Phase IV Completion Report by vaz16169

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With assistance provided by Normandeau Associates




PPL Martins Creek, LLC




Phase IV Completion Report



Martins Creek Steam Electric Station


6605 Foul Rift Road


Bangor, Pennsylvania 18013-4857

June 2007
                        Phase IV Completion
                        Report

                        Martins Creek Steam
                        Electric Station
G. Rob Scott
Vice President
ARCADIS-BBL

                        Prepared for:
                        PPL Martins Creek, LLC


                        Prepared by:
                        ARCADIS of New York, Inc.
Stuart D. Messur        6723 Towpath Road
Vice President          Syracuse
ARCADIS-BBL
                        New York 13214-0066
                        Tel 315.446.9120
                        Fax 315.449.0017


Terry Euston            Our Ref.:
Principal Scientist     B0023249
Normandeau Associates
                        Date:
                        June 8, 2007



                        This document is intended
                        only for the use of the
                        individual or entity for which it
                        was prepared and may
                        contain information that is
                        confidential and exempt from
                        disclosure under applicable
                        law. Any dissemination,
                        distribution or copying of this
                        document is strictly
                        prohibited.
                                                                                       Table of Contents




Executive Summary                                                                 1

1. Introduction                                                                 1-1

        1.1   Background                                                         1-1

        1.2   Delaware River Description                                         1-2

        1.3   Delaware River Hydrologic Data                                     1-3

        1.4   Fly Ash Description                                                1-6

        1.5   Summary of Emergency Response Activities                           1-7

              1.5.1   Initial Emergency Response                                 1-7

              1.5.2   Oughoughton Creek                                          1-7

              1.5.3   Phase I Activities                                         1-8

              1.5.4   Phase II Activities                                        1-8

              1.5.5   Phase III Activities                                       1-9

        1.6   Previous Investigations                                            1-9

        1.7   Objectives of Phase IV Sampling                                   1-10

              1.7.1   Residential Property and Shoreline Inspection Program     1-12

              1.7.2   Sediment Sampling                                         1-12

              1.7.3   Surface Water Sampling Program                            1-13

              1.7.4   Biological Monitoring Program                             1-13

        1.8   Phase IV Completion Report Organization                           1-14


2. Residential Property and Shoreline Inspection Program                        2-1

        2.1   Public Inquiries                                                   2-1

        2.2   Results of Site Evaluations                                        2-1


3. Sediment Sampling Program                                                    3-1

        3.1   Introduction                                                       3-1

              3.1.1   Arsenic as a Chemical Indicator                            3-2

              3.1.2   Normalization of Concentration Data                        3-4

              3.1.3   Use of Aluminum for Normalization of Concentration Data    3-4




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              3.1.4   Statistical Analyses                                               3-7

        3.2   River Bank Sediment Sampling                                               3-7

              3.2.1   Description of Sampling Events                                     3-7

                      3.2.1.1   Pre-Storm River Bank Investigation Summary               3-7

                      3.2.1.2   Post-Storm River Bank Investigation Summary              3-8

                      3.2.1.3   2006 Phase IV River Bank Investigation                   3-8

              3.2.2   River Bank Sediment Data Assessment                                3-9

                      3.2.2.1   Summary of the 2005 Phase IV DSR River Bank Sample
                                Results                                                  3-9

                      3.2.2.2   Summary of the 2006 Phase IV River Bank Sample Results 3-9

                      3.2.2.3   Comparison of June 2006 Data to September 2005          3-12

                      3.2.2.4   Comparison of Downstream Data to Delaware River Background
                                River Bank Data                                       3-13

                      3.2.2.5   Comparison to Regional Soils                            3-14

                      3.2.2.6   Determination of Ash Relatedness                        3-16

                      3.2.2.7   Comparison to Screening Values                          3-17

              3.2.3   Conclusions                                                       3-18

        3.3   In-River Sediment Sampling                                                3-19

              3.3.1   Description of Sampling Events and Visual Observations            3-19

                      3.3.1.1   Pre-Storm Investigation DSR Summary                     3-19

                      3.3.1.2   Post-Storm Investigation DSR Summary                    3-20

                      3.3.1.3   2006 Phase IV In-River Sediment Investigation           3-20

              3.3.2   In-River Sediment Data Assessment                                 3-21

                      3.3.2.1   Summary of the September 2005 Phase IV DSR In-River
                                Sediment Sample Results                                 3-22

                      3.3.2.2   Summary of the November 2005 Phase IV DSR In-River
                                Sediment Sample Results                                 3-25

                      3.3.2.3   Summary of the 2006 Phase IV In-River Sediment Sample
                                Results                                               3-26

                      3.3.2.4   Comparison to Background                                3-27

                      3.3.2.5   Results Adjacent to and Downstream from the Lehigh River 3-30



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                      3.3.2.6    Determination of Ash Relatedness                         3-34

                      3.3.2.7    Comparison to Screening Values                           3-34

              3.3.3     Conclusions                                                       3-35


4. Surface Water Sampling Program                                                          4-1

        4.1   Description of Sampling Events                                               4-1

              4.1.1     Sample Locations                                                   4-1

              4.1.2     Sample Collection and Analyses                                     4-2

        4.2   Surface Water Data Assessment                                                4-2

              4.2.1     Role of suspended solids in total metals concentrations            4-2

              4.2.2     Summary of Sample Results                                          4-6

              4.2.3     Evaluation of Metals Data                                          4-7

                      4.2.3.1    Water Quality during and Immediately After the Release and
                                 During the Subsequent Baseflow Period                      4-9

                      4.2.3.2    Water Quality during the First October High-Flow Event   4-13

                      4.2.3.3    Water Quality Following the First High-Flow Event        4-19

              4.2.4     Comparison of Surface Water Results to Ecological and Human Health
                        Criteria                                                         4-24

        4.3   Conclusions                                                                 4-26


5. Biological Monitoring Program                                                          5-27

        5.1   General                                                                     5-27

        5.2   Previous Biological Investigations                                          5-27

        5.3   Benthic Macroinvertebrate Community Assessment                              5-28

              5.3.1     Sample Locations and Methodology                                  5-29

              5.3.2     Data Analyses                                                     5-30

                      5.3.2.1    Bioassessment (Metric Scoring)                           5-32

                      5.3.2.2    Statistical Analysis                                     5-32

              5.3.3     Results and Discussion                                            5-33

                      5.3.3.1    Habitat Descriptions                                     5-33

                      5.3.3.2    Benthic Community Data                                   5-35



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              5.3.4   Bioassessment Results                                            5-42

              5.3.5   Statistical Results                                              5-43

              5.3.6   Comparisons to 2005 and Other Historical Data                    5-44

              5.3.7   Discussion                                                       5-45

              5.3.8   Summary                                                          5-46

        5.4   Fish Community Assessment                                                5-46

              5.4.1   Station Locations                                                5-47

              5.4.2   Field Methods                                                    5-48

              5.4.3   Data Analyses                                                    5-49

              5.4.4   Statistical Analyses                                             5-49

              5.4.5   Results                                                          5-50

                      5.4.5.1   Physical Habitat Descriptions                          5-50

                      5.4.5.2   Water Quality Results                                  5-51

                      5.4.5.3   Fish Community: Riffle Stations                        5-52

                      5.4.5.4   Comparison to 2005 Data                                5-54

                      5.4.5.5   Fish Community – Pool Stations                         5-55

                      5.4.5.6   Comparison to 2005 Data                                5-58

                      5.4.5.7   Condition Factors                                      5-59

                      5.4.5.8   Comparison of Historical (1981-1989) and Recent Sample Data
                                                                                        5-60

                      5.4.5.9   American Shad                                          5-61

              5.4.6   Discussion                                                       5-61

              5.4.7   Summary                                                          5-62

        5.5   Mussel Community Assessment                                              5-63

              5.5.1   Station Locations                                                5-63

                      5.5.1.1   Field Methods                                          5-63

                      5.5.1.2   Qualitative Survey                                     5-64

                      5.5.1.3   Quantitative Sampling                                  5-64

              5.5.2   Results                                                          5-64



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                      5.5.2.1     Qualitative Survey                         5-64

                      5.5.2.2     Quantitative Sampling                      5-67

                      5.5.2.3     Pool Stations                              5-69

                      5.5.2.4     Contiguous Habitats Stations               5-72

                      5.5.2.5     Federal- and State-Listed Species          5-73

                      5.5.2.6     Comparison to Other Delaware River Data    5-74

              5.5.3    Summary                                               5-75

        5.6   Fish and Mussel Tissue Sampling and Analyses                   5-77

              5.6.1    Field Methods                                         5-78

              5.6.2    Estimation of Risk Based Concentrations (RBCs)        5-79

              5.6.3    Statistical Analyses                                  5-82

              5.6.4    Results and Discussion                                5-84

              5.6.5    Summary                                              5-104

        5.7   Periphyton Community Assessment                               5-104

              5.7.1    Station Locations                                    5-105

              5.7.2    Field and Laboratory Methods                         5-106

              5.7.3    Data Analysis                                        5-107

              5.7.4    Results                                              5-108

              5.7.5    Summary                                              5-121

        5.8   Conclusions from the Ecological Investigations                5-122


6. Phase IV Conclusions                                                      6-1

        6.1   River Bank Sediments                                            6-2

        6.2   In-River Sediments                                              6-2

        6.3   Surface Water                                                   6-3

        6.4   Ecological Assessment                                           6-5

        6.5   Future Activities                                               6-5


7. References                                                                7-1




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Tables

Table 3-1    June 2006 River Bank Background Sample Summary Statistics                    3-11

Table 3-2    June 2006 River Bank Downriver Sample Summary Statistics                     3-11

Table 3-3    Average and Average Aluminum-Normalized Metals Concentrations for Paired
             River Bank Sample Locations                                              3-12

Table 3-4    Average Concentrations of Background Samples versus Downstream Samples
                                                                                   3-14

Table 3-5a   Upper Reach In-River Sediment Sample Summary Statistics – September 2005
                                                                                    3-22

Table 3-5b   Middle Reach In-River Sediment Sample Summary Statistics – September 2005
                                                                                     3-23

Table 3-6a   Upper Reach In-River Sediment Sample Summary Statistics – November 2005
                                                                                    3-23

Table 3-6b   Middle Reach In-River Sediment Sample Summary Statistics – November 2005
                                                                                    3-24

Table 3-7    Lower Reach In-River Sediment Sample Summary Statistics – June 2006          3-24

Table 3-8a   Delaware River Background In-River Sediment Sample Summary Statistics        3-28

Table 3-8b   Lehigh River Background In-River Sediment Sample Summary Statistics          3-28

Table 3-9    Average Aluminum-Normalized Sediment Concentration by Reach                  3-29

Table 4-1    Surface Water Sample Summary Statistics                                       4-7

Table 4-2    Frequency of Detection for Arsenic                                            4-9

Table 4-3    Comparison of Average Background and Downstream Concentrations for Each
             Analyte and Reach for Up to October 7, 2005                            4-11

Table 4-4    Comparison of Average Background and Downstream Concentrations for Each
             Analyte and Reach for October 8 to 9, 2005                             4-19

Table 4-5    Comparison of Average Background and Downstream Concentrations for Each
             Analyte and Reach after October 9, 2005                                4-20

Table 4-6    Regulatory Water Quality Standards                                           4-24

Table 4-7    Elemental Ratios in 11 Samples with Nickel Exceedances                       4-25

Table 5-1    Site Descriptions for the Benthic Macroinvertebrate Sample Stations on the
             Delaware River near PPL-Martins Creek LLC, 2006.                             5-29

Table 5-2    Habitat Descriptions for the Benthic Macroinvertebrate Sampling Stations on the
             Delaware River                                                                5-34

Table 5-3    Water Quality Data Measured at Benthic Macroinvertebrate Sample Locations on
             the Delaware River near PPL-Martins Creek LLC, Summer 2006                5-35


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Table 5-4    Relative Abundance of Benthic Macroinvertebrates Collected from the Delaware
             River near PPL-Martins Creek LLC According to Their Functional Feeding Group
             Classification                                                             5-35

Table 5-5    Relative Abundance of Sensitive, Facultative, and Tolerant Benthic
             Macroinvertebrates Collected from the Delaware River near PPL-Martins Creek
             LLC                                                                       5-36

Table 5-6    Summary of Benthic Macroinvertebrate Community Metrics from Seven Riffles
             Sampled in the Delaware River near PPL-Martins Creek LLC During Summer 2006
                                                                                       5-36

Table 5-7    Bioassessment Summary for Delaware River Benthic Macroinvertebrate
             Communities near PPL Martins Creek LLC, Summer 2006                            5-43

Table 5-8    Dominant Benthic Macroinvertebrate Taxa at Stations in the Delaware River near
             PPL-Martins Creek LLC Following the 2005 Fly Ash Release                    5-44

Table 5-9    Dominant Benthic Macroinvertebrate Taxa (> 5 Percent of total) near PPL Martins
             Creek LLC during EMSP Collections, 1981-1989                                5-45

Table 5-10   Phase IV Bioassessment Sample Site Habitat Descriptions for Fish Community
             Sampling in 2006, Delaware River near Martins Creek LLC                   5-48

Table 5-11   Sample Site Data Used to Calculate Catch per Unit Effort (CPUE) Estimates      5-50

Table 5-12   Water Quality Data Collected During Fish Community Sampling at PPL-Martins
             Creek LLC, Delaware River, July 24 - August 2, 2006                       5-51

Table 5-13   Number and Total Biomass (grams) of Fishes Collected at Riffle Sampling Stations
             in the Vicinity of PPL-Martins Creek LLC during July 24 - August 2, 2006    5-52

Table 5-14   Percent Similarity Matrix for Fish Communities at Riffle Sampling Sites Near
             Martins Creek Station, July 24 - August 2, 2006                                5-54

Table 5-15   Comparison of Delaware River Riffle Stations 194.5R and 190.2R Surveyed in
             Summer 2005 and 2006                                                       5-55

Table 5-16   Number and Total Biomass (Grams) of Fish Collected at Pool Sampling Locations
             in the Vicinity of PPL – Martins Creek LLC during July 24 to August 2, 2006 5-56

Table 5-17   Percent Similarity Matrix for Fish Communities at Pool Sampling Sites near PPL –
             Martins Creek LLC, July 24 to August 2, 2006                                 5-58

Table 5-18   Comparison of Electrofishing Catches at Delaware River Pool Stations 195.1P and
             193.9P in Summer 2005 and 2006                                              5-59

Table 5-19   Condition Factor (K) Values for Smallmouth Bass, Redbreast Sunfish, and Rock
             Bass Collected near PPL – Martins Creek LLC in Summer 2006                 5-60

Table 5-20   Electrofishing Catch Summary Comparisons at Selected Riffle Fish Community
             Sample Sites near PPL – Martins Creek LLC, 1981-1989 and 2005-2006        5-60

Table 5-21   Mussels Observed in the Pools and Contiguous Habitats – September 25-29, 2006
                                                                                       5-66

Table 5-22   Eastern Elliptio1 Collected for Tissue Contaminant Analysis                    5-67


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Table 5-23   Quantitative Mussel Survey Data - September 25-29, 2006                       5-68

Table 5-24   Delaware River Freshwater Mussels Reported in Lellis (2002)1 and in the Present
             Mussel Community Assessment                                                 5-75

Table 5-25   Species Composition of Darters Sampled per Station                            5-79

Table 5-26   Estimation of RBCs for Mussel and Darter                                      5-81

Table 5-27   Summary of Mean Metal Concentrations Downstream Compared to Mean Metal
             Concentrations Upstream                                             5-85

Table 5-28   Summary Table with Ecological Health Risk-Based Concentrations: Darter and
             Mussel                                                                    5-86

Table 5-29   Summary Table with Ecological Health Risk Based Concentrations: Eagle and
             Otter                                                                    5-87

Table 5-30   Summary Table with Human Health Risk Based Concentrations                     5-88

Table 5-31   ANOVA P-Values of Differences Among All Sites                                 5-90

Table 5-32   Ratios of All Downstream to All Upstream Metal Concentrations, with Associated P-
             Values Based on Contrast Tests                                               5-91

Table 5-33   Ratios of First Two Downstream Sites to All Upstream Metal Concentrations, with
             Associated P-Values Based on Contrast Tests                                 5-92

Table 5-34   Ratios of First Downstream Site to All Upstream Metal Concentrations, with
             Associated P-Values Based on Contrast Tests                                   5-93

Table 5-35   Length Correlations                                                           5-96

Table 5-36   Weight Correlations                                                           5-97

Table 5-37   Periphyton Sample Station Locations in the Delaware River, July 31 through
             August 3, 2006                                                             5-106

Table 5-38   Selected Physical and Biological Conditions at the Periphyton Sample Stations,
             July 31 through August 3, 2006                                              5-109

Table 5-39   Chlorophyl a and Ash-free Dry Weight Summary Data                            5-110

Table 5-40   Taxa Comprising > 5 Percent of Diatoms Identified at the Reference and
             Downstream Stations                                                          5-112

Table 5-41   Diatom Metrics Summary Data                                                  5-113

Table 5-42   Taxa Which Were Scored Abundant or Greater in at Least Five or More Soft Algae
             Replicates at the Reference and Downstream Stations                      5-118

Table 5-43   Soft Algae Metrics Summary Data                                              5-119




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Charts

Chart 1-1    Chronological Summary of Delaware River Flows (Belvidere Gage)             1-5

Chart 1-2    Summary of Delaware and Lehigh River Flows – Early October 2005            1-6

Chart 3-1    Ash Basin 4 Sample Data                                                    3-3

Chart 3-2    Comparison of Metals in Ash Basin 4 and Pool 2 Samples                     3-3

Chart 3-3    Correlation of Aluminum and Nickel                                         3-6

Chart 3-4    Correlation of Aluminum and Fines Content                                  3-6

Chart 3-5    Coefficients of Variation for Various Metals                               3-7

Chart 3-6a   Delaware River Bank Metals Concentrations versus Published Regional
             Background Soil Data                                                      3-15

Chart 3-6b   Delaware River Bank Metals Concentrations versus Published Regional
             Background Soil Data                                                      3-15

Chart 3-7    Arsenic Concentrations versus ESI Sample Locations                        3-16

Chart 3-8    In-River Sediment Sample TOC Results                                      3-27

Chart 3-9    In-River Sediment Sample Grain Size Results                               3-27

Chart 3-10   Comparison of Delaware and Lehigh River Aluminum-Normalized Sediments 3-30

Chart 3-11a In-River Sediment Aluminum-Normalized Arsenic Concentrations in the Delaware
            and Lehigh Rivers                                                        3-31

Chart 3-11b In-River Sediment Aluminum-Normalized Lead Concentrations in the Delaware and
            Lehigh Rivers                                                            3-32

Chart 3-12   Lead and Zinc Concentrations versus Arsenic In-River Sediment Concentrations
                                                                                        3-32

Chart 3-13   Selenium versus Vanadium In-River Sediment Concentrations Presented by Reach
                                                                                     3-33

Chart 4-1    Lead versus TSS at Trenton                                                 4-3

Chart 4-2    TSS versus Turbidity in the Delaware River                                 4-3

Chart 4-3    Aluminum versus Turbidity at MC Up River-1                                 4-4

Chart 4-4    Aluminum versus Flow at MC Up River-1                                      4-5

Chart 4-5    Turbidity at PAFC Boat Launch-1                                            4-5

Chart 4-6    Arsenic Concentration in Surface Water Samples and Delaware River Hydrograph
                                                                                       4-8

Chart 4-7    PPL Boat Launch-1 Water Sample Arsenic Concentrations Versus Time         4-10



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Chart 4-8    Turbidity Data during and Shortly After the Release                       4-12

Chart 4-9    Turbidity Data during and Shortly After the Release                       4-13

Chart 4-10   Chronology of Arsenic Levels during the First October 2005 High-Flow Event 4-14

Chart 4-11a Turbidity Data during the October 2005 High-Flow Event                     4-15

Chart 4-11b Aluminum Data during the October 2005 High-Flow Event                      4-15

Chart 4-11c Arsenic Data during the October 2005 High-Flow Event                       4-16

Chart 4-11d Zinc Data during the October 2005 High-Flow Event                          4-16

Chart 4-12   Flow and Turbidity at Trenton in Early October 2005                       4-17

Chart 4-13   Arsenic Concentration and Turbidity near Trenton                          4-18

Chart 4-14   Arsenic versus Aluminum Concentrations in MC FC Access-1 Water Column
             Samples                                                               4-22

Chart 4-15   Ratio of Aluminum to Arsenic in MC FC Access-1 Water Column Samples during
             October 2005 High Flows                                                 4-23

Chart 4-16   Arsenic versus Turbidity at PAFC Boat Launch-1                            4-23

Chart 4-17   Comparison of Arsenic Concentrations with Regulatory Standards            4-25


Figures

Figure 1-1   Site Location Map

Figure 1-2   Ecological Characteristic of the Delaware River

Figure 3-1   River Bank Background Sample Locations

Figure 3-2   River Bank Sample Locations – Oughoughton Creek to Easton, PA

Figure 3-3   River Bank Sample Locations – Oughoughton Creek to Easton, PA

Figure 3-4   River Bank Sample Locations – Oughoughton Creek to Easton, PA

Figure 3-5   In-River Sediment Sampling Locations – To Hendrick Island

Figure 3-6   In-River Sediment Sampling Locations – Hendrick Island to Trenton, NJ

Figure 3-7   In-River Sediment Sampling Locations – Hendrick Island to Trenton, NJ

Figure 3-8   In-River Sediment Sampling Locations – Hendrick Island to Trenton, NJ

Figure 3-9   In-River Sediment Sampling Locations – Hendrick Island to Trenton, NJ

Figure 4-1   Surface Water Sample Locations

Figure 5-1   2006 Martins Creek Phase IV Sample Sites

Figure 5-2   Locations of Mussel Concentration Downstream of the Ash Release

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Figure 5-3   Locations of Mussel Concentration Immediately Upstream of the Ash Release

Figure 5-4   Locations of Mussel Concentration Further Upstream of the Ash Release


Appendices

A            River Bank Sediment Sample Analytical Results

B            In-River Sediment Sample Analytical Results

C            Surface Water Sample Analytical Results

D            Benthic Community Sample Results

E            Fish Community Sample Results

F            Periphyton Community Sampling Procedures

G            Periphyton Community Sample Results

H            Residential Property & Shoreline Inspection Summary




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Executive Summary

This document summarizes the emergency response actions taken and the outcome of the natural resource
damage assessment (NRDA) conducted by PPL Martins Creek, LLC (PPL) following the accidental release
of an estimated 100 million gallons of a mixture of water and fly ash from its Martins Creek Steam Electric
Station facility in Pennsylvania on August 23 to 26, 2005. The emergency response actions were completed
in March 2006 while the assessment work continued through June 2006. The release deposited ash onto
PPL-owned land, onto the dry Oughoughton Creek bed, and into the Delaware River immediately
downstream of the failed Ash Basin 4 discharge control structure. PPL responded immediately to this event
by implementing the following activities:

     •      An immediate emergency response to contain and remove bulk ash deposits from along the
            Delaware River shoreline near the Basin 4 discharge structure and from all upland areas near the
            basin, which resulted in the recovery of approximately 19,000 cubic yards (cy) of material.

     •      An immediate cleanup of more than 2,500 cy of fly ash from the adjacent Oughoughton Creek bed.

     •      A Phase I cleanup (September 2005) of more than 400 tons of fly ash and sediments from the
            Delaware River immediately downstream of the Ash Basin 4 discharge structure.

     •      A Phase II cleanup (September to November 2005) recovering more than 800 cy of fly ash from
            within the Portadam structure in the Delaware River.

     •      A Phase III cleanup (November 2005 to March 2006) of nearly 56,500,000 gallons of slurry
            containing approximately 1,300 cy of fly ash (via vacuum dredging) from two depositional areas of
            the Delaware River within 1.5 miles of Ash Basin 4.

     •      Several scientific investigations to assist cleanup efforts and evaluate potential impacts of the
            release, including the Phase IV activities presented in this document.

     •      Communication with various local, state, and federal agencies and groups of interest to discuss
            work plans, cleanup activities, sample results, and any changes in river conditions and to obtain all
            required permits and approvals from the various agencies to implement the cleanup activities.

The Phase IV study area includes the Delaware River between a location upstream of the Ash Basin 4
release and downstream to Trenton, New Jersey (the river is under tidal influence downstream of Trenton).
This was described in the agency-approved Phase IV Work Plan (Blasland, Bouck & Lee, Inc. [BBL, now
ARCADIS BBL] 2006b), which was submitted to the Pennsylvania Department of Environmental Protection
(PADEP) in February 2006. The PADEP is acting as the main point of contact for the NRDA, In addition to
PADEP, the Natural Resource trustees and other agencies involved in the oversight and review of this work
include the New Jersey Department of Environmental Protection (NJ DEP), Pennsylvania Fish and Boat
Commission, and New Jersey Fish and Boat Commission, United States Fish & Wildlife Service (USFWS),
National Oceanic and Atmospheric Administration (NOAA), Delaware River Basin Commission,




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Pennsylvania Department of Conservation and Natural Resources (PA DCNR), National Parks Service, and
United States Environmental Protection Agency (USEPA).

This Phase IV Completion Report presents the objectives, scope, and results of investigations conducted
since the August 2005 release to determine the presence, extent, and potential impacts of fly ash in
Delaware River sediments, surface water, and biological communities. This report also describes the results
of sampling conducted on several residential properties. The results will be reviewed with the NRDA team
either to close out the investigation or to determine what additional actions may be required prior to closing
out the investigation.

The Phase IV Completion Report summarizes a number of studies performed in 2005 and 2006. These
studies included evaluating metals concentrations in sediment (both river bank and in-river) and surface
water, evaluating metals concentrations in fish and mussel tissues, and conducting aquatic surveys
including fish surveys, benthic macroinvertebrate surveys, mussel surveys and periphyton surveys. The
sediment and surface water studies were developed to address three basic questions:

     1. Were there any statistically significant differences in the metals concentration in sediment quality or
        water quality between reference (background) stations and downstream stations?

     2. For those metals for which there were statistically significant differences, are the differences
        potentially related to the fly ash release that occurred in August 2005?

     3. For those metals that showed statistically significant differences potentially related to the fly ash
        release, did any of them exceed any relevant ecological or human health screening criteria?

The biological study consisted of an evaluation of the following:

     1. A determination of whether there were any statistically significant differences in community
        characteristics of benthic invertebrates, mussels or fish in downstream stations compared to
        reference stations that could be related to the fly ash release.

     2. A determination of whether there were any statistically significant differences in metals
        concentrations in fish and mussels in downstream stations compared to reference stations that
        could be related to the fly ash release.

     3. Estimation of risk-based concentrations for all metals on the target analyte list.

To answer these questions and perform these evaluations, the following investigations were performed in
the Delaware River as part of the Phase IV activities:

     •      Sediment sampling, including river bank sampling and in-river sediment sampling (refer to Section 3
            for a detailed discussion of these activities and results).

     •      Surface water sampling (refer to Section 4 for a detailed discussion of these activities and results).


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     •      Biological monitoring, including fish surveys, benthic macroinvertebrate surveys, mussel surveys,
            periphyton surveys, and the collection of tissue samples for chemical analyses (refer to Section 5
            for a detailed discussion of these activities and results).

Results of the Phase IV investigation and subsequent data analysis support the following observations and
conclusions.

Public Inquiries

PPL and its contractors performed extensive assessments of the river banks and properties down river of
the release site for the presence of suspected ash particles immediately following the August 2005 release
and as part of the Phase IV investigation. To address all public inquiries related to potential ash deposits,
and to supplement the existing assessment data through identification and evaluation of the “recoverability”
of potential ash pockets, PPL developed a strategy for responding to public inquiries.

Although no recoverable ash was expected to be present following completion of the Phase III cleanup
activities, PPL developed an approach to address any public concerns regarding the potential presence of
suspected ash. In general, the approach used by PPL to address inquiries received (through phone, e-mail,
letter, or public meetings) was to contact the property owner who registered the concern, conduct a site visit
to assess if any recoverable ash was present, and report the findings of the investigation to the property
owner.

Of the eight inspections completed during the program, only two locations had any observable ash particles.
The two locations with observable ash particles were located along the shores of the Delaware River and
not on private land. The amount of ash particles at these two locations were determined to be “trace” and no
recoverable ash pockets were identified. The remaining sites and sampling locations had no observable ash
particles.

PPL did not identify any recoverable ash pockets through the program, and PPL has received no public
inquiries since April 2006.

Phase IV Sediment Sampling Results

River bank sampling conducted in June 2006 was a continuation of two previous sampling events
conducted in the same reach of the Delaware River (i.e., between the Site and the confluence with the
Lehigh River at Easton, Pennsylvania). The river bank sampling program was designed to evaluate
sediment quality along the edge of the river, with a focus on areas of probable sediment accumulation. The
goal of the sampling was to evaluate changes in the river bank sediments observed over time and to
document more current conditions along the shorelines. June 2006 river bank sampling included 10
background samples and 63 downstream samples (from 59 locations) collected from both banks of the
River, including 27 locations that were sampled previously in September 2005 and 20 samples that were
part of a visual sampling program in November 2005. The river bank samples were analyzed for target
analyte list (TAL) metals, grain size, total organic carbon (TOC), moisture content and bulk density.




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Data from the previous sediment investigations indicate that arsenic is the best chemical surrogate indicator
for the potential presence of fly ash materials as more fully explained in Section 3.1.1. Therefore, much of
the data analysis focuses on observed patterns in arsenic concentrations. Because of the role of river
dynamics and its influence on natural variability in sediments and subsequent variability in metals
concentrations, data analysis also includes consideration of parameters such as aluminum, TOC, and grain
size to adjust (i.e., normalize) the observed concentration values for variability in sediment characteristics.
Aluminum was selected as the best overall parameter to normalize for natural sediment variability for
purposes of the statistical analyses as more fully explained in Section 3.1.2.

Overall, the September 2005 and June 2006 river bank sample results indicate that aluminum-normalized
levels of certain constituents, likely related to the fly ash release, (e.g., arsenic, beryllium, mercury,
selenium, and vanadium) were statistically higher downstream of the release when compared to
background river bank sediments. Zinc was also higher in downstream sediment than background, but likely
is not related to fly ash because zinc concentrations are higher in background river bank samples than in the
Ash Basin 4 sample and because the temporal trend of zinc is opposite that of arsenic.

Despite some changes in the temporal/spatial distribution of fly-ash related constituents, comparison to
published background soil data for the eastern United States, New Jersey, and Pennsylvania indicate that
the metals concentrations observed in the river bank sediments are within the range of anticipated metals
concentrations for this geographic area. In addition, stream bank sediment concentrations of potential fly
ash-related metals in samples collected from both sides of the river were all below both the Pennsylvania
Medium-Specific Concentration (MSC) for direct contact and the New Jersey soil cleanup criteria. Therefore,
there was no identified human health risk related to potential contact with river bank sediment that may have
contained fly ash.

River bank sediment data were also compared to sediment screening benchmarks recommended as
guidance for sediment data assessment by the NJDEP (NJDEP 1998) and alternative sediment screening
values available from MacDonald et al. (2000). The NJDEP-recommended sediment values include lowest
effect levels (LELs) and severe effect levels (SELs). LELs are defined as a level of sediment contamination
that can be tolerated by the majority of benthic organisms, and SELs as the level at which pronounced
disturbance of the sediment dwelling community can be expected (Persaud et al. 1993). For the alternative
sediment screening values, the consensus-based threshold effect concentrations (TECs) were calculated by
determining the geometric mean of all threshold effect values from the literature, and the consensus-based
probable effect concentrations (PECs) were calculated by determining the geometric mean of all probable
effect values from the literature. All of these benchmarks are generic screening levels developed for
screening purposes only, and should typically be used in decision-making with other lines of evidence
(Burton et al 2002; Chapman et al. 2002). In fact, these levels are so conservative that use of these generic
benchmarks (even for screening purposes) is increasingly being questioned (O’Connor 2004; Jones-Lee
and Lee 2005; Smith and Jones 2005). Nonetheless, these levels were used here for conservative
screening purposes.

Comparison of river bank sediment results to ecological screening benchmarks recommended by NJDEP
indicates that the only metal with results higher than the LEL was arsenic (the LEL is 6 mg/kg). The limited
number of exceedances slightly above the LEL for arsenic were three of 29 samples in 2005, and four of 56


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samples in 2006. No SEL exceedances were identified. All of the river bank sediment arsenic results are
below both the TEC (9.8 mg/kg) and the PEC (33 mg/kg).

A goal of the Phase IV in-river sediment sampling program was to provide additional data to geographically
extend the evaluation of potential fly ash presence. The June 2006 Phase IV data supplement the existing
data from two previous in-river sediment sampling programs: one in September 2005 (after the release and
prior to first high-flow event) and one in November 2005 (after a series of October high-flow events). These
two previous sediment sampling programs focused on reaches of the Delaware River between the Site and
Hendrick Island. The June 2006 Phase IV in-river sediment sampling program included the reach of the
Delaware River from Hendrick Island downstream to Trenton, New Jersey. The June 2006 program
included the collection of 13 core samples. The samples were analyzed for TAL metals, TOC, grain size,
moisture content, and bulk density. Grey bands of material (a potential indicator of fly ash) were not
observed in any of the cores collected during the Phase IV in-river sediment sampling event conducted in
June 2006.

The results of the September and November 2005 in-river sediment samples from above the Lehigh River
confluence indicate that arsenic concentrations are slightly higher compared to upstream reference
samples. Co-located sediment samples collected in September 2005 and November 2005 show a
statistically significant decrease in arsenic concentrations, which likely was a result of a high-flow event that
occurred from October 8 to 10, 2005. Arsenic concentrations for four samples exceeded the LEL (two in
September 2005 and two in November 2005); however, LEL exceedance also occurred at one sample from
an upstream (reference) location. Only one sample from the September 2005 sampling exceeded the SEL
for arsenic, while none of the sediment samples from the November 2005 sampling exceeded the SEL for
arsenic. None of arsenic levels in this reach and in background samples from the November 2005 sampling
round exceeded the TEC or PEC screening criteria. Barium, beryllium, chromium, and vanadium were also
elevated between the Site and the Lehigh River as compared to background. Chromium is not likely related
to fly ash based upon the concentration of chromium in ash compared to background sediment
concentrations. Barium, beryllium, and vanadium, which may be related to the fly ash release, do not have
established LELs. The relatively low SEM/AVS ratios identified for samples from above the Lehigh River
indicate that metals bioavailability is limited and there is little potential for toxicity.

The in-river sediment results also indicate that the Lehigh River, which was not affected by the ash release,
is a significant if not dominant contributor of metals to the Delaware River. This is supported by the fact that
concentrations of all metals (except selenium) were higher (often by a factor of five or more) in the Lehigh
River than the Delaware River. All three Lehigh River background samples had exceedances of the LEL for
multiple metals including one for arsenic. In addition, the ΣSEM was much higher in the Lehigh River
sediments than Delaware River upstream of the Lehigh. As such, comparisons of in-river sediment
downstream of the Lehigh River to LELs are not presented.

Phase IV Surface Water Sampling Results

From August 25 to December 21, 2005, more than 2,200 surface water samples were collected to
characterize water quality during and after the fly ash release. During and following the release, significant
quantities of fly ash solids were suspended and transported in the water column, increasing concentrations


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of several metals likely related to fly ash. Metals concentrations greatly decreased in the month following the
release with time and downstream distance, then temporarily increased again during the first high-flow event
starting (October 8, 2005) after the release. These elevated concentrations likely were caused by the
resuspension of fly ash deposited in the river bed. Strong geochemical evidence exists that the first high-
flow event exhausted the vast majority of deposited fly ash. As early as the beginning of October 9, the
downstream concentrations, while elevated, were consistent with naturally elevated background
concentrations observed. These natural increases due to suspended solids, unrelated to the fly ash release,
caused exceedances of water quality criteria for some metals, most notably aluminum.

After the first high flow event, arsenic was detected in less than one percent of the 500+ water column
samples. For most metals, including those with an association to fly ash (e.g. arsenic and vanadium),
downstream concentrations were indistinguishable from background. Several metals not related to fly ash
(copper, nickel, vanadium, and zinc) had simultaneous, episodic increases during specific periods (October
25 to November 3, 2005 and December 8 to 16, 2005).

Surface water data were compared to PADEP Chapter 16 Human Health Criteria, and USEPA ambient
water quality criteria (AWQC). The PADEP human health criteria include potential exposure based on
drinking water and fish consumption. The USEPA AWQC are based on survival of aquatic organisms, and
include criterion continuous concentrations (CCCs) for long-term (chronic) exposure. Only arsenic exceeded
the PADEP Chapter 16 Human Health Criteria, which only occurred during the actual release in August
2005 and only at one sample point within 50 yards of the ash discharge. During the active release and after
the release was stopped, the PADEP Chapter 16 Human Health Criteria were not exceeded at any
sampling point beyond the discharge area. Arsenic exceeded the CCC only once during the release at the
sampling location immediately downstream of the release. Several metals, including arsenic, copper, lead,
nickel, and zinc, exceeded the USEPA AWQC at least once; however, all of these metals except arsenic
exceeded the CCC levels at the upstream sample location at least once. After October 9, there were no
criteria exceedances related to the fly ash release. The background river samples typically had elevated
metals concentrations during higher flow conditions and even background arsenic concentrations increased
during the more turbid high flow conditions. These increases are attributed to the natural sediments and
soils or other upriver sources that are suspended in the river during higher flow conditions.

Phase IV Biological Monitoring Results

A series of biological assessments were conducted by Normandeau Associates on the Delaware River. The
biological assessments included fish, benthic macroinvertebrate, mussel, and periphyton surveys, as well as
the collection of fish and mussel tissue samples for chemical analyses. The Phase IV biological studies
supplement the information from similar studies that were conducted immediately following the release.

Two field studies were performed to evaluate the aquatic communities in the Delaware River in the area
of the ash release. These studies were conducted to determine if there were any observable differences
in the biological communities between upstream and downstream stations and, if any measurable
differences were found, whether those differences were related to the ash release.




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The first study, conducted shortly after the spill with a second round follow-up in September 2005, was a
rapid bioassessment using USEPA protocol. The investigation included benthic macroinvertebrate and
fish community surveys and the collection of fish tissue samples for chemical analysis. The results of this
initial investigation showed that fish and macroinvertebrates were abundant and diverse with no apparent
effects on either of these communities from the ash release. The fish tissue analysis also identified no
consistent patterns of metals concentrations due to the ash release.

The second study, conducted after the cessation of ash recovery efforts in the summer of 2006, was
based on an agency-approved plan that was developed to provide the data necessary to evaluate
biological communities using statistical analyses as well an appropriate suite of metrics. The study
included evaluations of the fish, benthic macroinvertebrate, mussel and periphyton communities as well
as fish and mussel tissue analysis. The development of the plan included the input and oversight of the
Academy of Natural Sciences of Philadelphia, Pennsylvania. Background information on Delaware River
aquatic communities was obtained from published studies, especially work done by Dr. William Lellis on
freshwater mussels in the Delaware Water Gap National Recreation Area.

The fish, mussel, benthic macroinvertebrate and periphyton assessment metrics indicated that these
communities downstream of the release were generally similar to those observed upstream of the
release. Natural variability within the communities in the river accounted for much of what little differences
were found. Fish and mussel tissue data indicated that metals concentrations downstream of the release
were not elevated compared to background concentrations and were below risk-based thresholds.

Summary Recommendation

The multiple lines of evidence provided by the Phase IV investigation results (in combination with previous
data) indicate that the limited fly ash-related channel deposits remaining in the Delaware River after the
August 23 to 26, 2005 release either were removed as part of the removal actions, or were depleted by the
October 2005 high-flow event. Further, the data do not indicate that the release has adversely affected the
sediment or water quality or the various representative ecological communities or representative species of
the Delaware River. There is no evidence that the release has adversely affected human health or had any
direct impact (i.e. ash deposits) on privately owned land along the Delaware River. Neither the Agencies
nor PPL prohibited recreational opportunities in the river, except that PPL closed the PPL boat launch area
throughout the emergency response action. Based on these results, no additional data collection or
remedial action is warranted or recommended.




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