R.M. Schahfer Ash Pond Closure Public Meeting

Karen McLean:  Good evening. I am Karen McClean, NIPSCO Public Affairs and Economic Development Manager serving Jasper County. Thank you for joining us this evening. We are here to discuss NIPSCO's plan to close the ash ponds at the Roland M Shahfer Generation station and the company's groundwater remediation plan at the Shahfer site. The presentation will be separated into two separate topics to discuss both of these. After each topic, there will be an opportunity for you to submit questions into the Q and A box at the bright panel of your screen. Representatives from IDEM’s Office of Land Quality will also be in attendance this evening.

                                Here is a quick overview on how to ask questions. During the presentation, you'll see that ask a question button in the right bottom corner of your screen. Click this button and submit your name and question. There is an option to submit questions as anonymous. We will facilitate questions after the ash pond closure segment and at the end of the groundwater remediation plan segment. We will try to answer as many questions as we can this evening about the ash pond closure work and the groundwater remediation plan at Shafer. If you have dialed in today or have additional questions that fall outside of these two topics, please include a direct contact email in the chat box, and we will reach out to you directly. You can also submit questions to NIPSCO underscore environmental NiSource dot besides myself, our presenters this evening from NIPSCO are Maureen Turman, Director, Environmental Policy and sustainability, Rob Ridge, Manager Project Engineering, and Mark Oak, Director Environmental Mediation. The agenda will consist of an overview of NIPSCO, the Shahfer Station Pond Closures Project, followed by questions. The next topic will be the groundwater corrective measure process, also followed by questions in respect of everyone's time. Any questions outside of the scope of these two projects will not be addressed this evening.

Before we start the presentation on the ash pond closure work, I would like to provide you with a brief overview of NIPSCO's Company profile. NIPSCO serves 483,000 electric comp com customers in 20 counties and 820,000 natural gas customers in 32 counties. Our headquarters are located in Merrillville, and we employ approximately 2,900 employees in the state of Indiana. I will now turn it over to Marine Term Director of Environmental Policy and Sustainability.

                                Maureen, you're on mute.

Maureen Turman:           Oops, <laugh>. Thank you about that. Thank you. Sorry about that. Okay. Thank you, Karen. Uh, good evening, and thank you for joining us for our public meeting on our Ash Pond Closure Project and Groundwater Corrected Measures proposal. I'm going to take a few minutes to provide an overview of the coal combustion residuals role, but I'd like to start with a short description of what exactly a CCR is and how it's created. Coal ash or CCR is created when coal ash, when coal is burned to generate electricity. There are four kinds of coal ash. There's boiler ash, bottom ash, fly ash, and flue ash, desulfurization material or FGD material. Historically, all four kinds were generated at the Shahfer station. After the coal is burned, either boiler, slag, or bottom ash are found at the bottom of the boiler, similar to wood ash left, left after a campfire.

                                The type of boiler determines if boiler ash or bottom ash has created because we operated multiple types of boilers at the Shahfer station, both boiler ash and bottom ash were generated. Fly ash is created when the coal is being burned. Again, back to the campfire analogy, it's similar to the little particles that seem to float over a campfire as it burns. And finally, flue ash to sulfurization material or FGD material is generated, generated as a byproduct of an environmental control that's placed on a boiler to remove sulfur. Now that you know a little more about coal ash and how it's generated, we'll go back to our rule summary. The CCR rule was established by the United States Environmental Protection Agency in 2015 to regulate how coal ash or CCR is managed and disposed, and how to assess groundwater, call quality and address any groundwater impacts related to CCR activities at a generating station.

                                The CCR rule is a bit unique in that it is implemented in phases. Once one phase is complete, it informs what actions we must take to comply with the next phase of the rule. We have broken our compliance plan down into three phases. The first phase is to separate the ash ponds from the boilers in October of 2020. We completed this phase for three of the four ash ponds at Shahfer. The one remaining pond will be retired when the station ceases operation in 2025. We'll be back again in the future for a similar public meeting on that last pond's closure plan. But we're here tonight to talk about phase two for the three retired ponds, which we refer to as the Multicell unit or mcu. Since we submitted a closure application in 2019, we have worked with the Indiana Department of Environmental Management or item to design a plan to meet both state regulations and federal CCR rule requirements.

                                On August 3rd, we received a completeness letter from IDEM signifying that they have received adequate information regarding the technical aspects of our closure plan in the near future. After all, public comments are considered, we anticipate written approval of that plan from idem. I'd like to note that we expect the item approval to require 30 years of post-closure groundwater monitoring. We will be here monitoring groundwater for many years to come. And that leads us to, into phase three, which includes the assessment of groundwater quality and addressing any groundwater impacts created by the ash ponds. We initiated our assessment of groundwater quality in 2017 by installing a network of wells around the ash ponds and collecting groundwater samples for laboratory analysis. Based on the results of this groundwater monitoring program, it was determined that groundwater at Shafer was impacted by operation of the ash ponds as required by the rule.

                                We delineated the extent and determined that impacted groundwater is limited to the Shahfer Station. To be completely clear on this point, the groundwater impacts do not leave NIPSCO's property. You'll hear details on the groundwater work done to date and our plans to address the groundwater impacts later in this presentation. After we conclude our pond closure project presentation, again, thank you for joining us this evening. We will be addressing questions on the CCR Rule and the Pond closure Project at the conclusion of this portion of our formal presentation. Rob Ridge will now walk you through the details of the Pond closure project.

Rob Ridge:          Excellent. Thank you, Maureen. Uh, again, my name is Rob Ridge. I'm the manager of project Engineering for our major projects group. Um, on the next slide that'll be shown is a bird's eye view of RM Shahfer generating stations. So the yellow box on the left is, uh, uh, is the location of the pond system that will be closed during this project. The green box on the right, uh, shows the active landfill area that ultimately will be accepting the CCR material that is removed from that, that pond system. If you follow me to the next slide, um, this slide covers the scope of the project. So as you would expect, public outreach is one of the first steps of our project execution and is considered to be key for project success. So that is one of the reasons why we're, we're having today's meeting. Um, we also met with IDEM multiple times during our permitting process to cons to confirm a consistent understanding of our closure approach, as well as compliance with both state and federal, um, federal requirements.

                                Uh, this slide does show the three ponds that will be closed. So I'll start off with the, uh, material storage runoff basin. Uh, it was primarily utilized to receive flows from site storm water, coal pallet runoff, and flue ash desulfurization process sums. Uh, the metal cleaning waste basin was used to receive flows from plant demineralize, air heater washes, and storm water runoff. Uh, CCR material from these ponds was historically, uh, periodically removed from the ponds and disposed of in the onsite landfill. Uh, and then on the southern edge of the, the pond system is the waste runoff area, uh, that previously accepted fly ash and was also used as a drying area for, for multiple types of CCR onsite. These three ponds are collectively referred to as, uh, the multi-cell unit as Maureen mentioned, or mcu. Um, also around the ponds. It's surrounded by, uh, an underground slurry wall, which was installed when the pounds ponds were constructed.

                                The slurry wall consists of nonpermeable material and extends, uh, to shell or bedrock, uh, which ultimately limits, limits the groundwater movement underneath the, the impoundments, the MCU will be closed by removing the material and installing a capping system. Uh, this includes dewatering and excavation of the CCR material. Uh, this work will be primarily, uh, completed by front end loaders, bulldozers, and, and, um, heavy duty trucks, much like you'd see on like a residential development project or per perhaps a highway transportation project. Uh, after the CCR is removed, uh, backfill material and a plastic liner as well as top soil will be installed on the top ultimately to allow vegetation to grow and wa um, storm water to shut off of the closed impoundment. Uh, the active landfill, uh, that will be accepting the material on site was constructed in, in conformance with the CCR rule, and that liner system consists of, uh, the geo membrane liner, 24 inches of impermeable clay, and then an additional hydraulic barrier. The project is currently planned to be executed under the National Maintenance Agreement, which has requirements to utilize local union labor.

                                And then if you follow me to the next slide, this slide shows the anticipated schedule for the project. So, um, as Maureen mentioned, we did receive our notice of completeness from IDEM on August 3rd of this year. Uh, today we are holding the public meeting and then, uh, start of construction is actually dependent on a couple things. So first would be, um, approval of the, the formal closure application through idem, and then also award of our construction contractor to perform the work. After this project is complete, uh, NIPSCO will then move into post closure groundwater monitoring. If you then follow me to the next slide, um, we will be answering questions as, as announced previously live today. However, any formal questions or comments may also be submitted to IDEM for their review. Uh, that formal comment period then closes, um, after 30 days. I believe that is November 1st. So at this time, we will go ahead and, and answer any questions that we might have, uh, in the chat.

Tara McElmurry:               Yeah, thank you Rob. Um, hi everyone. My name is Tara McElmurry from NIPSCO Communications, and I'll be moderating our questions tonight. Um, right now we're not seeing any questions in the queue, but just a reminder, if you go to the top of your screen, you'll see a q and a little chat bubble. It's like two chat bubbles with a question mark in it. Once you click that, um, a screen will pop up on the right hand side and you can press ask a question. Um, if you wish, you can submit the question anonymously by checking a box, um, or if not, you can just submit your question and your name will be shown. But go ahead and do do that, and we will answer questions as they come in. Again, we're not seeing any questions right now, Rob, so maybe we can move forward with the presentation. And if you do come up with questions for Rob, he'll be sticking around and we can get to those, um, after the next portion of our presentation.

Rob Ridge:          Yes. Excellent. Thank you, Tara. Uh, then with that, I will turn it over to Mark Owen. Mark?

Mark Owen:       Right, Thanks Rob. Uh, my name is Mark Owen and I'm the director of Environmental Remediation. Uh, tonight I want to present a few slides on the assessment of corrective measures. Uh, the process for groundwater that has been impacted by the multi cell unit, uh, that Rob just described. Uh, the assessment of corrective measures, um, allows for public comment, which we're doing tonight. This is kind of our kickoff and sets the stage for the groundwater selection of remedy, which is ultimately, you know, what do we do, um, with the groundwater that's been impacted, Um, so that, that's kind of the trigger. So, you know, here we go. Um, so a little background on the assessment of corrective measures. Um, we started monitoring groundwater in 2017. In 2018, we detected cobalt, which is a metal above the groundwater protection standard at what the EPA calls a statistically significant level or an SSL detection of the SSL triggered or initiated the groundwater corrective action process, which I'm explaining tonight. Uh, the initial assessment of corrective measures was completed in 2019 with continued updates to the assessment over the next three years. I would like to note, however, and I believe Maureen had mentioned it earlier, that the groundwater impacts are limited to a single well and within the Shahfer Generation station property, as you'll see on the following slides.

                                Next slide. So on this slide, uh, groundwater flow is to the north northeast, as depicted by the two blue arrows. Uh, we'll probably be able to see it a little bit better on on the next slide, but for now, it goes towards the top of the page. And to the top right of the page, only cobalt was detected at a significantly statistical level concentration and a single downgraded monitoring wall, uh, which is al number eight on the, and on the next slide, I'll show you where that is. Uh, the vertical extent, um, has been limited to the shallow aquifer. Uh, we have well pairs out there that were, Sam, you know, we're basically monitoring the shallow ground water as well as the deep ground water. And no impacts in the deeper screened wells have been found. Uh, the horizontal extent has been defined by the assessment monitoring Well network as depicted in this map by the purple squares.

                                And, and I should go back for a second just to explain our background monitoring wells are those in red, in the red symbols? So they're on the left of the multicell unit, and there's one just to the bottom right. Um, and then our set, our down gradient wells are immediately, they're shown in little blue triangles, and they're immediately down gradient groundwater flow-wise at the north and, uh, uh, eastern sides of the MCU. And then our assessment wells, which are also our wells, basically to make sure nothing's moving, uh, off site, are in these, uh, these, these pinkish purple wells, uh, that you see here. Um, I would note that the assessment wells that you see closest to the MCU are 13 to 1800 feet away. They're bound gradient, but they're 13 to 1800 feet away, which, which is about a quarter mile. And the one, uh, assessment mantra, well, that you see at the top of the map, uh, next to the large pond, that's our northern property line, uh, that well is, um, over 6,000 feet away from the multi cell unit. So it's just showing you the scale. Um, let's go ahead and go to the next slide.

                                So this is really just a, a blow up of the previous slide, but here you could see two of the three background wells in red. You could see the five down gradient wells that are immediately adjacent, and then you kind of see a, a little pink, um, I don't know what you want to call it. It's not like a stop sign, but that's right next to the, the middle. Well, AL eight, um, and that's the one that showed the exceedance. Uh, the ground water protection standard for cobalt is 10 parts per billion. And, uh, in September of 2021, we had an exceedance and it was 15 parts per billion. Um, so this, this map is just to give you a better bird's eye view of which way the groundwater is flowing and where our our well network, um, is. Next slide, please.

                                The assessment of corrective measures is like a feasibility study in that it is a a two step process. In the first step, we look at a variety of ways to look at the effectiveness of the potential remedy. We look at such things as how does the, how does it perform, how difficult is it or easy to install and operate, What other impacts would the remedy have, as well as the time to begin and complete the remedy and any institutional requirements. And based on the above, we then look to identify or select the technologies for our evaluation. For the MCU, it all begins with the moving the ash from the ponds that Rob, uh, had just described, uh, removing the source. So in step two, we're looking at selecting the technologies for evaluation, all of them involved as the, as the first part of that, removing the source, which is the ash materials that are in the three ponds. Uh, we then looked at, we, we looked at a number of different remedies or tools in the toolbox, if you will, Uh, institutional controls, containment technologies, removal technologies, uh, below ground treatment, as well as aboveground treatment. Um, but I, I do want to note that both steps one and two have been completed. Next slide, please.

                                So this slide is just showing an example of an aboveground treatment, uh, something that's commonly referred to in our industry and many industries as a pump and treat system. This is where you put in a series of extraction wells where we extract the ground water that's been impacted in this case with cobalt. And then it's, it's taken above grade or above ground, and then it's treated above ground to remove the cobalt. And then the clean water is then discharged through, um, one of our permits at the plant. Next slide, please. In this example, this is an example of a below ground treatment system, one in which you would not know is there if you were walking around the plant. Um, this is an example of what we call a permeable reactive barrier, um, which is a type of inground trench, if you will, that you fill in, um, with the reactive filter media, um, that either absorbs the contaminant or treats or destroys or changes the chemistry of the contaminant. Such a clean water exit the trench. So in this, this example, this illustration, uh, you see impacted groundwater, um, going down to the water table, moving to the right. It then goes through this trench, which is filled with media that will treat, uh, for the contaminant of choice, in this case cobalt. And then on the other side of the wall would be clean water.

                                Next slide, please. So after looking at all the potential remedies, preliminarily, uh, we are leaning towards monitored natural attenuation. And we looked at five of them. We looked at five different options here. Uh, mantra natural attenuation itself, and then the next four vertical barriers. Hydraulic controls, uh, pump and treat Institute of Stabilization, but m and a or mantra natural attenuation, um, is included with each one of them. The reason that we're looking at mantra natural attenuation as a preferred method at this point in our study is a, that we're removing the source. So we're moving the coal ash from the MCU unit. Uh, we're putting a cap on it, uh, which will, uh, basically keep any surface infiltration from going into the unit. Um, we're also retaining the slurry walls, as Rob had talked about before. Um, the slurry walls will actually, uh, contain any remnants of ash that we're not able to remove and any contaminated groundwater, and it should keep it in the, uh, confines of that slurry wall.

                                Um, when looking at mantra natural attenuation, there are typically four tiers each progressively more, um, more technically challenging. We've completed three of the four tiers of work and have confirmed that mantra, natural, natural attenuation that's actually occurring, um, as I speak and is appropriate for cobalt. Um, the contaminant plume is stable, um, and the concentrations are actually declining, uh, in our last sampling effort, Um, cobalt was actually below the groundwater protection standard in the one well, where historically had been above. Uh, lastly, mantra natural attenuation. Um, tier four, which is the last four, which is the last tier. Um, there's a long term performance, uh, monitoring and post closure monitoring, and we do that to confirm that that mantra natural attenuation is still occurring. So, you know, this really wraps up my talk on this topic here. The formal selection of remedy process will follow today's public meeting, um, and the required 30 day public comment, which again, I, I believe, ends on November 1st.

                                So with that, um, will go ahead and open it for questions. And on the next slide you can see, oh, the one thing I did want to to mention is that, um, unlike the p closure, uh, questions, which are to be directed directly to idem, uh, questions regarding the assessment of corrective measures, uh, will be answered by NIPSCO. Uh, you can send them via mail to the attention of Jeff Lowie at the address on the screen, um, or you can email them at nipscoenvironmental@nisource.com. And, and lastly, um, included here is a link, uh, to our, um, assessment of corrective measure reports. Uh, there will be the initial assessment of corrective measures and then three addendums, uh, for the work that was conducted from 2019 through 2022. So with that, um, I'll, I'll take any questions.

Rob Ridge:          Hey, Mark, just for anyone who might have joined, joined via just by telephone, do you want to, um, would you mind walking through the address there?

Mark Owen:       Sure. Uh, the address is Nipsco Environmental Remediation 8 0 1 East 86th Avenue. That's 86 Merrillville, Indiana, 46 41 0. And to the attention of Jeff Lowe, l o e w e.

Tara McElmurry:               Thanks, Mark. Um, we are still showing no questions in the queue. So again, just a reminder, you can ask a question by going up top of your, of the right hand of your screen to the little q and a bubble, clicking on that, and you'll see a slide come down on the right hand of your screen that says, Ask a question. You can submit questions that way. We did have one come in during Mark's presentation, asking to have the screen enlarged. Um, unfortunately we're not able to do that live right here, but we will be posting the presentation online at nsco.com/environment. So you'll be able to access it there, um, after the meeting, along with the recording of this meeting too. And we are still showing no questions, but we'll hang out for just a little bit in case there's a delay. And as Mark and Rob said, if um, questions are sparked after the meeting, um, for NIPSCO, um, you can reach us at nipscoenvironmental@nisource.com, or you can go ahead to the webpage, nipsco.com/environment. Give it a few more moments here and maybe look back to the team. Is there anything else, Maureen, Rob, Mark, anything else you would like to add as we're kind of closing out here?

Mark Owen:       Not that I can think of. I, you know, I, I think it's a, it's a good story, um, that we have, uh, that we're removing the ash, uh, the majority of the ash, uh, from the three impoundments. Um, and that there's a slurry wall that, that, that has been in place for, gosh, probably 30 or 40 years and is functioning well. Um, and that will remain in place. And then we're going to cap it to make sure surface infiltration like rain, uh, doesn't go through, uh, the material after we backfill. Um, and then, you know, from a groundwater perspective, we had one exceedance for one metal cobalt in a single well, uh, immediately down gradient of the, um, of the unit. However, the assessment wells or the sentinel wells, uh, that are much further away, but not nearly, uh, close to any offsite properties or all non detect or below the standard, uh, for cobalt. So I, I, I think that's good news.

Tara McElmurry:               Thank you for that additional information. Mark. Um, again, we're still showing no question, so, um, you know, in the interest of time, I think we'll go ahead and wrap up. But you know, this is just the first step of these, um, of the closure Shafer Station here. So as we get further through the process, you know, there'll be more information to come, um, on our NIPSCO website, you know, out in the public media, and then there'll be additional opportunities, um, for you to get questions answered and receive more information from us as we move through this process. So thank you everyone for joining us tonight, and, um, have a great evening.