1. Introduction Description of Impoundments 1

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2 Mercer enerating tation, Hamilton Township, ew Jersey ctober, Table of Contents. Introduction. escription of Impoundments. 7 Annual Inspection. Annual Inspection.. eview of Available Information.. Visual Inspection of the CC unit..3 Visual Inspection of Hydraulic tructures 3. Annual Inspection eport 3 3. Changes in eometry 3 3. Location and Type of Instrumentation epths and levations 3 3. torage Capacity Volumes 3 3. tructural Weakness ther otes Changes 3 3. eficiency Identified Figures. ite Location Map. ite Plan 3. CC Impoundment Footprint and Initial Conditions Plan TK/lsf B:\Working\P\57 CC upport\7_eports\--5 Annual Inspection eports\mercer\--5 Mercer Facility Annual Inspection eport.docx I Consultants, Inc. i

3 Mercer enerating tation, Hamilton Township, ew Jersey ctober,. Introduction n behalf of P Fossil (P), I Consultants, Inc. (I) has prepared the Annual Inspection eport for the Coal Combustion esiduals (CC) urface Impoundments (Impoundments) at the Mercer enerating tation. There are two inactive Impoundments: orth Fly Ash Pond; and outh Fly Ash Pond. This report was prepared to meet the requirements of CF escription of Impoundments The Mercer enerating tation is owned by P Power and located at 5 Lamberton oad in Hamilton Township, ew Jersey. The facility maintains -acre orth Fly Ash Pond and a -acre outh Fly Ash Pond that ceased receiving CC prior to ctober 9, 5. The impoundments are constructed as predominantly incised impoundments with a bermed wall along Lamberton oad that varies in height above the surrounding grade by five-to-six feet. A otice of Intent (I) to initiate closure of the CC impoundment under ection 57. of the CC ule was posted on the P CC ule Compliance ata and Information website on ovember, 5. Though closure by removal of all CC is no longer permitted under ection 57. of the CC, Closure of these CC impoundments is proceeding in accordance with ection 57. of the CC rule and the associated 57-day timeframe extension. As documented in a March 3, 7 memo prepared by I, CC removal was completed on ctober 9, and all CC has been removed from the Impoundments. CC urface Impoundment is defined at CF I Consultants, Inc.

4 Mercer enerating tation, Hamilton Township, ew Jersey ctober,. Annual Inspection. Annual Inspection As required by CF 57.3(b), inspections of all CC surface impoundments were performed by a qualified professional engineer (Tyler K. chott, J P.. #79) on multiple occasions. The ctober 9, inspection served as the initial inspection. As discussed above, the Impoundments are inactive and have been closed through removal of all CC. The berms surrounding each Impoundment are still present and were inspected as part of the annual inspection conducted on August 3,... eview of Available Information In accordance with 57.3(b)(i), a review of available information regarding the status and condition of the CC unit is required. There were no available design documents or impoundment testing data to perform a quantitative analysis of the berm condition. Based on the visual observations of the impoundments during inspections, and the inactive/closed status of the impoundments, quantitative evaluation of each impoundment was not necessary... Visual Inspection of the CC unit In accordance with 57.3(b)(ii), a visual inspection of the CC unit to identify signs of distress or malfunction is required. The Impoundments are inactive and have been closed. Based on the visual inspections, the berms are in good condition and no signs of distress or malfunction was observed...3 Visual Inspection of Hydraulic tructures In accordance with 57.3(b)(iii), a visual inspection of any hydraulic structures underlying the base of the CC unit or passing through the dike of the CC unit is required. The hydraulic control structures were inspected visually by facility personnel on a weekly basis and subject to frequent inspection by a licensed Professional ngineer. Throughout the process of closure by removal, the hydraulic control structures remained intact, structurally sound, and unused. ischarge from the Mercer facility impoundments would require a significant volume of water and positive action from facility personnel to initiate discharge. I Consultants, Inc.

5 Mercer enerating tation, Hamilton Township, ew Jersey ctober, 3. Annual Inspection eport The following sections are required to be inspected and included in the inspection report as stated in CF 57.3(). 3. Changes in eometry o changes in geometry were noted. The Impoundments have undergone closure by removal. 3. Location and Type of Instrumentation Historically, there was no instrumentation used to evaluate the status and condition of the berms associated with facility CC impoundments. ue to the closure of the Impoundments, no new instrumentation is required for monitoring. 3.3 epths and levations valuation of the minimum, maximum and present depth and elevation of the impounded water is required as part of the inspection report. The CC has been fully removed and therefore this portion of the annual inspection is not applicable. 3. torage Capacity The Impoundments have undergone closure and therefore have no storage capacity available for CC. 3.5 Volumes The CC has been fully removed and therefore this portion of the annual inspection is not applicable. 3. tructural Weakness The Impoundments have undergone closure. The berms surrounding the Impoundments remain unchanged. There were no observed structural weaknesses in the Impoundments. 3.7 ther oted Changes As discussed throughout, the Impoundments are closed. Many of the inspection items required by CF 57.3() and discussed above are not applicable as the CC has been removed. I Consultants, Inc. 3

6 Mercer enerating tation, Hamilton Township, ew Jersey ctober, 3. eficiency Identified o deficiencies were observed as part of the annual inspection activities for the Impoundments. I Consultants, Inc.

7 Mercer enerating tation, Hamilton Township, ew Jersey ctober, Figures I Consultants, Inc.

8 IT Copyright: 3 ational eographic ociety, i-cubed UC:. U TPAPH MAP ACC VIA CILI.CM,, CAL: " = ' P - Mercer Hamilton, ew Jersey P Power, LLC ew Jersey Q:\Project\P - Mercer\7- \Fig - ite Location.mxd C o n s u l t a n t s Project 57 IT LCATI MAP August 7 Fig.

9 FM TH FLY AH P FM UTH FLY AH P L: Approximate Property Line UC:. IAL FM I WL IMAY - 5. \\mtlv-fs\gis\project\p - Mercer\7- \Fig - ite Plan.mxd CAL: " = ' P - Mercer Hamilton, ew Jersey IT PLA P Power, LLC Consultants ew Jersey Project 57 ctober Fig.

10 LAM A T A A H A B T B A C APP BA CAP P F, PP FM TH FLY AH P 9,5 L A CA L F M P P P P P P P P P P P 5:. P P P P P P P P 5:. IP P TA W AL L W PP IP P P IP P H A AFM A I TC, PP IP 7,5 I I : LL BX. T P WV.5 7, H U W A.3 P P P P X.B C L A PL,5. C 9, L IT CTU BA U LI UVY FM APIL 9. TH ATA WA BT FM TH W JY FF F IFMATI TCHLY, FF F APH IFMATI YM. 3. VTAL ATUM BA AV.. IL Y. I BU W P I TA HIZTAL ATUM BA W JY AT PLA CIAT, A 3. P P P. A T I U IL A K FF A I L TA T: PP XCAVATI CTU AB V U P VHA LC C LA ACK BU Y IL. I F C L U L P P A C U L BU Y IL. I A ABL C LC TW A TW P FC T C P P ' A BUILI FF P T W 3 KV ITC H YA LA W P C LA T I L U H XII U UFAC CTU VI K PPTY LI (APPXIMAT) P T C F C L A5 IL PA A LV WAMP A TW AT C K FMUTH FLY AH P P Y " IA. ABV U A P L P L T T A M B P C M CU F P U UVY CL MUMT P i BU Y IL. I P A F P M CA T P L P L L P L CA F PP P A P C A F L A C F C L P A F CA IP P L P C K P B C i IP P A P F L L H P L P C F F V IL LI M A T UC F M K I AL F F A L C IL T IP P T C A C F C L F F C L P C : IL KP TC 9, F IP IL P A.5 IL KP C 3 IL IL A.5 : P A M ) F & A P ( FF FF. C L BX T TW C :.5 U CK & TW KP IL IP P P C FF F P P P L P P LI P T AT FF W P PA V M H AL HI P PH A Y L T.5 : P P V g V V MC P g g g V MC LC. gg gv' BX g V' LC. g BX MC V' LC. gg gi BX gg V' P TH A T P.5: W M F P CA P F P L A B AT.5 : H AC L 9,5.5: W P F 7,5 7, L A CA F L M,5 W CAL: " = ' P - Mercer Hamilton, ew Jersey P Power, LLC ew Jersey Consultants Project 57 CC IMPUMT FTPIT A IITIAL CITI PLA - TH A UTH FLY AH P ctober Fig P:\Project\P\Mercer\7- CC Inspection eport\cc Conditions.dwg - /9/7

12 Mercer enerating tation, Mercer, ew Jersey ctober 7, 7 Table of Contents. Introduction. escription of Impoundments. 7 Annual Inspection. Annual Inspection.. eview of Available Information.. Visual Inspection of the CC unit..3 Visual Inspection of Hydraulic tructures 3. Annual Inspection eport 3 3. Changes in eometry 3 3. Location and Type of Instrumentation epths and levations 3 3. torage Capacity Volumes 3 3. tructural Weakness ther otes Changes 3 3. eficiency Identified Figures. ite Location Map. ite Plan 3. CC Impoundment Footprint and Initial Conditions Plan TK/lsf H:\WPC\Project\P\Mercer\Mercer Facility Annual Inspection eport - Final -7-7.docx I Consultants, Inc. i

13 Mercer enerating tation, Mercer, ew Jersey ctober 7, 7. Introduction n behalf of P Fossil (P), I Consultants, Inc. (I) has prepared the 7 Annual Inspection eport for the Coal Combustion esiduals (CC) urface Impoundments (Impoundments) at the Mercer enerating tation. There are two inactive Impoundments: orth Fly Ash Pond; and outh Fly Ash Pond. This report was prepared to meet the requirements of CF escription of Impoundments The Mercer enerating tation is owned by P Power and located at 5 Lamberton oad in Hamilton Township, ew Jersey. The facility maintains -acre orth Fly Ash Pond and a -acre outh Fly Ash Pond that ceased receiving CC prior to ctober 9, 5. The impoundments are constructed as predominantly incised impoundments with a bermed wall along Lamberton oad that varies in height above the surrounding grade by five-to-six feet. A otice of Intent (I) to initiate closure of the CC impoundment under ection 57. of the CC ule was posted on the P CC ule Compliance ata and Information website on ovember, 5. Though closure by removal of all CC is no longer permitted under ection 57. of the CC, Closure of these CC impoundments is proceeding in accordance with ection 57. of the CC rule and the associated 57-day timeframe extension. As documented in a March 3, 7 memo prepared by I, CC removal was completed on ctober 9, and all CC has been removed from the Impoundments. CC urface Impoundment is defined at CF I Consultants, Inc.

14 Mercer enerating tation, Mercer, ew Jersey ctober 7, 7. 7 Annual Inspection. Annual Inspection As required by CF 57.3(b), inspections of all CC surface impoundments were performed by a qualified professional engineer (Tyler K. chott, J P.. #79) on multiple occasions. The ctober 9, inspection served as the annual inspection event for this impoundment. In accordance with the CC ule, weekly inspections were initiated in April 7 and are ongoing. The weekly inspections confirm that there is no change to the Impoundments since the ctober 9, annual inspection. As discussed above, the Impoundments are inactive and have been closed through removal of all CC. The berms surrounding each Impoundment are still present and were inspected as part of the annual inspection... eview of Available Information In accordance with 57.3(b)(i), a review of available information regarding the status and condition of the CC unit is required. There were no available design documents or impoundment testing data to perform a quantitative analysis of the berm condition. Based on the visual observations of the impoundments during inspections, and the inactive/closed status of the impoundments, quantitative evaluation of each impoundment was not necessary... Visual Inspection of the CC unit In accordance with 57.3(b)(ii), a visual inspection of the CC unit to identify signs of distress or malfunction is required. The Impoundments are inactive and have been closed. Based on the visual inspections, the berms are in good condition and no signs of distress or malfunction was observed...3 Visual Inspection of Hydraulic tructures In accordance with 57.3(b)(iii), a visual inspection of any hydraulic structures underlying the base of the CC unit or passing through the dike of the CC unit is required. The hydraulic control structures were inspected visually by facility personnel on a weekly basis and subject to frequent inspection by a licensed Professional ngineer. Throughout the process of closure by removal, the hydraulic control structures remained intact, structurally sound, and unused. ischarge from the Mercer facility impoundments requires significant volumes of water to accumulate in the impoundments and positive action from facility personnel to initiate discharge. I Consultants, Inc.

15 Mercer enerating tation, Mercer, ew Jersey ctober 7, 7 3. Annual Inspection eport The following sections are required to be inspected and included in the inspection report as stated in CF 57.3(). 3. Changes in eometry o changes in geometry were noted. The Impoundments have undergone closure by removal. 3. Location and Type of Instrumentation Historically, there was no instrumentation used to evaluate the status and condition of the berms associated with facility CC impoundments. ue to the closure of the Impoundments, no new instrumentation is required for monitoring. 3.3 epths and levations valuation of the minimum, maximum and present depth and elevation of the impounded water is required as part of the inspection report. The CC has been fully removed and therefore this portion of the annual inspection is not applicable. 3. torage Capacity The Impoundments have undergone closure and therefore have no storage capacity available for CC. 3.5 Volumes The CC has been fully removed and therefore this portion of the annual inspection is not applicable. 3. tructural Weakness The Impoundments have undergone closure. The berms surrounding the Impoundments remain unchanged. There were no observed structural weaknesses in the Impoundments. 3.7 ther otes Changes As discussed throughout, the Impoundments are closed. Many of the inspection items are not applicable as the CC has been removed. I Consultants, Inc. 3

16 Mercer enerating tation, Mercer, ew Jersey ctober 7, 7 3. eficiency Identified o deficiencies were observed as part of the annual inspection activities for the Impoundments. I Consultants, Inc.

17 Mercer enerating tation, Mercer, ew Jersey ctober 7, 7 Figures I Consultants, Inc.

18 IT Copyright: 3 ational eographic ociety, i-cubed UC:. U TPAPH MAP ACC VIA CILI.CM Q:\Project\P - Mercer\7- \Fig - ite Location.mxd, CAL: " = ' P - Mercer Hamilton, ew Jersey P Power, LLC ew Jersey, IT LCATI MAP C o n s u lt a n t s Project 57 August 7 Fig.

19 TH FLY AH P UTH FLY AH P L: Approximate CC Footprint Approximate Property Line UC:. IAL FM I WL IMAY - 5. CAL: " = ' Q:\Project\P - Mercer\7- \Fig - ite Plan.mxd P - Mercer Hamilton, ew Jersey P Power, LLC ew Jersey IT PLA Consultants Project 57 ctober 7 Fig.

20 , 7,5 7, L,5 W B A T H A A A L A C A F M LAM B A C T APP F A 9,5 L A CA L F M P P P P P P P P P P. 5: P P P P P P P P P IP P P I W AL L W LL BX. T T PP IP P P IP P H AFM P - Mercer Hamilton, ew Jersey I TC, PP IP 7,5 WV W.5 : P P P UTH FLY AH P P T 7, H U 9, A 3. X.B L C A PL,5 A IT CTU BA U LI UVY FM APIL 9. TH ATA WA BT FM TH W JY FF F IFMATI TCHLY, FF F APH IFMATI YM. W A 3. VTAL ATUM BA AV. K L. IL Y. I BU HIZTAL ATUM BA W JY AT PLA CIAT, A 3. P P P. A I U IL A FF A I L K TA T: AB V U P VHA LC. BU Y IL. I F C L C I TA C BU Y IL. I :.5 YA BL CA PP XCAVATI CTU P KV LA ACK P U L P CT A LC TW A I TW L U P T FC A T C P H ITC A 3 A C P AT P C C W " IA. ABV U A P L P U H XII U UFAC CTU BUILI FF P P P LA T A PPTY LI (APPXIMAT) T ' I V I P K U T PA L UVY CL MUMT M B BU Y IL. I W WAMP A T- W T L Y LA P A A P i L C F L C A5 IL P P L F P M P LV F L P L CU A P CA IP P P A F A C L CA T & L M L IP P P L F IP P F A P C H IL F F L IL KP TC L F V LI M A T UC F M K I AL IL C F F F F F C IL KP C 3 F C L A L T A C F C L C T C 9, F M ) F & A P ( L L L FF : IP P.5 P : IP FF. C L BX FF.5 P T TW P C :.5 L TW IP P KP I P L C F APP P P P P K A P P C B P CK i FF P U F P T C P : PA V M LI T AT P AL PH W HI H Y L P.5 A V g V V MC P g g g V MC LC. gg gv' BX g V' LC. g BX MC V' LC. gg gi BX gg V' P P TH A P.5: W M TH FLY AH P F P P L P T : PP CA A F HA AC.5 B L 9,5.5: BA CAP P F W CAL: " = ' P Power, LLC ew Jersey Consultants Project 57 CC IMPUMT FTPIT A IITIAL CITI PLA - TH A UTH FLY AH P ctober 7 Fig P:\Project\P\Mercer\7- CC Inspection eport\cc Conditions.dwg - /9/7

HISTORY OF CONSTRUCTION FOR EXISTING CCR SURFACE IMPOUNDMENT PLANT GADSDEN ASH POND 40 CFR (c)(1)(i)-(xii)

HISTORY OF CONSTRUCTION FOR EXISTING CCR SURFACE IMPOUNDMENT PLANT GADSDEN ASH POND 40 CFR 257.73(c)(1)(i)-(xii) (i) Site Name and Ownership Information: Site Name: Site Location: Site Address: Gadsden