First Annual RCRA CCR Unit Inspection Report January 2016 WASTE DISPOSAL AREA SURFACE IMPOUNDMENT

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NORTHERN INDIANA PUBLIC SERVICE COMPANY R.M. SCHAHFER GENERATING STATION First Annual RCRA CCR Unit Inspection Report January 2016 REPORT WASTE DISPOSAL AREA SURFACE IMPOUNDMENT Submitted To: Northern Indiana Public Service Company (NIPSCO) 2723 East 1500 North Wheatfield, IN 46392 Submitted By: 15851 South US 27, Suite 50 Lansing, MI 48906 USA January 15, 2016 Project No. 1542998 A world of capabilities delivered locally Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation

January 2016 i WDA - Schahfer Table of Contents 1. INTRODUCTION... 1 2. FACILITY DESCRIPTION... 3 3. BACKGROUND AND DOCUMENT REVIEW SUMMARY... 4 4. 2015 VISUAL INSPECTION... 6 5. CLOSING... 8 List of Tables Table 1 Summary of Background Document Review January, 2016 1

January 2016 1 WDA - Schahfer 1. INTRODUCTION The United States Environmental Protection Agency (EPA) promulgated the Resource Conservation and Recovery Act (RCRA) Coal Combustion Residuals (CCR) Rule (Rule) on April 17, 2015, with an effective date of October 19, 2015. The Rule requires owners or operators of existing CCR surface impoundments to have those units inspected on an annual basis by a qualified professional engineer in accordance with 40 CFR 257.83(b)(1). The initial annual qualified professional engineer inspections are required to be completed and the results documented in inspection reports (per 40 CFR 257.83(b)(2)) for CCR surface impoundments. (Golder) was retained by Northern Indiana Public Service Company (NIPSCO) to perform the annual inspection of the Waste Disposal Area (WDA), a CCR surface impoundment located at the R.M. Schahfer Generating Station (Site). The CCR Rule establishes national minimum criteria and new CCR management obligations for existing, new, and lateral expansions of CCR disposal units. One of the new obligations pertains to inspections, specifically; CCR unit owners/operators must initiate the following activities: weekly inspections and monthly instrument monitoring of CCR Units by October 19, 2015; and annual inspections of CCR units by January 18, 2016. This report presents the results of the first annual inspection of the WDA CCR surface impoundment unit at the NIPSCO R.M. Schahfer Generating Station (RMSGS), located in Wheatfield, Jasper County, Indiana. The inspection was conducted to comply with 257.83 of the CCR Rule. Per 40 CFR 257.83(b)(1), Golder reviewed available information regarding the status and condition of the CCR unit and performed an onsite visual inspection which was conducted on November 3, 2015. The objectives of the inspection included the following: Review of Operational Records (as applicable, see Section 3): Design and construction information. Results of previous structural stability assessments. Results of previous annual inspections. A visual inspection of the CCR unit to identify signs of distress or malfunction of the CCR unit and appurtenant structures. A visual inspection of hydraulic structures underlying the base of the CCR unit or passing through the dike of the CCR unit for structural integrity and continued safe and reliable operation. In accordance with 257.83(b)(2), this inspection report has been prepared by a qualified professional engineer documenting the operational records review, visual inspection, and identifying the following since the previous annual inspection:

January 2016 2 WDA - Schahfer Any changes in geometry of the CCR surface impoundment since the previous annual inspection. The location and type of existing instrumentation and the maximum recorded readings for each instrument since the previous annual inspection. The approximate minimum, maximum, and present depth and elevation of the impounded water and CCR since the previous annual inspection. The storage capacity of the impounding structure at the time of inspection. The approximate volume of the impounded water and CCR at the time of inspection. Any appearances of an actual or potential structural weakness of the CCR unit, in addition to any existing conditions that are disrupting or have the potential to disrupt the operation and safety of the CCR unit and appurtenant structures. Any other change(s) which may have affected the stability or operation of the impounding structure since the previous annual inspection.

January 2016 3 WDA - Schahfer 2. FACILITY DESCRIPTION The WDA was designed by Sargent & Lundy Engineers of Chicago, Illinois in 1982. The WDA is formed by a ring earth-fill dike with slurry trench core that is approximately 17 feet high and 7,540 feet long (including the common embankment) with a crest elevation of 681 feet above mean sea level (Marbach, 2011). The WDA was constructed for NIPSCO, put in service in 1982, and has been continuously owned and operated by NIPSCO until this time. The WDA accepts sluiced bottom ash and boiler slag CCR and various sump discharges from the generating station. The sluiced CCR enters the WDA via elevated pipes at the north side and also via buried pipes located at the northwest corner. Water exits the WDA via an overflow weir, to the Recycle Basin, or through the auxiliary spillway located at the northwest side. The overflow weir is located at the southern end of the east side of the WDA. There is a spillway consisting of two, 24 inch diameter corrugated steel pipes with a concrete down-slope channel transitioning to a rip-rap lined downstream channel located near the northwest corner of the WDA. The east side of the WDA is common with the west side of the adjacent Recycle Basin. A survey of the WDA was performed by Marbach, Brady and Weaver, Inc. in December 2011 (Marbach, 2011).

January 2016 4 WDA - Schahfer 3. BACKGROUND AND DOCUMENT REVIEW SUMMARY The existing reports reviewed for this assessment are summarized below. Table 1: Summary of Background Document Review Document Date Author Assessment of Dam Safety of Coal Combustion Surface Impoundments, NIPSCO, RM Schahfer Generating Station July 2010 CDM for the EPA Report on Inspection of The Waste Disposal Area January 2011 Report on Inspection of The Waste Disposal Area September 2012 Report on Inspection of The Waste Disposal Area April 2014 Various construction drawings 1982 Sargent & Lundy Engineers Basin Operation, Maintenance and Inspection Plan, NIPSCO R. M. Schahfer Generating Station, February 2013 Emergency Action Plan, Final Settling Basin (FSB), Intake Settling Basin (ISB), Waste Disposal Area (WDA), Recycle Basin (RB), Northern Indiana Public Service Company (Nipsco), R.M. Schahfer Generating Station February 2013 Schahfer Spillway Hydrologic and Hydraulic Evaluation December 2011 Final Geotechnical Investigation and Embankment Stability Analyses June 2012

January 2016 5 WDA - Schahfer Final Hazard Classification Review Report NIPSCO Schahfer Generating Station January 2011 Construction in a Floodway Permit Application, NIPSCO R.M. Schahfer Generating Station, November 2012 State of Indiana Department of Natural Resources (DNR), Certificate of Approval, After-the-Fact, Construction in a Floodway April 23, 2013 State of Indiana DNR Construction Observation Documentation Report, Surface Water Basin Erosion Repairs, NIPSCO R.M. Schahfer Generating Station October 2014 Embankment Elevation Survey, Waste Disposal Area and Recycle Pond, NIPSCO Schahfer Generating Station December 2011 Marbach, Brady and Weaver, Inc.

January 2016 6 WDA - Schahfer 4. 2015 VISUAL INSPECTION The 2015 onsite inspection of the WDA was performed by Ms. Tiffany Johnson, P.E. and Ms. Halle Doering of (Golder) on November 3, 2015. Ms. Johnson is a Professional Engineer, licensed in the State of Indiana. Golder s inspectors were accompanied by Ms. Tamra Reece, Environmental Coordinator with NIPSCO RMSGS for a portion of the inspection. The inspection provides the following information as stipulated in 40 CFR 257.83(b)(2): Any changes in geometry of the CCR surface impoundment since the previous annual inspection. Not applicable. Since this is the first annual inspection, changes in geometry will be incorporated in the report for the next annual inspection. The location and type of existing instrumentation and the maximum recorded readings for each instrument since the previous annual inspection. There is currently no instrumentation in place designed to monitor for the structural stability of the WDA. The approximate minimum, maximum, and present depth and elevation of the impounded water and CCR since the previous annual inspection. Maximum: approximately 678 feet above mean sea level (based on visual observation) Minimum: approximately 677 feet above mean sea level (based on visual observation) Present Depth: approximately 15 feet (based on review of available information) Since this is the first annual inspection, this data has been provided for reference only and will be compared to the 2016 annual inspection. The storage capacity of the impounding structure at the time of inspection. 1,530 acre-feet (based on review of available information) The approximate volume of the impounded water and CCR at the time of inspection. Impounded water = approximately 498,600,000 gallons (from NIPSCO) CCR = approximately 1,267,900 cubic yards (from NIPSCO) Any appearances of an actual or potential structural weakness of the CCR unit, in addition to any existing conditions that are disrupting or have the potential to disrupt the operation and safety of the CCR unit and appurtenant structures. None were observed. Any other change(s) which may have affected the stability or operation of the impounding structure since the previous annual inspection. None were observed.

January 2016 7 WDA - Schahfer Given that this is the first annual CCR Rule inspection for the WDA at the RMSGS, the conditions noted during the November 3, 2015 inspection of the WDA will be compared to future annual inspections. Based on visual observations made on November 3, 2015, the overall condition of the WDA is acceptable. No structural weaknesses or safety issues were observed within the upstream, downstream, crest or hydraulic structures of the WDA. Based on visual observations made on November 3, 2015, there were no visual conditions identified that would likely impact the operation of the WDA.

15851 South US 27, Suite 50 Lansing, MI 48906 USA Tel: (517) 482-2262 Fax: (517) 482-2460 Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation