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2018 GROUNDWATER MONITORING AND CORRECTIVE ACTION REPORT

DISPOSAL AREA NO. 3

MONTOUR STEAM ELECTRIC STATION DERRY TOWNSHIP

MONTOUR COUNTY, PENNSYLVANIA

Prepared For:

MONTOUR, LLC WASHINGTONVILLE, PENNSYLVANIA

Prepared By:

CIVIL & ENVIRONMENTAL CONSULTANTS, INC. PITTSBURGH, PENNSYLVANIA

CEC Project 132-065.1203

JANUARY 31, 2019

-i- 2018 GWMCA Report, A3 January 2019

TABLE OF CONTENTS

1.0 INTRODUCTION..............................................................................................................1

2.0 SITE OVERVIEW .............................................................................................................2 2.1 Background ............................................................................................................. 2 2.2 Geologic Setting...................................................................................................... 2 2.3 Hydrogeologic Setting ............................................................................................ 3

2.3.1 Conceptual Model ........................................................................................3 2.3.2 Hydrogeologic Characteristics .....................................................................4

3.0 EXISTING MONITORING NETWORK .......................................................................5

4.0 2017 SAMPLING SUMMARY .........................................................................................6 4.1 Statistical Evaluation .............................................................................................. 6 4.2 Final UPL Values .................................................................................................... 7 4.3 Final 2017 SSI Determination ................................................................................ 7

5.0 ALTERNATE SOURCE DEMONSTRATION ..............................................................9

6.0 2018 GROUNDWATER SAMPLING AND FINDINGS SUMMARY.......................10 6.1 Detection Monitoring Sampling Events................................................................ 10 6.2 March 2018 Analytical Results ............................................................................. 11 6.3 September 2018 Analytical Results ...................................................................... 11

7.0 RECORD KEEPING REQUIREMENTS .....................................................................12

8.0 REFERENCES .................................................................................................................15

FIGURES Figure 1 – Site Location Map – Area 3 Figure 2 – CCR Rule Groundwater Sampling Locations – Area 3

TABLES

Table 1 – 2018 Downgradient Groundwater Results Table 2 – 2018 Upgradient Groundwater Results

APPENDIX

Appendix A – Area 3 Alternate Source Demonstration Appendix B – Area 3 Trend Plots

-1- 2018 GWMCA Report, A3 January 2019

1.0 INTRODUCTION

The United States Environmental Protection Agency (USEPA) issued 40 C.F.R. § 257, Subpart D,

Disposal of Coal Combustion Residuals from Electric Utilities (CCR Rule) on April 17, 2015. The

CCR Rule regulates disposal of coal combustion residuals (CCR) in new and active landfills and

impoundments. Civil & Environmental Consultants, Inc. (CEC) has been engaged by Montour,

LLC to complete the 2018 Groundwater Monitoring and Corrective Action Report at Disposal

Area 3 (Site) of the Montour Steam Electric Station (Montour) as required by 40 C.F.R. §257.90(e)

of the CCR Rule. This document summarizes the monitoring activity in 2018, including sampling

events and any changes to the network. It is intended that this document will be placed in the

facility operating record as required by 40 C.F.R. §257.105(h)(1), as well as posted on the publicly

accessible website as required by 40 C.F.R. §257.107(h)(1).


2.0 SITE OVERVIEW

2.1 BACKGROUND

Disposal Area No. 3 (Area 3), located south of the main generation station (Figure 1), is a residual

waste landfill constructed and operated under Residual Waste Permit #300987 issued by the

Pennsylvania Department of Environmental Protection. The landfill is used for the disposal of

plant-generated residual waste, including scrubber wastewater treatment plant sludge (sludge is a

mixture of calcium sulfate solids and precipitated heavy metals), fly ash, mill rejects, and various

sump sludges. The disposal area also receives resins, filter bags and construction and demolition

wastes. The existing disposal area was constructed beginning in September 1987 and completed

in March 1990.

Area 3 consists of a western half and an eastern half. Only the eastern half has been constructed to

date. It is unlikely that the western half will ever be constructed. The eastern half is constructed

with a geomembrane liner and leachate collection system. Leachate from the eastern half is drained

through a piping network above the liner that directs the leachate into a leachate collection basin

located southeast of Area 3. The leachate collection basin is also lined with a geomembrane liner

and covered with onsite low permeability silt-clay soils.

In addition to the monitoring requirements set forth by the CCR Rule, groundwater quality

continues to be monitored at Area 3 in accordance with the state residual waste permit. Monitoring

points associated with the permit include: underdrains, monitoring wells, and surface water

locations. Wells associated with the permit are sampled quarterly. Results are summarized in a

Form 14R quarterly report submitted to the state.

2.2 GEOLOGIC SETTING

The site is situated on the northern limb of a regional anticline. The shallowest bedrock formation

underlying Area 3 is the Devonian Age Marcellus Shale. The Marcellus Shale has an approximate

orientation of N45°W with a dip to the northeast of 5 to 8°. The competent shale bedrock is overlain


by weathered bedrock that ranges in thickness from less than 1 foot to 10 feet. The weathered

bedrock is overlain by glacial till material consisting of silt, clay, and broken rock fragments.

2.3 HYDROGEOLOGIC SETTING

2.3.1 Conceptual Model

Topographically, the site lies within a regional basin with the highland ridges consisting of the

more resistant rock formations of an anticline. There is potential for an upward hydraulic gradient

in the general area of the site. The water table is within 10 feet of the ground surface.

The water-bearing zone directly below the site is unconfined. The overburden and the bedrock

zones are hydraulically well connected. Groundwater monitoring wells in the area typically have

screen intervals that intercept both the overburden material and the underlying bedrock.

A small tributary of Mud Creek separates the two halves of Area 3. This southeastward-flowing

tributary is redirected into two subsurface 48-inch diameter pipe conduits installed within Area 3.

The flow enters piping on the northwestern side of Area 3 and exits the piping at the southeastern

side of Area 3 (Figure 2).

The groundwater underlying Area 3 is shallow (less than 10 feet below the ground surface) and

occurs within bedrock or at the bedrock/overburden interface. Groundwater underdrains were

installed under Area 3, below the geomembrane liner, to drain the groundwater during seasonal

high levels and maintain the state requirement for an 8-foot separation between the liner and

groundwater. The groundwater underdrains are separate from the 48-inch diameter conduits,

however both systems discharge into same area, southeast of Area 3 (see Figure 2). The general

groundwater flow direction is to the south.


2.3.2 Hydrogeologic Characteristics

Hydraulic gradients calculated from 2015 water levels range from 0.003 to 0.008, with an overall

average of 0.006. Hydraulic conductivity values for the site have been obtained from site specific

data collected as part of previous site evaluations. Hydraulic conductivities range between:

• 1.7xl0-6 cm/sec and 1.8xl0-8 cm/sec in soil,

• 2.2xl0-2 cm/sec to 5.0xl0-3 cm/sec in the upper weathered fractured shale,

• 3.0xl0-3 cm/sec to l.0xl0-4 cm/sec in fractured competent bedrock, and

• 1.7x10-6 cm/sec to 5.0xl0-7 cm/sec in competent shale with little to no fracturing.


3.0 EXISTING MONITORING NETWORK

The groundwater monitoring system consists of six wells screened within the uppermost aquifer

that accurately represent both background groundwater quality and the quality of groundwater

passing the waste boundary of the CCR unit. The well locations are shown on Figure 2. A more

in-depth discussion of the monitoring network as well as the geologic and hydrologic setting is

provided in the Groundwater Monitoring System Certification (CEC, 2017(2)), as placed in the

operating record and posted to the Talen CCR Rule website. No additional wells were installed or

decommissioned in 2018. The table below summarizes all wells that are included within the CCR

Rule Groundwater Monitoring System.

CCR RULE GROUNDWATER MONITORING SYSTEM

Location Relative Location

Well Diameter (in.)

Bottom of Screen (ft-

bgs)

Screen Length (ft)

PZ3-31 Downgradient 2 17.7 9.5 MW-3-100 Downgradient 4 15 10 MW-3-101 Downgradient 4 15 10 MW-3-102 Downgradient 4 17 10 MW-3-103 Upgradient 4 15 10 MW-3-104 Upgradient 4 14 10

Based on existing groundwater contours, locations MW-3-103 and MW-3-104 will provide

upgradient water quality for groundwater flowing toward Area 3. The remaining wells, PZ3-31,

MW-3-100, MW-3-101, and MW-3-102, provide downgradient groundwater quality.


4.0 2017 SAMPLING SUMMARY

The final four of the eight baseline sampling events were completed at Area 3 in 2017. The initial

detection monitoring sampling event then occurred in October 2017. The results from that

sampling event were provided in the 2017 Groundwater Monitoring and Corrective Action Report

(CEC, 2017(1)), however the determination of statistically significant increases (SSI) of

downgradient concentrations over background values was not finalized until January 15, 2018 and

therefore was not discussed in the 2017 report.

4.1 STATISTICAL EVALUATION

The baseline data was evaluated to determine the appropriate statistical method based on the data

statistical distribution. As was anticipated in the Detection Monitoring Statistical Methods

Certification (CEC, 2017(2)), Statistical Method 3 as described in §257.93(f) of the CCR Rule

was the final method chosen for Area 3. Method 3 is a tolerance or prediction interval procedure,

in which an interval for each constituent is established from the distribution of the baseline data,

and the level of each constituent in each compliance well during subsequent detection monitoring

events is compared to the upper tolerance limit (UTL) or upper prediction limit (UPL).

The background well data was first examined to determine if a straight comparison of background

to downgradient (interwell comparison) was appropriate. Preliminary evaluation of the

background data set indicated a lack of correlation between the water quality at the two background

locations (MW-3-100 and MW-3-101). In an attempt to further characterize regional background

water quality, regional background monitoring well MW-1-9 was included in the statistical

evaluation. The analysis of the combined background dataset (Area 3 and regional background

wells) utilized the USEPA-developed multi-variant evaluation technique, Fingerprint Analysis of

Leachate Contaminants (FALCON) (USEPA, 2014). FALCON uses fractional concentrations for

the Appendix III constituents to create a unique chemical fingerprint representative of water

quality at each location and then further create an average chemical fingerprint over time at each

location. The assessment showed a lack of correlation between the average fingerprints at the

background wells suggesting heterogeneity and supporting the use of an intrawell statistical


approach to monitor for evidence of a release from Area 3. The FALCON evaluation of the three

background wells is described in more detail in the Alternate Source Demonstration; Disposal

Area 3 (CEC, 2018), in Appendix A.

4.2 FINAL UPL VALUES

UPL values were calculated for each parameter at each location based on the initial eight baseline

samplings events to establish baseline values. The final values are as follows:

CCR RULE APPENDIX III BASELINE VALUES

Parameter Units UPL Value PZ-3-31 MW-3-100 MW-3-101 MW-3-102 MW-3-103 MW-3-104

Boron, Total mg/L 0.100 0.525 0.075 0.184 0.123 0.038 Calcium, Total mg/L 171 293 124 235 176 38.7 Chloride mg/L 10.9 9.5 7.6 12.7 18.00 3.62 Fluoride mg/L 0.57 0.29 0.22 0.60 0.25 0.50 pH, laboratory S.U. 7.29 8.29 8.21 8.26 8.00 6.70 pH, field S.U. 7.79 7.23 7.10 7.39 6.99 6.20 Sulfate mg/L 438.4 682.0 227.7 457.0 145.8 199.0 Total Dissolved Solids mg/L 788 1290 436 1030 561 419

4.3 FINAL 2017 SSI DETERMINATION

SSIs were determined based upon comparison of the results from the initial Detection Monitoring

event (October 2017) to the UPL of the mean concentration detected in each well from the eight

rounds of baseline monitoring (intrawell analysis). Based upon the results from the first round of

Detection Monitoring, one or more SSIs were identified at the following locations: PZ-3-31 and

MW-3-100 as summarized below.


SUMMARY OF OBSERVED SSIs AT AREA 3

OCTOBER 2017 DETECTION MONITORING EVENT

Appendix III Parameters

Monitoring Point Boron Calcium Chloride Fluoride pH Sulfate

Total Dissolved

Solids (TDS)

MW-3-100 X

MW-3-101

X

MW-3-102

PZ3-31

X – SSI Determined

The observed SSIs were suspected to be attributed to a source other than the Area 3 Landfill and

an Alternate Source Demonstration (CEC, 2018) was completed within 90 days of the SSI

determination in accordance with §257.94(e)(2).


5.0 ALTERNATE SOURCE DEMONSTRATION

The Alternate Source Demonstration identified multiple lines of evidence that an alternate source

of CCR constituents resulted in a determination of SSIs in groundwater obtained from wells

downgradient of Area 3 including:

• Statistical evaluation anomalies,

• Lack of correlation attributable to mixing from a theoretical release of leachate and the

chemistry of downgradient wells,

• Seasonal variability of boron where concentrations rise above the UPL for MW-3-100 in

the fall months, but remain below the UPL for the remainder of the year.

• Laboratory issues due to variability in determination of LOQ values used for non-detects

for boron resulting in potential false positives.

The SSIs at Area 3 were determined to not be attributed to a release from the landfill and Area 3

remained in Detection Monitoring for 2018. See Alternate Source Demonstration; Disposal Area

3 (CEC, 2018), in Appendix A for more information.


6.0 2018 GROUNDWATER SAMPLING AND FINDINGS SUMMARY

6.1 DETECTION MONITORING SAMPLING EVENTS

Semi-annual Detection Monitoring sampling events were performed between March 5 and 6, 2018

and September 14 and 20, 2018. All six locations were sampled and analyzed for Appendix III

parameters. Samples were collected per the Area 3 Groundwater Monitoring Program and

submitted to Hawk Mountain Laboratory, a National Environmental Laboratory Accreditation

Program (NELAP) accredited laboratory. The laboratory results were finalized on March 28, 2018

and October 9, 2018, respectively. Results for downgradient wells are provided in Table 1 and for

upgradient wells are provided in Table 2. The September sampling results at MW-3-102 for

calcium, sulfate, and total dissolved solids appeared abnormally high when compared to historical

concentrations. This is discussed further in Section 6.3, but MW-3-102 was resampled in

November 2018 to confirm the September sampling results.

A summary of the 2018 sampling events are listed below. No transition between CCR Rule

groundwater monitoring programs occurred in 2018.

2018 CCR RULE GROUNDWATER SAMPLING EVENTS

Location March 2018 Event

September 2018 Event

November 2018 Resample Event

Downgradient Well PZ3-31 3/6/2018 9/14/2018 None

MW-3-100 3/5/2018 9/20/2018 None MW-3-101 3/5/2018 9/20/2018 None MW-3-102 3/6/2018 9/14/2018 11/7/2018 Upgradient Wells MW-3-103 3/6/2018 9/18/2018 None MW-3-104 3/6/2018 9/17/2018 None


6.2 MARCH 2018 ANALYTICAL RESULTS

A SSI evaluation was prepared based upon comparison of the results from the March 2018

Detection Monitoring event to the UPL of the mean concentration detected in each well from the

eight rounds of baseline monitoring. Based on the results, no SSIs were found. Sampling results

are provided in Tables 1 and 2.

6.3 SEPTEMBER 2018 ANALYTICAL RESULTS

A SSI evaluation was prepared based upon comparison of the results from the September 2018

Detection Monitoring event to the UPL of the mean concentration detected in each well from the

eight rounds of baseline monitoring. Based on the results, three SSIs were found at MW-3-102 for

calcium, sulfate, and total dissolved solids. These SSIs were believed to be an anomaly as the

concentrations were above historical levels. Trend plots are provided in Appendix B; the

concentrations for these constituents in MW-3-102 were over two times the historical values.

MW-3-102 was resampled in November 2018. Results from this sampling event were consistent

with historical concentrations and no SSIs were found. Therefore, the initial SSIs from the

September sampling event are not attributed to Area 3 and the CCR unit will remain in Detection

Monitoring. Sampling results are provided in Tables 1 and 2.


7.0 PLANNED ACTIVITIES FOR 2019

This section discusses the groundwater monitoring and reporting activities anticipated at Area 3 in

2019.

January 2019: The 2018 Annual Groundwater Monitoring and Corrective Action Report will be

entered into the facility’s operating record.

March 2019: The 2018 Annual Groundwater Monitoring and Corrective Action Report will be

posted to the public internet site and a notification will be sent to the Pennsylvania Department of

Environmental Protection (PADEP).

March 2019: The first semi-annual groundwater monitoring event in 2019 will be conducted.

Detection Monitoring samples (i.e., Appendix III) will be collected during the event.

June 2019: Appendix III sample results collected in March 2019 will be evaluated for a

Statistically Significant Increase (SSI) over background.

September 2019: Amend Alternate Source Demonstration (ASD) certified by a Professional

Engineer if SSIs are detected in the March 2019 Sampling Event.

September 2019: The second semi-annual groundwater monitoring event in 2019 will be

conducted. Detection Monitoring samples (i.e., Appendix III) will be collected during the event

assuming no SSIs in the March 2019 or the ASD is negative/consistent with previous ASDs.

Assessment Monitoring samples (i.e., Appendix III and IV) will be collected if an alternative

source is not identified.

December 2019: Appendix III sample results collected in September 2019 will be evaluated for a

SSI over background. Note, if SSIs are detected in the September 2019 Sampling Event, an ASD

will be finalized by March 2020.


December 2019: Preparation of the 2019 Annual Groundwater Monitoring and Corrective Action

Report will begin.


8.0 RECORD KEEPING REQUIREMENTS

In accordance with §257.105(h) this document has been placed in Montour’s Operating Record.

This document will also be placed on the publicly accessible website, with a notification to be

provided to the Pennsylvania Department of Environmental Protection to comply with

§257.106(h) and §257.107(h) of the CCR Rule.


9.0 REFERENCES

CEC, 2017(1). 2017 Groundwater Monitoring and Corrective Action Report, Disposal Area No.

3, Derry Township, Pennsylvania, Prepared for Talen Energy/Montour, LLC,

Washingtonville, Pennsylvania, Prepared by Civil & Environmental Consultants, Inc.,

Pittsburgh, Pennsylvania, CEC Project 132-065, January, 2017.

CEC, 2017(2). Groundwater Monitoring System Certification, Disposal Area No. 3, Derry

Township, Pennsylvania, Prepared for Talen Energy/Montour, LLC, Washingtonville,

Pennsylvania, Prepared by Civil & Environmental Consultants, Inc., Pittsburgh,

Pennsylvania, CEC Project 132-065, October, 2017.

CEC, 2017(3). Detection Monitoring Statistical Methods Certification, Disposal Area No. 3, Derry

Township, Pennsylvania, Prepared for Talen Energy/Montour, LLC, Washingtonville,

Pennsylvania, Prepared by Civil & Environmental Consultants, Inc., Pittsburgh,

Pennsylvania, CEC Project 132-065, October, 2017.

CEC, 2018. Alternate Source Demonstration, Disposal Area No. 3, Derry Township,

Pennsylvania, Prepared for Talen Energy/Montour, LLC, Washingtonville, Pennsylvania,

Prepared by Civil & Environmental Consultants, Inc., Pittsburgh, Pennsylvania, CEC

Project 132-065, April, 2018.

USEPA, 2014. Fingerprint Analysis of Contaminant Data: A Forensic Tool for Evaluating

Environmental Contamination, EPA/600/5-04/054

FIGURES

www.cecinc.com333 Baldwin Road - Pittsburgh, PA 15205-9072

412-429-2324 800-365-2324

DRAWN BY:DATE:

APPROVED BY:PROJECT NO:

FIGURE NO: 1

MONTOUR, LLCGROUNDWATER MONITORING ANDCORRECTIVE ACTION REPORTMONTOUR STEAM ELECTRIC STATIONWASHINGTONVILLE, PA

CBL1/4/2018 1 " = 4,000 '

SITE LOCATION MAP - AREA 3BJH HTW*

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MW-3-104

MW-3-103

MW-3-102

MW-3-101

MW-3-100


412-429-2324 800-365-2324

DRAWN BY:DATE:


FIGURE NO: 2

MONTOUR, LLCGROUNDWATER MONITORING ANDCORRECTIVE ACTION REPORTMONTOUR STEAM ELECTRIC STATIONWASHINGTONVILLE, PA

NJH1/5/2018

CCR RULE GROUNDWATER SAMPLING LOCATIONS - AREA 3BJH

132-065.1203CHECKED BY:SCALE: 1 " = 300 '

LEGEND!( DOWNGRADIENT MONITORING POINT!( BACKGROUND MONITORING POINT

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REFERENCEGOOGLE EARTH PRO IMAGERYIMAGE DATE: 9/26/2014

0 300 600SCALE IN FEET

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TABLE 1

2018 DOWNGRADIENT GROUNDWATER RESULTS

Sample I.D.: PZ-3-31 PZ-3-31 MW-3-100 MW-3-100 MW-3-101 MW-3-101 MW-3-102 MW-3-102 MW-3-102*Parameter Date Collected: 3/6/2018 9/14/2018 3/5/2018 9/20/2018 3/5/2018 9/20/2018 3/6/2018 9/14/2018 11/7/2018Inorganics

Total MetalsBoron, Total mg/L 0.015 J < 0.00837 0.017 J 0.01 J 0.011 J 0.019 J 0.146 0.057 J 0.182Calcium, Total mg/L 94.8 94.6 162 165 77.5 112 135 312 136

Non-MetalsChloride mg/L 2.22 2.16 4.00 2.8 1.24 4.96 9.76 4.91 8.92Fluoride mg/L 0.290 J 0.26 0.170 J 0.23 0.200 0.24 0.510 0.3 0.51pH S.U. 4.50 H 4.85 H1 6.95 H 7.18 H1 6.72 H 6.95 H1 6.94 H 6.82 H1 7.39 H1Sulfate mg/L 278 237 227 228 138 149 167 603 209Total Dissolved Solids mg/L 460 447 586 611 293 414 522 1210 612

Field ParameterspH field reading (SM4500B) S.U. 4.16 4.45 6.29 6.54 6.01 6.54 7.06 6.74 7.06

Notes:Bolded values were detected at concentrations above laboratory reporting limits.-- Denotes parameter not run and/or sample not collectedH - Holding time for preparation or analysis exceeded; the recommend holding time for pH is 15 minutes in the field or as soon as possible for laboratory analysisJ - Analyte detected below the Quantitation Limit, the reported value is an estimate

DETECTION MONTIORING

TABLE 12018 FEDERAL CCR RULE DOWNGRADIENT RESULTS

ASH DISPOSAL LANDFILL AREA 3MONTOUR, LLC

WASHINGTONVILLE, PA

TABLE 2

2018 UPGRADIENT GROUNDWATER RESULTS

Sample I.D.: MW-3-103 MW-3-103 MW-3-104 MW-3-104Parameter Date Collected: 3/6/2018 9/18/2018 3/6/2018 9/17/2018Inorganics

Total MetalsBoron, Total mg/L 0.108 0.088 J 0.03 J 0.015 JCalcium, Total mg/L 120 135 16.1 25.3

Non-MetalsChloride mg/L 9.90 3.57 2.14 2.62Fluoride mg/L 0.170 J 0.19 J 0.180 J 0.17 JpH S.U. 6.71 H 6.96 H1 6.57 H 6.08 H1Sulfate mg/L 126 143 89.5 152Total Dissolved Solids mg/L 410 546 215 299

Field ParameterspH field reading (SM4500B) S.U. 5.78 6.95 5.48 5.85

Notes:Bolded values were detected at concentrations above laboratory reporting limits.-- Denotes parameter not run and/or sample not collectedH - Holding time for preparation or analysis exceeded; the recommend holding time for pH is 15 minutes in the field or as soon as possible for laboratory analysisJ - Analyte detected below the Quantitation Limit, the reported value is an estimate

DETECTION MONTIORING

TABLE 22018 FEDERAL CCR RULE UPGRADIENT RESULTS

ASH DISPOSAL LANDFILL AREA 3MONTOUR, LLC

WASHINGTONVILLE, PA

APPENDIX A

AREA 3 ALTERNATE SOURCE DEMONSTRATION

ALTERNATE SOURCE DEMONSTRATION DISPOSAL AREA 3

MONTOUR STEAM ELECTRIC STATION

DERRY TOWNSHIP MONTOUR COUNTY, PENNSYLVANIA

Prepared For: MONTOUR, LLC

WASHINGTONVILLE, PENNSYLVANIA

Prepared By: CIVIL & ENVIRONMENTAL CONSULTANTS, INC.

PITTSBURGH, PENNSYLVANIA

CEC Project 132-065.1202

APRIL 2018

-i- Area 3 ASD April 2018

TABLE OF CONTENTS

1.0 INTRODUCTION..............................................................................................................2

2.0 EXISTING CONDITIONS ...............................................................................................3 2.1 Site Conditions ........................................................................................................ 3 2.2 Monitoring Network ............................................................................................... 4

3.0 STATISTICALLY SIGNIFICANT INCREASE (SSI) DETERMINATION ..............5

4.0 LINES OF EVIDENCE .....................................................................................................6 4.1 Groundwater Constituent Analysis ......................................................................... 6 4.2 Seasonal Varibility .................................................................................................. 8 4.3 Laboratory Causes .................................................................................................. 9 4.4 Additional Considerations .................................................................................... 11

5.0 CONCLUSIONS ..............................................................................................................13

6.0 REFERENCES .................................................................................................................14

7.0 ALTERNATE SOURCE DEMONSTRATION CERTIFICATION ..........................15

FIGURES

Figure 1 – CCR Rule Groundwater Sampling Locations – Area 3 Figure 2 – CCR Rule Alternate Source Demonstration August 2017 Stiff Diagrams Figure 3 – Area 3 Piper Plot, CCR-Rule and Regional Monitoring Wells Averaged Over Past 9

Events, LD-3-1 Averaged Over Past 10 Years

APPENDIX Appendix A – FALCON Statistical Evaluation

Figure 1 – PZ-3-31 Analysis Figure 2 – MW-3-100 Analysis Figure 3 – MW-3-101 Analysis Figure 4 – MW-3-102 Analysis Figure 5 – MW-3-103 Analysis

Figure 6 – LD-3-1 Analysis Figure 7 – MW-3-104 Analysis Figure 8 – MW-1-9 Analysis Figure 9 – Fingerprint Summary

-2- Area 3 ASD April 2018

1.0 INTRODUCTION

The United States Environmental Protection Agency (USEPA) issued 40 C.F.R. § 257, Subpart D,

Disposal of Coal Combustion Residuals from Electric Utilities (CCR Rule; USEPA, 2015) on

April 17, 2015. The CCR Rule regulates disposal of coal combustion residuals (CCR) in new and

active landfills and impoundments. Civil & Environmental Consultants, Inc. (CEC) has been

engaged by Montour, LLC to complete the statistical analysis of CCR Rule, Detection Monitoring,

at Ash Landfill Disposal Area 3 (Area 3) of the Montour Steam Electric Station (Montour) as

required by the CCR Rule.

After statistical analysis of the initial Detection Monitoring sampling event performed in October

2017, a total of two Statistically Significant Increases (SSIs) for two of the Appendix III

constituents, were identified in two of the downgradient monitoring wells, on January 15, 2018.

Observed SSIs were suspected to be attributable to a source other than Area 3 based on a further

review of the data as compared to the landfill leachate data, the area wide data variability, and the

laboratory quality control information.

40 CFR § 257.94(e)(2) allows the owner or operator 90 days from the date of determination to

demonstrate that a source other than the CCR unit caused the SSI, or that the apparent SSI was

from a source other than the CCR unit, or resulted from errors in sampling, analysis, statistical

evaluation, or natural variation in groundwater quality. Pursuant to 40 CFR § 257.94(e)(2), the

following report is provided as a demonstration that the listed SSIs are due to alternate sources

including but not limited to regional groundwater heterogeneity, sampling and/or laboratory

causes, and seasonal variability. This report documents the findings of the Alternate Source

Demonstration (ASD) for Area 3.


2.0 EXISTING CONDITIONS

2.1 SITE CONDITIONS

Area 3 is located south of the main generation station and is a residual waste landfill constructed

and operated under Residual Waste Permit #300987 issued by the Pennsylvania Department of

Environmental Protection. The landfill is used for the disposal of plant-generated residual waste,

including scrubber wastewater treatment plant sludge (sludge is a mixture of calcium sulfate solids

and precipitated metals), fly ash, mill rejects, and various sump sludges. The disposal area also

receives resins, filter bags and construction and demolition wastes. The existing disposal area was

constructed beginning in September 1987 and completed in March 1990.

The shallowest bedrock formation underlying Area 3 is the Marcellus Shale. The competent shale

bedrock is overlain by weathered bedrock that ranges in thickness from less than 1 foot to 10 feet.

The weathered bedrock is overlain by glacial till material consisting of silt, clay, and broken rock

fragments.

Area 3 consists of a western half and an eastern half. Only the eastern half has been constructed to

date. It is unlikely that the western half will ever be constructed. The eastern half is constructed

with a geomembrane liner and leachate collection system. Leachate from the eastern half is drained

through a piping network above the liner that directs the leachate into a leachate collection basin

located southeast of Area 3. The leachate collection basin is also lined with a geomembrane liner

and covered with onsite low permeability silt-clay soils.

A small tributary of Mud Creek separates the two halves of Area 3. This southeastward-flowing

tributary is redirected into two subsurface 48-inch diameter pipe conduits installed within Area 3.

The flow enters piping on the northwestern side of Area 3 and exits the piping at the southeastern

side of Area 3 (Figure 1).

The groundwater underlying Area 3 is shallow (less than 10 feet below the ground surface) and

occurs within bedrock or at the bedrock/overburden interface. Groundwater underdrains were


installed under Area 3, below the geomembrane liner, to drain the groundwater during seasonal

high levels and maintain the state 8-feet separation requirement. The groundwater underdrains are

separate from the 48-inch diameter conduits, however both systems discharge into same area,

southeast of Area 3 (see Figure 1). The general groundwater flow direction is to the south.

2.2 MONITORING NETWORK

The CCR Rule groundwater monitoring system consists of six wells at appropriate locations and

depths to provide groundwater samples from the uppermost aquifer that accurately represent

background groundwater quality and the quality of groundwater passing the waste boundary of the

CCR unit. The monitoring network consists of one pre-existing well (PZ-3-31) and five new wells

installed in April 2016 to meet the requirements of the CCR Rule. The well locations are shown

on Figure 1. An in-depth discussion of the hydrogeology and geology can be found in the

Groundwater Monitoring System Certification for Area 3 (CEC, 2017), placed in the Montour

Operating Record in September 2017 and onto the publicly accessible internet site in October

2017.

CCR RULE GROUNDWATER MONITORING SYSTEM

Location Relative Location

Well Diameter

(in.)

Bottom of Screen (ft-

bgs)

Screen Length (ft.)

PZ-3-31 Downgradient 2 17.7 9.5 MW-3-100 Downgradient 4 15 10 MW-3-101 Downgradient 4 15 10 MW-3-102 Downgradient 4 17 10 MW-3-103 Upgradient 4 15 10 MW-3-104 Upgradient 4 14 10

Based on existing groundwater contours, monitoring wells MW-3-103 and MW-3-104 will

provide upgradient groundwater sampling locations for groundwater flowing toward Area 3. The

remaining wells, PZ-3-31, MW-3-100, MW-3-101, and MW-3-102, provide downgradient

groundwater sampling locations.


3.0 STATISTICALLY SIGNIFICANT INCREASE (SSI) DETERMINATION

SSIs were determined based upon an intrawell approach whereby results from the initial Detection

Monitoring event at each well were compared to the upper prediction limit (UPL) of the mean

baseline concentration detected in that same well from the eight rounds of baseline monitoring.

The selection of the intrawell approach was based on the absence of any correlation between

monitored constituents at the background wells. This aquifer heterogeneity supports the use of an

intrawell statistical approach to monitor for evidence of a release from Area 3. The analysis of the

aquifer heterogeneity is further discussed in Section 4. Based upon the initial statistical analysis of

the results from the first round of Detection Monitoring, one SSI was found at each of the following

downgradient locations: MW-3-100 and MW-3-101. The observed SSIs at each location are

summarized below:

SUMMARY OF OBSERVED SSIs AT AREA 3

Appendix III

Parameters Boron Calcium Chloride Fluoride pH Sulfate

Total Dissolved

Solids (TDS)

MW-3-100 X

MW-3-101

X

MW-3-102

PZ3-31

X – SSI Determined

The groundwater data was compared to the landfill leachate data, the area wide data variability,

and the laboratory quality control information. This evaluation lead to the hypothesis that the

observed SSIs are attributable to a source other than the Area 3 Landfill. The following sections

provide supportable evidence to demonstrate that the apparent SSIs are due to an alternate source.


4.0 LINES OF EVIDENCE

Statistical methods such as those used to determine the SSIs are subject to false positive results,

where a value that is not a true exceedance may be flagged as such. In addition, there can be

multiple causes related to sampling, laboratory analysis, natural variation, and other anthropogenic

sources that can trigger an exceedance that is not due to a release from the monitored unit. For the

SSIs identified for the October 2017 Detection Sampling event, field sampling errors, laboratory

issues, regional groundwater heterogeneity, and statistical evaluation issues were determined

individually and in combination to assess the SSIs that were initially identified.

4.1 GROUNDWATER CONSTITUENT ANALYSIS

The initial review of the groundwater quality data from each well did not yield the expected

distribution of constituents around Area 3. Under normal conditions, the overall makeup of the

water quality data from upgradient wells are expected to be similar to each other in constituents

detected and their respective constituents’ ratios. If the downgradient wells are unaffected by the

landfill, the analytical results should appear similar to the upgradient wells. If the downgradient

wells are affected by the landfill, the analytical results are expected show similarities to the source

(landfill leachate) or to show some mixing effects of groundwater that would still preserve the

leachate constituent ratios. None of these scenarios were found at Area 3. No discernable groupings

of similar water quality composition could be determined that were consistent with the

groundwater flow directions and potential contaminant transport assumptions.

To further analyze and quantify the groundwater constituent makeup in the various areas around

Area 3, the USEPA-developed multi-variant evaluation technique, Fingerprint Analysis of

Leachate Contaminants (FALCON) was used (USEPA, 2014). FALCON was utilized to create a

multi-parameter chemical fingerprint of the CCR monitoring wells, background wells and leachate

data from Area 3. Although not an Area 3 CCR well, monitoring well MW-1-9 was also included

in the study and is categorized as a regional background well (Figure 2). MW-1-9 is a background

monitoring well for the nearby Basin 1 disposal area.


Fractional percentages of chemical constituent concentrations measured at each monitoring point

during the nine CCR monitoring events were used to create a distinctive chemical fingerprint at

each location. A regression analysis between each monitoring event was performed for each well

to demonstrate the reproducibility of the results over time and identify statistical outliers (including

those attributable to seasonal variability). Histogram plots of the derived fingerprints are presented

in figures 1 through 8 of Appendix A.

The average concentration of each constituent at each location was then used to create an average

typical fingerprint. The relationship between the distinctive fingerprint at each location versus all

of the other locations was quantified to estimate the likelihood of source mixing (Figure 9 of

Appendix A). The strength of the relationship between each monitoring point is represented by a

correlation coefficient (r2). Coefficient values close to 1.0 indicate the samples being compared

have a similar fingerprint. Similarly, r2 values <0.8 were considered to not correlate. The summary

table below compares each of the upgradient wells to each other, the landfill leachate (LD-3-1) to

all the monitoring wells, and the upgradient wells to the downgradient wells.

REGRESSION ANALYSIS BETWEEN AVERAGED WELL FINGERPRINTS

MW-3-103 MW-3-104 MW-1-9 LD-3-1

Upgradient Wells and Leachate

MW-3-103 1.0000 MW-3-104 0.5100 1.0000 MW-1-9 0.8600 0.3000 1.0000

LD-3-1 0.0300 0.2200 0.3000 1.0000

Downgradient Wells

MW-3-100 0.8900 0.7700 0.6100 0.0100 MW-3-101 0.7600 0.8500 0.4400 0.0300 MW-3-102 0.9800 0.6200 0.8500 0.1600

PZ-3-31 0.3300 0.9100 0.0200 0.1000

Notes: This color represents r2 values greater than 0.80

The FALCON process is discussed in greater detail in Appendix A along with the details of our

regression analysis of the average location fingerprints. The FALCON regressions analysis

(summarized in the table above) suggests two key findings for Area 3.


• Leachate (LD-1) fingerprint does not correlate with any of the CCR wells.

• Fingerprints of CCR-Rule background wells (MW-3-103 and MW-3-104) and the

regional background well (MW-1-9) do not correlate strongly with each other.

The lack of correlation between the leachate fingerprints and any of the regional or CCR

upgradient and downgradient monitoring wells serves as evidence against any leachate migration

from the landfill to groundwater. Similarly, the non-optimal correlation between the three

designated background wells suggests a degree of aquifer heterogeneity and supports the use of an

intrawell statistical approach to monitor for evidence of a release from Area 3. The data suggests

the recorded SSIs were likely derived from an alternate source and not the result of leachate

migration. This is a key line of evidence supporting an alternate source for the two observed SSIs.

4.2 SEASONAL VARIABILITY

Boron was identified as a SSI at MW-3-100. A time trend plot of boron results through the nine

sampling events suggests a significant seasonal variation and indicates the first Detection

Monitoring event (October 2017) appears to have been collected during the season when boron

results climax (See boron time-trend below). To further examine the seasonality hypothesis, MW-

3-100 was resampled during February 2018, in advance of the next Detection Monitoring event.

The results were significantly below the detected concentration in October 2017 as well as the

UPL and were consistent with the January 2017 result. This result confirms the seasonal pattern

that had previously been observed. The source of the seasonal variability at this location is

unknown, but the elevated boron result is not attributable to a release from the Area 3 landfill. This

is a key line of evidence supporting an alternate source.


Total boron time-trend for MW-3-100, showing seasonal variability in total boron

concentration.

4.3 LABORATORY CAUSES

Boron was identified as a SSI at MW-3-100. Boron was additionally detected at trace levels (below

the limit of quantitation (LOQ) but above the limit of detection (LOD)) at most upgradient and

downgradient locations. These trace detections have been reported by the laboratory and used in

the statistical evaluation of the sampling results.

For constituents being compared to baseline concentrations during Detection Monitoring,

precision is of upmost concern and proper establishment of the LOQ is necessary to minimize the

potential for introducing variability into reported results such that SSIs unrelated to a release from

the facility are triggered.

Non-detects are currently processed at the LOD and results between the LOD and LOQ are

considered estimated values subject to low precision. These estimated values have been included

in the statistical evaluation based upon the assumption that an estimated value is preferable to a

less than value. While laboratories will often set their LOQ at three to five times the LOD, for

boron the ratio of LOQ/LOD is nearly twelve for the third through ninth sampling events.

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g/L)

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MW-3-100, Total Boron

Boron, Total

UPL


REPORTING LIMIT SUMMARY

Boron LOD (µg/L)

LOQ (µg/L) LOQ/LOD

Talen Laboratory 4 20 5 Hawk Mountain Laboratory 8.37 100 11.9

Discussions with Hawk Mountain Laboratory (Hawk Mt.) have indicated that they frequently run

major/minor elements in coal, coal ash, and coke. The sample preparation for these sample types

involves the digestion of a lithium tetraborate fusion pellet. Additionally, their instrument’s

introduction system for these samples is borosilicate glass therefore after running these samples,

they find that the boron persists in their system for some undetermined amount of time. While they

use a completely separate set of sample introduction glassware for the CCR groundwater samples,

boron levels can still lead to some issues. They also analyze odd landfill leachates and industrial

effluents that sometimes have high/very dirty matrices. All of the above can lead to elevated

transient background levels that can lead to false positives. Keeping the LOQ a little higher ensures

false positives (above the LOQ) are not reported.

By keeping their LOQ for boron at a higher ratio, Hawk Mt. can ensure that false positives (above

the LOQ) are not reported and limit the amount of sample reruns due to detections above the LOQ

in their laboratory blanks. Based upon the above, boron results below the LOQ are likely not totally

representative of field conditions and potentially include a contribution from transient laboratory

background.

Additionally, due to the decrease in precision and reproducibility as the concentration approaches

the LOD, variability in results below the LOQ between individual sampling events can lead to

“false SSI excursions”. A SSI based upon results below the LOQ is not a legitimate SSI, but rather

a statistical artifact, caused by the naturally higher variability in results below the LOQ. The

statistical protocols in use operate under the assumption that all values are equally “valid” (accurate

and precise) and, do not consider that certain values may be less precise and accurate than others,

based upon the value’s order of magnitude. While the identified SSIs do not fall into this category

for the October 2017 Detection Monitoring Event, it is probable that locations with trace detections

of Appendix III constituents may initially identify an SSI for a future Detection Monitoring Event.


This is a supporting line of evidence that trace or low level detections of boron are due to an

alternate source.

4.4 ADDITIONAL CONSIDERATIONS

Fluoride is identified as a SSI in MW-3-101 with an apparent increasing trend over the first nine

sampling events. However, neither boron nor sulfate, key coal ash indicators, have been identified

as an SSI at that location, nor do they show an increasing trend over the same time period. This

would be a supporting line of evidence that fluoride concentrations are not indicative of a release

from Area 3.

A Stiff diagram is a graphical representation of chemical analyses used to display the major ion

composition of a water sample. Constituent concentrations are converted to milliequivalents/liter

(meq/L) which accounts for the variability in ion charge. Cations are plotted on the left side of the

zero axis, and anions are plotted on the right side, such that the two sides of the diagram are

electrically neutral or “balanced”. Stiff diagrams are useful in making a rapid visual comparison

between water from different sources. The stiff diagram based upon August 2017 concentrations

at each location and the leachate are presented in Figure 2. The Stiff Diagrams confirm the

FALCON analysis determination of spatial heterogeneity in background locations and that the

leachate water quality appears significantly different than downgradient water quality. This is a

supporting line of evidence that SSIs are not due to a release from Area 3.

Piper diagrams (trilinear diagrams) are another form of graphical representation of the chemistry

of a water sample. A piper diagram is suitable for comparing the ionic composition of a set of

water samples and is useful for classifying the water types at various locations. A piper diagram

based upon average concentrations of the major constituents over the period of the nine sampling

events (or since 2010 for Leachate) is presented in Figure 3. Background wells MW-1-9, MW-3-

103 and downgradient well MW-3-102 classify as calcium/bicarbonate water sources, while the

other locations fall into the calcium/sulfate classification area. Neither the upgradient wells nor the

downgradient wells classify as the same type of water chemistry as is found in the Leachate as

presented in the 10-year average value plotted. The downgradient wells additionally do not plot


in-between the leachate data and the upgradient wells, as would be expected if there were mixing

of these two water sources. This is a supporting line of evidence that detected concentrations of

monitored constituents do not show any impacts from Area 3.


5.0 CONCLUSIONS

The preceding information serves as the ASD prepared in accordance with 40 CFR 257.94(e)(2)

and supports the position that the SSIs during the October 2017 monitoring period are not due to

a release from the CCR unit. Therefore, no further action (i.e., assessment monitoring) is warranted

and Montour Disposal Area No. 3 will remain in detection monitoring.


6.0 REFERENCES

CEC, 2017. Groundwater Monitoring System Certification, Disposal Area No. 3, Derry Township,

Pennsylvania, Prepared for Talen Energy/Montour, LLC, Washingtonville, Pennsylvania,

Prepared by Civil & Environmental Consultants, Inc., Pittsburgh, Pennsylvania, CEC

Project 132-065, October, 2017.

EPRI, 2017. Guidelines for Development of Alternative Source Demonstrations at Coal

Combustion Residual Sites. 3002010920. 132 pp.

USEPA, 2014. Fingerprint Analysis of Contaminant Data: A Forensic Tool for Evaluating

Environmental Contamination, EPA/600/5-04/054

USEPA, 2015. Disposal of Coal Combustion Residuals from Electric Utilities (CCR Rule) 40

C.F.R. § 257, Subpart D, April 17, 2015.


7.0 ALTERNATE SOURCE DEMONSTRATION CERTIFICATION

CCR Impoundment Information Name: Montour Disposal Area No. 3 Operator: Montour, LLC Address: 18 McMichael Road Washingtonville, PA 17884

Qualified Professional Engineer: Name: Rick Buffalini, P.E. Company: Civil & Environmental Consultants

I, Rick J. Buffalini, certify that this Alternate Source Demonstration for Montour Disposal Area No. 3 meets the requirements of the Coal Combustion Residual (CCR) rule 40 C.F.R. §257.94(e)(2). I am a duly licensed Professional Engineer under the laws of Pennsylvania.

Print Name: __Rick Buffalini ____________________________________________ Signature:

Date: ___April 11, 2018________________________________________________ License Number: PE 041196 My license renewal date is September 30, 2019

Qualified Professional Geologist: Name: H. Thomas Walsh, P.G.Company: Civil & Environmental Consultants

I, H. Thomas Walsh, certify that this Alternate Source Demonstration for Montour Disposal Area No. 3 meets the requirements of the Coal Combustion Residual (CCR) rule 40 C.F.R. §257.94(e)(2). I am a duly licensed Professional Geologist under the laws of Pennsylvania.

Print Name: ____H. Thomas Walsh__________________________________________ Signature:

Date: ___April 11, 2018_________________________________________________ License Number: PG 003251

My license renewal date is September 30, 2019

FIGURES

!(

!(

!(

!(

!(

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AREA 3 - EAST


UNNAMEDTRIBUTARY

PZ3-31

MW-3-104

MW-3-103

MW-3-102

MW-3-101

MW-3-100


412-429-2324 800-365-2324

DRAWN BY:DATE:


FIGURE NO: 1NJH1/5/2018

CCR RULE GROUNDWATER SAMPLING LOCATIONS - AREA 3BJH

132-065.1203CHECKED BY:SCALE: 1 " = 300 '

LEGEND!( DOWNGRADIENT MONITORING POINT!( BACKGROUND MONITORING POINT


REFERENCEGOOGLE EARTH PRO IMAGERYIMAGE DATE: 9/26/2014

0 300 600SCALE IN FEET

* Hand signature on file HTW*

\\svr-pittsburgh\projects\2013\132-065\-GIS\Maps\Task_1203\Area_3\132065_FIG2_MONITORING_LOCS_CCR.mxd 1/5/2018 11:35 AM (nhetrick)

ASHT ADILSEPNO ESNAEL RAGRYEA 3MONTOWUAR SSHTIENAGMT OENLEVICLTLREI, CP ASTATION

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AREA 3 - EAST


UNNAMEDTRIBUTARY

LD-3-1

MW-1-9

Tributary 18787 to Mud Creek

PZ3-31

MW-3-104MW-3-103

MW-3-102

MW-3-100

MW-3-101


412-429-2324 800-365-2324

DRAWN BY:DATE:


FIGURE NO: 2

TALEN ENERGYASH DISPOSAL AREA 3MONTOUR STEAM ELECTRIC STATIONWASHINGTONVILLE, PA

NJH/JLR3/29/2018

BJH132-065.1202

CHECKED BY:SCALE: 1 " = 600 '

LEGEND!( DOWNGRADIENT WELL!( BACKGROUND WELL!( REGIONAL BACKGROUND WELL!( LEACHATE


REFERENCEARCGIS MAP SERVICE: ESRI WORLD IMAGERY,IMAGERY DATE: 2015.

0 600 1,200SCALE IN FEET

*

\\svr-pittsburgh\Projects\2013\132-065\-GIS\Maps\Task_1202\Area_3\132065_FIG1_MONITORING_LOCS_CCR.mxd 3/29/2018 4:03 PM (jrokosz)

CCR RULE ALTERNATE SOURCE DEMONSTRATIONAUGUST 2017 STIFF DIAGRAMS

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na nfilde signature HTW*

bhastings

Stamp

bhastings

Stamp

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bhastings

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Line

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FIGURE 3 - Piper Plot showing Avg. Conc. of CCR Rule Wells and MW-1-9 from May 2016 to October 2017DESCRIPTION:

PROJECT: PROJECT NO:Ash Landfill 3 ASD 132-065

CLIENT: DATE:Talen Montour, LLC April 2018

and Leachate from 2010 to 2017

80 60 40 20 20 40 60 80

20

40

60

80

20

40

60

80

20

40

60

80

20

40

60

80

Ca Na+K Alk. Cl

Mg SO4

<=A

lk.

Na+

K=>

<=C

a + M

gCl +

SO

4=>

PZ-3-31

MW-3-100

MW-3-101

MW-3-102

LD-3-1

MW-3-103

MW-3-104

MW-1-9

PZ-3-31

MW-3-100

MW-3-101

MW-3-102

LD-3-1

MW-3-103

MW-3-104

MW-1-9

APPENDIX A

FALCON Statistical Evaluation

Explanation of the FALCON Statistical Evaluation

In response to the need to identify the source of contaminant plumes, EPA has developed an

empirical multi-variant contaminant fingerprinting process. The Fingerprint Analysis of Leachate

Contaminants (FALCON) process combines data for several contaminants to develop a distinctive

graphical fingerprint or multi-parameter chemical signature. These fingerprint patterns can be used

to characterize the source of a contaminant plume, differentiate the contaminant plume from

background conditions at the source, and monitor the migration of leachate into the environment.

The FALCON process was used to create a multi-parameter chemical fingerprint of the CCR

monitoring wells, background wells, and leachate data from Area 3. MW-1-9 (Basin 1) was also

included in the study and is categorized as a regional background well. The analysis included the

major constituents (calcium, sodium, magnesium plus potassium, chloride, sulfate and alkalinity)

as well as trace constituents (boron and lithium).

Ratios of concentrations of chemical constituents measured at each monitoring point during the

nine CCR monitoring events were used to create a distinctive chemical fingerprint for each

location. (see Figures 1 through 8). Individual constituent concentrations were normalized to the

total concentration of detected constituents to allow for comparisons between locations with

significantly different total dissolved solids levels (which is a measure of the constituent loading

at a given monitoring point).

A regression analysis between each monitoring event was performed on a well-by-well basis to

determine statistical outliers (including those attributable to seasonal variability) and establish

reproducibility of constituent concentrations over time. An average concentration for each

constituent at each monitoring location was calculated with the exclusion of any identified

statistical outliers. The average concentration and subsequent normalized fractional percentage

were then used to derive histogram plots or “fingerprints” for each location as shown in Figure 9.

The relationship between the distinctive fingerprint at each upgradient location and downgradient

location was determined to estimate the likelihood of an upgradient source mixing with the

downgradient water (See Summary Table in Figure 9). The strength of the relationship between

each source is represented by the correlation coefficient (r2). Based upon guidance provided in the

EPA document and EPRI guidance document on the use of FALCON as part of an Alternate

Source Demonstration at CCR sites the following interpretation was applied.

Values of r2 close to 1 would indicate the downgradient sample has a similar fingerprint to the

source water (i.e. background or leachate)., values below 0.8 were considered to not show a

correlation between the two locations and thus downgradient water quality was not impacted by

the upgradient source. The interwell evaluation was also examined to determine whether the

designated background wells (either individually or combined) could be used as representative of

regional groundwater quality. The results of our regression analysis of the fingerprints as presented

in Figure 9 suggests two key findings for Area 3.

• Leachate (LD-1) fingerprint shows no correlation with any of the CCR wells

(upgradient or downgradient).

• Background well (MW-1-9, MW-3-103, and MW-3-104) fingerprints do not correlate

well with each other.

The lack of correlation between leachate fingerprint and any of the CCR monitoring wells serves

as evidence against any leachate migration. Similarly, the absence of any correlation between the

designated background wells suggest aquifer heterogeneity and support the use of an intrawell

statistical approach to monitor for evidence of a release from Area 3. The data suggests the

recorded SSIs were likely derived from an alternate source and not the result of leachate migration.

FALCON SUMMARYALTERNATIVE SOURCE DEMONSTRATION

ASH LANDFILL 3MONTOUR, LLC

WASHINGTONVILLE, PA

5/16/2016 6/27/2016 8/16/2016 11/7/2016 2/14/2017 5/18/2017 6/21/2017 8/10/2017 10/10/2017Alkalinity, total as CaCO3 (mg/L) 20 26 65 103 20 1 10 10 24Boron, total (µg/L) 10 37 57 32 10 50 50 50 50Calcium, total (mg/L) 106 124 137 136 122 113 90 96 127Chloride, total as Cl (mg/L) 1.2 5.3 6.5 6.7 1.2 1.6 2.4 2.4 8.1Lithium, total (µg/L) 3.0 6.6 14.4 18.9 2.7 1.9 2.3 3.4 6.6Molybdenum, total (µg/L) 0.5 1.6 4.9 7.1 0.5 0.2 0.2 0.1 0.2Sulfate, as SO4 (mg/L) 349 370 358 356 390 317 310 313 375Magnesium + Potassium (mg/L) 14.0 19.7 21.0 20.9 14.9 13.5 13.7 15.5 20.6Sodium, Total (mg/L) 8.4 15.4 17.7 18.8 7.8 7.5 9.3 9.7 17.0

Sum of Constituents 512.1 605.8 682.2 699.6 569.1 505.7 488.2 500.2 629.0

5/16/2016 6/27/2016 8/16/2016 11/7/2016 2/14/2017 5/18/2017 6/21/2017 8/10/2017 10/10/20175/16/2016 1.0000 6/27/2016 0.9978 1.0000 8/16/2016 0.9883 0.9933 1.0000 11/7/2016 0.9765 0.9758 0.9902 1.0000 2/14/2017 0.9999 0.9979 0.9881 0.9758 1.0000 5/18/2017 0.9882 0.9952 0.9861 0.9558 0.9887 1.0000 6/21/2017 0.9900 0.9959 0.9876 0.9605 0.9896 0.9972 1.0000 8/10/2017 0.9906 0.9966 0.9884 0.9612 0.9904 0.9982 0.9999 1.0000

10/10/2017 0.9952 0.9994 0.9931 0.9718 0.9952 0.9974 0.9979 0.9985 1.0000 Average r2= 0.9909

Notes: values less than 0.80 r 2

Figure 1. PZ-3-31

Analytical Data

Regression Analysis Between CCR Monitoring Events

All show high r 2 (>0.8) demonstrating that results are consistent from event to event. Average value is appropriate to use.

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PZ 3-31 CCR Event Histogram

ALK B Ca Cl Li Mo SO4 Mg + K Na(Normalized to Sum)



WASHINGTONVILLE, PA



5/16/2016 6/27/2016 8/16/2016 11/7/2016 2/14/2017 5/18/2017 6/21/2017 8/10/2017 10/10/20175/16/2016 1.0000 6/27/2016 0.9969 1.0000 8/16/2016 0.7864 0.8235 1.0000 11/7/2016 0.5148 0.5710 0.9251 1.0000 2/14/2017 0.9873 0.9904 0.8561 0.6032 1.0000 5/18/2017 0.9902 0.9966 0.8640 0.6279 0.9944 1.0000 6/21/2017 0.9859 0.9942 0.8763 0.6431 0.9959 0.9989 1.0000 8/10/2017 0.8844 0.9114 0.9770 0.8478 0.9250 0.9396 0.9444 1.0000

10/10/2017 0.5156 0.5741 0.9108 0.9875 0.5925 0.6272 0.6407 0.8472 1.0000 Average r2= 0.9544


Figure 2. MW-3-100

Analytical Data


Highlighted values are not included in the Average r 2 value. The calculated r 2 value is exclusive of documented high late summer/early fall seasonal variability.

Average r 2 value of non-high seasonal impacts shows event to event reproducabiity, which allows for use of adjusted average.

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WASHINGTONVILLE, PA



5/16/2016 6/27/2016 8/16/2016 11/7/2016 2/14/2017 5/18/2017 6/21/2017 8/10/2017 10/10/20175/16/2016 1.0000 6/27/2016 0.9671 1.0000 8/16/2016 0.9185 0.9883 1.0000 11/7/2016 0.9319 0.9884 0.9931 1.0000 2/14/2017 0.9813 0.9045 0.8315 0.8608 1.0000 5/18/2017 0.9648 0.8846 0.8088 0.8127 0.9690 1.0000 6/21/2017 0.9861 0.9436 0.8887 0.8871 0.9638 0.9878 1.0000 8/10/2017 0.9537 0.9895 0.9844 0.9792 0.8817 0.8733 0.9363 1.0000

10/10/2017 0.9502 0.9961 0.9931 0.9860 0.8748 0.8650 0.9318 0.9954 1.0000 Average r2= 0.9478


Figure 3. MW-3-101

Analytical Data



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0.9

1


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MW3-101 CCR Event Histogram




WASHINGTONVILLE, PA



5/16/2016 6/27/2016 8/16/2016 11/7/2016 2/14/2017 5/18/2017 6/21/2017 8/10/2017 10/10/20175/16/2016 1.0000 6/27/2016 0.9928 1.0000 8/16/2016 0.8134 0.7444 1.0000 11/7/2016 0.9874 0.9949 0.7616 1.0000 2/14/2017 0.9921 0.9861 0.8320 0.9931 1.0000 5/18/2017 0.9275 0.8781 0.9426 0.8684 0.9143 1.0000 6/21/2017 0.9961 0.9875 0.8376 0.9905 0.9990 0.9276 1.0000 8/10/2017 0.9935 0.9868 0.8276 0.9915 0.9975 0.9182 0.9980 1.0000

10/10/2017 0.9877 0.9924 0.7749 0.9986 0.9942 0.8777 0.9921 0.9950 1.0000 Average r2= 0.9622


Figure 4. MW-3-102

Analytical Data


Highlighted values are not included in the Average r 2 value because they are suspected outliers.

Average r 2 value shows event to event reproducabiity, which allows for use of adjusted average.

0

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5/16/2016 6/27/2016 8/16/2016 11/7/2016 2/14/2017 5/18/2017 6/21/2017 8/10/2017 10/10/20175/16/2016 1.0000 6/27/2016 0.9990 1.0000 8/16/2016 0.9989 0.9982 1.0000 11/7/2016 0.9986 0.9961 0.9977 1.0000 2/14/2017 0.9926 0.9953 0.9928 0.9911 1.0000 5/18/2017 0.9968 0.9959 0.9984 0.9979 0.9951 1.0000 6/21/2017 0.9995 0.9990 0.9995 0.9987 0.9941 0.9984 1.0000 8/10/2017 0.9945 0.9969 0.9950 0.9932 0.9997 0.9967 0.9961 1.0000

10/10/2017 0.9965 0.9924 0.9963 0.9989 0.9846 0.9959 0.9967 0.9876 1.0000 Average r2= 0.9968


Figure 5. LD-3-1

Analytical Data



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0.7

0.8

0.9

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Leachate CCR Event Histogram




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5/16/2016 6/27/2016 8/16/2016 11/7/2016 2/14/2017 5/18/2017 6/21/2017 8/10/2017 10/10/20175/16/2016 1.0000 6/27/2016 0.9998 1.0000 8/16/2016 0.9999 0.9997 1.0000 11/7/2016 0.9977 0.9980 0.9985 1.0000 2/14/2017 0.9180 0.9198 0.9169 0.9080 1.0000 5/18/2017 0.9841 0.9817 0.9827 0.9716 0.9139 1.0000 6/21/2017 0.9997 0.9997 0.9994 0.9968 0.9271 0.9836 1.0000 8/10/2017 0.9987 0.9985 0.9993 0.9985 0.9209 0.9809 0.9983 1.0000

10/10/2017 0.9959 0.9959 0.9972 0.9994 0.9005 0.9702 0.9945 0.9980 1.0000 Average r2= 0.9810


Figure 6. MW-3-103

Analytical Data



0

0.1

0.2

0.3

0.4

0.5

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0.7

0.8

0.9

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May-16 Jun-16 Aug-16 Nov-16 Feb-17 May-17 Jun-17 Aug-17

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5/16/2016 6/27/2016 8/16/2016 11/7/2016 2/14/2017 5/18/2017 6/21/2017 8/10/2017 10/10/20175/16/2016 1.0000 6/27/2016 0.9866 1.0000 8/16/2016 0.9911 0.9983 1.0000 11/7/2016 0.9940 0.9830 0.9849 1.0000 2/14/2017 0.9883 0.9558 0.9671 0.9841 1.0000 5/18/2017 0.9410 0.9124 0.9334 0.9110 0.9568 1.0000 6/21/2017 0.9595 0.9712 0.9796 0.9381 0.9403 0.9646 1.0000 8/10/2017 0.9682 0.9417 0.9582 0.9423 0.9740 0.9928 0.9709 1.0000

10/10/2017 0.9266 0.8645 0.8884 0.9011 0.9619 0.9716 0.8931 0.9719 1.0000 Average r2= 0.9662


Analytical Data


Figure 7. MW-3-104


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5/16/2016 6/27/2016 8/16/2016 11/7/2016 2/14/2017 5/18/2017 6/21/2017 8/10/2017 10/10/20175/16/2016 1.0000 6/27/2016 0.9985 1.0000 8/16/2016 0.9983 0.9970 1.0000 11/7/2016 0.9909 0.9909 0.9944 1.0000 2/14/2017 0.9918 0.9902 0.9936 0.9981 1.0000 5/18/2017 0.9825 0.9845 0.9867 0.9977 0.9958 1.0000 6/21/2017 0.9982 0.9970 0.9976 0.9950 0.9953 0.9896 1.0000 8/10/2017 0.9967 0.9943 0.9978 0.9972 0.9984 0.9917 0.9982 1.0000

10/10/2017 0.9915 0.9859 0.9941 0.9935 0.9955 0.9855 0.9926 0.9972 1.0000 Average r2= 0.9950


Figure 8. MW-1-9 (Background Location for Basin 1)

Analytical Data

Regression Analysis Comparison


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PZ-3-31 MW-3-100 MW-3-101 MW-3-102 LD-3-1 MW-3-103 MW-3-104 MW-1-9Alkalinity, total as CaCO3 (mg/L) 31 257 106 278 162 291 43 161Boron, total (µg/L) 39 81 38 136 10208 101 36 111Calcium, total (mg/L) 117 172 91 122 542 127 23 55Chloride, total as Cl (mg/L) 3.9 4.1 3.4 7.9 155.9 4.3 1.9 37.4Lithium, total (µg/L) 6.6 11.5 5.2 18.9 1895.6 23.2 20.8 61.1Molybdenum, total (µg/L) 1.7 20.1 13.1 5.2 2247.8 2.2 1.8 5.0Sulfate, as SO4 (mg/L) 349 261 160 169 2919 131 110 51Magnesium + Potassium (mg/L) 17.1 19.2 11.7 34.8 197.3 21.2 13.3 22.3Sodium, Total (mg/L) 12.4 18.5 6.8 15.3 678.3 21.6 27.2 19.7

Sum of Constituents 576.9 844.7 434.0 787.3 19005.1 722.9 277.5 522.8

MW-3-103 MW-3-104 MW-1-9 LD-3-1MW-3-103 1.0000MW-3-104 0.5100 1.0000MW-1-9 0.8600 0.3000 1.0000LD-3-1 0.0300 0.2200 0.3000 1.0000MW-3-100 0.8900 0.7700 0.6100 0.0100MW-3-101 0.7600 0.8500 0.4400 0.0300MW-3-102 0.9800 0.6200 0.8500 0.1600

PZ-3-31 0.3300 0.9100 0.0200 0.1000

Notes: values greater than 0.80 r 2

Leachate (LD-1) fingerprint shows no correlation with any of the CCR wells (upgradient or downgradient). Background well (MW-1-9, MW-3-103, and MW-3-104) fingerprints do not correlate well with each other.

Figure 9. All Wells

Averaged Analytical Data by Well

Upgradient Wells and Leachate

Downgradient Wells

Regression Analysis Between Averaged Well Fingerprints

0.000

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1.000

PZ3-31 MW-3-100 MW-3-101 MW-3-102 LD-3-1 MW-3-103 MW3-104 MW-1-9

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Averaged Fingerprints of All Wells

Alk B Ca Cl Li Mo SO4 Mg+K Na(Normalized to Sum)

APPENDIX B

AREA 3 TIME TREND PLOTS

Talen EnergyMontour - Area No. 3 CCR - September 2018 Event

Boron, total [ug/l]

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300

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500

600

MW-3-100

MW-3-101

MW-3-102

MW-3-103 (BG)

MW-3-104 (BG)

PZ3-31


Calcium, total [mg/l]

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300

350

MW-3-100

MW-3-101

MW-3-102

MW-3-103 (BG)

MW-3-104 (BG)

PZ3-31


Chloride, total as Cl [mg/l]

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2

4

6

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10

12

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MW-3-100

MW-3-101

MW-3-102

MW-3-103 (BG)

MW-3-104 (BG)

PZ3-31


Fluoride, total as F [mg/l]

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0.6

MW-3-100

MW-3-101

MW-3-102

MW-3-103 (BG)

MW-3-104 (BG)

PZ3-31


pH, lab [s.u.]

3.0

3.5

4.0

4.5

5.0

5.5

6.0

6.5

7.0

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MW-3-100

MW-3-101

MW-3-102

MW-3-103 (BG)

MW-3-104 (BG)

PZ3-31


Sulfate, as SO4 [mg/l]

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MW-3-101

MW-3-102

MW-3-103 (BG)

MW-3-104 (BG)

PZ3-31


Total Dissolved Solids [mg/l]

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MW-3-101

MW-3-102

MW-3-103 (BG)

MW-3-104 (BG)

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pH, field [s.u.]

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8.0

MW-3-100

MW-3-101

MW-3-102

MW-3-103 (BG)

MW-3-104 (BG)

PZ3-31

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