DTE Energy St. Clair Power Plant

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DTE Energy St. Clair Power Plant Unit 6 Scrubber Basins CCR Rule Compliance Project Annual Inspection Report - 2017 Project Number: 60546402 June 30, 2017 Prepared by: 27777 Franklin Road, Suite 2000 Southfield, MI 48034 Tel: 248-204-5900 Fax: 248-204-5901 http://www.aecom.com/

Table of Contents Table of Contents... i 1. Introduction... 1 1.1 Introduction... 1 1.2 Background Information... 1 1.3 Personnel... 1 2. Annual Inspection Results... 2 2.1 2017 Inspections... 2 3. Maintenance Activities in 2017... 3 3.1 Maintenance Activities... 3 4. Conclusion and Certification... 4 4.1 Conclusion... 4 4.2 Certification... 4 Appendices A. 2017 Annual Inspection Report i

1. Introduction 1.1 Introduction The 2017 Annual Inspection Report (AIR) was prepared by AECOM for the DTE Electric Company (DTE) to summarize the results of the annual inspection of the St. Clair Power Plant Unit 6 Scrubber Basins (Scrubber Basins). This annual inspection complies with the United States Environmental Protection Agency Coal Combustion Residual Rule (40 CFR 257.73). Under the CCR Rule, the Scrubber Basins is an existing surface impoundment and must be inspected by a qualified professional engineer on a periodic basis, not to exceed one year. 1.2 Background Information The St. Clair Power Plant is located in East China Township, St. Clair County, Michigan on the west bank of the St. Clair River. The plant was initially built in 1953. Unit 6 Scrubber basins were built in 1973 to handle FGD scrubber material generated as the scrubber cleaned the gases passing through the smokestacks. Filling of the basins ceased in the mid-1970 s. 1.3 Personnel The annual inspection was performed by Mr. Scott G. Hutsell, P.E., with assistance from DTE personnel. Weekly inspections have been and continue to be performed by DTE s plant personnel. 1

2. Annual Inspection Results 2.1 2017 Inspections DTE performed the following visual inspections in 2017: The annual inspection on June 28, 2017 (provided in Appendix A Weekly inspections during 2017 The annual and weekly inspections included the embankment crest, exterior slopes of the embankment, discharge structures, and discrete observations of the interior of the basins based on accessibility. In addition to the annual and weekly inspections, the general condition of the site and embankment was visually inspected by DTE on a daily basis. In general, no sign of vegetative distress or structural issues were observed during the annual inspection on the embankment crest, exterior slopes of the embankment and discharge structure. These structures appeared to be in good condition. Areas of concern are listed below; these conditions do not represent an immediate concern for the safe operation or stability of the Scrubber Basins. The Scrubber Basins are heavily vegetated and a thorough inspection of the entire surface area of the impoundment is not practical; DTE will be removing the overgrowth from the Scrubber Basins in late July and weekly inspections after that time should focus on areas that are more accessible 2

3. Maintenance Activities in 2017 3.1 Maintenance Activities DTE has been pumping down the accumulated surface water in the pond since late May 2017 in preparation for closure of the ponds beginning in September 2017. The current water level is less than 6 inches of water in the eastern basin and between 6 to 12 inches of water in the western basin. Standing water is only present in the southern third of each basin. 3

Appendix A

CCR Impoundment Inspection Report Page 1 of 5 Station/Owner St. Clair Unit 6 Scrubber Basins / DTE Energy Inspected By Scott G. Hutsell, P.E. Type of Impoundment: Gravity Embankment Arch Stone Masonry Buttress County, St. Clair Hazard Description The Unit 6 Scrubber Basins have not been used for active disposal of CCR materials in decades; the current impoundment is in good condition and holds surface water runoff. Remarks DTE has been pumping the basins down since late May in preparation of closure activities later this summer. Pool Level (ft) Approximately 1 ft of water is standing in the basin Date 07/01/2017 Type of Inspection Initial Periodic Follow up Condition Assessment Satisfactory Unsatisfactory Poor Not rated Fair Actions None Maintenance Monitoring Minor Repair Engineering Recommendations Inspection letter Deficiency letter EOR notice Engineering study Inspection by EOR Total Precipitation since last inspection n/a State Michigan Phone No. 517-505-1301 Weather Wet Dry Snow Cover Periodic reinspection UPSTREAM SLOPE/FACE 2. >2 dia. 3. Veg. height >6 4. High bushes 5. Animal Burrows 6. Livestock damage 7. Wave Erosion 8. Slides 9. Depressions 10. Bulges 11. Cracks 12. Spalling Problems 13. Scarps 14. Sloughing 15. Holes 16. Undermining 17. Displaced joints 18. Deteriorated joints 19. Exposed reinforcement 20. Veg. or sediment in rip rap 21. Displaced rip rap 22. Sparse rip rap 23. Erosion 24. COVER: Exterior of Scrubber Basins are overgrown with vegetation; very difficult to walk around and inspection was limited to established paths and areas of lesser undergrowth. No cracks or structural issues were noticed during the inspection. In limited areas trees and bushes with trunks greater than 2 occur. Some holes from animal burrows were noticed. The Scrubber Basins are scheduled for closure by removal in late summer of 2017. TOP OF DAM/CREST 7. Ruts 12. Cracks 17. Scarps 2. >2 dia. 8. Depressions 13. Deteriorated joints 18. Spalling 3. Veg. height >6 9. Unlevel 14. Displaced joints 19. Sinkholes 4. High bushes 10. Misalignment 15. Exposed reinforcement 20. Puddles 5. Animal Burrows 11. Signs of overtopping 16. Settlement 21. 6. Livestock damage COVER: Some areas of rip-rap from the original construction exist around the crest of the Scrubber Basins these areas are generally in good repair although some limited vegetation is present. The remainder of the crest is overgrown with dense vegetation; this includes the separation berm.

CCR Impoundment Inspection Report Page 2 of 5 COVER: DOWNSTREAM SLOPE/FACE 2. >2 dia.\ 3. Veg. height >6 4. High bushes 5. Poor grass cover 6. Animal Burrows 7. Livestock damage 8. Wetness 9. Seepage 10. Boils 11. Puddles 12. Erosion 13. Slope instability 14. Scarps 15. Sloughs/bulges 16. Depressions 17. Undercutting 18. Rutting/rills 19. Cracks 20. Scour 21. Spalling 22. Displaced joints 23. Deteriorated joints 24. Exposed reinforcement 25. Riprap needs attention 26. Veg. or sediment in rip rap 27. 28. Does standing water or seepage contain sediment? Yes No NA 29. Is there natural hillside seepage in in embankment area? Yes No NA Describe seepage with regard to quantity and clarity (turbidity). Note changes: None Some areas of rip-rap from the original construction exist on the interior slopes of the Scrubber Basins these areas are generally in good repair although some limited vegetation is present. TOE CONTACT COVER: 8. Wetness 15. Sloughs/bulges 22. Displaced joints 2. >2 dia. 9. Seepage 16. Depressions 23. Deteriorated joints 3. Veg. height >6 10. Boils 17. Undercutting 24. Exposed reinforcement 4. High bushes 11. Puddles 18. Rutting/rills 25. Riprap needs attention 5. Poor grass cover 12. Erosion 19. Cracks 26. Veg. or sediment in rip rap 6. Animal Burrows 13. Slope instability 20. Scour 27. 7. Livestock damage 14. Scarps 21. Spalling 28. Does standing water or seepage contain sediment? Yes No NA Describe seepage with regard to quantity and clarity (turbidity). Note changes: None ABUTMENT CONTACTS Toe is inaccessible to direct inspection due to heavy vegetation. Portions of the toe of slope that are visible from the south bank and other slopes look to be in good condition. COVER: 2. >2 dia. 3. Veg. height >6 4. High bushes 5. Poor grass cover 6. Animal Burrows 7. Livestock damage Not applicable 8. Wetness 9. Seepage 10. Boils 11. Puddles 12. Erosion 13. Slope instability 14. Scarps 15. Sloughs/bulges 16. Depressions 17. Undercutting 18. Rutting/rills 19. Cracks 20. Scour 21. Spalling 22. Displaced joints 23. Deteriorated joints 24. Exposed reinforcement 25. Riprap needs attention 26. Veg. or sediment in rip rap 27.

CCR Impoundment Inspection Report Page 3 of 5 PRINCIPAL SPILLWAY OBSERVATIONS No Spillway Is spillway control system operating properly? Yes No 2. Trashguard 3. Debris 4. Obstructed 5. Plugged/Clogged 6. Gates Damaged 7. Gates leaking 8. Gates Rusted Not Applicable 9. Misalignment 10. Joints leaking 11. Joint deterioration 12. Joint displacement 13. Conduit collapsed 14. Exposed reinforcement 15. Erosion 16. Undermining 17. Voids 18. Cracks 19. Holes 20. Spalling 21. Slides 22. Outlet undercutting 23. Sloughing 24. Scarps 25. Deteriorated lining 26. Boils 27. Outlet erosion 28. Displaced rip rap 29. Sparse rip rap 30. CHANNEL LINING EMERGENCY SPILLWAY OBSERVATIONS No emergency spillway 2. Debris in channel 3. Gates 4. Misalignment Not Applicable 5. Joint deterioration 6. Joint displacement 7. Exposed reinforcement 8. Erosion 9. Undermining 10. Voids 11. Cracks 12. Holes 13. Outlet erosion Same as primary spillway 14. Displaced rip rap 15. Sparse rip rap 16. Outlet undercutting 17.Inadequate capacity 18. CHANNEL LINING DRAINS/OUTLET STRUCTURE Observations 1. Is discharge system operating properly? Yes No N/A 2. Valves and operators in good condition? Yes No N/A 3. Walkway in good condition? Yes No N/A 4. Is there any turbidity observed at the outlet? Yes No N/A 5. Seepage at pipe outlet Yes No N/A 6. No Bottom Drain Yes No N/A 7. Bottom Drain Operable Yes No N/A 8. Subsurface Drain Dry Yes No N/A 9. Subsurface drain muddy flow Yes No N/A 10. Subsurface drain obstructed Yes No N/A 11. Animal guard Yes No N/A 12. other Yes No N/A DTE discharges from the basin on an as-needed basis; pumping has been going on in the basin since late May in preparation for closure activities later this summer.

CCR Impoundment Inspection Report Page 4 of 5 RESERVIOR/POOL OTHER OBSERVATION Has there been a sudden drop in the content level of the Impoundment Yes No 2. Inadequate freeboard 3. Skimmer 4. Depressions 5. Whirlpools 6. Sinkholes 7. Unwanted growth in pond water DTE discharges from the basin on an as-needed basis; pumping has been going on in the basin since late May in preparation for closure activities later this summer. OBSERVATIONS 1. leachate/stormwater (RCP; CMP) drain pipes that pass through or under an ash basin intact? Yes No N/A 2. Drainage/ diversion ditches/riprap-lined channels in good condition? Yes No N/A 3. steel structures/steel reinforcement in concrete structures in good condition? Yes No N/A 4. concrete structures in good condition? Yes No N/A 5. Overflow pipes and flap gates on filter dam/ drain pipe filter zone in good condition? Yes No N/A 6. Howell Bunger Valves in good condition? Yes No N/A 7. Weirs in good condition? Yes No N/A 8. Perimeter Fences and Gates in good condition? Yes No N/A 9. Security devices in good condition Yes No N/A 10. Signs in good condition Yes No N/A 11. Instrumentation in good condition Yes No N/A 12. Reference monuments/survey Monuments in good condition Yes No N/A 13. other Yes No N/A Fence surrounding the Scrubber Basins is old but generally in good repair access to the scrubber basins are through gates on the north and south ends. The gates remain open a majority of the time. Are there any other abnormal conditions at the Impoundment that could pose a risk to public health, safety or welfare; the environment or natural resources Yes No Inspector Signature Date: 07/01/17

CCR Impoundment Inspection Report Page 5 of 5 Photo 1: West Basin, picture taken from coal conveyor, 06/09/17 Photo 2: Headwall and East Basin, 06/09/17 Photo 3: East Basin, view from south, 06/16/17 Photo 4: West basin, view from north, 04/20/17