date. Therefore, there are no transitions between monitoring programs to discuss for (5) Other information required to be included in the annual report as specified in 40 CFR through a. Alternative monitoring frequency certification in accordance with 40 CFR (d)(3) and 40 CFR (c)(3). No alternative monitoring frequency has been requested at this time. Therefore; no certification is required at this time. b. Any alternate source demonstration completed in response to any statistically significant increases completed during the previous year in accordance with (e)(2) and 40 CFR (g)(3)(ii). No alternate source demonstrations were completed during c. Assessment of corrective measures completed during the previous year in accordance with 40 CFR (a). No assessment of corrective measures was completed during CONCLUSION This annual groundwater monitoring and corrective action report has been provided in accordance with 40 CFR (e). The annual report for monitoring year 2018 will be provided by January 31, Andrews Engineering, Inc. 3 City Water, Light and Power

6 FIGURES Andrews Engineering, Inc. City Water, Light and Power

7 SITE LOCATION ILLINOIS 2018 Microsoft Corporation 2018 DigitalGlobe CNES (2018) Distribution Airbus DS ANDREWS ENGINEERING, INC GINGER CREEK DRIVE SPRINGFIELD, ILLINOIS PH (217) FAX (217) PONTIAC, IL LOMBARD, IL INDIANAPOLIS, IN WARRENTON, MO PROFESSIONAL DESIGN ENGINEERING AND LAND SURVEYING FIRM #

8 ANDREWS ENGINEERING, INC GINGER CREEK DRIVE SPRINGFIELD, ILLINOIS PH (217) FAX (217) PONTIAC, IL LOMBARD, IL INDIANAPOLIS, IN WARRENTON, MO PROFESSIONAL DESIGN ENGINEERING AND LAND SURVEYING FIRM #

9 TABLE Andrews Engineering, Inc. City Water, Light and Power

10 TABLE 1 City Water, Light and Power - Coal Combustion Residual Surface Impoundments November 9, 2017 Detection Monitoring Results Well Parameter Units 11/9/2017 Appendix III AP-1 Boron, total mg/l 20.3 AP-2 Boron, total mg/l 3.16 AP-3 Boron, total mg/l 19.2 AP-4 Boron, total mg/l AP-5 Boron, total mg/l AW-3 Boron, total mg/l AP-1 Calcium, total mg/l 259 AP-2 Calcium, total mg/l 203 AP-3 Calcium, total mg/l 176 AP-4 Calcium, total mg/l 141 AP-5 Calcium, total mg/l 118 AW-3 Calcium, total mg/l 77.7 AP-1 Chloride, total mg/l 54.1 AP-2 Chloride, total mg/l 48.6 AP-3 Chloride, total mg/l 40.9 AP-4 Chloride, total mg/l 12.1 AP-5 Chloride, total mg/l < 30 AW-3 Chloride, total mg/l 26.2 AP-1 Fluoride, total mg/l < 0.5 AP-2 Fluoride, total mg/l < 0.5 AP-3 Fluoride, total mg/l < 0.5 AP-4 Fluoride, total mg/l < 0.5 AP-5 Fluoride, total mg/l < 0.5 AW-3 Fluoride, total mg/l 1.1 AP-1 ph (field) STD units 6.89 AP-2 ph (field) STD units 6.78 AP-3 ph (field) STD units 6.95 AP-4 ph (field) STD units 7.12 AP-5 ph (field) STD units 7.19 AW-3 ph (field) STD units 6.92 AP-1 Sulfate, total mg/l 664 AP-2 Sulfate, total mg/l 348 AP-3 Sulfate, total mg/l 319 AP-4 Sulfate, total mg/l < 5 AP-5 Sulfate, total mg/l 55.3 AW-3 Sulfate, total mg/l < 5 AP-1 Total Dissolved Solids mg/l 1420 AP-2 Total Dissolved Solids mg/l 966 AP-3 Total Dissolved Solids mg/l 848 AP-4 Total Dissolved Solids mg/l 544 AP-5 Total Dissolved Solids mg/l 470 AW-3 Total Dissolved Solids mg/l 424 Andrews Engineering, Inc. J:\S\Springfield CWLP\CWLP Ash Pond\DOC\2018\Annual GW and Corrective Action Report\Tables.xlsx Table 1