Location Restrictions Certification Report NIPSCO Michigan City Generating Station Boiler Slag Pond

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Location Restrictions Certification Report NIPSCO Michigan City Generating Station Boiler Slag Pond Pursuant to: 40 CFR 257.60 40 CFR 257.61 40 CFR 257.62 40 CFR 257.63 40 CFR 257.64 Submitted to: Northern Indiana Public Service Company Michigan City Generating Station Michigan City, Indiana Submitted by: Golder Associates Inc. 15851 South US 27, Suite 50 Lansing, Michigan, USA 48906 +1 517 482-2262 Project No. 164817101 October 17, 2018

October 17, 2018 164817101 Table of Contents CERTIFICATION... C-1 1.0 INTRODUCTION... 1 1.1 Background... 1 1.2 Purpose... 1 2.0 LOCATION RESTRICTIONS... 1 2.1 Placement Above the Uppermost Aquifer [40 CFR 257.60]... 1 2.2 Wetlands [40 CFR 257.61]... 1 2.3 Fault Areas [40 CFR 257.62]... 2 2.4 Seismic Impact Zones [40 CFR 257.63]... 2 2.5 Unstable Areas [40 CFR 257.64]... 2 2.5.1 Petroleum Fields/Wells... 2 2.5.2 Sand and Gravel Pit... 2 2.5.3 Active Mineral... 2 2.5.4 Karst... 2 2.5.5 Liquefaction Potential... 2 2.5.6 Surface Mine... 3 2.5.7 Underground Mine... 3 2.5.8 Steep Slope... 3 2.5.9 Abandoned Quarries... 3 2.5.10 Differential Settlement... 3 3.0 CONCLUSION AND SUMMARY... 3 4.0 REFERENCES... 3 Figures Figure 1 Figure 2 Site Location Map CCR Unit Location Map i

October 17, 2018 164817101 1.0 INTRODUCTION 1.1 Background 40 Code of Federal Regulations (CFR) Parts 257 and 261, Hazardous and Soil Waste Management System; Disposal of Coal Combustion Residuals From Electric Utilities; Final Rule (CCR Final Rule), as amended, and corresponding regulations under 329 Indiana Administrative Code (IAC) 10-9-1 place requirements on the location of CCR management units. Golder Associates Inc. (Golder) on behalf of Northern Indiana Public Service Company (NIPSCO) evaluated the location criteria and prepared this Location Restrictions Certification Report for the Michigan City Generating Station (MCGS - Site) Boiler Slag Pond (BSP, the CCR Unit) located in Michigan City, Indiana. MCGS is located at 101 Wabash Street, in Michigan City, LaPorte County, Indiana (Latitude 41 43 15 N and Longitude 86 54 30 W, see Figure 1). The Site, located in a mixed industrial, commercial, and residential area, is bounded to the east by Trail Creek, to the north by Lake Michigan, to the south by Chicago South Shore & South Bend Railroad (CSS) tracks and further south by West Michigan Street/Indiana Route 12 and commercial/residential properties, and to the west/southwest by the Indiana Dunes National Lake Shore (IDNL). The BSP is an approximately 2.5-acre surface impoundment (Figure 2). 1.2 Purpose The purpose of this Location Restrictions Certification Report is to provide demonstrations for the certification required by 40 CFR 257.60-64. Location Restrictions criteria include: 257.60 Placement above the uppermost aquifer 257.61 Wetlands 257.62 Fault areas 257.63 Seismic impact zones 257.64 Unstable areas 2.0 LOCATION RESTRICTIONS The following sections outline NIPSCO s ( owner ) requirements as presented in 40 CFR 257 Subpart D, Location Restrictions regulations. 2.1 Placement Above the Uppermost Aquifer [40 CFR 257.60] NIPSCO collected groundwater elevation data from monitoring wells surrounding the BSP. The data indicate the maximum upper limit of the uppermost aquifer was approximately 588 feet mean sea level (msl). Golder advanced a soil boring within the BSP and completed three geophysical lines to assess the presence and thickness of CCR and thus, the bottom elevation (base) of the BSP. Results of these activities indicate the bottom elevation of the BSP (and, thus, the base) is between 585 feet msl and 589 feet msl. This separation distance does not satisfy the requirements set forth in 40 CFR 257.60(a). 2.2 Wetlands [40 CFR 257.61] To evaluate the location of the BSP relative to wetlands, Golder reviewed readily available information: US Geological Survey (USGS) topographic map National Wetland Inventory (NWI) map 1

October 17, 2018 164817101 US Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) soil survey map Aerial imagery Federal Emergency Management Agency (FEMA) floodplain map In addition to the desktop data review, Golder staff completed a field reconnaissance to evaluate the presence or absence of wetlands at the Site. Wetlands are mapped in areas adjacent to BSP (NWI Map). The BSP is located in areas mapped as non-hydric soil types (NRCS Web Soil Survey). Visual observation during the Site visit indicated that there were no wetlands within the footprint of the BSP. Based on Site reconnaissance and information compiled by Golder, the BSP is not located within wetlands and meets the requirements of 40 CFR 257.61. 2.3 Fault Areas [40 CFR 257.62] Based on Gray and Steinmetz (2012), the closest fault that has displaced during Holocene time is the Royal Center Fault which is located approximately 60 miles south of the MCGS. Therefore, the BSP is not located within 200 feet of the outermost damage zone of a Holocene fault and meets the requirements of 40 CFR 257.62. 2.4 Seismic Impact Zones [40 CFR 257.63] The United Stated Geological Survey (USGS) reports peak horizontal ground acceleration (PGA) at MCGS to be approximately 0.05 g with a 2% probability of exceedance in 50 years using the values from the 2015 National Earthquake Hazards Reduction Program Recommended Seismic Provisions for New Buildings and Other Structures (USGS, 2018). Therefore, the BSP is not located within a seismic impact zone as defined by 40 CFR 257.63, thereby meeting this requirement. 2.5 Unstable Areas [40 CFR 257.64] Based on research conducted through the Indiana Geological Survey information website (http://igs.indiana.edu/), the USGS, and historical reports prepared by Golder and others for the MCGS site, the following unstable areas information was identified. 2.5.1 Petroleum Fields/Wells There is an 860 feet deep dry petroleum well identified approximately 0.35 miles west of the Site. 2.5.2 Sand and Gravel Pit There is an abandoned sand/gravel pit identified approximately 0.35 mile west of the Site. 2.5.3 Active Mineral There are no active industrial mineral sites identified within three miles of the Site. 2.5.4 Karst There are no karst terrain locations mapped near the Site. 2.5.5 Liquefaction Potential Based on the historical information prepared for the site (Golder, 2018), the BSP embankments and foundation soils are not susceptible to seismically induced liquefaction. 2

October 17, 2018 164817101 2.5.6 Surface Mine There are no surface coal mines identified near the Site. 2.5.7 Underground Mine There are no underground coal mines identified near the Site. 2.5.8 Steep Slope There are notable steep slopes, north of the BSP, sloping down to Lake Michigan. Golder performed a slope stability analysis. Results of the slope stability analysis indicate that the BSP slopes have an acceptable factor of safety (Golder, 2012, 2018). 2.5.9 Abandoned Quarries There are no abandoned quarries identified near the Site. 2.5.10 Differential Settlement Differential settlement is not expected in the foundation soils for the BSP (Golder, 2012). Based on Golder s evaluation of the data resources available, the BSP meets the stability requirements under 40 CFR 257.64. 3.0 CONCLUSION AND SUMMARY This report has been prepared in general accordance with normally accepted civil engineering practices to fulfill the reporting requirements of 40 CFR 257.60-257.64. Based on the review of the available information provided by NIPSCO, the BSP does not meet the requirements for the minimum separation between the CCR Unit base and the upper limit of the uppermost aquifer and therefore is subject to 40 CFR 257.101(b)(1). This report will be placed in the facility s operating record in accordance with 40 CFR 257.105(e) and will be made available on the facility s publicly accessible internet site in accordance with 40 CFR 257.107(e). 4.0 REFERENCES Advanced Geosciences, Inc. (2008). Instruction Manual for EarthImager 2D Version 2.3.0 Resistivity and IP Inversion Software. Gray, W. E., Steinmetz, J. C. 2012, Map showing known faults and historic earthquake epicenters having magnitude 3.0 and larger in Indiana: Indiana Geological Survey Miscellaneous Map 85. Golder Associates Inc., 2012 Geotechnical Investigation and Embankment Stability Analyses, NIPSCO Michigan City Generating Station, August 2012. Golder Associates Inc., NIPSCO Michigan City Generating Station Primary Settling Pond No. 2 (Primary 2) Structural Stability and Safety Factor Assessment, Michigan City Indiana, Pursuant to 40 CFR 257.73(d) & 257.73(e), March 2018. Indiana Geological website, http://maps.indiana.edu/layergallery.html, September 2018. Rubin, Yoram and S. Hubbard (2006). Hydrogeophysics. Dordrecht, Netherlands: Springer. 3

October 17, 2018 164817101 Sheriff, Robert E. (2002). Encyclopedic Dictionary of Applied Geophysics. Tulsa, Oklahoma: Society of Exploration Geophysicists, 2002. United Stated Geological Survey website, http://earthquake.usgs.gov, September 2018. United Stated Geological Survey, U.S. Seismic Design Maps. Retrieved September 2018, from https://earthquake.usgs.gov/designmaps/beta/us/. 4

2360000 IF THIS MEASUREMENT DOES NOT MATCH WHAT IS SHOWN, THE SHEET SIZE HAS BEEN MODIFIED FROM: ANSI A Porter LaPorte 3000000 LEGEND CLIENT Approximate Property Line NORTHERN INDIANA PUBLIC SERVICE COMPANY PROJECT NORTHERN INDIANA PUBLIC SERVICE COMPANY MICHIGAN CITY GENERATING STATION MICHIGAN CITY, INDIANA 1 " = 1,250 feet 1,250 2,500 Feet NOTE(S) REFERENCE(S) SERVICE LAYER CREDITS: SOURCES: ESRI, HERE, GARMIN, USGS, INTERMAP, INCREMENT P, NRCAN, ESRI JAPAN, METI, ESRI CHINA (HONG KONG), ESRI KOREA, ESRI (THAILAND), NGCC, OPENSTREETMAP CONTRIBUTORS, AND THE GIS USER COMMUNITY TITLE SITE LOCATION MAP CONSULTANT PROJECT NO. 164817101 CONTROL A YYYY-MM-DD 10/12/2018 DESIGNED DFS PREPARED SHL REVIEWED JSP APPROVED 1 in 0 MAH REV. 0 FIGURE 1 0 PATH: V:\001 GIS Projects\NIPSCO\MichiganCity\99_PROJ\164817101_EA\40_PROD\0003_LocationRestriction\1648171A0001-HS-0001.mxd PRINTED ON: 2018-10-12 AT: 2:58:54 PM 2360000 3000000

3000000 LEGEND CCR Unit Existing Sheet Piles Approximate Property Line PATH: V:\001 GIS Projects\NIPSCO\MichiganCity\99_PROJ\164817101_EA\40_PROD\0003_LocationRestriction\1648171A0001-HS-0002.mxd PRINTED ON: 2018-10-12 AT: 2:54:22 PM 3000000 NOTE(S) REFERENCE(S) SERVICE LAYER CREDITS: 2018 MICROSOFT CORPORATION 2018 DIGITALGLOBE CNES (2018) DISTRIBUTION AIRBUS DS CLIENT NORTHERN INDIANA PUBLIC SERVICE COMPANY PROJECT NORTHERN INDIANA PUBLIC SERVICE COMPANY MICHIGAN CITY GENERATING STATION MICHIGAN CITY, INDIANA TITLE CCR UNIT LOCATION MAP CONSULTANT 0 375 750 1 " = 375 feet YYYY-MM-DD DESIGNED PREPARED REVIEWED APPROVED 10/12/2018 PROJECT NO. CONTROL REV. FIGURE 164817101 A 0 2 DFS SHL JSP Feet MAH IF THIS MEASUREMENT DOES NOT MATCH WHAT IS SHOWN, THE SHEET SIZE HAS BEEN MODIFIED FROM: ANSI B 1 in 0

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