[me homer city - epa archives · [me homer city generation l.p 1750 power plant road homer city, pa...

$: [ME HOMER CITY - EPA Archives · [ME HOMER CITY GENERATION l.P 1750 Power Plant Road Homer City, PA 15748 An ED1SOI'V aVTER/\'A TlONAL Company VIA OVERNIGHT DELIVERY Mr. Richard Kinch$

[ME HOMER CITYGENERATION l.P

1750 Power Plant Road

Homer City, PA 15748

An ED1SOI'V aVTER/\'A TlONAL Company

VIA OVERNIGHT DELIVERY

Mr. Richard Kinch

U.S. Enviromnental Protection AgencyTwo Potomac Yard

2733 South Crystal Drive5th Floor, N-5738Arlington, VA 22202-2733

February 1, 2010

Subject: Request for Information Under Section 104(e) of the ComprehensiveEnvironmental Response, Compensation, and Liability Act, 42 U.S.C. 9604(e)

Dear Mr. Kinch:

This letter, which is submitted on behalf ofEME Homer City Generation L.P. ("EME HCG"),the operator of the Homer City Generating Station ("Station"), responds to the U.S.Enviromnental Protection Agency's December 29,2009 "Request for Information Under Section104(e) of the Comprehensive Enviromnental Response, Compensation, and Liability Act, 42U.S.C. 9604(e)" ("Request"). The Request, which was received by the Station on January 2,2010, seeks voluminous information regarding the Station's

surface impoundments or similar diked or bermed managementunit(s) or management units designated as landfills which receiveliquid-borne material from a surface impoundment used for storageor disposal of residuals or by-products from the combustion ofcoal, including, but not limited to, fly ash, bottom ash, boiler slag,or flue gas emission control residuals

in the form often specific questions. EME HCG has made a diligent effort to compile therequested information in the limited time period provided to respond to the Request.

As an initial matter, the Station generates coal combustion bypro ducts ("CCBs") and disposes ofits fly ash in dry form in its permitted ash disposal landfill or uses it for approved beneficial uses,such as for conditioning coal refuse. The bottom ash is temporarily stored in settling ponds, andthen dewatered prior to disposal or beneficial use. For purposes of responding to this Request,EME HCG has interpreted the above-quoted phrase from the Request to mean any surfaceimpoundment that directly receives coal combustion by-products in a liquid-borne manner (i.e.,water mixed with ash) from the coal combustion process in the Station's boilers, as well as any

DB2/21528989.3

Mr. Richard Kinch

February 1,2010Page 2

subsequent surface impoundments or ponds through which this mixture of CCBs and water maypass before the water exits the management units via NPDES or other permitted dischargepoints. This includes units associated with the management of the Station's wastewater andCCBs, as well as its coal refuse. With regard to coal refuse, information is provided becauseCCBs (i.e., fly ash) are beneficially used to condition the coal refuse in accordance with theStation's coal refuse disposal permit. EME RCG is not providing any information relating tostormwater retention ponds, coal pile runoff retention ponds, or other similar ponds that maycontain incidental amounts of CCBs that have been transmitted via precipitation or as fugitivedust. These ponds were neither designed nor intended for temporary or long-term storage ordisposal of CCBs.

The "management units" for which information is provided are not used for the disposal or longterm storage of liquid-borne CCBs. Rather, these units are components of comprehensivesystems for the management of wastewater, stormwater, CCBs, and coal refuse generated at theStation and are used primarily for the treatment or storage of wastewater, leachate andstormwater (collectively, "wastewaters") prior to discharge at permitted outfalls (e.g., 004 and005). The CCBs that are contained in these units settle out from these wastewaters, the units areultimately dewatered, and the sediments containing CCBs are then disposed in the Station's ashlandfill or its coal refuse disposal site. The ponds are typically cleaned out a minimum of onceor twice a year.

As part of its review of this information, EPA should note that the "management units" and thesystems of which they are components are extensively regulated by the Pennsylvania Departmentof Environmental Protection ("PADEP") under five major programs. These include the NationalPollutant Discharge Elimination System and surface mining primacy programs delegated to thestate by EPA and the federal Office of Surface Mining, respectively, as well as longstanding andcomprehensive state programs relating to the construction and operation of wastewater treatmentfacilities, the management of residual wastes (i.e., CCBs) and the construction and operation ofdams and impoundments. In particular, the Station's coal refuse and ash disposal facilities aresubject to extensive design, operational and performance standards, and PADEP inspects thesefacilities on a monthly basis. Moreover, the Station is required to provide and maintain multimillion dollar collateral bonds in the form ofletters of credit to assure performance of theenvironmental obligations under its ash and coal refuse disposal permits. EPA should also notethat only one of the ponds is constructed and operated in such a fashion that it is subject toregulation by PADEP's Bureau of Waterways Engineering, Division of Dam Safety.

In providing this response EME RCG expressly reserves its right to assert at any future date anyapplicable privilege regarding the information, as well as any relevant objections to the scopeand reasonableness ofEP A's Request. Neither the fact nor the substance of this response shallbe construed in any way as an admission of any liability or as a waiver of EME RCG's rights,claims, or defenses.

DB2/21528989.3

Mr. Richard Kinch

February 1, 2010Page 3

EME RCG's response is presented in the form of an Excel spreadsheet for each "managementunit." A summary table listing each unit by type, material contained, and program under whichit is regulated is included. The associated certification statement is attached.

If you have any questions regarding EME RCG's response, please contact Joseph Stanek at724.479.6256 or Jeffrey Bard at 630.771.7905.

Sincerely,

~f<.~~eph R. StanekEnvironmental Manager

DB2I21528989.3

I certify that the information contained in this response to EPA's request forinformation and the accompanying documents is true, accurate, and complete. Asto the identified portions of this response for which I cannot personally verifytheir accuracy, I certify under penalty of law that this response and all attachmentswere prepared in accordance with a system designed to assure that qualifiedpersonnel properly gather and evaluate the information submitted. Based on myinquiry of the person or persons who manage the system, those persons directlyresponsible for gathering the information, the information submitted is, to the bestof my knowledge, true, accurate, and complete. I am aware that there aresignificant penalties for submitting false information, including the possibility offines and imprisonment for knowing violations.

Signature: {?A. ~Name: Cpilv fl Ct-,q~/!=Title: W.::. (2... {Y/N CRt.! £.tl-

This request has been reviewed and approved by the Office of Management and Budgetpursuant to the Paperwork Reduction Act, 44 U.S.C., 3501-3520.

Please send your reply to:

Mr. Richard Kinch

US Environmental Protection Agency (5306P)1200 Pennsylvania Avenue, NWWashington, DC 20460

If you are using overnight or hand delivery mail, please use the following address:

Mr. Richard Kinch

US Environmental Protection AgencyTwo Potomac Yard

2733 S. Crystal Dr.5th Floor; N-5738Arlington, VA 22202 2733

TABLE 1HOMER CITY GENERATING STATION PONDS AND IMPOUNDMENTS

No

Ash Recycle Pond #2

Short-term ash storageAsh/waterNPDESNo

Ash Recycle Pond #3


Ash Recycle Pond #4


Coal Refuse Site - Stage I & II

Stormwater runoff from Coal Refuse SiteStormwater runoff, sediment, ashPADEP Bureau of MiningSedimentation Pond

(only during storm events). Leachateresiduals. Leachate and associated& ReclamationINofrom Coal Refuse Site.

leachate solids.

Coal Refuse Site - Stage III & IV I Stormwater runoff from Coal Refuse Site

Stormwater runoff, sediment, ashPADEP Bureau of MiningIV Surge Pond

(only during storm events). Leachateresiduals. Leachate and associated& Reclamationfrom Coal Refuse Site.

leachate solids.PADEP Bureau of

Waterways Engineering - IYes

Division of Dam Safety (Class B - Low Hazard)

Coal Refuse Site - Storage

Stormwater runoff from Coal Refuse SiteStormwater runoff, sediment, ashPADEP Bureau of MiningPond #1

(only during storm events). Leachateresiduals. Leachate and associated& ReclamationI

Nofrom Coal Refuse Site.

leachate solids.

Coal Refuse Site - Storage

Stonnwater runoff from Coal Refuse SiteStormwater runoff, sediment, ashPADEP Bureau of MiningPond #2


leachate solids.

Coal Refuse Site - Leachate Pump

Stormwater runoff from Coal Refuse SiteStormwater runoff, sediment, ashPADEP Bureau of MiningPond

(only during storm events). Leachateresiduals. Leachate and associated& ReclamationI

Nofrom Coal Refuse Site.

leachate solids.

Coal Refuse Site - Small Sediment

Stormwater runoff from Coal Refuse SiteStormwater runoff, sediment, ashPADEP Bureau of MiningTrap


leachate solids.

TABLE 1HOMER CITY GENERATING STATION PONDS AND IMPOUNDMENTS (cont.)

Ash Disposal Site - StormwaterI Stormwater runoff from Ash Disposal

Stormwater runoff, sediment, ashSurge Pond

Site (only during storm events).residuals. Leachate solids.& Waste ManagementINo

Ash Disposal Site - Treatment

I Stormwater runoff from Ash DisposalStormwater runoff, sediment, ashPADEP Bureau of Land

Pond #1Site (only during storm events). Leachateresiduals. Leachate and associated& Waste ManagementINo

from Ash Disposal Site.leachate solids.

Ash Disposal Site - Treatment

I Stormwater runoff from Ash DisposalStormwater runoff, sediment, ashPADEP Bureau of Land

Pond #2Site (only during storm events). Leachateresiduals. Leachate and associated& Waste ManagementINo


I Ash Disposal Site - Polishing PondI Stormwater runoff from Ash DisposalStormwater runoff, sediment, ashPADEP Bureau of Land

Site (only during storm events). Leachate

residuals. Leachate and associated& Waste ManagementINo


COMPANYEME Homer City Generation L.P.

PLANTHomer City Generating Station

ASH MANAGEMENT UNITAsh Recycle Pond #1

~UESTION 1 - NATIONAL lNVENTORY OF DAMS

A. Dam hazard rating

None. This impoundment does not meet the criteria for regulation

by PADEP's Division of Dam Safety, Bureau of WaterwaysEnginnering.B. Hazard rating established by

N/Ar. Basis for hazard ratin!!

N/AD. Regulated by (Agency)

The impoundment is regulated by PADEP's Bureau of Water

Standards and Facility Regulation under NPDES Permit PAOO05037and various Water Quality Management Part II Permits relating tothe construction and operation of wastewater treatment works.E. If no rating, note the fact

No Rating

OUESTION 2 - COMMISSIONED 1EXPANDEDA. Year management unit commissioned

1973B. Year management unit expanded

Ash Recycle Pond #1 has not been expanded

QUESTION 3 - MATERIALS CONTAINED (mark all that apply)

A. FlvashYes - Temporarily & typically less than one year.

B. Bottom AshYes - Temporarily & typically less than one year.

C. Boiler SlagYes - Temporarily & typically less than one year.

D. Flue Gas Emission Control Residuals E. Other (Specify)Yes - Temporarily & typically less than one year. Sludges from

potable water, cooling tower and industrial waste treatment.

QUESTION 4 - PROFESSIONAL ENGINEER (P.E.) INVOLVEMENT

A. Designed by a P. E.

Yes - Gilbert & AssociatesB. Constructed under supervision ofP.E.

IYes - Gilbert & Associates

C. Inspection/monitoring safety under supervision ofP.E.Yes - Please refer to Question 5.

QUESTION 5 - COMPANY INSPECTIONS

A. Date of last safety assessment/evaluation

On-going visual insnectionsB. Credentials of evaluator of assessment/evaluation

Professional Engineer - Commonwealth of PennsylvaniaC. Actions taken/planned by facility personnel as a result

Please refer to Ouestion 8.C & D

D. Credentials of personnel performing corrective actions

Qualified contractors

E. Next scheduled assessment/evaluation

On-going

QUESTION 6 - STATE OR FEDERAL OFFICIAL INSPECTION

A. Last insnection/evaluation

6/24/2009

B. Date of next inspection/evaluation

As determined byPADEP.

C. Name of Agency conducting inspection/evaluation

PADEP's Bureau of Water Standards and Facility Regu1ation

D~ COpy of most recent official inspection/evaluation

See Attachment A

QUESTION 7 - SAFETY ISSUES IDENTIFIED BY STATE OR FEDERAL AGENCY

A. Safety issue(s) from assessment/evaluations w/in past year

No

B. Actions taken to resolve safety issuer s)

N/A

C. Documentation attached

N/A

K)UESTION 8 - SIZE AND VOLUME

.--.------A. Surface area (acres)0.58 acre

B. Storage capacity190,800 cubic feet

C. Volume of material currently stored

The volume of material is monitored by on-going visual inspections

performed by plant personnel. Removal of material from theimpoundments is scheduled based on these inspections .. Thematerial removed is tranported via dump truck to the Station'spermitted ash landfill site for disposal. After cleaning, the emptiedimpoundment is surveyed. In 2009, this surface impoundment wascleaned two (2) times and a total of9,257 cubic yards of materialwas removed The most recent cleaning and survey event wascompleted on Sept 21, 2009.D. Date volume measurement (s) taken

The volume of material is monitored on an on-going basis. See

I Question 8.C for this procedure.E. Maximum height (feet) of embankment

9 feet

QUESTION 9 - SPILLS OR UNPERMITTED RELEASES IN LAST 10 YEARS

~. Historv of spills or unpermitted releases w/in last ten years

No releases or spills

B. Were these spillslunpermitted releases reported to al!encies

N/A

QUESTION 10 - OWNER 1OPERATOR

A. IdentifY all current legal owner(s)EME Homer City Generation LP.

lB. IdentifY all current legal oneratotis)EME Homer City Generation LP.



<\SHMANAGEMENT UNITAsh Recycle Pond #2

QUESTION 1 - NATIONAL INVENTORY OF DAMSA. Dam hazard rating

None. This impoundment does not meet the criteria for regulationby PADEP's Division of Dam Safety, Bureau of WaterwaysEnginnering.B. Hazard rating established by

N/AC. Basis for hazard rating

N/AD. Regulated by (Agency)

The impoundment is regulated by PADEP's Bureau of WaterStandards and Facility Regulation underNPDES Permit PAOO05037and various Water Qulaity Management Part II Permits relating tothe construction and operation of wastewater treatment works.

E. If no rating, note the fact

No Rating

QUESTION 2 - COMMISSIONED / EXPANDED

---A. Year management unit commissioned 1973B. Year management unit expanded

Ash Recycle Pond #2 has not been expanded

K)UESTION 3 - MATERIALS CONTAINED (mark all that apply)A. Flvash

Yes - Temporarily & typically less than Oneyear.B. Bottom Ash

Yes - Temporarily & typically less than one year.C. Boiler Slag

Yes - Temporarily & typically less than one year.D. Flue Gas Emission Control Residuals Yes - Temporarily & typically less than one year. Sludges fromE. Other (SpecifY)

lootable water coolin!?tower and industrial waste treatment

QUESTION 4 - PROFESSIONAL ENGINEER (P.E.) INVOLVEMENTA. Designed by a P.E.

Yes - Gilbert & AssociatesB. Constructed under suoervision ofP.E.

Yes - Gilbert & AssociatesC. Insoection/monitoring safety under supervision ofP.E.

Yes - Please refer to Question 5.


--A. Date oflast safety assessment/evaluation On-going visual inspectionsB. Credentials of evaluator of assessment/evaluation

Professional Engineer - Commonwealth of PennsylvaniaC. Actions taken/planned by facility oersonnel as a result

Please refer to Question 8.C & DD. Credentials of personnel performing corrective actions

IQualified contractorsE. Next scheduled assessment/evaluation

On-going

K)UESTION6 - STATE OR FEDERAL OFFICIAL INSPECTIONA.La~insoection/evaluation

6/24/2009B. Date of next insoection/evaluation

As determined bv PADEP.C. Name of Agency conducting inspection/evaluation

PADEP's Bureau of Water Standards and Facility RegulationD. CoPYof most recent official inspection/evaluation

See Attachment A


-A. Safety issue(s) from assessment/evaluations w/in past year NoB. Actions taken to resolve safety issue(s)

N/AC. Documentation attached

N/A

OUESTION 8 - SIZE AND VOLUME

--A. Surface area (acres)0.59 acre

B. Storage capacity210,200 cu ft

C. Volume of material currently storedThe volume of material is monitored by on-going visual inspections

performed by plant personnel. Material is removed from theimpoundment based on these inspections. After the material isremoved, it is transported via dump truck to the Station's permittedash landfill for disposal. After cleaning, the emptied impoundmentis surveyed. In 2009, this surface impoundment was cleaned two (2times, and a total of7,528 cubic yards of material was removed.The most recent cleaning and survey event was completed onOctober 22 2009.D. Date volume measurement(s) takenThe volume of material is monitored on an on-going basis. See

100estion 8.C for this procedure.E. Maximum height (feet) of embankment

9 feet

QUESTION 9 - SPILLS OR UNPERMITTED RELEASES IN LAST 10 YEARSA. History of spills or unoermitted releases w/in last ten years

No releases or spillsB. Were these spills/unpermitted releases reported to agencies

N/A

OUESTION 10 - OWNER/OPERATOR

-"- .. -"A. IdentifYall current legal owner(s) EME Homer City Generation L.P.B. IdentifYall current legal ooerator(s)

EME Homer City Generation L.P.



ASH MANAGEMENT UNITAsh Recycle Pond #3


None. 1bis impoundment does not meet the criteria for regulation by

PADEP's Division of Dam Safety, Bureau ofWatelWaysEmnnnerimz.B. Hazard rating established by

N/A

C. Basis for hazard rating

N/A

D. Regulated by (Agency)


Standards and Facility Regulation under NPDES Permit PAOO05037and various Water Quality Management Part II Permits for theconstruction and operation of wastewater treatment works.E. If no rating, note the fact

No Rating


--A. Year management unit commissioned 11973

B. Year management unit expandedIAsh Recycle Pond #3 has not been expanded


A.Flyash

Yes - Temporarily & typically less than one year.

B. Bottom Ash

Yes - Temporarily & typically less than one Year.

C. Boiler Slag

Yes - Temporarily & typically less than one year.D. Flue Gas Emission Control Residuals Yes - Temporarily & typically less than one year. Sludges fromE. Other (Specify)

otable water, cOOlinlZtower and industrial waste treatment


A. Designed by a P .E.


B. Constructed under supervision ofP.E.


C. Inspection/monitoring safety under supervision ofP.E.

1Yes - Please refer to Question 5.


A. Date of last safety assessment/evaluationOn-going visual inspections

B. Credentials of evaluator of assessment/evaluationProfessional Engineer - Commonwealth of Pennsylvania

C. Actions taken/planned by facility personnel as a result

Please refer to Ouestion 8.C & D


~ualified contractors

E. Next scheduled assessment/evaluation

On-lZoinlZ


A. Last inspection/evaluation

6/24/2009


As determined by PADEP

C. Name of Allency conductinll inspection/evaluation

PADEP's Bureau of Water Standards and Facility Regulation

D. CoPy of most recent official inspection/evaluation

See Attachment A

OUESTION 7 - SAFETY ISSUES IDENTIFIED BY STATE OR FEDERAL AGENCYA. Safety issue{s) from assessment/evaluations w/in past year

INo

B. Actions taken to resolve safety issue{s)

IN/A

C. Documentation attachedIN/A

QUESTION 8 - SIZE AND VOLUME

-A. Surface area (acres) 0.57 acre

B. Storage capacity

204.500 cubic feet



performed by plant personnel. Material is removed from theimpoundment based on these inspections. The materials removed aretransported via dump truck to the Station's permitted ash landfill fordisposal. After cleaning, the emptied impoundment is surveyed. In2009. this surface impoundment was cleaned one (I) time in May2009. 1bis cleaning was coordinated with the cleaning of AshRecycle Pond 4. During the cleaning event, a total of 6, 199 cubicyards of material was removed from Ash Recycle Ponds 3 and 4.

D. Date volume measurement(s) taken


Ouestion 8.C for this orocedure.E. Maximum heiJlht (feet) of embankment

9 feet

QUESTION 9 - SPILLS OR UNPERMITTED RELEASES IN LAST 10 YEARSA. History of spills or unpermitted releases wfin last ten years

INo releases or spills

B. Were these spills/unpermitted releases reported to agencies

N/A

QUESTION 10 - OWNER/OPERATOR

-A. Identify all current lelia! owner(s) EME Homer City Generation L.P.

B. Identify all current legal operator(s)


COMPANYEME Homer City Generation LP.


4.SH MANAGEMENT UNIT

Ash Recycle Pond #4

QUESTION 1 - NATIONAL INVENTORY OF DAMS

A Dam hazard rating

None. This impoundment does not meet the criteria for regulation

by PADEP's Division of Dam Safety, Bureau of WaterwaysEnginnering.B. Hazard rating established by

N/A

C. Basis for hazard rating

N/A

D. Regulated by (Agency)


Standards and Facility Regulation under NPDES Permit PAOO05037and various Water Quality Management Part II Permits for theconstruction and ooeration of treatment works.E. Ifno rating, note the factNo Rating

QUESTION 2 - COMMISSIONED I EXPANDED

--A Year management unit commissioned11973

B. Year management unit expanded1Ash Recycle Pond #3 has not been expanded


A Flyash

Yes - TempOrarily & typically less than one year.

B. Bottom Ash

Yes - TempOrarily & typically less than one Year.

C. Boiler Slag

Yes - TempOrarily & typically less than one year.D. Flue Gas Emission Control Residuals E. Other (SpecifY)

Yes - Temporarily & typically less than one year. Sludges frompOtable water cooling tower and industrial waste treatment.


--A Designed by a P.E. IYes - Gilbert & Associates

B. Constructed under suoervision of P .E.

1Yes - Gilbert & Associates

C. Inspection/monitoring safety under supervision of P.E.

1Yes - Please refer to Question 5.


---

A Date oflast safety assessment/evaluationOn-going visual inspections



Please refer to Question 8.C & D


Qualified contractorsE. Next scheduled assessment/evaluation

On-going


-A Last inspection/evaluation 6/24/2009


To be determined by PADEP

C. Name of Agency conducting inspection/evaluation

PADEP - Bureau of Water Ouality

D. Copy of most recent official inspection/evaluation

See Attachment A


A Safety issue(s) from assessment/evaluations w/in past year

[No

B. Actions taken to resolve safety issue(s)

IN/A


IN/A


--A Surface area (acres)0.56 acre

B. Storage capacity

200,200 cu ft



performed by plant personnel. Removal of material is scheduledbased on these inspections. The material removed is transported viadump truck to the Station's permitted ash landfill for disposal. AfterIcleaning, the emptied impoundment is surveyed. In 2009, thissurface impoundment was cleaned one (1) time in May 2009. Thiscleaning was coordinated with the cleaning of Ash Recycle Pond 3.During the cleaning event, a total of 6, 199 cubic yards of materialwas removed from Ash Recycle Ponds 3 and 4.



Ouestion 8.C for this procedure.E. Maximum heilZht (feetl of embankment

9 feet


-----A History of spills or unpermitted releases w/in last ten yearsNo releases or spills

B. Were these spillslunpermitted releases reported to agencies

N/A

QUESTION 10 - OWNER I OPERATOR

--A Identify all current legal owner(s)EME Homer City Generation LP.

B. IdentifY all current legal operator(s)

EME Homer City Generation LP.



ASH MANAGEMENT UNITCoal Refuse Disposal Site - Stage I & II Pond



None. This impoundment is not subject to regulation by PADEP's Divisionof Dam Safety, Bureau of Waterways Emrineering.B. Hazard rating established by


N/A

D. Regulated by (Agency)This surface impoundment is part of the Station's permitted Coal Refuse

Disposal Site (PADEP #32753702) and is regulated by PADEP's Bureau ofMining & ReclamationE. If no rating, note the factNo Rating

QUESTION 2 - COMMISSIONED I EXPANDEDA. Year management unit commissioned

Prior to 1988.---

B. Year mlltllU!ement unit exnanded

N/A

IQUESTION 3 - MATERIALS CONTAINED (mark all that apply)A. Flyash


Fly Ash is approved for beneficial use in stabilizing coal refuse as part of theStation's Coal Refuse Disposal Permit (PADEP #32753702).B. Bottom Ash

C. Boiler SlagD. Flue Gas Emission Control ResidualsE. Other (Specify)

Yes - Temporarily & typically less than one year. Other materials include coalrefuse & leachate solids

QUESTION 4 - PROFESSIONAL ENGINEER (p.E.) INVOLVEMENT

A. Desilll1ed by a P.E.

Yes - Schneider

B. Constructed under supervision of P .E.

Yes - Schneider

C. Inspection/monitoring safety under supervision of P .E.Yes - Please refer to Question 5.



9/25/2009B. Credentials of evaluator of assessment/evaluation

Professional Engineer - Commonwealth of Pennsylvania


1. Check outlet of decant pipe. (Completed)2. Monitor area proximal to emerl!:enev spillway. (Completed)D. Credentials of personnel performing corrective actions

Qualified ContractorE. Next scheduled assessment/evaluation

1st Quarter 2010



12/16/2009

B. Date of next inspection/evaluationJanuary 2010

C. Name of Agency conducting insoection/evaluation

PADEP's Bureau of Mining & Reclamation

D. Conv of most recent official inspection/evaluation

See Attachment B


--A. Safety issuers) from assessment/evaluations w/in past year No

B. Actions taken to resolve safety issuers)

N/AC. Documentation attached

N/A


-A. Surface area (acres) 1 acreB. Storage capacity

566.634 cu ft



performed by plant personnel, and removal of material is scheduled based onthese visual inspections. In 2009, the network of surface impoundments in thCoal Refuse Disposal Site was cleaned two (2) times. The most recentcleaning occuning in September 2009. During the cleaning events care istaken not to disturb the PVC liner. Material removed from theseimpoundments is transported via dump truck to the permitted Coal RefuseDisposal Site.D. Date volume measurement(s) taken

IThe volume of material is monitored on an on-going basis. See Question 8.C

Ifor this procedure.E. Maximum heiRht (feet) of embankment

22 feet

QUESTION 9 - SPILLS OR UNPERMITTED RELEASES IN LAST 10 YEARSA. History of spills or unpermitted releases w lin last ten Years


B. Were these spills/unpermitted releases reoorted to agencies

N/A


--A. Identify all current legal owner(s) EME Homer City Generation L.P.B. Identify all current legal operator( s)




I\SH MANAGEMENT UNITCoal Refuse Disposal Site - Stage III & IV Pond

A. Dam hazard ratiIu!

Class B, Catel1;orv3 - Low Hazard (#D32-084)B. Hazard ratinl1;established by

PADEP's Bureau of Waterways EnJtineerinl1;,Division of Dam SafetyC. Basis for hazard ratin~

Size, heil!:itt,and ootential for downstream damage.

The impoundment is regulated by the PADEP's Bureau of Waterways

Engineering, Division of Dam Safety. This surface impoundment is part ofD. Reszulated bv (A2encv)

the Station's permitted Coal Refuse Disposal Site (PADEP #32753702) and is

reszulated by PADEP's Bureau ofMininl1; & Reclamation.E. If no ratin2, note the fact

N/A


--.----.--A. Year mana2ement unit commissioned 11991B. Year manal1;ement unit exoanded

IN/A

QUESTION 3 - MATERIALS CONTAINED (mark aU that apply) IYes - Temporarily & typically less than one year. ,--.-----

A. FlyashPADEP has approved the beneficial use of fly ash to stabilize the coal refuseas part of the Station's Coal Refuse Disposal Permit (PADEP #32753702).

B. Bottom AshC. Boiler SlagD. Flue Gas Emission Control ResidualsE. Other (Specify)

Yes - Temporarily & typically less than one year. Other materials include coalrefuse & leachate solids

K>UESTION 4 - PROFESSIONAL ENGINEER (P .E,) INVOLVEMENT

.-----A. Desi~ed by a P.E. IYes - Gilbert/Commonwealth Inc.


IYes - Gilbert/Commonwealth Inc.

C. Jnspection/monitoring safety under supervision ofP.E.IYes - Please refer to Question 5.

QUESTION 5 - COMPANY INSPECTIONSA. Date of last safety assessment/evaluation

12/31/2009 by EME Plant PersonnelB. Credentials of evaluator of assessment/evaluation

United States - Dept. of Interior Dam Safety Training Seminar

C. Actions takenlolanned bv facility personnel as a result

No corrective action reauired

D. Credentials of oersonnel oerfOrnllnl1;corrective actions

N/AE. Next scheduled assessment/evaluation

Next Quarterly assessment is scheduled in 1st Quarter 2010

K>UESTION 6 - STATE OR FEDERAL OFFICIAL INSPECTION

--_ ..~A. Last inspection/evaluation PADEP - Bureau of Mining & Reclamation, 12/16/2009PADEP - Bureau of Waterways Engineering, Division of Dam Safety-6/11/99B. Date of next inspection/evaluation

PADEP - Bureau of Mining & Reclamation- January 2010PADEP - Division of Dam Safety, Bureau of Waterways Engin=ing - to bedetermined by Bureau of Waterwavs En2ineerin2C. Name of Al1;encvconducting insoection/evaluation

PADEP - Bureau of Mininl1;& Reclamation


See Attachments B (Bureau of Mining & Reclamation) and C (Bureau ofWaterways Engineering)

K>UESTION 7 - SAFETY ISSUES IDENTIFffiD BY STATE OR FEDERAL AGENCY

A. Safety issue(s) from assessment/evaluations w/in past year

[No


IN/AC. Documentation attached

IN/A


A. Surface area (acres)

1.54 acre

B. Storage capacity1,142,450 cu ft

C. Volume of material currently storedThe volume of material is monitored by on-going visual inspections

performed by plant personneL Removal of material from the impoundment isscheduled based on these visual inspections. In 2009, the network of surfaceimpoundments in the Coal Refuse Disposal Site was cleaned two (2) times.with the most recent cleaning occurring in September 2009. During thecleaning events care is taken not to disturb the PVC liner. Material removedfrom these impoundments is transported via dump truck to the permitted CoalRefuse Disposal Site.


The volume of material is monitored on an on-going basis. See Question 8.Cfor this orocedure.E. Maximum heil!:itt(feet) of embankment

22 feet

()UESTION 9 - SPILLS OR UNPERMITTED RELEASES IN Ll\ST 10 YEARSA. History of spills or unpermitted releases w/in last ten years

INo releases or spills

B. Were these spills/unpermitted releases reported to agenciesIN/A


A. Identify all current legal owner(s)IEME Homer City Generation L.P.

B. Identify all current le2a1 ooerator(s)

IEME Homer City Generation L.P.

COMPANY EME Homer City Generation L.P.PLANT

Homer City Generating StationASH MANAGEMENT UNIT

Coal Refuse Disposal Site - Storage Pond #1

QUESTION 1 - NATIONAL INVENTORY OF DAMSNone, This impoundment is not subject to regulation by PADEP's BureauA. Dam hazard rating

of Waterways Engineering, Division of Dam Safety.B. Hazard rating established by

N/A

C. Basis for hazard ratingN/A

This surface impoundment is part of the Station's permitted Coal RefuseDisposal Site (PADEP #32753702) and is regulated by PADEP's BureauD. Regulated by (Agency)ofMinine: & Reclamation

E. If no rating, note the factNo Rating

QUESTION 2 - COMMISSIONED 1EXPANDED

.-A. Year management unit commissioned2003

B. Year management unit expandedIN/A


--Yes - Temporarily & typically less than one year.Fly Ash is approved for beneficial use to stabilize coal refuse as part ofA. Flyash

the Station's Coal Refuse DiSpOsal Permit (PADEP #32753702).B. Bottom Ash C. Boiler SlagD. Flue Gas Emission Control Residuals Yes - Temporarily & typically less than one year. Other materials includeE. Other (Specify)

coal refuse & leachate solids

QUESTION 4 - PROFESSIONAL ENGINEER (p.E.) INVOLVEMENT

-.--------- ..----------A. Designed by a P.E. IYes- Worley ParsonsB. Constructed under supervision ofP.E.

IYes- Worley Parsons


IYes - Please refer to Question 5.


..-----------A. Date ofJast safety assessment/evaluation9/25/2009



No comments requiring corrective action.D. Credentials of personnel performing corrective actions

N/A

E. Next scheduled assessment/evaluationIst Quarter 20 I0

~UESTION 6 - STATE OR FEDERAL OFFICIAL INSPECTIONA. Last inspection/evaluation

12/16/2009

B. Date of next inspection/evaluationJanuary 20 I0

C. Name of Agency conducting inspection/evaluationPADEP's Bureau of Mining & Reclamation


See Attachment B


-.•-----A. Safety issue(s) from assessment/evaluations w/in past year

INo


IN/A


N/A

QUESTION 8 - SIZE AND VOLUMEA. Surface area (acres)

1.26 acre

B. Storage capacity96,102 cu ft

The volume of material is monitored by on-going visual inspectionsperformed by plant personnel. Removal of material is scheduled based onthese inspections. In 2009, the network of surface impoundments in theCoal Refuse Disposal Site was cleaned two (2) times. The most recentcleaning occurred in September 2009. During the cleaning events care istaken not to disturb the PVC liner. Material removed from theseimpoundments is transported via dump truck to the Station's permittedC. Volume of material currently stored

Coal Refuse Disposal Site.

The volume of material is monitored on an on-going basis. See QuestionD. Date volume measurement(s) taken

8.C for this procedure.E. Maximum height (feet) of embankment

10 feet


.-A. History of spills or unpermitted releases w/in last ten yearsINo releases or spills


IN/A

QUESTION 10 - OWNER 1OPERATOR

.---.-A. Identify all current legal owner(s) IEME Homer City Generation L.P.

B. Identify aU current legal operator(s)




ASH MANAGEMENT UNITCoal Refuse Disposal Site - Storage Pond #2

QUESTION 1 - NATIONAL lNVENTORY OF DAMS

A. Dam hazard rating None. The impoundment is not subject to regulation by PADEP'sBureau of Waterways Engineering. Division of Dam Safety.B. Hazard rating established bv


N/A

D. Regulated by (Agency)The surface impoundment is part of the Station's permitted Coal

Refuse Disposal Site (P ADEP #32753702) and is regulated byPADEP's Bureau of Mining & ReclamationE. If no ratinlt. note the factNo Rating

QUESTION 2 - COMMlSSIONED 1EXPANDEDA. Year manalZement unit commissioned

/2003B. Year management unit exoanded

IN/A

OUESTION 3 - MATERIALS CONTAINED (mark all that apply)

A. FlyashYes - Temporarily & typically less than one year.

Fly Ash is approved for beneficial use in stabilizing coal refuse aspart of the Station's Coal Refuse Disposal Permit (PADEP#327537021.B. Bottom Ash C. Boiler SlaiZD. Flue Gas Emission Control ResidualsE. Other (Specify)Yes - Temporarily & typically less than one year. Other materials

include coal refuse & leachate solids

QUESTION 4 - PROFESSIONAL ENGINEER lP.E.l INVOLVEMENT

A. Designed bv a P.E.!Yes- Worley Parsons

B. Constructed under suoervision of P .E.IYes- Worley Parsons

C. Insoection/monitorinlt safety under supervision ofP.E.

IYes - Please refer to Question 5.




Professional Enl!ineer - Commonwealth of Pennsvlvania

C. Actions taken/olanned bv facility personnel as a result

No comments reaniring corrective action.

D. Credentials of oersonnel oerforming corrective actions


I st Ouarter 20 10



12/16/2009


January 2010

C. Name of Altency conductinlt inspection/evaluationPADEP's Bureau of Mining & Reclamation


See Attachment B

OUESTION 7 - SAFETY ISSUES IDENTIFIED BY STATE OR FEDERAL AGENCYA. Safety issue(s) from assessment/evaluations w/in oast vear

INo


IN/A


IN/A



0.84 acre

B. Storage capacity

478.473 cu ft



performed by plant personnel. Removal of material is scheduledbased on these inspections. In 2009. the network of surfaceimpoundments in the Coal Refuse Disposal Site was cleaned two (2)times. The most recent cleaning occurred in September 2009.During the cleaning events care is taken not to disturb the PVC liner.Material removed from these impoundments is transported via dumptruck to the permitted Coal Refuse Disposal Site.


The volume of material is monitored on an on-going basis. SeeOuestion 8.C for this orocedure.E. Maximum height (feet) of embankment

10 feet


A. History of spills or unpermitted releases wfin last ten years

/No releases or spills

B. Were these spills/unoermitted releases reported to a!Zencies

IN/A


A. Identify all current 1el!al owner( s)


B. Identify all current legal ooerator(s)

fEME Homer City Generation L.P.



ASH MANAGEMENT UNITCoal Refuse Disposal Site - Leachate Pump Pond

OUESTION 1 - NATIONAL INVENTORY OF DAMS


None. The impoundment is not subject to regulation by PADEP's Bureau

of Waterways Engineering, Division of Dam Safety.B. Hazard rating established by

N/A

. Basis for hazard rating

N/A

D. Regulated by (Agency)This surface impoundment is part of the Station's Coal Refuse Disposal

Site (PADEP #32753702) and is regulated by PADEP's Bureau of Mining& ReclamationE. If no rating, note the factNo Rating

OUESTION 2 - COMMISSIONED 1EXPANDED

---A. Year management unit commissionedIPrior to 1988

B. Year management unit expanded

IN/A

QUESTION 3 - MATERIALS CONTAINED (mark all that appJv)

A.FlyashYes - Temporarily & typically less than one year.

Fly ash has been approved for beneficial use in stabilizing coal refuse aspart of the Station's Coal Refuse Disposal Permit (PADEP #32753702).B. Bottom Ash C. Boiler Slag

D. Flue Gas Emission Control ResidualsE. Other (Specify)

Yes - Temporarily & typically less than one year. Other materials includecoal refuse & leachate solids

QUESTION 4 - PROFESSIONAL ENGINEERCP.K) INVOLVEMENTA. Designed by a P.E.

Yes - Schneider

B. Constructed under supervision ofP.E.

IYes - Schneider


IYes - Please refer to Ouestion 5.


.A. Date oflast safety assessment/evaluation 9/25/2009B. Credentials of evaluator of assessment/evaluation

Professional Engineer - Commonwealth of Pennsylvania

C. Actions taken/planned by facility oersonnel as a result

No comments reqniring corrective action.


N/A

E. Next scheduled assessment/evaluation1st Quarter 2010

OUESTION 6 - STATE OR FEDERAL OFFICIAL INSPECTION

--A. Last inspection/evaluation12/16/2009


January 2010C. Name of Agency conducting inspection/evaluation


D. Copy of most recent official insoection/evaluation

See Attachment B

OUESTION 7 - SAFETY ISSUES IDENTIFIED BY STATE OR FEDERAL AGENCYA. Safety issue(s) from assessment/evaluations w/in past vear

INo


IN/A


IN/A


-----.-A. Surface area (acres)0.26 acre

B. Storage capacity

44,916 cu ft



performed by plant personnel. Removal of material is scheduled'based onthese inspections. In 2009, the network of surface impoundments in theCoal Refuse Disposal Site was cleaned two (2) times. The most recentcleaning occurring in September 2009. During the cleaning events careis taken not to disturb the PVC liner. Material removed from theseimpoundments is transported via dump truck to the permitted CoalRefuse Disposal Site.D. Date volume measurement(s) taken

The volume of material is monitored on an on-going basis. See Question

8.C for this procedure.E. Maximum height (feet) of embankment

o feet -constructed via excavation into natural ground

OUESTION 9 - SPILLS OR UNPERMITIED RELEASES IN LAST 10 YEARS

..-------A. History of spills or unpermitted releases w/in last ten years



IN/A

OUESTION 10 - OWNER 1OPERATOR

A. Identify all current le2111owner(s)




COMPANYEME Homer City Generation LP.


ASH MANAGEMENT UNITCoal Refuse Disposal Site - Small Sediment Trap



None. The impoundment is not subject to regulation by PADEP's

Bureau of Waterways Enlrineerin", Division of Dam Safety.B. Hazard ratin" established by


N/A

D. Regulated by (Agency)This surface impoundment is part of the Station's permitted Coal

Refuse Disposal Site (PADEP #32753702) and is regulated byPADEP's Bureau of Mining & ReclamationE. If no rating, note the fact

No RatinJl:

OUESTION2 - COMMISSIONED/EXPANDEDA. Year management unit commissioned

12008

B. Year management unit expanded

IN/A

OUESTION 3 - MA'I'ERIALS CONTAINED (mark all that auuMA. Flyash


Fly ash has been approved for beneficial use in stabilizing coal refuseas part of the Station's Coal Refuse Disposal Permit (P ADEP#32753702\.B. Bottom Ash · Boiler SlagD. Flue Gas Emission Control ResidualsE. Other (Specify)Yes - Temporarily & typically less than one year. Other materials

include coal refuse & leachate solids

OUESTION 4 - PROFESSIONAL ENGINEER (P.E') INVOLVEMENT

..A. Designed by a P.E. IYes-CME


IYes-CME

· Inspection/monitoring safety under supervision ofP.E.

Iyes - Please refer to Ouestion 5.


A. Date oflast safety assessment/evaluation


Professional Enlrineer - Commonwealth of Penns vivania

· Actions taken/planned by facility personnel as a result

No comments reauiring corrective action.

D. Credentials of nersonnel Performing corrective actions


I stOUarter 20 I 0

OUESTION 6 - STATE OR FEDERAL OFFICIAL INSPECTION

A Last inspection/evaluation

12/16/2009


January 2010

C. Name of Agency conducting insnection/evaluation


D. COpy of most recent official inspection/evaluation

See Attachment B

OUESTION 7 - SAFETY ISSUES IDENTIFIED BY STATE OR FEDERAL AGENCY

A. Safety issuers) from assessment/evaluations w/in past year

No

B. Actions taken to resolve safety issuers)

IN/A

C.Documentationattached

IN/A

IoUESTION 8 - SIZE AND VOLUME

IA. Surface area (acres)

0.18 acre

B. Storage capacity

35,970 cu ft



performed by plant personnel. Removal of material is scheduled basedon these inspections. In 2009, the network of surface impoundmentsin the Coal Refuse Disposal Site was cleaned two (2) times. The mostrecent cleaning occurred in September 2009. During the cleaningevents care is taken not to disturb the PVC liner. Material removedfrom these impoundment is transported via dump truck to thepermitted Coal Refuse Disposal Site.D. Date volume measurement(s) taken


Question 8.C for this nrocedure.E. Maximum height (feet) of embankment

6 feet

!QUESTION 9 - SPILLS OR UNPERMTITED RELEASES IN LAST 10 YEARS

----IA. History of spills or unpermitted releases w/in last ten vearsINo releases or spills

B. Were these spills/unnerrnitted releases renorted to agencies

IN/A

IoUESTIONI0 - OWNER/OPERATOR

IA. Identifv all current legal owner( s)

IEME Homer City Generation LP.

B. Identify all current leJl;aI operator(s)


~OMPANY EME Homer City Generation L.P.PLANT

Homer City Generating Station~SH MANAGEMENT UNIT

Ash Disposal Site - Stormwater Surge Pond

~UESTION 1 - NATIONAL INVENTORY OF DAMSA. Dam hazard rating

None. The impoundment is not subject to regulation by PAD EP'sBureau of Waterways Engineering, Division of Dam Safety.

B. Hazard ratinR established by

N/AC. Basis for hazard ratifiR

N/A

D. Regulated by (Agency)This impoundment is part of the Station's Ash Disposal Site, a

permitted residual waste landfill (PADEP #300491) and isregulated by PADEP's Bureau of Waste ManagementE. If no ratinR, note the factNo Rating


A. Year manaRement unit commissioned11995

B. Vear manaRement unit expanded

IN/A

UESTION 3 - MATERIALS CONTAINED (mark all that apply)

· FlyashYes - TemoorariIv & typically less than one year.

· Bottom AshVes - TempOrarily & typicallv less than one year.

· Boiler SlagVes - Temporarily & typically less than one year.

D. Flue Gas Emission Control ResidualsVes - Temporarily & typicallv less than one year.

E. Other (Specify)Ves - Temporarily & typically Jess than one year. Other materials

include plant runoff sediments, ash disposal site leachate solids,anthracite, sand, activated carbon filters, demineraIizer resins,frreclay brick, sand blasting material and paint chips, asphalt,concrete, stones, rocks, and bricks, asbestos.

QUESTION 4 - PROFESSIONAL ENGINEER IP.E.) INVOLVEMENT

--A. Designed by a P.E.IVes

B. Constructed under supervision of P.E.

IVesC. Jnspection/monitorinR safety under supervision ofP.E.

IVes

QUESTION 5 - COMPANY INSPECTIONSA. Date of last safety assessment/evaluation

Monthly inspections are performed by both qualified EMEpersonnel and Qualified contractor.B. Credentials of evaluator of assessment/evaluation

EME Personnel is Professional Engineer - Commonwealth ofPennsylvania.

C. Actions takenlplanned by facility personnel as a result

No comments requiring corrective action from most recentinspection.D. Credentials of personnel performing corrective actions


Monthly

UESTION 6 - STATE OR FEDERAL OFFICIAL INSPECTION· Last insoection/evaluation

Monthly· Date of next inspection/evaluation

Monthly

· Name of Agency conducting inspection/evaluationPADEP's Bureau of Waste Management

D. Copy of most recent official insoection/evaluation

See Attachment D

QUESTION 7 - SAFETY ISSUES IDENTIFIED BY STATE OR FEDERAL AGENCYA. Safety issue(s) from assessment/evaluations w/in oast year

INo



IN/A



1.22 Acres


C. Volume of material currently storedThe volume of material is monitored by on-going visual

inspections performed by plant personnel. Removal of material isscheduled based on these inspections. In 2009, the network ofsurface impoundments at the Ash Disposal Site was cleaned in Jul~2009. Material removed from this impoundment is transported viadump truck to the Ash Disposal Site, a permitted residual wastelandfill.D. Date volume measurement(s) taken


Question 8.C for this procedure.E. Maximum height (feet) of embankment

16 feet


.------------A. History of spills or unpermitted releases w/in last ten yearsINo releases or spills

B. Were these spills/unoermitted releases reported to aRencies

IN/A


A. Identify all current leRaI owner(s)IEME Homer City Generation L.P.



OMPANYEME Homer City Generation L.P.


ASH MANAGEMENT UNITAsh Disposal Site - Polishing Pond

QUESTION I - NATIONAL INVENTORY OF DAMS

A. Dam hazard ratingNone. The impoundment is not subject to regulation by

PADEP's Bureau of Waterways Engineering, Division ofDam Safety.B. Hazard ratine established byN/A

C. Basis for hazard ratin~N/A

D. Regulated bY(Agency)This surface impoundment is part of the Station's Ash

Disposal Site, a permitted residual waste landfill (PADEP#300491) regulated byPADEP's Bureau of WasteManagement

E. If no rating, note the filet

No Ratine

OUESTION 2 - COMMISSIONED 1 EXPANDED

--A. Year man=ent unit commissioned 11969B. Year management unit expanded

IN/A

OUESTION 3 - MATERIALS CONTAINED (mark all that applJ

A. FlyashYes - TemPOrarilv & tvoicallv less than one year.

B.BottomAshYes - Temporarily & typically less than one year.

C. BoilerS!al1:Yes - TemPOrarily & typically less than one year.

D. Flue Gas Emission Control ResidualsYes - TemPOrarilv & tvoicallv less than one year.

E. Other (Specify)Yes - Temporarily & typically less than one year. Other

materials include plant runoff sediments, ash disposal siteleachate solids, anthracite, sand, activated caIbon filters,demineralizer resins, fireclay brick, sand blasting materialand paint chips, asphalt, concrete, stones, rocks, and bricks,asbestos.UESTION 4 - PROFESSIONAL ENGINEER (P .E.) INVOLVEMENT

· Deswed bv a P.E.IYes

· Constructed under supervision ofP .E.IYes

· Inspection/monitoring safety under supervision ofP.E.IYes

UESTION 5 - COMPANY INSPECTIONSA. Date of last safety assessment/evaluation

Montly inspections are performed by both qualified EMEoersonnal and oualified contractor.B. Credentials of evaluator of assessment/evaluation

EME Personnel is Professional Engineer - Commonwealth 0Pennsylvania.

C. Actions taken/planned by fileility personnel as a result

No comments requiring corrective action from most recentinspection.D. Credentials ofoersonnel PeffOrmin2 corrective actions

N/A

E. Next scheduled assessment/evaluationMonthly

UESTION 6 - STATE OR FEDERAL OFFICIAL INSPECTION· Last inspection/evaluation

12/1612009

· Date of next inspection/evaluationJanuary 2010

· Name of Aeencv conductine inspection/evaluationPADEP's Bureau of Waste Manaeement

· Copy of most recent official inspection/evaluation

See Attachment D

UESTION 7 - SAFETY ISSUES IDENTIFIED BY STATE OR FEDERAL AGENCYA. Safety issue(s) from assessment/evaluations w/in past year

INoB. Actions taken to resolve safety issue(s)

IN/A



---

· Surface area (acres)0.13 acres


C. Volume of material currently storedThe volume of material is monitored by on-going visual

inspections performed by plant personneL Removal ofmaterial is scheduled based on these inspections. In 2009,the network of surface impoundments in the Ash DispsoalSite was cleaned one (1) time in July 2009. Materialremoved from these impoundments is pumed into theStormwater Sume Pond.D. Date volume measurement(s) takenThe volume of material is monitored on an on-going basis.

See Question 8.C for this procedure.E. Maximum heieht (feet) of embankment

6 feet


· History of spills or unpermitted releases w/in last ten yearsINo releases or spills

B. Were these sDills/unpermitted releases reported to 112enciesIN/A

OUESTION 10 - OWNER 1 OPERATOR

· Identify all current lew ownens)IEME Homer City Generation L.P.





ASH MANAGEMENT UNITAsh Disposal Site - Treatment Pond #1


None. The impoundment is not subject to regulation byPADEP's Bureau of Waterways Engineering, Division ofDam Safety.B. Hazard ratin2 established by

N/AC. Basis for hazard ratin2

N/A

D. Regulated by (Agency)This surfuce impoundment is part of the Station's Ash

Disposal Site, a permitted residual waste landfill (pADEP#300491) regulated by PADEP's Bureau of WasteManagement

E. If no ratine, note the fact

No Rating

OUESTION 2 - COMMISSIONED 1 EXPANDEDA. Year manaeement unit commissioned


N/A

OUESTION 3 - MATERIALS CONTAINED (mark all that apply

--A. Flyash Yes - Temoorarily & tvoically less than one year.B.BottomAsh

Yes - TemDOrarilv& tvoicallv less than one year.C. Boiler Slag

Yes - Temporarily & tvoically less than one year.D. Flue Gas Emission Control Residuals

Yes - TemDOrarily& tvoicaIlv less than one Year.

E. Other (Specify)Yes - Temporarily & typically less than one year. Other

materials include plant runoff sediments, ash disposal siteleachate solids, anthracite, sand, activated carbon filters,demineralizer resins, fireclay brick, sand blasting materialand paint chips, asphalt, concrete, stones, rocks, and bricks,asbestos.QUESTION 4 - PROFESSIONAL ENGINEER (P.E.) INVOLVEMENT

--A. Designed by a P.E. IYesB. Constructed under sunervision ofP.E.

IYesC.lnspectionlmonitoring safety under supervision ofP.E.

I Yes

QUESTION S - COMPANY INSPECTIONSA. Date of last safety assessment/evaluation

Montly inspections are performed by both qualified EMEoersonnal and aualified contractor.S. Credentials of evaluator of assessment/evaluation

EME Personnel is Professional Engineer - Commonwealth 0Pennsylvania.

· Actions taken/planned by facility personnel as a result

No comments requiring corrective action from most recentinspection.D. Credentials ofoersonnel perfol1llin.2corrective actions

N/A

E. Next scheduled assessment/evaluationMonthly

UESTION 6 - STATE OR FEDERAL OFFICIAL INSPECTION

· Last insoection/evaluation12/16/2009

· Date of next inspection/evaluationJanuary 2010

· Name of A2ency conductin2 inspection/evaluationPADEP's Bureau of Waste Management

D. Copy of most recent official inspection/evaluationSee Attachment D

OUESTION 7 - SAFETY ISSUES IDENTIFIED BY STATE OR FEDERAL AGENCYA. Safety isSue(s) from assessment/evaluations w/in nast vear

INo


IN/A


QUESTION 8 - SIZE AND VOLUMEA. Surface area (acres)

0.25 acresB. Stora2e capacity

43,512 cubic feetC. Volume of material cwrently stored

The volume of material is monitored by on-going visualinspections performed by plant personnel. Removal ofmaterial is scheduled based on these inspections. In 2009,the network of surface impoundments at the Ash DisposalSite was cleaned in July. Material removed from thisimpoundment is pumped to the Stormwater Surge Pond.


The volume of material is monitored on an on-going basis.See Ouestion 8.C for this orocedure.E. Maximum height (fuet) of embankment

o feet - Because installed via excavation into natural ground


A. HistoN of spills orunoermitted releases w/in last ten yearsINo releases or spills

B. Were these spills/unoermitted releases reoorted to a2enciesIN/A

QUESTION 10 - OWNER 1OPERATORA. Identify all cwrent ICl!aIowner(s)


B. Identify all cwrent le2a1ooeratons)

IEME HomerCitvGeneration L.P.

COMPANY EME Homer City Generation L.P.

iPLANTHomer City Generating Station

lASH MANAGEMENT UNITAsh Disposal Site - Treatment Pond #2

IQUESTION 1 - NATIONAL INVENTORY OF DAMSNone. The impoundment is not subject to regulation byPADEP's Bureau of Waterways Engineering, Division ofA. Dam hazard ratin2 (High, Si2Uificant, Low, or Less-than-Low)

DamSafetv.B. Hazard ratin2 established bv


N/A

This surface impoundment is part of the Station~ AshDisposal Site, a permitted residual waste landfill (PADEP#300491) regulated byPADEP's Bureau of WasteManagement

D. RC2Ulatedby (Agency)

E. Ifno rating, note the fact

No Rating

OUESTlON2 - COMMISSIONED/EXPANDEDA. Year management unit commissioned


IN/A

QUESTION 3 - MATERIALS CONTAINED (mark all tbat apply

--A. Flyash Yes - Temoorarily & typically less than one year.B. Bottom Ash

Yes - Temoorari1v & typically less than one year.

C. Boiler SlagYes - Temporari1y & typically less than one Year.

D. Flue Gas Emission Control ResidualsYes - Temoorarily & typically less than one year.

Yes - Temporarily & typically less than one year. Othermaterials include plant runoff sediments, ash disposal siteleachate solids, anthracite, sand, activated carbon filters,demineralizer resins, fireclay brick, sand blasting materialand paint chips, asphalt, concrete, stones, rocks, and bricks,E. Other (Specify)asbestos.

QUESTION 4 - PROFESSIONAL ENGINEER (p.E.) INVOLVEMENTA Designed by a P.E.

1YesB. ConslIUCted under supervision of P.E.

Yes

C.lnsoection/monitoring safety under supervision ofP.E.IYes

QUESTION 5 - COMPANY INSPECTIONSMonthly inspections are performed by both qualified EMEA. Date of last safety assessment/evaluation

loersonnel and Qualified contractor.

EME Personnel is Professioual Engineer - Commonwealth 0Pennsylvania.B. Credentials of evaluator of assessment/evaluation No comments requiring corrective action from most recentC. Actions taken/planned by facility oersonnel as a result

insoection.D. Credentials ofoersonnel oerfurming corrective actions


Monthly


A. Last insoectionlevaluation12/16/2009

B. Date of next insoectionlevaiuationJanuary 2010

C. Name of Agency conducting insoectionlevaluationPADEP's Bureau of Waste Mana2ement

D. Cony of most recent official insoectionlevaluation

See Attachment D

IQUESTION 7 - SAFETY ISSUES IDENTIFIED BY STATE OR FEDERAL AGENCYA. Safety issue(s) from assessment/evaluations w/in nast year

INo



IN/A


--A Surface area (acres)0.28 acres

B. Storage caoacity43,512 cubic feet

The volume of material is monitored by on-going visualinspections performed by plant personnel. Removal ofmaterial is scheduled based on these inspections. In 2009,the netWork of surface impoundments at the Ash DisposalSite was cleaned in July 2009. Material removed from thisimpoundment was pumped to the Stormwater Surge Pond.C. Volume of material currently stored The volume of material is monitored on an on-going basis.D. Date volume measurement(s) takenSee Ouestion 8.C for this procedure.

E. Maximum heiJdlt (feet) of embankment

o feet - Because installed via excavation into natural ground

QUESTION 9 - SPILLS OR UNPERMJTI'ED RELEASES IN LAST 10 YEARS

A History of spills or unpermitted releases w/in last ten yearsINo releases or spills

B. Were these spiUs/nnpermitted releases reported to agencies

IN/A

DUESTION 10 - OWNER / OPERATOR

-. Identify all current legal owner(s) IEME Homer City Generation L.P.B. IdentifY all current le2al ooerator(s)

1EME Homer City Generation L.P.

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