| Commitments and Contingencies | 10 . Commitments and Contingencies (PPL) All commitments , contingencies and guarantees associated with PPL Energy Supply and its subsidiaries were retained by Talen Energy Supply and its subsidiaries at the spinoff date without recourse to PPL. Legal Matters (All Registrants) PPL and its subsidiaries are involved in legal proceedings, claims and litigation in the ordinary course of business. PPL and its subsidiaries cannot predict the outcome of such matters, or whether such matters may result in material liabilities, unless other wise noted. WKE Indemnification (PPL and LKE) See footnote (e) to the table in "Guarantees and Other Assurances" below for information on an LKE indemnity relating to its former WKE lease, including related legal proceedings. (PPL, LKE, LG&E and KU) Ca ne Run Environmental Claims In December 2013, six residents, on behalf of themselves and others similarly situated, filed a class action complaint against LG&E and PPL in the U.S. District Court for the Western District of Kentucky alleging violations of the Clean Air Act and RCRA. In addition, these plaintiffs assert common law claims of nuisance, trespass and negligence. These plaintiffs seek injunctive relief and civil penalties, plus costs and attorney fees, for the alleged statutory violations. Under the common law claims, these plaintiffs seek monetary compensation and punitive damages for property damage and diminished property values for a class consisting of residents within four miles of the plant. In their individual capacities, these plaintiffs seek compensation for alleged adverse health effects. In response to a motion to dismiss filed by PPL and LG&E, in July 2014, the court dismissed the plaintiffs' RCRA claims and all but one Clean Air Act claim, but declined to dismiss their common law tort claims. Upon motion of LG&E and PPL, the district court certified for appellate review the issue of whether the state common law claims are preempted by federal statute. In December 2014, the U.S. Court of Appeals for the Sixth Circuit issued an order granting appellate review regarding the above matter and such issues as may appropriately be presented by the parties and determined by the court. Oral argument before the Sixth Circuit was held in August 2015, but a ruling has not yet been issued by the Court. PPL, LKE and LG&E cannot predict the outcome of this matter. LG&E retired one coal-fired unit at the Cane Run plant in March 2015 and the remaining two coal-fired units at the plant in June 2015. Mill Creek Environmental Claims In May 2014, the Sierra Club filed a citizen suit against LG&E in the U.S. District Court f or the Western District of Kentucky for alleged violations of the Clean Water Act. The Sierra Club alleges that various discharges at the Mill Creek plant constitute violations of the plant's water discharge permit. The Sierra Club seeks civil penalties, injunctive relief, costs and attorney's fees. In August 2015, the Court denied cross-motions for summary judgment filed by both parties and directed the parties to proceed with discovery. PPL, LKE and LG&E cannot predict the outcome of this matter or th e potential impact on the operations of the Mill Creek plant but believe the plant is operating in compliance with the permits. E.W. Brown Environmental Claims In October 2015, KU received a notice of intent from Earthjustice and the Sierra Club informing certain federal and state agencies of the Sierra Club’s intent to file a citizen suit , following expiration of the mandatory 60-day notification period, for alleged violations of the Clean Water Act . The claimant alleges discharges a t the E.W. Brown plant in violation of applicable rules and the plant’s water discharge permit . The c laimant asserts that, unless the alleged discharges are pr omptly brought into complianc e, it intends to seek civil penalties, injunct ive relief and attorney’s fees. PPL, LKE and KU cannot predict the outcome of this matter or the potential impact on the operations of the E. W. Brown plant. Regulatory Issues ( All Registrants) See Note 6 for information on regulatory matters related to utility rate regulation. Electricity - Reliability Standards The NERC is responsible for establishing and enforcing mandatory reliability standards (Reliability Standards) regarding the bulk power s ystem. The FERC oversees this process and independently enforces the Reliability Standards. The Reliability Standards have the force and effect of law and apply to certain users of the bulk power electricity system, including electric utility companies, generators and marketers. Under the Federal Power Act, the FERC may assess civil penalties of up to $ 1 million per day, per violation, for certain violations. PPL, LG&E, KU and PPL Electric monitor their compliance with the Re liability Standards and continue to self-report or self-log potential violations of certain applicable reliability requirements and submit accompanying mitigation plans, as required. The resolution of a small number of potential violations is pending. An y Regional Reliability Entity (including RFC or SERC) determination concerning the resolution of violations of the Reliability Standards remains subject to the approval of the NERC and the FERC. In the course of implementing their programs to ensure com pliance with the Reliability Standards by those PPL affiliates subject to the standards, certain other instances of potential non-compliance may be identified from time to time. The Registrants cannot predict the outcome of these matters, and cannot estim ate a range of reasonably possible losses, if any. In October 2012, the FERC initiated its consideration of proposed changes to Reliability Standards to address the impacts of geomagnetic disturbances on the reliable operation of the bulk-power system, which might, among other things, lead to a requirement to install equipment that blocks geomagnetically induced currents on implicated transformers. In May 2013, FERC issued Order No. 779, requiring NERC to submit two types of Reliability Standards for FE RC's approval. The first type would require certain owners and operators of the nation's electricity infrastructure, such as the Registrants, to develop and implement operational procedures to mitigate the effects of geomagnetic disturbances on the bulk-p ower system. This NERC-proposed standard was approved by FERC in June 2014. These requirements do not impose significant costs on the Registrants. The second type is to require owners and operators of the bulk-power system to assess certain geomagnetic disturbance events and develop and implement plans to protect the bulk-power system from those events. FERC issued a notice of proposed rulemaking on this second type of Reliability Standard on May 14, 2015. The Registrants do not presently anticipate si gnificant costs to comply with the requirements if finalized as proposed. Environmental Matters - Domestic (All Registrants) Due to the environmental issues discussed below or other environmental matters, it may be necessary for the Registrants to modify, curtail, replace or cease operation of certain facilities or performance of certain operations to comply with statutes, regulations and other requirements of regulatory bodies or courts. In addition, legal challenges to new environmental permits or rules add to the uncertainty of estimating the futur e cost of these permits and rules. LG&E and KU are entitled to recover, through the ECR mechanism, certain costs of complying with the Clean Air Act, as amended, and those federal, state or local environmental requirements applicable to coal combustion wastes and by-products from facilities that generate electricity from coal in accordance with approved compliance plans. Costs not covered by the ECR mechanism for LG&E and KU and all such costs for PPL Electric are subject to rate recovery before the com panies' respective state regulatory authorities, or the FERC, if applicable. Because PPL Electric does not own any generating plants, its exposure to related environmental compliance costs is reduced. PPL , PPL Electric, LKE , LG&E and KU can provide no as surances as to the ultimate outcome of future environmental or rate proceedings before regulatory authorities. ( PPL , LKE , LG&E and KU ) Air The C lean Air Act , which regulates air pollutants from mobile and stationary sources, has a significant impact on the operation of fossil fuel plants. The C lean Air Act requires the EPA periodically to review and establish concentration levels in the ambient air for six criteria pollutants to protect public health and welfare. These concentration levels are known as NAAQS . The six criteria pollutants are carbon monoxide, lead, nitrogen dio xide, ozone, particulate matter and SO 2 . Federal environmental regulations of these criteria pollutants require states to adopt implementation plans, known as SIPs , for certain pol lutants, which detail how the state will attain the standards that are mandated by the relevant law or regulation. Each state identifies the areas within its boundaries that meet the NAAQS (attainment areas) and those that do not (non-attainment areas), a nd must develop a SIP both to bring non-attainment areas into compliance with the NAAQS and to maintain good air quality in attainment areas. In addition, for attainment of ozone and fine particulates standards, states in the eastern portion of the countr y, including Kentucky, are subject to a regional program developed by the EPA known as the Cross-State Air Pollution Rule. The NAAQS , future revisions to the NAAQS and SIPs implementing them , or future revisions to regional programs, may require install at ion of additional pollution controls, the costs of which PPL , LKE , LG&E and KU believe are subject to cost recovery. Although PPL , LKE , LG&E and KU do not currently anticipate significant costs to comply with these programs, changes in market or operating conditions could result in different costs than anticipated. National Ambient Air Quality Standards ( NAAQS ) Under the Clean Air Act, the EPA is required to reassess the NAAQS for certain air pollutants on a five-year schedule. In 2008, the EPA revised the NAAQS for ozone and proposed to further strengthen the standard in November 2014. The EPA released a new ozone standard on October 1, 2015. The states an d EPA will determine attainment with the new ozone standard through review of relevant ambient a ir monitoring data, with attainment or nonattainment designations scheduled no later than October 2017. States are also obligated to address interstate transport issues associated with new ozone standards through the establishment of "good neighbor" state implementation plans for those states that are found to contribute significantly to another states' non-attainment. States that are not in the ozone transport region, including Kentucky, are working together to evaluate further nitrogen oxide reductions from fossil-fueled plants with SCRs . The nature and timing of any additional reductions resulting from these evaluations cannot be predicted at this time. In 2010, the EPA finalized revised NAAQS for sulfur dioxide and required states to identify areas t hat meet those standards and areas that are in "non-attainment". In July 2013, the EPA finalized non-attainment designations for parts of the country, including part of Jefferson County in Kentucky. Attainment must be achieved by 2018. PPL , LKE , LG&E an d KU anticipate that certain previously required compliance measures , such as upgraded or new sulfur dioxide scrubbers at certain plants and the retirement of coal-fired generating units at LG&E’s Cane Run plant and KU’s Green River and Tyrone plants, will help to achieve compliance with the new sulfur dioxide and ozone standard s . If additional reductions are required, the costs could be significant. Mercury and Air Toxics Standards ( MATS ) In February 2012, the EPA finalized the MATS rule requiring redu ctions of mercury and other hazardous air pollutants from fossil-fuel fired power plants, with an effective date of April 16, 2012. The MATS rule was challenged by industry groups and states and was upheld by the U .S. Court of Appeals for the D. C. Circui t Court (D.C. Circuit Court) in April 2014. A group of states subsequently petitioned the U.S. Supreme Court (Supreme Court) to review this decision and on June 29 , 2015, the Supreme Court held that the EPA failed to properly consider costs when deciding t o regulate hazardous air emissions from power plants under MATS. The Court remanded the matter to the D.C. Circuit Court. EPA’s MATS rule remains in effect pending action by the D.C. Circuit Court. It is uncertain whether the D.C. Circuit Court will vac ate the MATS rule, remand the rule to the EPA, or require further proceedings or actions. LG&E and KU have installed significant controls in connection with the MATS rule and in conjunction with compliance with other environmental requirements, including fabric- filter baghouses , upgraded FGDs or chemical additive systems for which appropriate KPSC authorization and/or ECR treatment has been received. PPL , LKE , LG&E and KU cannot predict the outcome of this matter or the potential impact, if any, on plant operations, rate treatment or future capital or operating needs. New Source Review ( NSR ) The EPA has continued its NSR enforcement efforts targeting coal-fired generating plants. The EPA has asserted that modification of these plants has increased their emissions and, consequently, that they are subject to stringent NSR requirements under the Clean Air Act . PPL , LKE , LG &E and KU received various EPA information requests in 2007 and 2009, but have received no further communications from the EPA related to those requests since providing their responses. States and environmental groups also have commenced litigation allegi ng violations of the NSR regulations by coal-fired genera ting plants across the nation. PPL , LKE , LG&E and KU cannot predict the outcome of these matters, and cannot estimate the impact , if any. If LG&E or KU is found to have triggered the applicability of NSR regulations by increasing pollutants beyond allowable thresholds through a plant modification , the company c ould, among other things, be required to meet substantially more stringent permit limits . The costs to meet such limits, including installat ion of technology at certain units, could be significant . Trimble County Unit 2 Air Permit The Sierra Club and other environmental groups petitioned the Kentucky Environmental and Public Protection Cabinet to overturn the air permit issued for the Trimb le County Unit 2 baseload coal-fired generating unit, but the agency upheld the permit in an order issued in September 2007. In response to subsequent petitions by environmental groups, the EPA ordered certain non-material changes to the permit which, in January 2010, were incorporated into a final revised permit issued by the Kentucky Division for Air Quality. In March 2010, the environmental groups petitioned the EPA to object to the revised state permit. Until the EPA issues a final ruling on the pend ing petition and all available appeals are exhausted, PPL , LKE , LG&E and KU cannot predict the outcome of this matter or the potential impact on plant operations, including increased capital costs, if any. Climate Change (All Registrants) Authority to R egulate Carbon Dioxide Emissions The EPA issued rules in 2014 regulating carbon dioxide emissions from stationary sources under the NSR and Title V operating permit provisions of the C lean Air Act . The EPA's rules were challenged in court and , i n June 2014, the U.S. Supreme C ourt ruled that the EPA has authority to regulate carbon dioxide emissions under the C lean Air Act but only for stationary sources that would otherwise have been subject to these provisions due to significant increases in emissions of other pollutants. As a result, any new sources or major modifications to an existing GHG source causing a net significant increase in carbon dioxide emissions must comply with permit limits for carbon dioxide , but only if it would otherwise be subject to limits on new or modified sources due to significant increases in other pollutants. The EPA’s Rules under Section 111 of the Clean Air Act As fur ther described below, in August 2015 , the EPA finalized rules imposing greenhouse gas emission standards f or both new and existing power plants. The EPA has also issued a proposed federal implementation plan which would apply to any states that fail to submit an acceptable state implementation plan under these rules. The EPA's authority to promulgate these r egulations under Section 111 of the Clean Air Act has been challenged in the D.C. Circuit Court by several states and industry groups. The EPA's rule for new power plants imposes separate emission standards for coal and natural gas units based on the ap plication of different technologies. The coal standard is based on the application of partial carbon capture and sequestration technology, but because this technology is not presently commercially available, the rule effectively precludes the construction of new coal-fired plants. The standard for NGCC power plants is the same as the EPA proposed in 2012 and is not continuously achievable. The preclusion of new coal-fired plants and the compliance difficulties posed for new natural gas-fired plants could have a significant industry-wide impact. ( PPL , LKE , LG&E and KU) The EPA's Clean Power Plan The EPA’s rule for existing power plants, referred to as the Clean Power Plan , was published in the Federal Register in October 2015. The Rule contains state-specific rate-based and mass-based reduction goals and guidelines for the development, submission and implementation of state implementation plans to achieve the state goals. State-specific goals were calculated from 2012 data by applying EPA's broad interpretation and definition of the BSER , resulting in the most stringent targets to be met in 2030 , with interim targets to be met beginning in 2022. The EPA believes it has offered some flexibility to the states as to how their compliance p lans can be crafted, including the option to use a rate-based approach (limit emissions per megawatt hour) or a mass-based approach (limit total tons of emissions per year), and the option to demonstrate compliance through emissions trading and multi-state collaborati ons. Under the rate-based approach, Kentucky would need to make a 41% reduction from its 2012 emissions rate and under a mass-based approach it would need to make a 36% reduction. These reductions are significantly greater than initially proposed and present signi ficant challenges to the state. If Kentucky fails to develop an approvable implementation plan by September 2016 (with the possibility of an extension until 2018), the EPA will i mpose a federal implementation plan that could be more stringent than what the state plan might provide. Depe nding on the provisions of the Kentucky implementation plan, LG&E and KU may need to modify their current portfolio of generating assets during th e next decade and/or participate in an allowance trading program . LG&E and KU are participating in the ongoing regulatory processes at the state and federal level in an effort to provide input into the state or federal implementation plan that will govern reductions in Kentucky. PPL , LKE , LG&E and KU cannot predict the outcome of this matter or the potential impact, if any, on plant operations, or future capital or operating needs. PPL , LKE , LG&E and KU believe that the costs, which could be significant, would be subject to cost recovery. In April 2014, the Kentucky General Assembly passed legislation which limits the measures that the Kentucky Energy and Environment Cabinet may consider in setting performance standards to comply with the EPA's regulations governing GHG emissions from existing sources. The legislation provides that such state GHG performance standards shall be based on emission reductions, efficiency measures, and other improvements available at each power plant, rather than ren ewable energy, end-use energy efficiency, fuel switching and re-dispatch. These statutory restrictions may make it more difficult for Kentucky to achieve the GHG reduction levels that the EPA has established for Kentucky. A number of lawsuits have been f iled asserting common law claims including nuisance, trespass and negligence against various companies with GHG emitting plants and, although the decided cases to date have not sustained claims brought on the basis of these theories of liability, the law r emains unsettled on these claims. In June 2011, the U.S. Supreme Court in the case of AEP v. Connecticut ruled that federal common law claims against five utility companies for allegedly causing a public nuisance as a result of their emissions of GHGs were displaced by the C lean Air Act and regulatory actions of the EPA. In addition, in Comer v. Murphy Oil (Comer case), the U.S. Court of Appeals for the Fifth Circuit (Fifth Circuit) upheld a district court ruling that plaintiff s did not have standing to pursue state common law claims against companies that emit GHGs . The plaintiffs in the Comer case later filed a substantially similar complaint against a larger group of companies which was subsequently d ismissed by the U. S. Dis trict Court for the Southern District of Mississippi. The lower court’s ruling was affirmed by the Fifth Circuit in May 2013. Additional litigation in federal and state courts over such issues is continuing. PPL , LKE , LG&E and KU can not predict the outc ome of these matters. Water/Waste Coal Combustion Residuals ( CCRs ) On April 17, 2015, the EPA published its final rule regulating CCRs . CCRs include fly ash, bottom ash and sulfur dioxide scrubber wastes. The rule became effective on October 19 , 2015. It imposes extensive new requirements, including location restrictions, design and operating standards, groundwater monitoring and corrective action requirements and closure and post-closure care requirements on CCR impoundments and landfills that a re located on active power plants and not closed. Under the rule, the EPA will regulate CCRs as non-hazardous under Subtitle D of RCRA and allow beneficial use of CCRs , with some restrictions. This self-implementing rule requires posting of compliance do cumentation on a publicly accessible website and is enforceable through citizen suits. LG&E’s and KU’s plants us ing surface impoundments for management and disposal of CCRs will be most impacted by this rule . The rule's requirements for covered CCR impou ndments and landfills include commencement or completion of closure activities generally between three and ten years from certain triggering events. PPL , LKE , LG&E and KU also anticipate incurring capital or operation and maintenance costs prior to that t ime to address other provisions of the rule, such as groundwater monitoring and disposal facility modifications or closings, or to implement various compliance strategies. In connection with the final CCR rule, LG&E and KU recorded increases to existing A ROs during the three and nine months ending September 30, 2015. See Note 16 for additional information. Further increases to AROs or changes to current capital plans or to operating costs may be required as estimates are refined based on closure developments, groundwater monitoring results, and regulatory or legal proceedings. C osts relating to this rule are subject to rate recovery . Trimble County Landfill In May 2011, LG&E submitted an application for a special waste landfill permit to handle CCRs generated at the Trimble County plant. In May 2013, the Kentucky Division of Waste Management denied the permit application on the grounds that the proposed facility would violate the Kentucky Cave Protec tion Act. In January 2014, LG&E submitted to the Kentucky Division of Waste Management a landfill permit application for an alternate site adjacent to the plant. LG&E has also applied for other necessary regulatory approvals including a dredge and fill p ermit from the U.S. Army Corps of Engineers . LG&E and KU have responded to comments on the permit application submitted by EPA and other parties. PPL , LKE , LG&E and KU are unable to determine the potential impact of this matter until all permits are issu ed and any resulting legal challenges are concluded. See Note 6 for additional information on Kentucky Public Service Commission proceedings relating to the Trimble County Landfill. Clean Water Act Regulations under the federal Clean Water Act dictate p ermitting and mitigati on requirements for many of LG&E’s and KU’s construction projects. Many of those requirements relate to power plant operations, including requirements related to the treatment of pollutants in effluents prior to discharge, the temper ature of effluent disc harges and the location, design and construction of cooling water intake structures at generating facilities, standards intended to protect aquatic organisms by reducing capture in the screens attached to cooling water intake structur es (impingement) a t generating facilities and the water volume brought into the facilities (entrainment). The requirements could impose significant costs which are subject to rate recovery. Effluen t Limitations Guidelines ( ELGs ) On September 30, 2015, the EPA released its final effluent limitations guidelines for wastewater discharge permits for new and existing steam electric generating facilities. The rule provides strict technology-based discharge limitations for control of po llutants in scrubber wastewater, fly ash and bottom ash transport water, mercury control wastewater, gasification wastewater, and combustion residual leachate. The new guidelines require deployment of additional control technologies providing physical, ch emical, and biological treatment of wastewaters. The guidelines also mandate operational changes including “no discharge” requirements for fly ash and bottom ash transport waters and mercury control wastewaters. The implementation date for individual gen erating stations will be determined by the state s on a case-by-case basis according to criteria provided by the EPA, but the requirements of the rule must be fully implemented no later than 2023. It is not currently known how Kentucky intends to integrate the ELGs into its ongoing permit renewal process. LG&E and KU continue to assess the requirements of this complex rule to determine available compliance strategies. PPL , LKE , LG&E and KU are unable to fully estimate compliance costs or timing at this ti me although certain preliminary estimates are included in current capital forecasts, for applicable periods. Costs to comply with ELGs or other discharge limits , which are expected to be significant, are subject to rate recovery. ( PPL , LKE and LG&E ) Clean Water Act Section 316(b) The EPA's final 316(b) rule for existing facilities became effective in October 2014, and regulates cooling water intake structures and their impact on aquatic organisms. States are allowed broad discretion to make site-s pecific determinations under the rule. The rule requires existing facilities to choose between several options to reduce the impact to aquatic organisms that become trapped against water intake screens (impingement) and to determine the intake structure's impact on aquatic organisms pulled through a plant's cooling water system (entrainment). Plants equipped with closed-cycle cooling, an acceptable option, would likely not incur substantial costs. Once-through systems would likely require additional tech nology to comply with the rule. Mill Creek Unit 1 is the only unit expected to be impacted. PPL , LKE , and LG&E are evaluating compliance strategies but do not presently expect the compliance costs , which are subject to rate recovery, to be significant . (All Registrants) Water s of the United States ( WOTUS ) The U.S. Court of Appeals for the Sixth Circuit has issued a stay of EPA ’s rule on the definition of WOTUS pending the court’s review of the rule . The effect of the stay is that the WOTUS rule is not currently in effect anywhere in the United States . The ultimate outcome of the court’s review of the rule remains uncertain. The Registrants had not expected the rule to have a signifi cant impact on their operations, but were unable to predict the impac t of the rule in light of the ongoing litigation, particularly in Pennsylvania where the rule could have resulted in significant project delays and added costs, as permits and other regulatory requirements could have be en imposed for many activities not ot herwise covered by permitting requirements (including vegetation management for transmission lines and activities affecting storm water conveyances and wetlands). Other Issues The EPA is reassessing its p olychlorinated biphenyls (PCB) regulations under the Toxic Substance Control Act, which currently allow certain PCB articles to remain in use. In April 2010, the EPA issued an Advanced Notice of Proposed Rulemaking for changes to these regulations. This rulemaking could lead to a phase-out of all or some PCB-containing equipment. The EPA has postponed the release of the revised regulations to March 2016 . The Registrants cannot predict at this time the outcome of these proposed EPA regulations and what impact, if any, they woul d have on their facilities, but the costs could be significant. ( PPL , LKE , LG&E and KU) In May 2010, the Kentucky Waterways Alliance and other environmental groups filed a petition with the Kentucky Energy and Environment Cabinet ( KEEC ) challenging the K entucky Pollutant Discharge Elimination System permit issued in April 2010, which covers water discharges from the Trimble County plant. In November 2010, the KEEC issued a final order upholding the permit which was subsequently appealed by the environmen tal groups. In September 2013, the Franklin Circuit Court reversed the KEEC order upholding the permit and remanded the permit to the agency for further proceedings. LG&E and the KEEC appealed the order to the Kentucky Court of Appeals. In July 2015, th e Court of Appeals upheld the lower court ruling. LG&E and the KEEC have moved for discretionary review by the Kentucky Supreme Court . PPL , LKE , LG&E and KU are unable to predict the outcome of this matter or the potential impact, if any, on plant operat ions or future capital or operating needs. Superfund and Other Remediation (All Registrants) PPL Electric is potentially responsible for costs at several sites listed by the EPA under the federal Superfund program, including the Columbia Gas Plant site, the Metal Bank site and the Brodhead site. Clean-up actions have been or are being undertaken at all of these sites, the costs of which have not been significant to PPL Electric. Should the EPA require different or additional measures in the future, however, or should PPL Electric's share of costs at multi-party sites increase substantially more than currently expected, the costs could be significant. PPL Electric, LG&E and KU are investigating, responding to agency inquiries, remediating, or have completed the remediation of, several sites that were not addressed under a regulatory program such as S uperfund, but for which PPL Electric, LG&E and KU may be liable for remediation. These include a number of former coal gas manufacturing plants in Pennsylvania and Kentucky previously owned or operated or currently owned by predecessors or affiliates of P PL Electric, LG&E and KU. To date, the costs of these sites have not been significant. There are additional sites, formerly owned or operated by PPL Electric, LG&E and KU predecessors or affiliates, for which PPL Electric, LG&E and KU lack information on current site conditions and are therefore unable to predict what, if any, potential liability they may have. Depending on the outcome of investigations at sites where investigations have not begun or been completed or developments at sites for which PPL Electric, LG&E and KU currently lack information, the costs of remediation and other liabilities could be significant . PPL , PPL Electric, LKE , LG&E and KU cannot estimate a range of reasonably possible losses, if any, related to these matters. The EPA i s evaluating the risks associated with polycyclic aromatic hydrocarbons and naphthalene, chemical by-products of coal gas manufacturing. As a result of the EPA's evaluation, individual states may establish stricter standards for water qualit |
