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HomeMy WebLinkAboutNC0004979_5. Allen CAP Part 2 Appx B_FINAL_20160219Appendix B This page intentionally left blank CI�21ELECTRIC POWER I RESEARCH INSTITUTE Memorandum February 18, 2016 TO: Ed Sullivan and Tyler Hardin, Duke Energy FROM: Bruce Hensel, EPRI SUBJECT: ALLEN MODEL REVIEW Summary EPRI has reviewed the Allen model report and files provided by Duke Energy, HDR Engineering, Inc., and the University of North Carolina Charlotte. The review was performed by Tim Dale and John Ewing (Intera), with input by Chunmiao Zheng and myself. Based on this review, it is our opinion that, subject to the caveats below, this model is set-up and meets its flow and transport calibration objectives sufficiently to meet its final objective of predicting effects of corrective action alternatives on groundwater quality. The caveat associated with this opinion is: • Constant heads used to represent the Catawba River may provide an unmitigated source of water for simulation of any corrective action alternatives that potentially involve pumping near those boundaries. If corrective actions involve pumping, drain boundaries may be a more appropriate boundary condition selection than constant heads for this boundary. Specific Comments Model Report, Setup, and Calibration a) Is the objective/purpose of modeling clearly defined? Yes. The purpose of the study is clearly defined in Section 1 as three activities: 1) development of a calibrated steady-state flow model of current conditions; 2) development of a transport model for constituents identified as COIs; and 3) predictive transport simulations based on two corrective action options — existing conditions and cap -in -place. b) Is the site description adequate? Yes. The site description provided in Section 1.1 is sufficient for the purposes of evaluating the model. c) Is the conceptual model well described with appropriate assumptions? Yes. The conceptual model section contains subsections discussing the regional and local geology and hydrogeology, the evolution of the ash basin system, the local groundwater flow system, local hydrologic and hydraulic boundaries, groundwater sources and sinks, water budget, modeled constituents of interest, and constituent transport. The CSA report is referenced as the source of the conceptual model and assumptions. The method used to estimate recharge is briefly discussed along with references. The rationale behind the choice of constituents to be modeled is discussed. Allen Model Review February 18, 2016 Page 2 d) Is the numerical model properly set up (steady state or transient; initial condition; boundary conditions; parameterization; etc)? i) Appropriateness of the simulator The use of MODFLOW-NWT and MT3DMS to simulate groundwater flow and contaminant transport, respectively, are both appropriate for the modeling objectives and represent an industry standard in choice of simulators. ii) Discretization: temporal and spatial (x y notably z) The spatial discretization for this model appears more than adequate to delineate differences in simulated heads and concentrations for all reasonable calibration and predictive purposes. For transport simulations, the Courant Number and the Grid Peclet Number can be used to determine whether discretization is numerically appropriate for a given model. In this model, transport time steps are automatically calculated by the simulator based on a specified Courant Number constraint of 1. This ensures that temporal discretization is appropriate for the spatial discretization of the model. The Grid Peclet Number (Pe_grid = Al/a) can be used to evaluate whether numerical dispersion dominates constituent transport based on spatial discretization and physical dispersion. Grid Peclet numbers preferably less than 2 and no more than 10 are generally recommended to minimize numerical dispersion. The model discretization in the lateral direction is consistent at 20 ft by 20 ft and with the noted longitudinal and transverse lateral dispersivity values result in Grid Peclet numbers of approximately 0.25 and 2.5, which is adequate. The model discretization in the vertical direction is variable ranges from 20 to 40 ft and thus with the noted transverse dispersivity values, the Grid Peclet numbers range from 0.625 to 5, with the maximum value higher than preferable but still within the acceptable range. ii) Hydrologic framework — hydraulic properties The hydrostratigraphy appears to be implemented reasonably within the model domain. The hydraulic property values implemented in the model fall within their respective ranges as presented in the CSA report. iv) Boundary conditions The boundary conditions implemented in the model included aerially distributed recharge, drains, no -flow and constant -heads. Aerially distributed recharge was the primary source of water inflow to the model and represents 99.99% of the simulated inflow. The remaining inflow, less than 0.01% of the total inflow, occurs in constant -head boundaries. The recharge rate was applied based on type of land cover. The recharge value assigned to non -impacted land was within the defined applicable range. The method for calculating the recharge in the ash basins and ash ponds based on depth of water or thickness of saturated ash is appropriate. No -flow boundaries were assigned along the northern, western and southern edges of the model domain. These were assigned at locations that were noted as a natural topographic Allen Model Review February 18, 2016 Page 3 divide and thus a presumed natural groundwater divide. This justification appears reasonable. The eastern boundary of the model is the Catawba River. The effects of the river on the flow field is incorporated through the use of constant -head boundary (CHB) conditions in model layers 5 through 8. These CHBs constitute 96% of the simulated outflow in the model. The CHBs are used to assign a constant hydraulic head to a model cell and allows an unrestricted amount of water to move both into and out of the model depending on the hydraulic gradient. As noted in the report, the use of the CHB should be carefully considered during the predictive simulations if any corrective actions are to include pumping near the assigned CHBs. Residential wells in the model domain were included and account for 4% of the simulated outflow in the model. v) Initial conditions in transient simulations The flow models are run in steady state, where initial conditions are not relevant apart from numerical convergence, which was achieved. The transient transport model assumes background concentration for each COI prior to the start of the ash basin usage with the ash basins acting as a constant concentration sources in model layer 4 thereafter. These initial conditions are reasonable. vi) Convergence criteria and mass balance errors The head tolerance in the NWT packages of 1 e-4 is more than adequate in ensuring head precision for the purposes of the model. The flow mass balance discrepancy in the MODFLOW listing file of 0.00 percent is indicative of negligible flow mass balance errors. The cumulative concentration mass balance discrepancy from MT3DMS is consistently less than 1 percent for the transport simulations. All of the cumulative mass balance errors are adequate in ensuring minimal constituent mass balance errors by the end of the historical simulation. e) Is the calibration done properly and adequately? The flow model calibration head targets were based on the observed hydraulic heads from a single point in time of July 2015. The calibration results indicate a Root Mean Absoluter Error over the range in observed heads of 6.2 percent which is within the industry standard of 10 percent. Therefore the flow model adequately matches the observed values of July 2015. The report Section 5.1 states that this single time frame of July 2015 was selected to be representative of a "long-term average condition." For selection of a long-term average water -level surface, it would be more appropriate to do a quantitative analysis on the variation in the water levels over a period of time. However, based on communication with the model author there was an insufficient amount of water -level data, both spatially and temporally, to conduct a quantitative analysis. As noted in Section 5.1, this should be evaluated in the future as more site wide data is collected. Allen Model Review February 18, 2016 Page 4 Comparison of simulated and observed concentrations for each of the COIs is discussed by constituent. In general, the transport calibration is judged by the model simulating high concentrations where measured concentrations are significantly above background. Because for many of the constituents, simulated background concentrations are higher than a significant number of the measured values, matching values in the low range is not possible. The higher simulated background concentrations should be considered conservative. Antimony: Of the 13 measured values above background, eight had simulated concentrations above background. Arsenic: Of the 18 values that are above the background level, 16 were simulated with a concentration higher than background but seven values are under estimated by more than 50 percent. Barium: Of the 26 measured values above background, all but five were simulated with concentrations above background. Boron: Of the 29 measured values above background, all but one were simulated with concentrations above background. Of these, only seven simulated concentrations were underestimated by greater than 50 percent. Chromium: Only four measured values were above background. Of these four, only one was simulated with elevated concentrations. Cobalt: Of the 24 measured values above background, 18 have simulated concentrations above background. Of these, 11 had simulated concentrations that were underestimated by 50 percent or more. Hexavalent Chromium: There were 25 measured values above background with all simulated values also above background. A total of nine values had simulated concentrations that were underestimated by 50 percent or more. Selenium: Of the 14 measured values above background, 10 were simulated to have concentrations above background. Of these, four were simulated with concentrations that were underestimated by 50 percent or more. Sulfate: Of the 25 measured values above background, 20 were simulated to have concentrations above background. Of these, nine had simulated concentrations that were underestimated by 50 percent or more. Vanadium: Of the seven measured values above background, three were simulated at concentrations above background while the remaining four were simulated at background values. In summary, the transport calibration varies among the thirteen constituents. Barium, boron and sulfate can be considered to have a good fit between measured and simulated, as low/high concentration trends are generally similar between the measured and simulated values. Arsenic, hexavalent chrome, selenium and vanadium can also be considered adequate but with slight underestimation at wells with higher measured concentrations. Antimony, Allen Model Review February 18, 2016 Page 5 chromium and cobalt have high measured values that consistently have lower simulated values than the higher measured values. Overall, it is difficult to achieve strong concentration match for large numbers of modeled constituents, particularly if some are affected by geochemical reactions that are not simulated by MT3DMS. However, the constituents with good concentration match will enable use of the model for its stated objective. i) Property/boundary condition correlation —parameter bounds For the flow model calibration, the recharge was held constant at the assigned values based on land cover type and the hydraulic conductivity was varied. As the overall magnitude of the recharge is less uncertain than the hydraulic conductivity distribution across the site, setting the recharge to a constant value during the calibration process is a reasonable assumption. ii) Discretization of calibration parameters Hydraulic properties vary primarily by model layer which is used to differentiate between hydrologic units. Within a given layer, calibrated hydraulic properties are either uniform or based on zones of piece -wise constancy. This is a reasonable and typical approach. iii) Appropriateness of target as a metric of simulation objectives (e.g., calibrating primarily to heads when transport is the primary purpose) The use of hydraulic heads and observed concentration values for calibration of the flow and transport models, respectively, are appropriate targets for the stated objectives. Is the sensitivity analysis conducted and if so, correctly? i) Sensitivity Analysis approach (look for parameters which maybe insensitive to flow but not to transport) A flow model sensitivity analysis was conducted whereby the horizontal and vertical hydraulic conductivity of the shallow and transition zone, and the recharge outside and inside the ash basin system were varied. The parameter values were varied about the calibrated values by ±20% and the results indicate the selected parameters for which the calibration results were most sensitive. For the transport models, the report noted that a formal sensitivity was not conducted as part of CAP Part 2 as the parameter sensitivity did not change as a result of updated modeled parameters. The previous model review conducted indicated that no qualitative comparison was provided for the transport sensitivity results but an overall discussion was provided. That review and this subsequent review recommends the inclusion of the constant concentration source magnitude and location to be included in the sensitivity analysis, along with the previously included Kd and porosity. In addition, a quantitative description of the sensitivity results would be beneficial. Allen Model Review February 18, 2016 Page 6 Model Files: a) Can the model be run with the input files provided by the developer? Yes. b) Do the model results match those presented in the report? i) Independent check of input data vs. conceptual model/report An independent check of the input data files shows that the conceptual model was implemented as noted in the report and the parameter values as noted in the report were input into the model. ii) Check of water balance vs. conceptual model A check of the water balance shows that over 99.99% of the inflows to the model is from recharge with the remaining from the CHBs and is appropriate given the conceptual model. A check of the water balances for the outflows shows approximately 96% is attributed to the CHBs and the remaining 4% is attributed to the domestic production wells. iii) Independent check of model results vs. those reported The model results were independently checked and agree with those reported. Groundwater Flow and Transport Model Allen Steam Station Gaston County, NC Contributors: F)2 HDR Engineering, Inc. 440 S. Church St, Suite 1000 Charlotte, NC 28202 Investigators: 11,� UNC, c William G. Langley, Ph.D., P.E. Dongwook Kim, Ph.D. UNC Charlotte / Lee College of Engineering Department of Civil and Environmental Engineering EPIC Building 3252 9201 University City Blvd. Charlotte, NC 28223 Revised February 18, 2016 Groundwater Flow and Transpot Model Allen Steam Station TABLE OF CONTENTS 1 Introduction............................................................................................................................1 1.1 General Setting and Background...................................................................................1 1.2 Third Party Review.........................................................................................................2 2 Conceptual Model..................................................................................................................2 2.1 Geology and Hydrogeology............................................................................................2 2.2 Hydrostratigraphic Layer Development..........................................................................3 2.3 Ash Basins and Ash Storage Areas...............................................................................4 2.3.1 Ash Basin................................................................................................................5 2.3.2 Ash Landfill..............................................................................................................5 2.3.3 Structural Fills..........................................................................................................6 2.3.4 Ash Storage.............................................................................................................6 2.4 Groundwater Flow System.............................................................................................7 2.5 Hydrologic Boundaries...................................................................................................7 2.6 Hydraulic Boundaries.....................................................................................................7 2.7 Sources and Sinks..........................................................................................................8 2.8 Water Balance................................................................................................................8 2.9 Modeled Constituents of Interest (COI)..........................................................................8 2.10 COI Transport.................................................................................................................9 3 Computer Model....................................................................................................................9 3.1 Model Selection..............................................................................................................9 3.2 Model Description.........................................................................................................10 4 Groundwater Flow and Transport Model Construction........................................................10 4.1 Model Hydrostratigraphy..............................................................................................10 4.2 GMS MODFLOW Version 10.......................................................................................11 4.3 Model Domain and Grid................................................................................................12 4.4 Hydraulic Parameters...................................................................................................13 4.5 Flow Model Boundary Conditions.................................................................................13 4.6 Flow Model Sources and Sinks....................................................................................14 4.7 Flow Model Calibration Targets....................................................................................14 4.8 Transport Model Parameters........................................................................................14 4.9 Transport Model Boundary Conditions.........................................................................16 4.10 Transport Model Sources and Sinks............................................................................16 Groundwater Flow and Transpot Model Allen Steam Station 4.11 Transport Model Calibration Targets............................................................................16 5 Model Calibration to Current Conditions..............................................................................16 5.1 Flow Model Residual Analysis......................................................................................16 5.2 Flow Model Sensitivity Analysis....................................................................................17 5.3 Transport Model Calibration and Sensitivity.................................................................18 5.4 Advective Travel Times................................................................................................18 5.5 One Year's Advective Travel Time from Residential Pumping Wells ...........................18 6 Simulations of Closure Scenarios........................................................................................18 6.1 Existing Conditions Scenario........................................................................................19 6.2 Cap -In -Place Scenario.................................................................................................19 7 Closure Scenario Results....................................................................................................19 7.1 Antimony.......................................................................................................................20 7.2 Arsenic..........................................................................................................................20 7.3 Barium..........................................................................................................................20 7.4 Boron............................................................................................................................21 7.5 Chromium.....................................................................................................................21 7.6 Hexavalent Chromium..................................................................................................21 7.7 Cobalt...........................................................................................................................21 7.8 Selenium.......................................................................................................................21 7.9 Sulfate..........................................................................................................................22 7.10 Vanadium.....................................................................................................................22 8 Summary .............................................................................................................................22 8.1 Model Assumptions and Limitations.............................................................................22 8.2 Model Predictions.........................................................................................................23 9 References..........................................................................................................................24 TABLES Table 1 MODFLOW and MT31DMS Input Packages Utilized Table 2 Model Hydraulic Conductivity Table 3 Observed vs. Predicted Hydraulic Head Table 4 Model Effective Porosity Table 5 Flow Parameter Sensitivity Analysis Table 6 Transport Model Calibration Results Table 7 Predicted Advective Travel Time Groundwater Flow and Transpot Model Allen Steam Station FIGURES Figure 1 Conceptual Groundwater Flow Model/Model Domain Figure 2 Model Domain North -South Cross Section (A -A') through Inactive and Active Ash Basins Figure 3 Model Domain East-West Cross Section (B-B') through the Active Ash Basin Figure 4 Flow Model Boundary Conditions Figure 5 Model Recharge Areas and Contaminant Source Zones (Constant Concentration Cells) Figure 6 Observation Wells in Shallow Groundwater Zone Figure 7 Observation Wells in Deep Groundwater Zone Figure 8 Observation Wells in Bedrock Groundwater Zone Figure 9 Hydraulic Conductivity Zonation in S/M1 Model Layers (Model Layers 5-6) Figure 10 Hydraulic Conductivity Zonation in M2 Model Layer (Model Layer 7) Figure 11 Hydraulic Conductivity Zonation in Transition Zone Model Layer (Model Layer 8) Figure 12 Hydraulic Conductivity Zonation in Bedrock Model Layers (Model Layers 9 and10) Figure 13 Modeled Hydraulic Head vs. Observed Hydraulic Head Figure 14 Hydraulic Head in Shallow Groundwater Zone (Model Layer 6) Figure 15 Particle Tracking Results (see Table 6 for Advective Travel Times) Figure 16 1 Year Reverse Particle Tracking from Residential Wells Figure 17 Predicted Antimony in Monitoring Well AB-22S Figure 18 Predicted Antimony in Monitoring Well AB-26S Figure 19 Predicted Antimony in Monitoring Well AB-32S Figure 20 Initial (2015) Antimony Concentrations in Shallow Groundwater Zone Figure 21 Initial (2015) Antimony Concentrations in Deep Groundwater Zone Figure 22 Initial (2015) Antimony Concentrations in Bedrock Groundwater Zone Figure 23 Existing Conditions Scenario 1 - 2115 Predicted Antimony in Shallow Groundwater Zone Figure 24 Existing Conditions Scenario 1 - 2115 Predicted Antimony in Deep Groundwater Zone Figure 25 Existing Conditions Scenario 1 - 2115 Predicted Antimony in Bedrock Groundwater Zone Figure 26 Cap -in -Place Scenario 2 - 2115 Predicted Antimony in Shallow Groundwater Zone Figure 27 Cap -in -Place Scenario 2 - 2115 Predicted Antimony in Deep Groundwater Zone Figure 28 Cap -in -Place Scenario 2 - 2115 Predicted Antimony in Bedrock Groundwater Zone Figure 29 Predicted Arsenic in Monitoring Well AB-22S Figure 30 Predicted Arsenic in Monitoring Well AB-26S Figure 31 Predicted Arsenic in Monitoring Well AB-32S Figure 32 Initial (2015) Arsenic Concentrations in Shallow Groundwater Zone Figure 33 Initial (2015) Arsenic Concentrations in Deep Groundwater Zone Figure 34 Initial (2015) Arsenic Concentrations in Bedrock Groundwater Zone Figure 35 Existing Conditions Scenario 1 - 2115 Predicted Arsenic in Shallow Groundwater Zone Figure 36 Existing Conditions Scenario 1 - 2115 Predicted Arsenic in Deep Groundwater Zone Figure 37 Existing Conditions Scenario 1 - 2115 Predicted Arsenic in Bedrock Groundwater Zone Figure 38 Cap -in -Place Scenario 2 - 2115 Predicted Arsenic in Shallow Groundwater Zone Groundwater Flow and Transpot Model Allen Steam Station Figure 39 Cap -in -Place Scenario 2 - 2115 Predicted Arsenic in Deep Groundwater Zone Figure 40 Cap -in -Place Scenario 2 - 2115 Predicted Arsenic in Bedrock Groundwater Zone Figure 41 Predicted Barium in Monitoring Well AB-22S Figure 42 Predicted Barium in Monitoring Well AB-26S Figure 43 Predicted Barium in Monitoring Well AB-32S Figure 44 Initial (2015) Barium Concentrations in Shallow Groundwater Zone Figure 45 Initial (2015) Barium Concentrations in Deep Groundwater Zone Figure 46 Initial (2015) Barium Concentrations in Bedrock Groundwater Zone Figure 47 Existing Conditions Scenario 1 - 2115 Predicted Barium in Shallow Groundwater Zone Figure 48 Existing Conditions Scenario 1 - 2115 Predicted Barium in Deep Groundwater Zone Figure 49 Existing Conditions Scenario 1 - 2115 Predicted Barium in Bedrock Groundwater Zone Figure 50 Cap -in -Place Scenario 2 - 2115 Predicted Barium in Shallow Groundwater Zone Figure 51 Cap -in -Place Scenario 2 - 2115 Predicted Barium in Deep Groundwater Zone Figure 52 Cap -in -Place Scenario 2 - 2115 Predicted Barium in Bedrock Groundwater Zone Figure 53 Predicted Boron in Monitoring Well AB-22S Figure 54 Predicted Boron in Monitoring Well AB-26S Figure 55 Predicted Boron in Monitoring Well AB-32S Figure 56 Initial (2015) Boron Concentrations in Shallow Groundwater Zone Figure 57 Initial (2015) Boron Concentrations in Deep Groundwater Zone Figure 58 Initial (2015) Boron Concentrations in Bedrock Groundwater Zone Figure 59 Existing Conditions Scenario 1 - 2115 Predicted Boron in Shallow Groundwater Zone Figure 60 Existing Conditions Scenario 1 - 2115 Predicted Boron in Deep Groundwater Zone Figure 61 Existing Conditions Scenario 1 - 2115 Predicted Boron in Bedrock Groundwater Zone Figure 62 Cap -in -Place Scenario 2 - 2115 Predicted Boron in Shallow Groundwater Zone Figure 63 Cap -in -Place Scenario 2 - 2115 Predicted Boron in Deep Groundwater Zone Figure 64 Cap -in -Place Scenario 2 - 2115 Predicted Boron in Bedrock Groundwater Zone Figure 65 Predicted Chromium in Monitoring Well AB-22S Figure 66 Predicted Chromium in Monitoring Well AB-26S Figure 67 Predicted Chromium in Monitoring Well AB-32S Figure 68 Initial (2015) Chromium Concentrations in Shallow Groundwater Zone Figure 69 Initial (2015) Chromium Concentrations in Deep Groundwater Zone Figure 70 Initial (2015) Chromium Concentrations in Bedrock Groundwater Zone Figure 71 Existing Conditions Scenario 1 - 2115 Predicted Chromium in Shallow Groundwater Zone Figure 72 Existing Conditions Scenario 1 - 2115 Predicted Chromium in Deep Groundwater Zone Figure 73 Existing Conditions Scenario 1 - 2115 Predicted Chromium in Bedrock Groundwater Zone Figure 74 Cap -in -Place Scenario 2 - 2115 Predicted Chromium in Shallow Groundwater Zone Figure 75 Cap -in -Place Scenario 2 - 2115 Predicted Chromium in Deep Groundwater Zone Figure 76 Cap -in -Place Scenario 2 - 2115 Predicted Chromium in Bedrock Groundwater Zone Figure 77 Predicted Hexavalent Chromium in Monitoring Well AB-22S iv Groundwater Flow and Transpot Model Allen Steam Station Figure 78 Predicted Hexavalent Chromium in Monitoring Well AB-32S Figure 79 Initial (2015) Hexavalent Chromium Concentrations in Shallow Groundwater Zone Figure 80 Initial (2015) Hexavalent Chromium Concentrations in Deep Groundwater Zone Figure 81 Initial (2015) Hexavalent Chromium Concentrations in Bedrock Groundwater Zone Figure 82 Existing Conditions Scenario 1 - 2115 Predicted Hexavalent Chromium in Shallow Groundwater Zone Figure 83 Existing Conditions Scenario 1 - 2115 Predicted Hexavalent Chromium in Deep Groundwater Zone Figure 84 Existing Conditions Scenario 1 - 2115 Predicted Hexavalent Chromium in Bedrock Groundwater Zone Figure 85 Cap -in -Place Scenario 2 - 2115 Predicted Hexavalent Chromium in Shallow Groundwater Zone Figure 86 Cap -in -Place Scenario 2 - 2115 Predicted Hexavalent Chromium in Deep Groundwater Zone Figure 87 Cap -in -Place Scenario 2 - 2115 Predicted Hexavalent Chromium in Bedrock Groundwater Zone Figure 88 Predicted Cobalt in Monitoring Well AB-22S Figure 89 Predicted Cobalt in Monitoring Well AB-26S Figure 90 Predicted Cobalt in Monitoring Well AB-32S Figure 91 Initial (2015) Cobalt Concentrations in Shallow Groundwater Zone Figure 92 Initial (2015) Cobalt Concentrations in Deep Groundwater Zone Figure 93 Initial (2015) Cobalt Concentrations in Bedrock Groundwater Zone Figure 94 Existing Conditions Scenario 1 - 2115 Predicted Cobalt in Shallow Groundwater Zone Figure 95 Existing Conditions Scenario 1 - 2115 Predicted Cobalt in Deep Groundwater Zone Figure 96 Existing Conditions Scenario 1 - 2115 Predicted Cobalt in Bedrock Groundwater Zone Figure 97 Cap -in -Place Scenario 2 - 2115 Predicted Cobalt in Shallow Groundwater Zone Figure 98 Cap -in -Place Scenario 2 - 2115 Predicted Cobalt in Deep Groundwater Zone Figure 99 Cap -in -Place Scenario 2 - 2115 Predicted Cobalt in Bedrock Groundwater Zone Figure 100 Predicted Selenium in Monitoring Well AB-22S Figure 101 Predicted Selenium in Monitoring Well AB-26S Figure 102 Predicted Selenium in Monitoring Well AB-32S Figure 103 Initial (2015) Selenium Concentrations in The Shallow Groundwater Zone Figure 104 Initial (2015) Selenium Concentrations in Deep Groundwater Zone Figure 105 Initial (2015) Selenium Concentrations in Bedrock Groundwater Zone Figure 106 Existing Conditions Scenario 1 - 2115 Predicted Selenium in Shallow Groundwater Zone Figure 107 Existing Conditions Scenario 1 - 2115 Predicted Selenium in Deep Groundwater Zone Figure 108 Existing Conditions Scenario 1 - 2115 Predicted Selenium in Bedrock Groundwater Zone Figure 109 Cap -in -Place Scenario 2 - 2115 Predicted Selenium in Shallow Groundwater Zone Figure 110 Cap -in -Place Scenario 2 - 2115 Predicted Selenium in Deep Groundwater Zone Figure 111 Cap -in -Place Scenario 2 - 2115 Predicted Selenium in Bedrock Groundwater Zone Figure 112 Predicted Sulfate In Monitoring Well AB-22S v Groundwater Flow and Transpot Model Allen Steam Station Figure 113 Predicted Sulfate In Monitoring Well AB-26S Figure 114 Predicted Sulfate In Monitoring Well AB-32S Figure 115 Initial (2015) Sulfate Concentrations in Shallow Groundwater Zone Figure 116 Initial (2015) Sulfate Concentrations in Deep Groundwater Zone Figure 117 Initial (2015) Sulfate Concentrations in Bedrock Groundwater Zone Figure 118 Existing Conditions Scenario 1 - 2115 Predicted Sulfate in Shallow Groundwater Zone Figure 119 Existing Conditions Scenario 1 - 2115 Predicted Sulfate in Deep Groundwater Zone Figure 120 Existing Conditions Scenario 1 - 2115 Predicted Sulfate in Bedrock Groundwater Zone Figure 121 Cap -in -Place Scenario 2 - 2115 Predicted Sulfate in Shallow Groundwater Zone Figure 122 Cap -in -Place Scenario 2 - 2115 Predicted Sulfate in Deep Groundwater Zone Figure 123 Cap -in -Place Scenario 2 - 2115 Predicted Sulfate in Bedrock Groundwater Zone Figure 124 Predicted Vanadium In Monitoring Well AB-22S Figure 125 Predicted Vanadium In Monitoring Well AB-26S Figure 126 Predicted Vanadium In Monitoring Well AB-32S Figure 127 Initial (2015) Vanadium Concentrations in Shallow Groundwater Zone Figure 128 Initial (2015) Vanadium Concentrations in Deep Groundwater Zone Figure 129 Initial (2015) Vanadium Concentrations in Bedrock Groundwater Zone Figure 130 Existing Conditions Scenario 1 - 2115 Predicted Vanadium in Shallow Groundwater Zone Figure 131 Existing Conditions Scenario 1 - 2115 Predicted Vanadium in Deep Groundwater Zone Figure 132 Existing Conditions Scenario 1 - 2115 Predicted Vanadium in Bedrock Groundwater Zone Figure 133 Cap -in -Place Scenario 2 - 2115 Predicted Vanadium in Shallow Groundwater Zone Figure 134 Cap -in -Place Scenario 2 - 2115 Predicted Vanadium in Deep Groundwater Zone Figure 135 Cap -in -Place Scenario 2 - 2115 Predicted Vanadium in Bedrock Groundwater Zone vi Groundwater Flow and Transpot Model Allen Steam Station ACRONYMS 2L Standard North Carolina groundwater standards as specified 3D three-dimensional BR bedrock wells CAP Corrective Action Plan CCR coal combustion residuals COI constituent of interest CSA comprehensive site assessment D deep wells NCDHHS North Carolina Department of Health and Human Services DORS distribution of residuals solids EPRI Electric Power Research Institute FGD flue gas desulfurization GIS geographic information systems HSL health screening level IMAC interim maximum allowable concentration MW megawatt NRMSE normalized root mean square error RAB retired ash basin REC recovery RMS root mean squared RQD rock quality designation S shallow wells in T15A NCAC 02L vii Groundwater Flow and Transpot Model Allen Steam Station INTRODUCTION The purpose of this study is to predict the groundwater flow and constituent transport that may occur as a result of different possible closure actions at the site. The study consists of three main activities: development of a calibrated steady-state flow model of site conditions observed in June 2015, development of a historical transient model for constituent transport calibrated to current conditions, and predictive simulations of the closure scenarios. 1.1 General Setting and Background Duke Energy owns and operates the Allen Steam Station (Allen), which is located on a 1,009 acre tract near the town of Belmont, in Gaston County, North Carolina. Allen is a coal-fired electricity generating facility with a capacity of 1,155 megawatts (MW) along the Lake Wylie portion of the Catawba River. The five -unit station began commercial operation in 1957 with operation of coal-fired Units 1 and 2 (330 MW total). Unit 3 (275 MW) was placed into commercial operation in 1959, followed by Unit 4 (275 MW) in 1960, and Unit 5 (275 MW) in 1961. The coal ash residue from Allen's coal combustion process has historically been disposed in the ash basin system located to the south of the station and adjacent to Lake Wylie (CSA Report Figures 2-1 through 2-4)1. The ash basin system at Allen consists of an active ash basin and an inactive ash basin. For convenience, the two ash basins are sometimes jointly referred to as the ash basin in this report. Two unlined dry ash storage areas, two unlined structural fill units, and a double -lined dry ash landfill are located within the footprint of the inactive ash basin. The ash landfill was constructed in 2009. Construction of the structural fill units began in 2003 and was completed in 2009. The dry ash storage areas were constructed in 1996. In general, the ash basin is located south of the power complex in historical drainage features formed from tributaries that flowed toward Lake Wylie. There are two earthen dikes impounding the active ash basin: the East Dike, located along the west bank of Lake Wylie; and the North Dike, separating the active and inactive ash basins. The original ash basin at the Allen site (the inactive ash basin) began operation in 1957 and was formed by constructing an underlying portion of the earthen North Dike and the northern portion of the main East Dike where tributaries flowed toward Lake Wylie. As the original ash basin capacity diminished over time, the active ash basin was formed by constructing the southern portion of the East Dike and raising the North Dike. Ash has been sluiced to the active ash basin since 1973. The Allen ash basin is situated between the Allen powerhouse to the north and topographic divides to the west (along South Point Road) and south (along Reese Wilson Road) (CSA Report Figure 2-2). Natural topography at the site generally slopes downward and eastward from that divide toward Lake Wylie, from approximately 650 feet to 680 feet elevation near the west and southwest boundaries of the site to an approximate low elevation of 570 feet at the shoreline of Lake Wylie (an approximate distance of 0.8 miles). 1 Please refer to the Comprehensive Site Assessment (CSA) Report, Allen Steam Station Ash Basin, August 2015 (HDR 2015a) for more information and referenced CSA Report figures and tables. 1 Groundwater Flow and Transpot Model Allen Steam Station The air pollution control system for the coal-fired units at Allen includes a flue gas desulfurization (FGD) system that was placed into operation in 2009. Coal is delivered to the station by a railroad line. Other areas of the site are occupied by facilities supporting the production and transmission of power (two switchyards and associated transmission lines), the FGD wastewater treatment system, and the gypsum handling station (associated with the FGD system). A site features map is included as Figure 2-4 in the CSA Report. Based on the CSA, the groundwater system in the natural materials (alluvium, soil, soil/saprolite, and bedrock) at Allen is consistent with the Piedmont regolith-fractured rock system and is an unconfined, connected system of groundwater flow layers (CSA Report Figure 5-5). In general, groundwater within the shallow and deep layers (S and D wells) and bedrock layer (BR wells) flows from west and southwest to the east toward Lake Wylie and to the north toward Duke Energy property and the Station Discharge Canal. 1.2 Third Party Review The calibrated flow and transport model third -party peer review team was coordinated by the Electric Power Research Institute (EPRI) and included Dr. Chunmiao Zheng from the University of Alabama, James Rumbaugh from Environmental Simulations, Inc, and experienced modelers from Intera, Inc. The reviewers were provided with the conceptual site model, the Comprehensive Site Assessment (CSA) Report (HDR 2015a), a draft model report, and digital model input and output files, allowing them to reconstruct the model for independent review. During the course of the review, the reviewers communicated with the modelers in order to better understand how the model was developed and calibrated. As a result of these communications, the model was modified and recalibrated, which allowed the reviewers to conclude that the model was constructed and calibrated sufficiently to achieve its primary objective of comparing the effects of closure alternatives on nearby groundwater quality. In addition, the reviewers identified limitations with the model, which are included in the discussion of model limitations later in this documentation. After EPRI acceptance of the initial Allen groundwater model, the model was refined to incorporate post-CSA data. These changes did not affect the model structure or boundaries and did not deviate from EPRI guidelines.An independent review of the refined Allen model was reviewed by EPRI and found that the model was sufficient to meet the objective of predicting effects of corrective action alternatives on groundwater quality. 2 CONCEPTUAL MODEL The site conceptual model for Allen is primarily based on the CSA Report. The CSA Report contains extensive detail and data related to most aspects of the site conceptual model that are used in this report. 2.1 Geology and Hydrogeology The Allen site is located within the Charlotte terrane, one of a number of tectonostratigraphic terranes that have been defined in the southern and central Appalachians and is in the western portion of the larger Carolina superterrane (CSA Report Figure 5-1). The Charlotte terrane is dominated by a complex sequence of plutonic rocks that intrude a suite of metaigneous rocks. A geologic map of the area around Allen is shown on CSA Report Figure 5-2. 2 Groundwater Flow and Transpot Model Allen Steam Station The fractured bedrock is overlain by a mantle of unconsolidated material known as regolith. The regolith includes residual soil and saprolite zones and where present, alluvial deposits. Saprolite, the product of chemical weathering of the underlying bedrock, is typically composed of clay and coarser granular material and reflects the texture and structure of the rock from which it was formed. The weathering products of granitic rocks are quartz -rich and sandy textured. Rocks poor in quartz and rich in feldspar and ferro-magnesium minerals form a more clayey saprolite. The groundwater system in the Piedmont province, in most cases, is comprised of two interconnected layers, or mediums: 1) residual soil/saprolite and weathered fractured rock (regolith) overlying 2) fractured crystalline bedrock. The regolith layer is a thoroughly weathered and structureless residual soil that occurs near the ground surface with the degree of weathering decreasing with depth. The residual soil grades into saprolite, a coarser grained material that retains the structure of the parent bedrock. Beneath the saprolite, partially weathered/fractured bedrock occurs with depth until sound bedrock is encountered. This layer serves as the principal storage reservoir and provides an intergranular medium through which the recharge and discharge of water from the underlying fractured rock occurs. Within the fractured crystalline bedrock layer, the fractures control both the hydraulic conductivity and storage capacity of the rock mass. A transition zone at the base of the regolith has been interpreted to be present in many areas of the Piedmont. It is described as consisting of partially weathered/fractured bedrock and lesser amounts of saprolite that grades into bedrock and is considered to be the most permeable part of the system (HDR 2015a). 2.2 Hydrostratigraphic Layer Development Soil conditions encountered in the borings showed minimal variation across the site. Residual soil consists of clayey sand, silty sand, silty sand with gravel, micaceous silty sand, and gravel with silt and sand. The following materials were encountered during the CSA and are consistent with material descriptions from previous site exploration studies: Ash — Ash was encountered in borings advanced within the ash basins, as well as through dikes. Ash was generally described as gray to dark gray, non -plastic, loose to medium dense, dry to wet, fine to coarse -grained. Fill — Fill material generally consisted of reworked silts, clays, and sands that were borrowed from one area of the site and redistributed to other areas. Fill was generally classified as silty sand, clay with sand, clay, and sandy clay on the boring logs. Fill was used in the construction of dikes, and as cover for ash storage areas. Alluvium —Alluvium encountered in borings during the project was classified as clay and sand with clay. In some cases alluvium was logged beneath ash. Residuum (Residual soils) — Residuum is the in -place weathered soil that consists primarily of silt with sand, clayey sand, sandy clay, clay with gravel, and clayey silts. Residuum varied in thickness and was relatively thin compared to the thickness of saprolite. Saprolite/Weathered Rock — Saprolite is soil developed by in -place weathering of rock that retains remnant bedrock structure. Saprolite consists primarily of medium dense to very dense Groundwater Flow and Transpot Model Allen Steam Station silty sand, sandy silt, sand, sand with gravel, sand with clay, clay with sand, and clay. Sand particle size ranges from fine to coarse grained. Much of the saprolite is micaceous. Partially Weathered/Fractured Rock — Partially weathered (slight to moderate) and/or highly fractured rock encountered below auger refusal. Bedrock — Sound rock in boreholes, was generally slightly weathered to fresh and relatively unfractured. Based on the CSA, the groundwater system is consistent with the regolith-fractured bedrock system. To define the hydrostratigraphic units the following classification system was used and is based on standard penetration testing (N) values, Recovery (REC), and Rock Quality Designation (RQD) collected during the drilling and logging of boreholes. The material designations shown below (M1, M2, TZ, and BR) are used on the geologic cross - sections with transect locations in the CSA (CSA Report Figure 11-1). The ash, fill and alluvial layers are represented by A, F, and S, respectively, on cross sections and in tables in the CSA. The ranges of hydrostratigraphic layer properties measured at Allen are provided in CSA Report Tables 11-8 through 11-12. To further define the hydrostratigraphic units, the following classification system was used based on standard penetration testing values, recovery (REC), and rock quality designation (RQD) collected during drilling and logging of boreholes. The ash, fill, and alluvial layers are as encountered at the site. The natural system (except alluvium) includes the following layers: M1 — Soil/Saprolite: M2 — Saprolite/Weathered Rock: TZ — Transition Zone: BR — Bedrock: N <50 N>50 or REC<50% REC>50% and RQD<50% REC>85% and RQD>50%. Rock core runs that fell between the values for TZ and BR (REC<85% and RQD>50% or REC>85% and RQD<50%) were assigned a hydrostratigraphic layer based on a review of the borehole logs, rock core photographs, and geologic judgment. The same review was performed to determine the thickness of the transition zone just in case it extended into the next core run, which when reviewed alone might have met the bedrock criterion, because of potential core loss or fractured/jointed rock with indications of water movement (iron/manganese staining). 2.3 Ash Basins and Ash Storage Areas Historical and current information about the Allen ash basin system assembled during the CSA is relevant to developing the conceptual and numerical groundwater flow models. Refer to CSA Report Figures 2-2 and 2-4 for locations of ash basin system components described below. Coal ash residue from the coal combustion process has historically been disposed in the Allen ash basin. The area contained within the entire ash basin waste boundary, which is shown on CSA Report Figures 2-2 and 2-7, encompasses approximately 322 acres. The ash basin system is comprised of an inactive ash basin and an active ash basin. In general, the ash basin is located in historical depressions formed from tributaries that flowed toward Lake Wylie. The ash basin is operated as an integral part of the station's wastewater treatment system, which 4 Groundwater Flow and Transpot Model Allen Steam Station receives flows from the ash removal system, coal pile runoff, landfill leachate, FGD wastewater, the station yard drain sump, and site stormwater. The original ash basin at the Allen site (the inactive ash basin) began operation in 1957 and was formed by constructing the earthen North Dike and the north portion of the East Dike where tributaries flowed toward Lake Wylie. As the original ash basin capacity diminished over time, the active ash basin was formed in 1973 by constructing the southern portion of the East Dike. Ash has been sluiced to the active ash basin since 1973. In addition to the ash basin, two unlined dry ash storage areas, two unlined structural fill units, and a lined dry ash landfill are located on top of the inactive ash basin. The ash landfill was constructed in 2009. Construction of the structural fill units began in 2003 and was completed in 2009. The dry ash storage areas were constructed in 1996. Additional information pertaining to each ash management unit is provided below. 2.3.1 Ash Basin The active ash basin, located on the southern portion of the property, is approximately 169 acres in area and contains an estimated 7,660,000 tons of ash. The inactive ash basin, located between the generating units and the active ash basin, is approximately 132 acres in area and contains approximately 3,920,000 tons of ash. The inactive ash basin was commissioned in 1957 and is located adjacent to and north of the active ash basin. Coal ash was sluiced to the inactive ash basin until the active ash basin was constructed in 1973. Fly ash precipitated from flue gas and bottom ash collected in the bottom of the boilers were sluiced to the ash basin using conveyance water withdrawn from Lake Wylie. Since 2009, fly ash has been dry -handled and disposed in the on -site ash landfill, and bottom ash has continued to be sluiced to the active ash basin. During operations, the sluice lines discharge the water/ash slurry (and other permitted flows) into the primary ponds of the northern portion of the active ash basin. Primary Ponds 1, 2, and 3 were constructed in approximately 2004. Currently, Primary Ponds 2 and 3 are utilized for settling purposes. Other inflows to the ash basin include flows from coal pile runoff, landfill leachate, FGD wastewater, station yard drain sump, and stormwater flows. Due to variability in station operations and weather, inflows to the ash basin are highly variable. Effluent from the ash basin is discharged from the discharge tower to Lake Wylie via a 42-inch diameter reinforced concrete pipe located in the southeastern portion of the ash basin (Outfall 002). The water surface elevation in the ash basin is controlled by the use of stop logs in the discharge tower. 2.3.2 Ash Landfill The ash landfill unit, referred to as the Retired Ash Basin (RAB) Ash Landfill (North Carolina Department of Environmental Quality (NCDEQ2) Division of Waste Management (DWM) Solid Waste Section Permit No. 3612-INDUS), is located on the eastern portion of the Allen site, on top of the inactive ash basin. The landfill is bound to the north, east, and south by earthen dikes. The RAB Ash Landfill dike comprises the eastern boundary of the landfill. Lake Wylie is located 2 Prior to September 18, 2015, the NCDEQ was referred to as the North Carolina Department of Environment and Natural Resources (NCDENR). Both naming conventions are used in this report, as appropriate 5 Groundwater Flow and Transpot Model Allen Steam Station immediately to the east of the landfill. To the south of and adjacent to the RAB Ash Landfill is the existing active ash basin, and to the west is a structural fill area. The lined landfill is permitted to receive coal combustion residuals (CCR) including fly ash, bottom ash, boiler slag, mill rejects, and FGD waste generated by Duke Energy. In addition to these CCR materials, the landfill is permitted to receive nonhazardous sandblast material, limestone, coal, carbon, sulfur pellets, cation and anion resins, sediment from sumps, and cooling tower sludge. The RAB Ash Landfill is planned to contain two phases (Phase I and Phase 11), and when fully constructed will cover a total of 47 acres. Phase I has been constructed and encompasses 25 acres on the southern half of the landfill footprint. The estimated gross capacity of Phase I is 2,082,500 cubic yards. Phase 11 has not yet been constructed and is planned to encompass 22 acres immediately north of the Phase I footprint. The estimated gross capacity of Phase II is 3,958,200 cubic yards. The entire landfill facility, including the waste footprint, associated perimeter berms, ditches, stormwater management systems and roads, is projected to encompass an area of approximately 62 acres, when complete. The approximate boundary of the RAB Ash Landfill is shown on CSA Report Figure 2-2. The permit to construct for Phase I of the landfill was issued by NCDENR DWM in September 2008. Its initial Permit to Operate was issued by NCDENR DWM in December 2009, and the most recent permit to operate renewal was issued in December 2014. The landfill is situated over the inactive ash basin and was constructed with a leachate collection and removal system; a three -component liner system consisting of a primary and secondary geomembrane with a leak detection system between them; and a clay soil liner. Placement of waste material in the RAB Ash Landfill began in December 2009. Phase I contact stormwater and leachate are collected in the leachate collection pipe system and pumped to the discharge location in the northeastern portion of the active ash basin. NCDEQ Division of Water Quality determined that use of the leachate collection system and leak detection system, coupled with and leachate sampling, is an acceptable alternative to groundwater monitoring for the landfill which would be difficult conduct due to the underlying inactive ash basin. 2.3.3 Structural Fills Two unlined distribution of residuals solids (DORS) structural ash fills are located on top of the western portion of the inactive ash basin, adjacent to and west of the RAB Ash Landfill. These fills were constructed of ponded ash removed from the active ash basin per Duke Energy's DORS Permit issued by NCDENR DWQ. Placement of dry ash in the structural fills began in 2003 and was completed in 2009. During and following the completion of filling, the structural fill areas were graded to drain, and soil cover was placed on the top slopes and side slopes, and vegetation was established. The eastern structural fill covers approximately 17 acres and contains approximately 500,000 tons of ash. The western structural fill covers approximately 17 acres and contains approximately 328,000 tons of ash. 2.3.4 Ash Storage Two unlined ash storage areas are located on top of the western portion of the inactive ash basin, adjacent to and west of the two DORS structural fills. Similar to the two DORS structural fills, the ash storage areas were constructed in 1996 by excavating ash from the northern portion of the active ash basin in order to provide capacity for sluiced ash in the active ash basin 0 Groundwater Flow and Transpot Model Allen Steam Station and the future construction of Primary Ponds 1, 2, and 3. Following the completion of stockpiling, the ash storage areas were graded to drain, and a minimum of 18 to 24 inches of soil cover was placed on the top slopes and side slopes, respectively, and vegetation was established. The ash storage areas encompass an area of approximately 15 to 20 acres and contain approximately 300,000 cubic yards of ash. 2.4 Groundwater Flow System Groundwater recharge occurs from precipitation infiltration into the subsurface where the ground surface is permeable, including the dikes and ash of the ash basin system where exposed at the ground surface. After infiltrating the ground surface, water in the unsaturated zone percolates downward to the unconfined water table, except where ponded water conditions exist on portions of the active ash basin. From the water table, groundwater moves downward, then laterally through unconsolidated material (residual soil/saprolite) into the transition zone and, then fractured bedrock. Mean annual recharge to shallow unconfined aquifers in the Piedmont ranges from 4.0 to 9.7 inches per year (Daniel 2001). Based on the site investigation, the groundwater system in the natural materials (alluvium, soil, soil/saprolite, and fractured bedrock) at Allen is consistent with the regolith-fractured rock system and is an unconfined, connected aquifer system without confining layers. The Allen groundwater system is divided into three layers referred to in this report as the shallow, deep and bedrock zones to distinguish the flow layers within the connected aquifer system. In general, groundwater within each layer at the site flows from west and southwest to the east toward Lake Wylie and to the northeast and north toward Duke Energy property and the station discharge canal (CSA Report Figures 6-5 through 6-7). Locally, groundwater is mounded beneath Primary Ponds 1 through 3 and depressed beneath the ash landfill and the southeastern active ash basin. Steep hydraulic gradients are associated with the North and East Dikes. In accordance with the Piedmont slope aquifer system (LeGrand 2004), fractured density in bedrock decreases with depth, limiting deep groundwater flow (CSA Report Figure 5-5). 2.5 Hydrologic Boundaries The major discharge locations for the groundwater system at Allen, Lake Wylie to the east and the Station Discharge Canal to the north, act as hydrologic boundaries for the site (CSA Report Figure 2-4). A no -flow boundary is located between the Discharge Canal and the ash basin system at a presumptive, natural groundwater divide corresponding to a topographic divide. Thus, the Discharge Canal is not a component of the ash basin model to the south. 2.6 Hydraulic Boundaries The RAS Ash Landfill acts as a hydraulic boundary due to its leachate collection system and three -component liner. Otherwise, the groundwater flow system at Allen does not contain impermeable barriers or boundaries with the exception of bedrock at depth where fracture density, and fracture flow, is minimal. Natural groundwater divides exist along topographic divides, but are a result of local flow conditions as opposed to barriers. Groundwater Flow and Transpot Model Allen Steam Station 2.7 Sources and Sinks Recharge, including to the ash basins, is the major source of water for the groundwater system. Most of this water discharges to the hydrologic boundary at Lake Wylie. Recharge that infiltrates the ash landfill is intercepted by the liner system at depth and is diverted to the active ash basin. Four public water supply wells and 219 private water supply wells have been identified within a 0.5-mile radius of the ash basin Compliance Boundary at Allen. Two existing water supply wells at the Allen site (CIF Well and pH Well) were sampled to supplement groundwater quality data in the vicinity of the active ash basin. Fifty-eight private water supply wells are included within the model domain. The CSA does not consider any effect these wells may have on groundwater flow at the site, nor does it identify other sources or sinks. The CSA does not suggest the Allen ash basin is within the capture zone or zone of influence of any extraction well or supply wells. Furthermore, it states that the groundwater flow direction across the site is away from the direction of the nearest public or private water supply wells. 2.8 Water Balance Over an extended period of time, the rate of water inflow to the modeled area is equal to its rate of water outflow. That is, there is no net change in groundwater storage. Water enters the groundwater system through recharge and ultimately discharges to Lake Wylie. 2.9 Modeled Constituents of Interest (COI) As defined in the CSA, COls are those chemicals or compounds identified in the approved groundwater assessment plans for sampling and analysis. The following criteria were used to determine if a COI required modeling: if the constituent exceeded regulatory groundwater standards (15A NCAC 02L.0202 groundwater 2L Standard or IMAC), and was traceable back to the source (i.e., existed in porewater), the constituent was deemed a COI for transport modeling. Per the CSA, the metals and trace metals detected in ash basin porewater are: antimony, arsenic, barium, boron, chromium, hexavalent chromium, cobalt, selenium, iron, manganese, sulfate, thallium, and vanadium. Exclusive of iron, manganese, and thallium, all of these COls were considered in the transport simulations. Iron and manganese are naturally occurring in the groundwater system and may warrant more complex modeling than what is currently being performed. Thallium has only one estimated value above the exceedence threshold detected in groundwater which does not yield a discerned plume for calibration purposes. The simulated COls all occur at elevated levels in groundwater near the ash basins (CSA Report Figures 10-80 to 10-89, 10-93 to 10-95, 10-99 to 10-104, 10-114 to 10-119, and 10-126 to 10-128). Boron and sulfate are considered very mobile in groundwater as they do not readily precipitate or adsorb to soils. The other COls adsorb to commonly occurring soil types based upon the linear sorption coefficient (Kd) analysis performed. 3 2L Standard North Carolina groundwater standards as specified in T15A NCAC 02L. 8 Groundwater Flow and Transpot Model Allen Steam Station 2.10 COI Transport COls enter the ash basin system in the dissolved phase and solid phase of the station's wastewater discharge. Some constituents are also present in native soils and groundwater beneath the basin. The accumulation and subsequent release of chemical constituents in the ash basin over time is complex. In the active and inactive ash basin, constituents may incur phase changes via dissolution, precipitation, chemical reactions and adsorption/desorption. Dissolved phase constituents may incur these phase changes as they are transported by advection and dispersion in groundwater flowing downgradient from the ash basins. In the fate and transport model, chemical constituents enter the basin in the dissolved phase by specifying a steady state concentration in the ash porewater. Phases changes (dissolution, precipitation, adsorption, and desorption) are collectively taken into account by specifying a linear sorption coefficient (distribution coefficient Kd). In the conceptual fate and transport model, it was assumed that the entry of constituents into the ash basin is represented by a constant concentration in the saturated zone of the basin, which is continually flushed by recharge water infiltrating from above. At the ash storage area, leachable constituents enter the dissolved phase during transient infiltration events through the stored ash. Infiltration of constituents in solution occurs downward through the stored ash and underlying, unsaturated soils and finally into groundwater at the water table. Dissolved phase constituents may incur phase changes as they migrate through the stored ash and native soils to the water table. In the conceptual fate and transport model, it was assumed that the entry of constituents into groundwater beneath the ash storage area is represented by a constant concentration at the water table beneath the ash storage area, which is continually flushed by infiltrating recharge from above. The following approach was used for transport modeling: • A physical -type modeling approach was used, as site -specific geochemical conditions are not understood or characterized at the scale and extent required for inclusion in the model. • The flux of contaminant mass from the ash sources is not quantified, so it is not included in the conceptual site model or represented in the numerical model. As such, a simplified approach was used and the entry of constituents was represented in the model using a constant concentration in the saturated zone of the basin (which is continually flushed by water moving through the porous media). The constant concentration cells cover the ash basin Primary Cells and ash storage area sources and the concentrations for each of these sources were determined during transport model calibration. The retardation effects of the COls (e.g., by adsorption onto solid surfaces) were collectively taken into account by specifying a linear soil -water partitioning coefficient (Kd)- 3 COMPUTER MODEL 3.1 Model Selection The computer code MODFLOW solves the system of equations that quantify the flow of groundwater in three dimensions. MODFLOW can simulate steady-state and transient flow, as 0 Groundwater Flow and Transpot Model Allen Steam Station well as confined and water table conditions. Additional components of groundwater can be considered, including: pumping wells, recharge, evapotranspiration, rivers, streams, springs, and lakes. The information assembled in the conceptual site model is translated into its numerical equivalent from which a solution is generated by MODFLOW. 3.2 Model Description The specific MODFLOW package chosen for the study is NWT —a Newton formulation of MODFLOW-2005 that is specifically designed for improving the stability of solutions involving drying and re -wetting under water table conditions (Niswonger, et al. 2011). The numerical code selected for the transport model is MT3DMS (Zheng and Wang 1999). MT3DMS is multi - species three-dimensional (3-D)mass transport model that can simulate advection, dispersion/diffusion, and chemical reaction of COls in groundwater flow systems, and has a package that provides a link to the MODFLOW codes. The MODFLOW-NWT and MT3DMS input packages used to create the groundwater flow and transport models, and a brief description of their use, are provided in Table 1. 4 GROUNDWATER FLOW AND TRANSPORT MODEL CONSTRUCTION The flow and transport model for the study was developed through a multi -step process. First, a 3D model of the site hydrostratigraphy was constructed based on historical site construction drawings and field data. Once the model domain was determined, a 3D steady-state groundwater model based on the hydrostratigraphy and the site conceptual model was produced. Flow parameters, assigned to the numerical grid, were adjusted during the steady- state flow model calibration process. Once the flow model was calibrated, a transient transport simulation for the selected COls was developed, and then calibrated by adjusting transport parameters and revising flow parameters to best match the observed 2015 concentrations and water levels in selected monitoring wells. Three terrain surface models for Allen were created using geographic information systems (GIS) software: 1) current existing surface, 2) pre -construction surface without ash and ash basin dikes, and 3) pre -construction surface with dikes but without ash. An interpolation tool in ArcGIS 10.3 software was used to generate the terrain surfaces as raster datasets with 20-foot cells. Each surface was created to cover the extent of the groundwater model domain. 4.1 Model Hydrostratigraphy The model hydrostratigraphy was developed using historical site construction drawings and borehole data to construct three-dimensional (3D) surfaces representing contacts between hydrostratigraphic units with properties provided in CSA Tables 11-8 through 11-12. 1) Existing Ground Surface Topographic and bathymetric elevation contours and spot elevations were produced from surveys conducted in 2014. Since these surveys did not cover the entire model extent, elevation data extracted as spot elevations from the North Carolina Floodplain Mapping Program's 2010 LiDAR elevation data were used for the areas surrounding the surveys At Allen, simplified elevation contours were digitized along the river channels to depress the surface a small amount below water level. 10 Groundwater Flow and Transpot Model Allen Steam Station 2) Pre -construction Surface Elevation contours of the original ground surface were digitized in CAD from engineering drawings supplied by Duke Energy. These data were imported into GIS, and georeferenced. These contours were trimmed to the areas underlying ash basins, dams, dikes and ash storage areas. The source data used in the existing surface were then replaced by the original surface data where there was overlap. Elevation data from coal storage areas were removed. The pre - construction surface was then created using the combination of original surface elevations, 2014 survey elevations, and 2010 LiDAR elevations. 3) Pre -construction Surface with Dikes Surface models of the ash basin dams and dikes were constructed from crest elevations as determined from the 2014 survey and slopes given on the engineering drawings. Only the sections of the dams and dikes facing the ash basins were modeled in this way. The 2014 survey data were used for dike/dam crests and outwardly facing surfaces. These surfaces were merged with the pre -construction surface. These GIS data sets were exported into formats readable by RockWorks and GMS MODFLOW. 4) 3-D Hydrostratigraphic Grids The natural materials in the CSA boreholes and existing boreholes were assigned a hydrostratigraphic layer using the above classification scheme and judgment and the borehole data entered into RockWorks 16TM for 3D modeling. In the portions of the area to be modeled for which borehole data is not available, dummy boreholes were used to extend the model to the model boundaries. These boreholes were based on the hydrostratigraphic thickness of the existing boreholes and the elevation of the existing boreholes based on the assumption that the hydrostratigraphic layers are a subdued replica of the original topography of the site and geologic judgment. The grid of the pre -construction ground surface (described above) was used to constrain the modeling of the natural layers. For gridding the data on a 20 foot x 20 foot grid across the area to be modeled, a hybrid algorithm was used with inverse distance weighted two and triangulation weighted one and declustering, smoothing, and densifying subroutines. The declustering option is used to remove duplicate points and de -cluster clustered points. The option creates a temporary grid with a z-value assigned based on the closet data point to the midpoint of a voxel. The smoothing option averages the z-values in a grid based on a filter size. For this modeling, the z-value is assigned the average of itself and that of the eight nodes immediately surrounding it. One smoothing pass is made. The densify option adds additional points to the xyz input by fitting a Delaunay triangulation network to the data and adding the midpoint of each triangle to the xyz input points. The net result is that the subsequent gridding process uses more control points and tends to constrain algorithms that may become creative in areas of little control. Only one densification pass is made. The completed model grids were exported in spreadsheet format for use in the groundwater flow and transport model. 4.2 GMS MODFLOW Version 10 The conceptual model approach to construct a MODFLOW simulation in GMS MODFLOW consists of employing GIS tools in a map module to develop a conceptual model of the site 11 Groundwater Flow and Transpot Model Allen Steam Station being modeled. The location of sources/sinks, layer parameters (such as hydraulic conductivity), and all other data necessary for the simulation can be defined at the conceptual model level. Once this model is complete, the grid is generated and the conceptual model is converted to the grid model and all of the cell -by -cell assignments are performed automatically. The following table presents the sequence of the steps used for the groundwater modeling. Steps 1 through 6 describe the creation of 3D MODFLOW model. Step 1. Creating raster files for the model layer - Three surface layers (pre -construction, pre -construction with dike, and existing surface including dike and ash) using GIS and AutoCAD - Ttwo subsurface layers transition and bedrock by converting 3D scatter data Step 2. Creating the raster catalog to group the raster layers - Assigning horizons and materials for each layer Step 3. Creating horizon surfaces (i.e., triangulated irregular network (TIN)) from raster data - Used exiting surface and bedrock rasters Step 4. Building solids from the raster catalog and TINs - Used raster data for the top and bottom elevations of the solids Step 5. Creating the conceptual model - Building model boundary, specified head boundary - Defining zones and assigning hydraulic conductivity and recharge rate - Importing observation wells and surface flow data Step 6. Creating the MODFLOW 3D grid model Converting the solids to 3D grid model using boundary matching Mapping the conceptual model to 3D MODFLOW grid Step 7. Flow model calibration/sensitivity analysis Initializing the MODFLOW model Steady-state calibration with the trial -and error method Parameters: hydraulic conductivity and recharge rate Used observation well and surface flow data Step 8. Setting the transport model (MT3DMS) - Species - Stress periods Porosity and dispersion coefficient Distribution coefficient (Kd) from the lab experiments Recharge concentrations Step 9. Performing model simulations - Model scenarios — 1) Existing Conditions and 2) Cap in -place 4.3 Model Domain and Grid The model domain encompasses the Allen site, including a section of Lake Wylie and all site features relevant to the assessment of groundwater associated with the ash basins. Figure 1 shows the conceptual groundwater flow model and model domain. The model domain extends beyond the ash management areas to hydrologic boundaries so groundwater flow and COI transport through the area is accurately simulated without introducing artificial boundary effects. The bounding rectangle around the model domain extends 9,000 feet north to south and 6,000 feet east to west and has a grid consisting of 345,996 active cells in eleven layers. In plan view, the Allen model domain is bounded by the following hydrologic features of the site. 12 Groundwater Flow and Transpot Model Allen Steam Station • the western shore of Lake Wylie to the east; • the groundwater divide corresponding to the topographic divide to the north along Plant Allen Road; • the groundwater divide corresponding to the topographic divide to the east along NC 273/South Pointe Road; and • the groundwater divide corresponding to the topographic divide to the south along Reese Wilson Road and Bell Post Road. The domain boundary was developed by manually digitizing the topographic divides using a base map containing two -foot Lidar contours. The lower limit of the model domain coincides with an assumed maximum depth of water yielding fractures in bedrock. This was estimated to be 800 feet below the base of the transition zone across the site upper limit based on a review of boring logs contained in the CSA Report. There are a total of 11 model layers divided among the identified hydrostratigraphic units to simulate flow with a vertical flow component. The units are represented by the model layers listed below: • Model layers 1 through 3 • Model layers 2 through 4 • Model layer 5 and 6 • Model layer 7 • Model layer 8 • Model layers 9 through 11 Ash Material Dike and ash storage material M1 Saprolite and alluvium where present M2 Saprolite Transition Zone Fractured Bedrock In the groundwater flow model, fractured bedrock was simulated as an equivalent porous medium. The materials comprising each layer and typical layer thicknesses are shown in the north -south and east -west cross -sections through the ash basins on Figure 2 and Figure 3. 4.4 Hydraulic Parameters Horizontal and vertical hydraulic conductivities, which are specific for each hydrostratigraphic unit, are the primary determinants of groundwater flow for a given configuration of boundary conditions and sources and sinks, including recharge. Field measurements of these parameters from CSA Report Tables 11-8 through 11-12 provided guidance for their selection during the flow model calibration. Values assigned to the model are shown in Table 2. 4.5 Flow Model Boundary Conditions Boundary conditions for the Allen flow model are constant head. The outer boundary of the model domain was selected to coincide with physical hydrologic boundaries at rivers and drainage features, and no flow boundaries at groundwater divides corresponding to topographic divides (Section 2.5 and Figure 4). At Lake Wylie, constant head boundaries representing the river stage elevation were applied to those layers above fractured bedrock (model layers 9 through 11) with bottom elevations below the water surface interpolated from photogrammetric surveys. 13 Groundwater Flow and Transpot Model Allen Steam Station It is noted that constant head boundary conditions may not be valid for groundwater extraction as a corrective action alternative. In this case, the constant head boundary assumption should be validated by a pump test or other means. 4.6 Flow Model Sources and Sinks Recharge is the main source considered in the model. (Drainage boundaries are described above as flow boundary conditions.) Mean annual recharge in the Piedmont ranges from 4.0 to 9.7 inches per year (Daniel 2001). Recharge applied to the area of the model outside the ash basins was assigned a value of 7 inches per year. Recharge within the ash basins was calculated using Darcy's Law based on the area of the ash basin, the approximate depth of water or saturated ash, and the range of measured hydraulic conductivity values within the ash and fill. The calculation provided a narrow range of recharge values, with a value of 14.5 inches per year applied to the ash basins and a value of 21.9 inches per year over the ash pond. Recharge in the model is shown on Figure 5. Pumping wells were identified in the CSA. 44 residential pumping wells are within the current model domain and have been included as active pumping wells completed within the bedrock layer during calibration and predictive scenarios. Actual pumping rates are unknown, so a constant pumping rate of 400 gallons per day, which is the average EPA household usage, has been used. 4.7 Flow Model Calibration Targets The steady-state flow model calibration targets are the 56 static water level measurements taken in observations made in July 2015. The observation wells included 22 wells screened in the shallow saprolite flow layers (S/M1/M2), 27 wells screened in the deep transition zone; and eight (7) wells screened in fractured bedrock. The observation wells in shallow (M1/M2), deep, and bedrock groundwater zones are shown on Figures 6, 7, and 8. Observations were assigned by layer as shown in Table 3. 4.8 Transport Model Parameters The calibrated, steady-state flow model was used to apply flow conditions for the transport model at the active ash basin and the inactive ash basin (CSA Report Figures 2-2 and 2-4) where the elevated concentrations of COls were detected during the June/July 2015 sampling event. Although their approximate dates of operation are known, the sluiced ash loading histories for these locations are not available. In order to calibrate the transport model to existing conditions, constant concentration source zones were applied at the ash (model layer 4) in the active and inactive ash basins starting from the date when the first ash basin was placed in service (i.e., 1957). The relevant input parameters were the constant concentration at the source zone, the linear sorption coefficient (Kd) for sorptive constituents (including all COls, except for sulfate), the effective porosity, and the dispersivity tensor. Because a portion of the inactive ash basin was covered by the lined RAB Ash Landfill, the constant concentration in the inactive ash basin at that location was simulated as being covered and receives no recharge. This is discussed further in Section 4.10. 14 Groundwater Flow and Transpot Model Allen Steam Station The conceptual transport model specifies that Cols enter the model from the shallow saturated source zones in the ash basins. The range of Kd values applied was derived from UNCC laboratory measured values and adjusted to achieve calibration in the model. The most appropriate method to calibrate the transport model was to use the lower limit of measured Kd values to produce an acceptable agreement between measured and modeled concentrations. Thus, an effective Kd value results which likely represents the combined result of intermittent activities over the service life of the ash basin. These may include pond dredging, dewatering for dike construction, and ash grading and placement. This approach is expected to produce conservative results, as sorbed constituent mass is released and transported downgradient. The Kd values for the COls were applied as follows: • Antimony: 2 ml/g • Arsenic: 30 ml/g • Barium: 2.5 ml/g • Boron: 1 ml/g • Chromium: 4 ml/g • Cobalt: 2 ml/g • Hexavalent Chromium: 0.8 ml/g • Selenium: 5 ml/g • Sulfate: conservative (sorption not modeled) • Vanadium: 10 ml/g The bulk density used in the model is 2.65 grams/cubic centimeter for saprolite, deep, and bedrock materials, and 2.12 grams/cubic centimeter for ash and dike materials. The velocity of COls in groundwater is directly related to the effective porosity of the porous medium. Effective porosity applied was estimated based on the values reported in the CSA (CSA Report Tables 11-9 and 11-12). All values applied to the model are shown in Table 4. Dispersivity is a physical property of the aquifer medium and is normally a fraction of the field scale problem (i.e., plume length), commonly 10% (Zheng and Bennett 2002). The dispersivity quantifies the degree to which mechanical dispersion of COls occurs. Dispersivity values of 80 feet, 8 feet, and 8 feet (longitudinal, transverse horizontal, transverse vertical) were applied in this model. In order to avoid artificial oscillation in the numerical solution to the advection dispersion equation, the grid Peclet number, or the ratio of grid spacing to longitudinal and transverse dispersivity, and the ratio of layer thickness to vertical dispersivity, should be less than two and no more than 10 to minimize numerical dispersion (Zheng and Bennett 2002). The longitudinal and transverse dispersivity results in grid Peclet numbers of 0.25 and 2.5, which is within the acceptable range. The vertical discretization is more variable than the horizontal discretization with model layers 5 and 6 and fracture bedrock layers at approximately 20 to 40 feet, and the transition zone on the order of 10 feet or less. The variable vertical discretization results in grid Peclet numbers of 0.625 to 5, which is within the acceptable range. 15 Groundwater Flow and Transpot Model Allen Steam Station 4.9 Transport Model Boundary Conditions The transport model boundary conditions have an initial concentration of zero where water leaves the model. The background concentration used as initial concentrations for each COI is specified as the proposed provisional background concentration (PPBC) identified in the Allen Corrective Action Plan (CAP) Part 1 (HDR 2015b). The background concentrations for the COls applied as initial concentrations are as follows: • Antimony: 0.5 pg/L/g • Arsenic: 2.3 pg/L • Barium: 99 pg/L • Boron: 50 pg/L • Chromium: 16 pg/L/g • Cobalt: 0.74 pg/L • Hexavalent Chromium: 0.05 pg/L • Selenium: 0.5 pg/L • Sulfate: 30,300 pg/L • Thallium: 0.1 pg/L • Vanadium: 22.5 pg/L 4.10 Transport Model Sources and Sinks The active and inactive ash basins are the sources for COls in the model. During the transport model calibration and the existing conditions scenario, the sources were modeled as constant concentration cells in the saturated portions of the ash (model layer 4) of the ash basin (Figure 5). Their magnitudes are based on COI measurements in the shallow groundwater zone from the June/July 2015 sampling event. The source zone for the inactive ash basin is covered in part by the lined RAB Ash Landfill. Recharge to this area beneath the landfill was set to zero to represent the effects of the overlying landfill liner system. The transport model sinks correspond to the constant head boundaries of the flow model. Water and COI mass are removed as they enter cells comprising these boundaries. 4.11 Transport Model Calibration Targets The calibration targets are the measured COI concentrations for the June/July 2015 sampling event as shown in CSA Report Tables 7-6 and 10-8. Specific calibration targets for the transport model calibration are discussed in Section 5.3. 5 MODEL CALIBRATION TO CURRENT CONDITIONS 5.1 Flow Model Residual Analysis The flow model was calibrated to the water level observations obtained during June 2015 in the shallow, deep, and bedrock wells (Table 3). The water table elevation in the ash basin cells and 16 Groundwater Flow and Transpot Model Allen Steam Station selected depressions across the site were also considered as calibration targets. The observation data from this single point in time were used as a flow model calibration data set. The locations of the observation wells are provided on Figures 6, 7, and 8. The initial trial -and - error calibration assumed homogeneous conditions in each model layer. Recharge was also fixed at reasonable values early in the calibration process, and then refinements were made by adjusting hydraulic conductivity zones, as shown on Figures 9, 10,11, and 12. The basis for delineating the zones in this way was to obtain the best local calibration using conductivity values within the range of measurements from monitor well testing as documented during the CSA. The calibrated flow model parameters are provided in Table 2. Modeled and observed water levels (post -calibration) are compared in Table 3 and on Figure 13. The calibrated flow model is assumed to represent long term, steady-state flow conditions for the site and the ash basin system under long-term, average conditions. This assumption should be verified as additional data are collected from the existing and any additional monitoring wells. The square root of the average square error (also referred to as the root mean squared error, or RMS error) of the modeled versus observed water levels for wells gauged in June 2015 is also provided in Table 3. The model calibration goal is an RMS error less than 10% of the change in head across the model domain. The ratio of the average RMS error to total measured head change is the normalized root mean square error (NRMSE). The NRMSE of the calibrated model is 6.2%. Contours of hydraulic heads in the calibrated flow model are shown for the shallow groundwater zone (model layer 6) on Figure 14. Groundwater flow transitions from vertical to primarily horizontal flow directly beneath the ash basins due to the absence of a dike or fill layer beneath the ash and above the shallow groundwater zone. Groundwater within the shallow, deep, and bedrock layers flows from the west and southwest to the east and discharges to Lake Wylie. Locally the water table gradient is reduced beneath Primary Ponds 1, 2, and 3, and increased beneath the RAB Ash Landfill and the southeastern portion of the active ash basin. Steep hydraulic gradients are associated with the North, East and RAB Landfill dikes. 5.2 Flow Model Sensitivity Analysis It is important to understand the sensitivity of the flow model parameters on the predicted hydraulic head field, so that the affects of changing the parameters are known. The sensitivity of flow model parameters was tested by varying a subset of parameters by 20% above and below the values used in the calibrated flow model. The sensitivity was evaluated by re -running the model and comparing the NRMSE for each simulation (Table 5). A smaller NRMSE indicates that the model is better calibrated (i.e., model -predicted hydraulic head values better match the actual or observed values). Using this approach, it was determined that NRMSE is maximized and the flow model is most sensitive to positive or negative changes in horizontal hydraulic conductivity in the shallow aquifer, followed by changes in recharge outside of the ash basins. The least sensitive flow model parameter tested (minimized NRMSE) was changes in the vertical hydraulic conductivity in the shallow groundwater zone and transition zone. 17 Groundwater Flow and Transpot Model Allen Steam Station 5.3 Transport Model Calibration and Sensitivity For the transport model calibration, the calibration parameters consisted of the constant source concentrations, porosity and the linear sorption coefficient (Kd) for each COI. These parameters were adjusted to minimize residual concentrations in target wells. The model assumed an initial concentration of 0 within the groundwater system for all Cols at the beginning of operations approximately 58 years ago. A source term matching the pore water concentrations for each COI was applied within the inactive ash basin, active ash basin and the ash storage areas at the start of the calibration period. The source concentrations were adjusted based on the measured pore water concentrations to match measured values in the downgradient monitoring wells that had exceedances of the 2L Standard for each COI in June 2015. Calibration results comparing measured versus predicted model concentrations are provided in Table 5 for the modeled COIs. Table 6 also shows the calibration source concentrations in the inactive ash basin, active ash basin and the ash storage areas. The locations of the monitoring wells are provided on Figures 6, 7, and 8. These calibration parameters were used in the transport model to simulate the initial (2015) concentrations in the shallow, deep and bedrock groundwater zones of each COI for each closure simulation. Detailed sensitivity analyses for porosity, dispersivity, and sorption were not completed as part of CAP Part 2 as informal sensitivity analysis indicated that sensitive parameters did not change due to revisions to the model parameters. A decrease in the Kd resulted in an increase in the spatial extent in the modeled concentrations from the source areas. An increase in porosity and dispersivity also resulted in an increase in the spatial extent in the modeled concentrations from the source areas. 5.4 Advective Travel Times Particle tracking was performed during model calibration to determine if advective travel times are reasonable. Particles were placed at wells located near Lake Wylie and also near the western model boundary. The particle tracks are shown on Figure 15 and predicted advective travel times are provided in Table 7. 5.5 One Year's Advective Travel Time from Residential Pumping Wells As previously discussed, 44 residential pumping wells are included in the model domain, pumping at a rate of 400 gallons per day each. The advective travel time one year from each each well was performed using MODPATH and is shown on Figure 16. The one year advective travel time pathlines do not intersect the Compliance Boundary at Allen. 6 SIMULATIONS OF CLOSURE SCENARIOS The groundwater model, calibrated for flow and constituent fate and transport under existing conditions, was applied to evaluate two ash basin closure scenarios at Allen: 1) Existing Conditions and 2) Cap -in -Place. Being predictive, these simulations produce flow and transport results for conditions that are beyond the range of those considered during the calibration. Thus, 18 Groundwater Flow and Transpot Model Allen Steam Station the model should be recalibrated and verified over time as new data becomes available in order to improve its accuracy and reduce its uncertainty. The model domain developed for existing conditions was applied without modification for the Existing Conditions scenario. For the Cap -in -Place scenario, recharge was set to zero over the ash basin and ash storage areas to simulate an engineered cap. Source concentrations remained active in the model, as long as, they remained saturated. Water levels were reduced due to zero recharge over the ash basin and ash storage areas and flow parameters for this model were identical to the Existing Conditions scenario. 6.1 Existing Conditions Scenario The Existing Conditions scenario consists of modeling each COI using the calibrated model for steady-state flow and transient transport under the existing conditions across the site to estimate when steady-state concentrations would be reached across the site and at the Compliance Boundary. COI concentrations can only remain the same or increase initially for this scenario with source concentrations being held at their constant value over all time. Thereafter, their concentrations and discharge rates remain constant. This scenario represents the most conservative case in terms of groundwater concentrations on and off site, and COls discharging to surface water at steady-state. The time to achieve a steady-state concentration plume depends on the source zone location relative to the Compliance Boundary and its loading history. Source zones close to the Compliance Boundary will reach steady-state sooner. The time to reach steady-state concentration is also dependent on the sorptive characteristics of each COI. Sorptive Cols will be transient for a longer time period as their peak breakthrough concentration travels at a rate that is less than the groundwater pore velocity. Lower effective porosity will result in shorter times to achieve steady state for both sorptive and non-sorptive COIs. Lower total porosity will result in longer times for sorptive COIs. 6.2 Cap -In -Place Scenario The Cap -in -Place scenario simulates the effects of covering the ash basins at the beginning of the predictive simulation with an engineered cap. In the model, recharge at the ash basins is set to zero. Groundwater flow is affected by this scenario as the water table is lowered and groundwater velocities may be reduced beneath the capped areas. Near the center of the inactive ash basin, the water table is lowered by approximately 24 feet relative to the level simulated under the Existing Conditions scenario. In the active ash basins, the difference in water level is approximately 32 feet. In the model, non-sorptive COls will move downgradient at the pore velocity of groundwater and will be displaced by the passage of a single pore water volume, while sorptive COI migration in groundwater is retarded relative to the pore velocity of groundwater due to sorption. The model uses the predicted concentration from the 2015 calibration as the initial concentration at the start of the model scenario. 7 CLOSURE SCENARIO RESULTS Closure scenario results are presented as predicted concentration vs. time plots in downgradient monitor wells and as predicted groundwater concentration maps for each modeled COI on Figures 17 through 135, as discussed in the following sub -sections. 19 Groundwater Flow and Transpot Model Allen Steam Station Concentration contours and concentration breakthrough curves are all referenced to a time zero that represents the time the closure action was implemented, which for the purposes of modeling is assumed to be 2016. Concentration contours and concentration breakthrough curves are referenced to 1957, since that is the year that the ash basin became effective. Constituent concentrations were analyzed at three downgradient monitoring wells: AB-22S, AB- 26S and AB-36S (Figure 6) for all COls. Each of these wells is directly downgradient from the ash basins or ash storage area and upgradient of the ash basin Compliance Boundary at Lake Wylie. 7.1 Antimony Figures 17 through 28 show predicted antimony concentrations for the modeled downgradient monitoring wells. The concentration versus time curves (Figures 17 to 19) show that, under the Existing Conditions scenario, antimony exceeds the IMAC of 1 pg/L in 2015 at AB-26S. The Cap -in -Place scenario results in the reduction of concentrations over time. However, the observed antimony value in AB-26S is 0.5 pg/L and the model is overpredicting (based on calibrated input values ) the concentration. Figures 20 to 22 show initial (2015) antimony concentrations in the shallow, deep and bedrock groundwater zones. In 2115, antimony is predicted to exceed the IMAC along the Compliance Boundary along Lake Wylie in all layers under both the Existing Conditions scenario (Figures 23 to 25) and the Cap -in -Place scenario (Figures 26 to 28). 7.2 Arsenic Figures 29 through 40 show predicted arsenic concentrations for the modeled downgradient monitoring wells. The concentration versus time curves (Figures 29 to 31) show that, under the Existing Conditions scenario, arsenic exceeds the 2L Standard (10 pg/L) at AB-22S and AB-32S within the next 85 years and is below the 2L Standard at AB-26S. The Cap -in -Place scenario shows an increase in concentration at two wells over time, exceeding the standard at AB-22S by the end of the modeling period. Although, the observed arsenic value in AB-22S and AB-32S is below 0.5 ug/L and the model is overpredicting the concentration partially due to the initial concentration in the model of 2.3 ug/L. Figures 32 to 34 show initial (2015) arsenic concentrations in the shallow, deep and bedrock groundwater zones. Arsenic is predicted to exceed the groundwater standard at the Compliance Boundary under both the Existing Conditions scenario (Figures 35 to 37) and Cap -in -Place scenario (Figures 38 to 40) in shallow and deep groundwater layers. 7.3 Barium Figures 41 through 52 show predicted barium concentrations for the modeled downgradient monitoring wells. The concentration versus time curves (Figures 41-43) show thatwhile barium is predicted to show a slight increase in concentration, it remains far below the 2L Standard (700 pg/L) through the modeled period. Figures 44 to 46 show initial (2015) barium concentrations in the shallow, deep and bedrock groundwater zones. After 100 years, barium is not predicted to exceed the 2L Standard at the Compliance Boundary under the Existing Conditions scenario (Figures 47 to 49) or the Cap -in -Place scenario (Figures 50 to 52) in all groundwater layers. 20 Groundwater Flow and Transpot Model Allen Steam Station 7.4 Boron Figures 53 through 64 show predicted boron concentrations for the modeled downgradient monitoring wells. The concentration versus time curves (Figures 53 to 55) show that, under the Existing Conditions scenario, boron is predicted to exceed the 2L Standard of 700 lag/L at AB- 22S and AB-26S, but remain under the 2L Standard in all three wells under the Cap -in -Place scenario. Figures 56 to 58 show initial (2015) boron concentrations in the shallow, deep and bedrock groundwater zones. After 100 years, boron is predicted to exceed the 2L Standard at Lake Wylie Compliance Boundary under both the Existing Conditions scenario (Figures 59 to 61) and Cap -in -Place scenario (Figures 62 to 64) in the shallow and deep groundwater zones. 7.5 Chromium Figures 65 through 76 show predicted chromium concentrations for the modeled downgradient monitoring wells. The concentration versus time curves (Figures 65 to 67) show that chromium decreases to below the 2L Standard of 10 lag/L in the all three downgradient monitor wells under both scenarios. Figures 68 to 70 show initial (2015) chromium concentrations in the shallow, deep and bedrock groundwater zones. After 100 years, chromium is predicted to remain above the 2L Standard at the Compliance Boundary under both the Existing Conditions and Cap -in -Place scenario (Figures 71 to 73 and 74 to 76, respectively). 7.6 Hexavalent Chromium Figure 77 through 87 shows predicted hexavalent chromium concentrations at AB-22S and AB- 32S downgradient of the ash storage area for both scenarios. The concentration versus time curves (Figures 77 to 78) show hexavalent chromium is predicted to remain above the NCDHHS HSL of 0.07 lag/L. However, the model overpredicts concentrations in these monitor wells, which both show measured concentrations below the NCDHHS HSL. Figures 79 to 81 show initial (2015) hexavalent chromium concentrations in the shallow, deep and bedrock groundwater zones. After 100 years, hexavalent chromium is predicted to exceed the NCDHHS HSL at the southern Compliance Boundary in all groundwater zones under the Existing Conditions scenario (Figures 82-84) and in the shallow zone only under the Cap -in -Place scenario (Figures 85 to 87. 7.7 Cobalt Figures 88 through 99 show predicted cobalt concentrations for the modeled downgradient monitoring wells. The concentration versus time curves (Figures 88 to 90) for the three downgradient monitor wells show that cobalt is predicted to remain above the IMAC of 1 lag/L for both scenarios, although the Cap -in -Place scenario shows a slower rate of increase in two wells and decreases the third. Figures 91 to 93 show initial (2015) cobalt concentrations in the shallow, deep and bedrock groundwater zozones. After 100 years, cobalt is predicted to exceed the IMAC at Compliance Boundary under both the Existing Conditions scenario (Figures 94 to 96) and the Cap -in -Place scenario (Figures 97 to 99) in all groundwater zones. 7.8 Selenium Figures 100 through 111 show predicted selenium concentrations for the modeled downgradient monitoring wells. The concentration versus time curves (Figures 100 to 102) show that selenium 21 Groundwater Flow and Transpot Model Allen Steam Station remains at background concentrations well under the 2L Standard of 20 pg/L under both scenarios. Figures 103 to 105 show initial (2015) selenium concentrations in the shallow, deep and bedrock groundwater zones. After 100 years, selenium is not predicted to exceed the 2L Standard of 20 pg/L at the Compliance Boundary under either the Existing Conditions scenario (Figures 206 to 108) or Cap -in -Place scenario (Figures 109 to 111) within all groundwater zones. 7.9 Sulfate Figures 112 through 123 show predicted sulfate concentrations for the modeled downgradient monitoring wells for both scenarios. The concentration versus time curves (Figures 112 to 114) for all three monitoring wells show that sulfate remains below the 2L Standard of 250,000 pg/L for both scenarios. Figures 115 to 117 show initial (2015) sulfate concentrations exceeding the 2L Standard in the shallow, deep and bedrock groundwater zones. After 100 years, sulfate is predicted to exceed the 2L Standard at the northern Compliance Boundary under the Existing Conditions scenarios within all groundwater zones (Figures 118 to 121). Under the Cap -in -Place scenario (Figures 121 to 123), sulfate is predicted to fall below the standard at the Compliance Boundary in all groundwater zones. 7.10 Vanadium Figures 124 through 135 show predicted vanadium concentrations for the modeled downgradient monitoring wells. The concentration versus time curves (Figures 124 to 126) show that vanadium remains elevated above the IMAC of 0.3 pg/L for both scenarios due to the initial background concentrations of 22.5 pg/L. Figures 127 to 129 show initial (2015) vanadium concentrations in the shallow, deep and bedrock groundwater zones. After 100 years, vanadium is predicted to exceed the proposed rpovisional background concentration at Lake Wylie Compliance Boundary under the Existing Conditions scenario (Figures 130 to 132), and the Cap -in -Place scenario (Figures 133 to 135) within all groundwater zones. 8 SUMMARY 8.1 Model Assumptions and Limitations The model assumptions include the following: • The steady-state flow model was calibrated to hydraulic heads measured at observation wells in June 2015 and included considereation of ash basin water levels. The model is not calibrated to transient water levels over time, recharge, or river flow. A steady-state calibration does not consider groundwater storage and does not calibrate the groundwater flux into adjacent surface water bodies. • MODFLOW simulates flow through porous media and groundwater flow in the bedrock groundwater zone is via fractures in the bedrock. A single domain MODFLOW modeling approach for simulating flow in the primary porous groundwater zones and bedrock was used for contaminant transport at Lake Wylie. The model was calibrated by adjusting the constant source concentrations at the ash basins and ash storage area to genearally match 2015 COI concentrations in 22 Groundwater Flow and Transpot Model Allen Steam Station groundwater. The ash basin and ash storage area source concentrations are held constant throughout the simulation period which results in greater contaminant mass entering the groundwater system than would occur in the system. • For the purposes of numerical modeling and comparing closure scenarios, it is assumed that the selected closure scenario will be completed in 2016. • Predictive simulations were performed and steady-state flow conditions were assumed from the time the ash basins and ash storage area were placed in service through the current time until the end of the predictive simulations (2265). • COI source zone concentrations at the inactive and active ash basins and ash storage area were applied uniformly within each source area and assumed to be constant with respect to time for transport model calibration. • The uncertainty in model parameters and predictions has not been quantified; therefore, the error in the model predictions is not known. It is assumed the model results are suitable for a relative comparison of closure scenario options. As previously mentioned, model predictions ultimately overpredict to remain conservative. • Since Lake Wylie is modeled as a constant head boundary in the numerical model, it will not be possible to assess the effects of pumping wells or other groundwater sinks that are near the river. • Presented travel times are advective and do not account for sorption of COls to host rock, which would cause the travel times to be reduced. • Residential wells have an assumed constant pumping rate of 400 gallons per day and are completed within bedrock. • The model does not account for varying geochemical conditions such as pH and redox potential that could affect COI mobility and change modeling results. 8.2 Model Predictions The model predictions are summarized as follows: • Antimony and cobalt are predicted to exceed the IMAC at Compliance Boundary along Lake Wylie in all groundwater zones under both the Existing Conditions and Cap -in - Place scenarios. • Barium, selenium are not predicted to exceed the 2L Standard at the Compliance Boundary under either scenario. • Chromium and arsenic are predicted to exceed the 2L Standard at the Compliance Boundary under the Existing Conditions and Cap -in -Place scenarios for all groundwater zones. • Boron is predicted to exceed the 2L Standard at the Compliance Boundary along Lake Wylie under the Existing Conditions and Cap -in -Place scenarios in both the shallow and deep groundwater zones, but not the bedrock layer. 23 Groundwater Flow and Transpot Model Allen Steam Station • Hexavalent chromium is predicted to exceed the NCDHHS HSL at the southern Compliance Boundary under the Existing Conditions scenario in all groundwater zones and in the shallow layer only under the Cap -in -Place scenario. • Sulfate Is predicted to exceed the 2L Standard at the northern Compliance Boundary under the Existing Conditions scenario but not under the Cap -in -Place scenario. Among the COls, sulfate is considered conservative; that is, this constituent does not have a strong affinity to attenuate nor adsorb to soil/rock surfaces. • Vanadium is predicted to exceed the IMAC at Compliance Boundary along Lake Wylie under the Existing Conditions scenario and under the Cap -in -Place scenario. • COls are not predicted to exceed standards at the western Compliance Boundary. 9 REFERENCES Daniel, C.C., III, 2001, Estimating ground -water recharge in the North Carolina Piedmont for land use planning [abs.], in 2001 Abstracts with Programs, 50th Annual Meeting, Southeastern Section, April 5-6, 2001: Raleigh, N.C., The Geological Society of America, v. 33, no. 2, p. A-80. Haven, W.T. Introduction to the North Carolina Groundwater Recharge Map -Groundwater Circular Number 19, North Carolina Department of Environment and Natural Resources Division of Water Quality, Groundwater Section. HDR. 2015a. Comprehensive Site Assessment Report, Allen Steam Station Ash Basin, August 23, 2015. HDR, 2015b. Corrective Action Plan Part 1. Allen Steam Station Ash Basin, November 20, 2015. Langley, W.G. and Oz, S. Soil Sorption Evaluation for ALSS Steam Station, UNC-Charlotte, in preparation. LeGrand, H. E. 2004. A Master Conceptual Model for Hydrogeological Site Characterization in the Piedmont and Mountain Region of North Carolina, A Guidance Manual, North Carolina Department of Environment and Natural Resources Division of Water Quality, Groundwater Section. Niswonger, R.G., Panday, S., and Ibaraki, M. 2011. MODFLOW-NWT, A Newton formulation for MODFLOW-2005: U.S. Geological Survey Techniques and Methods 6-A37, 44 p. Zheng, C. and Bennett, G. 2002. Applied Contaminant Transport Modeling, Second Edition, Wiley Interscience. Zheng, C. and Wang, P. 1999. MT3DMS, A modular three-dimensional multi -species transport model for simulation of advection, dispersion and chemical reactions of contaminants in groundwater systems, Documentation and Users Guide, U.S. Army Engineer Research and Development Center Contract Report SERDP-99-1, Vicksburg, MS, 202 p. 24 This page intentionally left blank Groundwater Flow and Transport Model Allen Steam Station Ash Basin Tables Table 1 MODFLOW and MT3DMS Input Packages Utilized Table 2 Model Hydraulic Conductivity Table 3 Observed vs. Predicted Hydraulic Head Table 4 Model Effective Porosity Table 5 Flow Parameter Sensitivity Analysis Table 6 Transport Model Calibration Results Table 7 Predicted Advective Travel Time Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 1 MODFLOW and MT3DMS Input Packages Utilized MODFLOW Input Package Description Name (NAM) Contains the names of the input and output files used in the model simulation and controls the active model program Basic (BAS) Specifies input packages used, model discretization, number of model stress periods, initial heads and active cells Contains finite -difference grid information, including the number Discretization (DIS) and spacing of rows and columns, number of layers in the grid, top and bottom model layer elevations and number of stress periods Specified Head and Specifies a head and/or a concentration that remains constant Concentration (CHD) throughout the simulation Drain (DRN) Acts as a "drain" to remove water from the groundwater system. Simulates drainage areas within the model Recharge (RCH) Simulates areal distribution of recharge to the groundwater system Newton Solver (NWT) Contains input values and the Newton and matrix solver options Upstream Weighting (UPW) Replaces the LPF and/or BCF packages and contains the input required for internal flow calculations Flow Transfer Link File (LMT) Used by MTDMS to obtain the location, type, and flow rates of all sources and sinks simulated in the flow model MT3DMS Input Package Description Flow Transfer Link File (FTL) Reads the LMT file produced by MODFLOW Basic Transport Package (BTN) Reads the MODFLOW data used for transport simulations and contains transport options and parameters Advection (ADV) Reads and solves the selected advection term Dispersion (DSP) Reads and solves the dispersion using the explicit finite - difference formulation Source and Sink Mixing (SSM) Reads and solves the concentration change due to sink/source mixing using the explicit finite -difference formulation Chemical Reaction (RCT) Reads and solves the concentration change due to chemical reactions using the explicit finite -difference formulation Generalized Conjugate Gradient Solves the matrix equations resulting from the implicit solution of (GCG) Solver the transport equation Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 2 Model Hydraulic Conductivity Model Layer Hydrostrati- graphic Unit Measured Value Range Calibrated Model Value Horizontal Hydraulic Conductivity (ft/day) Horizontal Hydraulic Conductivity (ft/day) Vertical Hydraulic Conductivity (ft/day) 1-4 Ash 9.12-0.05 Z-1 5 1 Z-2 2 0.8 4 Dike 7.86-0.01 Z-3 0.004 0.004 5-6 7 M1/Alluvium M2 14.29-0.0033 11.67-0.0042 Z-4 0.1480 0.0500 Z-5 0.2700 0.1000 Z-6 0.5000 0.5000 Z-7 1.0000 0.2000 Z-8 1.3000 0.1000 Z-9 1.4000 0.1000 Z-10 2.0000 0.8000 Z-11 3.1260 0.3126 Z-12 6.0000 2.0000 Z-13 14.0000 1.0000 Z-25 2.3300 0.5000 Z-26 2.6990 0.2699 8 Transition Zone 60.06-0.09 Z-5 0.2700 0.1000 Z-6 0.5000 0.5000 Z-7 1.0000 0.2000 Z-17 5.0000 2.0000 Z-18 9.0000 2.0000 9-11 Bedrock 5.52-0.0004 Z-19 0.0001 0.00001 Z-20 0.0010 0.0001 Z-21 0.0050 0.0005 Z-22 0.0070 0.0007 Z-23 0.0100 0.0010 Z-24 1.4000 0.1000 'Range = geometric mean +/- one standard deviation (see CSA Report Tables 11-10) Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 3 Observed vs. Predicted Hydraulic Head Well Name Model Layer Meas. WL ft MSL Model WL ft MSL Residual ft AB-20S 6 636.88 636.98 -0.10 AB-21 BR 9 635.69 632.13 3.56 AB-22D 8 599.04 596.27 2.77 AB-23S 6 636.29 630.93 5.36 AB-24D 8 634.68 625.59 9.09 AB-26D 8 583.61 584.09 -0.48 AB-27D 8 617.22 607.19 10.03 AB-28D 8 629.26 616.99 12.27 AB-29D 8 612.71 606.22 6.49 AB-30D 8 619.54 615.34 4.20 AB-31 D 8 578.91 581.30 -2.39 AB-31 S 8 577.90 581.30 -3.40 AB-32D 8 577.00 581.71 -4.71 AB-32S 6 582.74 582.52 0.22 AB-33D 8 593.95 599.20 -5.25 AB-33S 6 600.39 599.41 0.98 AB-34D 8 611.73 612.47 -0.74 AB-34S 6 612.65 612.17 0.48 AB-35BR 9 620.57 619.61 0.96 AB-35D 8 620.47 618.48 1.99 AB-35S 6 619.80 618.49 1.31 AB-36D 8 620.93 623.26 -2.33 AB-36S 6 620.23 623.42 -3.19 AB-37D 8 622.69 625.49 -2.80 AB-37S 6 621.13 625.35 -4.22 AB-38D 8 624.26 622.78 1.48 AB-38S 6 624.70 622.78 1.92 AB-39D 8 619.72 613.59 6.13 GWA-14D 8 626.04 631.12 -5.08 GWA-14S 6 627.66 631.42 -3.76 GWA-15D 8 625.87 627.06 -1.19 GWA-15S 6 625.80 627.36 -1.56 GWA-1 BR 9 614.27 613.25 1.02 GWA-1 D 8 614.73 614.82 -0.09 GWA-1S 6 615.24 614.82 0.42 GWA-21D 8 573.27 576.72 -3.45 GWA-2S 6 570.53 576.88 -6.35 GWA-313R 9 573.69 578.06 -4.37 Continued on next page Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 3 Observed vs. Predicted Hydraulic Head (continued) Well Name Model Layer Meas. WL ft MSL Model WL ft MSL Residual ft GWA-3D 8 573.82 574.41 -0.59 GWA-3S 6 571.48 574.65 -3.17 GWA-4D 8 570.83 570.57 0.26 GWA-4S 6 571.72 571.13 0.59 GWA-5BR 9 562.37 574.61 -12.24 GWA-51D 8 571.24 570.81 0.43 GWA-5S 6 567.19 572.00 -4.81 GWA-6BR 9 588.56 595.80 -7.24 GWA-6D 8 586.68 599.52 -12.84 GWA-6S 6 597.31 598.72 -1.41 GWA-9D 8 636.70 637.26 -0.56 GWA-9S 6 635.68 637.30 -1.62 AB-21 D 8 635.70 632.53 3.17 AB-20D 8 636.41 636.97 -0.56 AB-22S 6 595.01 596.76 -1.75 AB-26S 6 582.05 584.23 -2.18 SSE 1143.62 Max 636.88 OBS 54 Min 562.37 MSE 4.60 Max -Min 74.51 NRMSE 0.062 Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 4 Model Effective Porosity Model Layer Hydrogeologic Unit Effective Porosity 1 — 3 Ash and Dike Materials 0.14 4 Dike Materials 0.10 5-6 M1 — Saprolite and Alluvium 0.12 7 M2 — Saprolite 0.20 8 Transition Zone 0.01 9 — 10 Bedrock 0.005 Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 5 Flow Parameter Sensitivity Analysis Calibrated Calibrated +20% Calibrated -20% Parameter NRMSR (Head) NRMSR (Head) % NRMSR (Head) % Shallow 0.0900 45.16 0.1070 72.58 Zone Kh Shallow 0.0620 0.00 0.0610 -1.61 Zone Kv Transition 0.0640 3.23 0.0640 3.23 Zone Kh 0.0620 Transition Zone 0.0640 3.23 0.0620 0.00 Kv Recharge 0.0860 38.71 0.0840 35.48 ex. ash basin Recharge 0.0680 9.68 0.0730 17.74 ash basin Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 6 Transport Model Calibration Results COI Monitoring Well Measured Concentration (pg/L)/L Predicted Concentration Antimony Ash Basin Constant Concentration Range = 0.5 - 20 pg/I Ash Storage Area Concentration Range = 0.5 - 20 pg/I Sorption Coefficient [Kd] = 2 mI/g AB-1 OD 0.28 0.49 AB-1 OS 0.50 0.48 AB-11 D 0.50 0.44 AB-12D 0.50 0.50 AB-12S 0.50 0.47 AB-13D 0.50 0.50 AB-13S 0.43 0.48 AB-14D 0.50 0.50 AB-1 R 0.50 0.50 AB-2 0.50 0.50 AB-20D 0.50 0.50 AB-21 BR 0.50 0.50 AB-21 D 0.18 0.50 AB-22D 0.21 0.50 AB-22S 0.50 0.50 AB-23BRU 1.10 0.50 AB-24 D 1.30 0.60 AB-25BR 0.63 0.52 AB-25BRU 0.50 0.52 AB-26D 2.70 0.77 AB-26S 0.50 2.15 AB-27D 0.19 0.54 AB-28D 0.50 0.50 AB-29D 0.50 2.00 AB-21D 0.20 0.50 AB-30D 0.50 0.50 AB-31 D 6.00 2.49 AB-31 S 0.50 7.01 AB-32D 0.50 0.49 AB-32S 0.36 0.48 AB-33D 0.50 0.49 AB-33S 0.50 0.48 AB-34D 0.23 0.50 AB-34S 0.50 0.48 Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 6 Transport Model Calibration Results (continued) COI Monitoring Well Measured Concentration N /L Predicted Concentration N /L Antimony (cont.) AB-35BR 0.50 0.50 AB-35D 0.33 0.50 AB-36D 0.50 0.50 AB-36S 0.50 0.50 AB-37D 1.00 0.49 AB-38D 0.24 0.49 AB-39D 0.21 0.58 AB-4S 0.50 0.47 AB-5 0.50 0.49 AB-6R 0.50 0.50 AB-91D 0.19 0.79 AB-9S 0.50 1.78 AB-20S 0.50 0.50 AB-21 S 1.30 0.50 AB-21SL 8.00 0.50 AB-23S 0.28 0.42 AB-24S 1.00 1.00 AB-24SL 0.27 1.00 AB-25S 9.90 10.00 AB-25SL 0.63 10.00 AB-27S 0.50 0.60 AB-28S 0.30 0.44 AB-29S 0.38 10.00 AB-29SL 10.30 10.00 AB-30S 0.23 0.50 AB-35S 0.50 0.50 AB-37S 0.50 0.50 AB-38S 1.20 0.43 Arsenic Ash Basin Constant Concentration Range = 42 - 1600 pg/I Ash Storage Area Concentration Range = 42 - 1600 pg/I Sorption Coefficient [Kd] = 30 ml/g AB-10D 0.13 2.30 AB-10S 0.50 2.29 AB-11 D 0.50 2.25 AB-12D 0.15 2.30 AB-12S 0.50 2.30 AB-13D 0.18 2.30 Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 6 Transport Model Calibration Results (continued) COI Monitoring Well Measured Concentration N /L Predicted Concentration N /L Arsenic (cont.) AB-13S 0.50 2.30 AB-14D 0.50 2.30 AB-1 R 1.70 2.30 AB-2 0.50 2.30 AB-20D 1.70 2.30 AB-21 BR 1.50 2.30 AB-21 D 1.20 2.30 AB-22D 0.30 2.35 AB-22S 0.19 4.57 AB-23BRU 2.40 2.30 AB-24D 1.00 2.31 AB-25BR 1.40 2.30 AB-25BRU 1.80 2.30 AB-26D 6.90 2.30 AB-26S 0.16 2.39 AB-27D 0.39 2.31 AB-28D 0.68 2.30 AB-29D 0.91 2.36 AB-21D 0.15 2.30 AB-30D 0.32 2.31 AB-31 D 0.68 2.30 AB-31 S 0.13 2.30 AB-32D 0.43 2.33 AB-32S 0.21 2.94 AB-33D 0.47 2.30 AB-33S 0.18 2.41 AB-34D 0.52 2.30 AB-34S 0.33 2.30 AB-35BR 0.84 2.30 AB-35D 1.20 2.30 AB-36D 1.10 2.32 AB-36S 369.00 204.15 AB-37D 0.37 2.31 AB-38D 0.41 2.30 AB-39D 2.40 2.38 AB-4S 0.12 2.30 AB-5 0.50 2.30 Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 6 Transport Model Calibration Results (continued) COI Monitoring Well Measured Concentration p /L Predicted Concentration N /L Arsenic (cont.) AB-6R 0.14 2.30 AB-91D 0.50 2.30 AB-9S 0.15 2.30 AB-20S 1230.00 1200.00 AB-21 S 351.00 350.00 AB-21 SL 759.00 350.00 AB-23S 1060.00 8.35 AB-24S 41.80 50.00 AB-24SL 867.00 50.00 AB-25S 74.70 865.00 AB-25SL 865.00 293.12 AB-27S 56.40 17.66 AB-28S 27.60 15.47 AB-29S 671.00 280.00 AB-29SL 69.80 280.00 AB-30S 284.00 280.00 AB-35S 83.10 83.00 AB-37S 0.40 45.41 AB-38S 0.50 2.28 Barium Ash Basin Constant Concentration Range = 160 - 1000 pg/I Ash Storage Area Concentration Range = 160 - 1000 pg/I Sorption Coefficient [Kd] = 2.5 ml/g AB-10D 34.00 166.86 AB-10S 51.00 183.21 AB-11 D 40.00 78.84 AB-12D 42.00 88.81 AB-12S 31.00 69.22 AB-13D 41.00 95.03 AB-13S 37.00 72.20 AB-14D 61.00 94.56 AB-1 R 16.00 99.00 AB-2 26.00 91.48 AB-20D 14.00 109.32 AB-20S 240.00 250.00 AB-21 BR 10.00 99.00 AB-21 D 41.00 174.75 AB-21 S 380.00 250.00 Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 6 Transport Model Calibration Results (continued) COI Monitoring Well Measured Concentration N /L Predicted Concentration N /L Barium (cont.) AB-21 SL 250.00 250.00 AB-22D 82.00 202.46 AB-22S 64.00 223.30 AB-23BRU 17.00 99.00 AB-23S 60.00 127.78 AB-24D 130.00 144.64 AB-24S 170.00 200.00 AB-24SL 100.00 200.00 AB-25BR 150.00 99.05 AB-25BRU 12.00 99.05 AB-25S 170.00 200.00 AB-25SL 190.00 200.00 AB-26D 140.00 202.36 AB-26S 100.00 326.10 AB-27D 51.00 163.75 AB-27S 110.00 182.09 AB-28D 38.00 136.84 AB-28S 110.00 169.25 AB-29D 35.00 140.93 AB-29S 300.00 160.00 AB-29SL 150.00 160.00 AB-21D 26.00 87.42 AB-30D 40.00 119.11 AB-30S 280.00 160.00 AB-31 D 25.00 127.98 AB-31 S 20.00 128.32 AB-32D 46.00 134.95 AB-32S 27.00 143.03 AB-33D 46.00 127.31 AB-33S 27.00 139.62 AB-34D 16.00 108.22 AB-34S 39.00 112.07 AB-35BR 19.00 99.00 AB-35D 21.00 122.92 AB-35S 160.00 160.00 AB-36D 18.00 342.90 AB-36S 990.00 794.52 Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 6 Transport Model Calibration Results (continued) COI Monitoring Well Measured Concentration N /L Predicted Concentration N /L Barium (cont.) AB-37D 27.00 68.25 AB-37S 21.00 21.00 AB-38D 140.00 141.68 AB-38S 31.00 - AB-39D 180.00 352.68 AB-4S 27.00 71.93 AB-5 30.00 85.75 AB-6R 28.00 98.99 AB-91D 28.00 115.66 AB-9S 150.00 125.92 GWA-14D 210.00 95.60 GWA-14S 110.00 66.33 GWA-15D 32.00 82.15 GWA-15S 39.00 63.36 GWA-1 BR 72.00 102.79 GWA-1 D 30.00 115.87 GWA-1 S 60.00 118.53 GWA-21D 20.00 89.27 GWA-2S 49.00 77.58 GWA-3BR 9.40 123.32 GWA-31D 4.60 181.26 GWA-3S 37.00 284.90 GWA-41D 20.00 119.78 GWA-4S 55.00 126.77 GWA-5BR 15.00 111.85 GWA-51D 26.00 125.76 GWA-5S 140.00 131.59 GWA-6BR 110.00 98.16 GWA-6S 250.00 93.13 GWA-91D 36.00 92.87 GWA-9S 35.00 72.45 Boron Ash Basin Constant Concentration Range = 50 - 3800 pg/I Ash Storage Area Concentration Range = 50 - 3800 pg/I Sorption Coefficient [Kd] = 1 ml/g AB-10D 50.00 254.72 AB-10S 50.00 347.27 AB-11 D 50.00 42.95 Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 6 Transport Model Calibration Results (continued) COI Monitoring Well Measured Concentration N /L Predicted Concentration N /L Boron' (cont.) AB-12D 50.00 48.63 AB-12S 50.00 42.72 AB-13D 50.00 49.77 AB-13S 50.00 44.67 AB-14D 37.00 49.65 AB-1 R 50.00 49.99 AB-2 50.00 51.40 AB-20D 50.00 121.92 AB-21 BR 50.00 53.47 AB-21 D 29.00 531.02 AB-22D 1500.00 451.28 AB-22S 50.00 596.26 AB-23BRU 30.00 71.77 AB-24D 50.00 102.13 AB-25BR 50.00 84.09 AB-25BRU 50.00 87.03 AB-26D 93.00 169.89 AB-26S 730.00 479.14 AB-27D 1500.00 1362.05 AB-28D 37.00 80.38 AB-29D 210.00 527.02 AB-21D 50.00 48.80 AB-30D 50.00 149.02 AB-31 D 310.00 864.76 AB-31 S 1800.00 1739.38 AB-32D 490.00 49.55 AB-32S 50.00 48.70 AB-33D 180.00 341.23 AB-33S 690.00 627.41 AB-34D 50.00 83.97 AB-34S 230.00 141.61 AB-35BR 50.00 63.70 AB-35D 50.00 187.71 AB-36D 50.00 107.01 AB-36S 260.00 274.53 AB-37D 50.00 49.08 AB-38D 50.00 46.58 Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 6 Transport Model Calibration Results (continued) COI Monitoring Well Measured Concentration p /L Predicted Concentration N /L Boron (Cont.) AB-39D 80.00 353.00 AB-4S 50.00 44.10 AB-5 50.00 47.46 AB-6R 50.00 95.04 AB-91D 520.00 62.37 AB-9S 620.00 92.91 AB-20S 6800.00 3800.00 AB-21 S 3800.00 3800.00 AB-21 SL 7400.00 3800.00 AB-23S 560.00 520.73 AB-24S 190.00 200.00 AB-24SL 650.00 200.00 AB-25S 2800.00 3000.00 AB-25SL 1400.00 3000.00 AB-27S 470.00 2256.51 AB-28S 960.00 168.99 AB-29S 1100.00 1100.00 AB-29SL 2400.00 1100.00 AB-30S 830.00 830.00 AB-35S 860.00 860.00 AB-37S 50.00 27.18 AB-38S 50.00 - Chromium Ash Basin Constant Concentration Range = 2 - 35 pg/I Ash Storage Area Concentration Range = 2 - 35 pg/I Sorption Coefficient [Kd] = 4 ml/g AB-10D 4.30 15.74 AB-10S 0.26 15.16 AB-11 D 3.10 14.64 AB-12D 0.73 15.98 AB-12S 0.88 15.61 AB-13D 1.70 16.00 AB-13S 0.74 15.79 AB-14D 1.40 16.00 AB-1 R 4.20 16.00 AB-2 0.60 15.98 AB-20D 3.60 16.00 AB-21 BR 18.90 16.00 Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 6 Transport Model Calibration Results (continued) COI Monitoring Well Measured Concentration N /L Predicted Concentration N /L Chromium (cont.) AB-21 D 13.90 15.87 AB-22D 1.20 13.57 AB-22S 0.61 10.15 AB-23BRU 65.60 15.99 AB-24D 13.30 15.04 AB-25BR 9.10 15.99 AB-25BRU 2.30 15.99 AB-26D 29.80 15.86 AB-26S 1.90 14.31 AB-27D 1.70 15.10 AB-28D 4.00 15.86 AB-29D 1.50 14.96 AB-21D 2.70 15.98 AB-30D 0.82 15.75 AB-31 D 4.40 15.56 AB-31 S 0.79 12.92 AB-32D 5.00 13.54 AB-32S 0.94 9.65 AB-33D 2.20 15.65 AB-33S 0.50 12.33 AB-34D 3.80 15.98 AB-34S 0.33 15.62 AB-35BR 3.40 16.00 AB-35D 24.70 16.07 AB-36D 1.60 15.85 AB-36S 0.38 7.67 AB-37D 1.00 15.37 AB-38D 0.61 15.72 AB-39D 2.20 14.34 AB-4S 1.80 15.72 AB-5 12.50 15.95 AB-6R 15.90 15.99 AB-91D 0.85 15.91 AB-9S 0.61 15.24 AB-20S 0.20 2.00 AB-21 S 0.56 2.00 AB-21 SL 0.55 2.00 Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 6 Transport Model Calibration Results (continued) COI Monitoring Well Measured Concentration N /L Predicted Concentration N /L Chromium (cont.) AB-23S 0.19 12.04 AB-24S 0.25 2.00 AB-24SL 0.30 2.00 AB-25S 0.38 2.00 AB-25SL 1.60 2.00 AB-27S 0.78 10.42 AB-28S 0.70 8.65 AB-29S 0.24 2.00 AB-29SL 0.63 2.00 AB-30S 0.42 2.00 AB-35S 0.43 2.00 AB-37S 1.00 2.00 AB-38S 0.87 12.97 Cobalt Ash Basin Constant Concentration Range = 0.5 - 45 pg/I Ash Storage Area Concentration Range = 0.5 - 45 pg/I Sorption Coefficient [Kd] = 2 ml/g AB-10D 0.29 1.96 AB-10S 1.60 2.94 AB-11 D 0.50 0.65 AB-12D 0.50 0.73 AB-12S 0.72 0.69 AB-13D 0.50 0.74 AB-13S 1.10 0.71 AB-14D 10.10 0.74 AB-1 R 0.50 0.74 AB-2 2.00 0.73 AB-20D 0.22 0.74 AB-21 BR 0.50 0.74 AB-21 D 0.22 0.81 AB-22D 0.62 4.81 AB-22S 8.60 8.27 AB-23BRU 0.19 0.74 AB-24D 0.50 0.69 AB-25BR 0.50 0.74 AB-25BRU 0.50 0.74 AB-26D 9.90 1.86 AB-26S 5.90 7.05 Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 6 Transport Model Calibration Results (continued) COI Monitoring Well Measured Concentration N /L Predicted Concentration N /L Cobalt (Cont.) AB-27D 0.50 6.02 AB-28D 0.15 1.44 AB-29D 0.13 1.49 AB-21D 0.18 0.73 AB-30D 1.40 0.78 AB-31 D 0.79 0.78 AB-31 S 0.18 0.78 AB-32D 2.00 8.55 AB-32S 14.30 14.98 AB-33D 0.53 3.61 AB-33S 12.30 10.12 AB-34D 0.32 0.74 AB-34S 40.00 0.72 AB-35BR 0.50 0.74 AB-35D 1.70 0.72 AB-36D 0.15 0.72 AB-36S 0.32 0.57 AB-37D 0.20 0.71 AB-38D 5.00 1.14 AB-39D 0.90 3.11 AB-4S 0.40 0.70 AB-5 0.40 0.73 AB-6R 0.17 0.74 AB-91D 0.50 0.78 AB-9S 6.80 0.95 AB-20S 2.10 2.00 AB-21 S 5.20 2.00 AB-21 SL 0.26 2.00 AB-23S 0.29 0.93 AB-24S 0.66 0.50 AB-24SL 0.50 0.50 AB-25S 2.90 0.50 AB-25SL 0.29 0.50 AB-27S 14.20 14.00 AB-28S 42.30 17.37 AB-29S 0.50 1.10 AB-29SL 0.22 1.10 Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 6 Transport Model Calibration Results (continued) COI Monitoring Well Measured Concentration N /L Predicted Concentration N /L Cobalt (cont.) AB-30S 1.10 1.10 AB-35S 0.50 0.50 AB-37S 0.23 - AB-38S 11.80 2.69 Hexavalent Chromium Ash Basin Constant Concentration Range = 0.02 - 45 pg/I Ash Storage Area Concentration Range = 0.02 - 45 pg/I Sorption Coefficient [Kd] = 0.8 ml/g AB-10D 3.00 0.32 AB-10S 0.02 0.24 AB-11 D 2.60 0.95 AB-12D 0.47 0.48 AB-12S 0.10 0.41 AB-13D 1.20 0.50 AB-13S 0.43 0.43 AB-14D 0.87 0.49 AB-1 R 4.00 0.50 AB-20D 1.70 0.65 AB-21 BR 20.00 0.50 AB-21 D 20.00 12.61 AB-22D 0.02 0.26 AB-22S 0.02 0.15 AB-24D 19.00 17.46 AB-25BR 4.70 0.50 AB-25BRU 0.83 0.50 AB-29D 0.82 2.23 AB-31 D 1.40 1.02 AB-31 S 0.16 1.03 AB-32D 0.02 1.26 AB-32S 0.02 1.60 AB-33D 0.07 1.05 AB-33S 0.02 1.47 AB-35BR 2.90 0.50 AB-35D 6.10 5.53 AB-36D 0.73 0.87 AB-36S 0.02 1.66 AB-37D 0.34 0.79 AB-38D 0.02 0.43 Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 6 Transport Model Calibration Results (continued) COI Monitoring Well Measured Concentration p /L Predicted Concentration N /L Hexavalent Chromium (cont.) AB-39D 0.02 0.89 AB-4S 0.36 0.43 AB-91D 0.08 0.79 AB-9S 0.02 1.14 GWA-31D 0.92 0.44 GWA-3S 0.02 0.31 GWA-91D 0.64 0.50 GWA-9S 0.02 0.43 Selenium Ash Basin Constant Concentration Range = 1 - 20 pg/I Ash Storage Area Concentration Range = 1 - 20 pg/I Sorption Coefficient [Kd] = 5 ml/g AB-10D 0.50 0.50 AB-10S 0.50 0.50 AB-11 D 0.50 0.46 AB-12D 0.71 0.50 AB-12S 0.50 0.49 AB-13D 0.50 0.50 AB-13S 0.50 0.50 AB-14D 0.50 0.50 AB-1 R 0.32 0.50 AB-2 0.50 0.50 AB-20D 0.30 0.50 AB-21 BR 1.10 0.50 AB-21 D 0.84 0.60 AB-22D 0.50 0.56 AB-22S 0.50 0.68 AB-23BRU 6.70 0.50 AB-24D 0.91 0.93 AB-25BR 0.82 0.50 AB-25BRU 0.34 0.50 AB-26D 0.88 0.52 AB-26S 0.50 0.73 AB-27D 0.50 0.70 AB-28D 0.27 0.50 AB-29D 0.44 1.40 AB-21D 0.50 0.50 AB-30D 0.50 0.51 Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 6 Transport Model Calibration Results (continued) COI Monitoring Well Measured Concentration N /L Predicted Concentration N /L Selenium (cont.) AB-31 D 2.10 0.85 AB-31 S 0.50 0.88 AB-32D 0.50 0.56 AB-32S 0.50 0.67 AB-33D 0.50 0.50 AB-33S 0.50 0.58 AB-34D 0.50 0.50 AB-34S 0.50 0.50 AB-35BR 0.50 0.50 AB-35D 0.31 0.50 AB-36D 0.24 0.50 AB-36S 0.50 0.74 AB-37D 0.50 0.51 AB-38D 0.50 0.53 AB-39D 1.70 1.67 AB-4S 0.50 0.49 AB-5 0.50 0.50 AB-6R 0.41 0.50 AB-91D 2.70 0.51 AB-9S 0.50 0.68 AB-20S 0.48 1.00 AB-21 S 0.50 20.00 AB-21 SL 1.20 20.00 AB-23S 0.24 2.76 AB-24S 0.50 10.00 AB-24SL 0.22 10.00 AB-25S 1.90 5.00 AB-25SL 0.44 5.00 AB-27S 0.50 2.78 AB-28S 0.57 0.70 AB-29S 0.50 20.00 AB-29SL 18.70 20.00 AB-30S 0.50 1.00 AB-35S 0.50 1.00 AB-37S 0.24 0.11 AB-38S 0.50 - Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 6 Transport Model Calibration Results (continued) COI Monitoring Well Measured Concentration N /L Predicted Concentration N /L Sulfate Ash Basin Constant Concentration Range p /I = 25,000 - 350,000 Ash Storage Area Concentration Range = 25,000 - 350,000 pg/I Sorption Coefficient [Kd] = 0 ml/g AB-10D 20700 45874 AB-10S 16700 45250 AB-11 D 1000 6990 AB-12D 4100 6744 AB-12S 1000 5731 AB-13D 490 6423 AB-13S 760 4030 AB-14D 11100 5611 AB-1 R 37800 9728 AB-2 1000 8039 AB-20D 11700 46030 AB-21 BR 46800 36449 AB-21 D 23600 90428 AB-22D 42800 49297 AB-22S 55300 49192 AB-23BRU 171000 66065 AB-24D 13200 40512 AB-25BR 22200 40280 AB-25BRU 15800 40225 AB-26D 57100 59608 AB-26S 68400 56592 AB-27D 109000 60853 AB-28D 23400 25916 AB-29D 41600 119951 AB-21D 1000 5567 AB-30D 18900 36242 AB-31 D 35800 80146 AB-31 S 108000 79754 AB-32D 23300 58049 AB-32S 2100 54164 AB-33D 12500 298187 AB-33S 337000 297471 AB-34D 3900 110093 Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 6 Transport Model Calibration Results (continued) COI Monitoring Well Measured Concentration N /L Predicted Concentration N /L Sulfate (cont.) AB-34S 119000 110241 AB-35BR 3900 48077 AB-35D 15700 32652 AB-36D 18900 31060 AB-36S 1400 36497 AB-37D 6100 18758 AB-38D 35100 11237 AB-39D 26400 214389 AB-4S 10100 4471 AB-5 950 3562 AB-6R 26400 31163 AB-91D 42500 65117 AB-9S 30100 63497 AB-20S 390000 125000 AB-21 S 80400 80000 AB-21 SL 122000 80000 AB-23S 9900 55477 AB-24S 12800 25000 AB-24SL 23300 25000 AB-25S 127000 25000 AB-25SL 79800 25000 AB-27S 30000 72404 AB-28S 158000 23529 AB-29S 93700 200000 AB-29SL 220000 200000 AB-30S 46500 48000 AB-35S 313000 40000 AB-37S 4200 22100 AB-38S 1100 - Vanadium Ash Basin Constant Concentration Range = 10 - 50 pg/I Ash Storage Area Concentration Range = 10 - 50 pg/I Sorption Coefficient [Kd] = 10 ml/g AB-10D 5.30 22.47 AB-10S 0.37 22.25 AB-11 D 1.80 21.41 AB-12D 3.90 22.50 AB-12S 0.37 22.39 Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 6 Transport Model Calibration Results (continued) COI Monitoring Well Measured Concentration N /L Predicted Concentration N /L Vanadium (cont.) AB-13D 7.10 22.50 AB-13S 1.10 22.45 AB-14D 0.96 22.50 AB-1 R 21.50 22.50 AB-2 0.54 22.50 AB-20D 36.90 22.50 AB-21 BR 17.70 22.50 AB-21 D 14.00 22.50 AB-22D 3.30 22.50 AB-22S 1.20 22.45 AB-23BRU 29.90 22.50 AB-24D 16.80 22.50 AB-25BR 27.20 22.50 AB-25BRU 18.10 22.50 AB-26D 93.20 22.53 AB-26S 2.10 23.36 AB-27D 6.30 22.50 AB-28D 13.20 22.50 AB-29D 16.30 22.52 AB-21D 6.10 22.50 AB-30D 13.60 22.50 AB-31 D 13.90 22.50 AB-31 S 1.10 22.50 AB-32D 9.50 22.54 AB-32S 0.81 22.66 AB-33D 7.60 22.50 AB-33S 1.00 22.30 AB-34D 16.30 22.50 AB-34S 1.00 22.41 AB-35BR 16.10 22.50 AB-35D 21.10 22.50 AB-36D 16.80 22.50 AB-36S 0.39 23.26 AB-37D 8.60 22.51 AB-38D 3.00 22.46 AB-39D 6.30 22.53 AB-4S 0.60 22.42 Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 6 Transport Model Calibration Results (continued) COI Monitoring Well Measured Concentration N /L Predicted Concentration N /L Vanadium (cont.) AB-5 2.30 22.49 AB-6R 4.40 22.50 AB-91D 7.20 22.49 AB-9S 1.00 22.36 AB-20S 0.99 22.50 AB-21 S 3.00 22.50 AB-21 SL 28.60 22.50 AB-23S 5.10 21.02 AB-24S 3.10 22.50 AB-24SL 2.20 22.50 AB-25S 47.40 50.00 AB-25SL 18.00 50.00 AB-27S 2.10 21.63 AB-28S 1.00 20.70 AB-29S 13.50 25.00 AB-29SL 70.80 25.00 AB-30S 2.20 25.00 AB-35S 1.90 25.00 AB-37S 7.90 13.37 AB-38S 1.10 - Groundwater Flow and Transport Model Allen Steam Station Ash Basin Table 7 Predicted Advective Travel Time Groundwater Zone Monitoring Well Advective Travel Time to Model Boundary (days) Shallow AB-35S 6,659 AB-36S 8,093 AB-24S 16,212 AB-20S 126,138 GWA-1 S 2,508 AB-32S 276 GWA-3S 406 GWA-2S 669 Deep AB-35D 9,559 AB-36D 4,393 AB-24D 12,209 GWA-1 D 87 AB-32D 8 GWA-3D 28 GWA-2D 24 Bedrock AB-35BR 182,978 GWA-1 BR 2,021 GWA-5BR 1,035 GWA-3BR 20,413 AB-21 BR 6,784,247 'Computed travel time over 3-D flow path using flow and transport terms from the groundwater flow and transport model. Groundwater Flow and Transport Model Allen Steam Station Ash Basin Figures Figure 1 Conceptual Groundwater Flow Model/Model Domain Figure 2 Model Domain North -South Cross Section (A -A') through Inactive and Active Ash Basins Figure 3 Model Domain East-West Cross Section (B-B') through the Active Ash Basin Figure 4 Flow Model Boundary Conditions Figure 5 Model Recharge Areas and Contaminant Source Zones (Constant Concentration Cells) Figure 6 Observation Wells in Shallow Groundwater Zone Figure 7 Observation Wells in Deep Groundwater Zone Figure 8 Observation Wells in Bedrock Groundwater Zone Figure 9 Hydraulic Conductivity Zonation in S/M1 Model Layers (Model Layers 5-6) Figure 10 Hydraulic Conductivity Zonation in M2 Model Layer (Model Layer 7) Figure 11 Hydraulic Conductivity Zonation in Transition Zone Model Layer (Model Layer 8) Figure 12 Hydraulic Conductivity Zonation in Bedrock Model Layers (Model Layers 9 and10) Figure 13 Modeled Hydraulic Head vs. Observed Hydraulic Head Figure 14 Hydraulic Head in Shallow Groundwater Zone (Model Layer 6) Figure 15 Particle Tracking Results (see Table 6 for Advective Travel Times) Figure 16 1 Year Reverse Particle Tracking from Residential Wells Figure 17 Predicted Antimony in Monitoring Well AB-22S Figure 18 Predicted Antimony in Monitoring Well AB-26S Figure 19 Predicted Antimony in Monitoring Well AB-32S Figure 20 Initial (2015) Antimony Concentrations in Shallow Groundwater Zone Figure 21 Initial (2015) Antimony Concentrations in Deep Groundwater Zone Figure 22 Initial (2015) Antimony Concentrations in Bedrock Groundwater Zone Figure 23 Existing Conditions Scenario 1 - 2115 Predicted Antimony in Shallow Groundwater Zone Figure 24 Existing Conditions Scenario 1 - 2115 Predicted Antimony in Deep Groundwater Zone Figure 25 Existing Conditions Scenario 1 - 2115 Predicted Antimony in Bedrock Groundwater Zone Figure 26 Cap -in -Place Scenario 2 - 2115 Predicted Antimony in Shallow Groundwater Zone Figure 27 Cap -in -Place Scenario 2 - 2115 Predicted Antimony in Deep Groundwater Zone Figure 28 Cap -in -Place Scenario 2 - 2115 Predicted Antimony in Bedrock Groundwater Zone Figure 29 Predicted Arsenic in Monitoring Well AB-22S Figure 30 Predicted Arsenic in Monitoring Well AB-26S Figure 31 Predicted Arsenic in Monitoring Well AB-32S Figure 32 Initial (2015) Arsenic Concentrations in Shallow Groundwater Zone Figure 33 Initial (2015) Arsenic Concentrations in Deep Groundwater Zone Figure 34 Initial (2015) Arsenic Concentrations in Bedrock Groundwater Zone Figure 35 Existing Conditions Scenario 1 - 2115 Predicted Arsenic in Shallow Groundwater Zone Figure 36 Existing Conditions Scenario 1 - 2115 Predicted Arsenic in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin Figure 37 Existing Conditions Scenario 1 - 2115 Predicted Arsenic in Bedrock Groundwater Zone Figure 38 Cap -in -Place Scenario 2 - 2115 Predicted Arsenic in Shallow Groundwater Zone Figure 39 Cap -in -Place Scenario 2 - 2115 Predicted Arsenic in Deep Groundwater Zone Figure 40 Cap -in -Place Scenario 2 - 2115 Predicted Arsenic in Bedrock Groundwater Zone Figure 41 Predicted Barium in Monitoring Well AB-22S Figure 42 Predicted Barium in Monitoring Well AB-26S Figure 43 Predicted Barium in Monitoring Well AB-32S Figure 44 Initial (2015) Barium Concentrations in Shallow Groundwater Zone Figure 45 Initial (2015) Barium Concentrations in Deep Groundwater Zone Figure 46 Initial (2015) Barium Concentrations in Bedrock Groundwater Zone Figure 47 Existing Conditions Scenario 1 - 2115 Predicted Barium in Shallow Groundwater Zone Figure 48 Existing Conditions Scenario 1 - 2115 Predicted Barium in Deep Groundwater Zone Figure 49 Existing Conditions Scenario 1 - 2115 Predicted Barium in Bedrock Groundwater Zone Figure 50 Cap -in -Place Scenario 2 - 2115 Predicted Barium in Shallow Groundwater Zone Figure 51 Cap -in -Place Scenario 2 - 2115 Predicted Barium in Deep Groundwater Zone Figure 52 Cap -in -Place Scenario 2 - 2115 Predicted Barium in Bedrock Groundwater Zone Figure 53 Predicted Boron in Monitoring Well AB-22S Figure 54 Predicted Boron in Monitoring Well AB-26S Figure 55 Predicted Boron in Monitoring Well AB-32S Figure 56 Initial (2015) Boron Concentrations in Shallow Groundwater Zone Figure 57 Initial (2015) Boron Concentrations in Deep Groundwater Zone Figure 58 Initial (2015) Boron Concentrations in Bedrock Groundwater Zone Figure 59 Existing Conditions Scenario 1 - 2115 Predicted Boron in Shallow Groundwater Zone Figure 60 Existing Conditions Scenario 1 - 2115 Predicted Boron in Deep Groundwater Zone Figure 61 Existing Conditions Scenario 1 - 2115 Predicted Boron in Bedrock Groundwater Zone Figure 62 Cap -in -Place Scenario 2 - 2115 Predicted Boron in Shallow Groundwater Zone Figure 63 Cap -in -Place Scenario 2 - 2115 Predicted Boron in Deep Groundwater Zone Figure 64 Cap -in -Place Scenario 2 - 2115 Predicted Boron in Bedrock Groundwater Zone Figure 65 Predicted Chromium in Monitoring Well AB-22S Figure 66 Predicted Chromium in Monitoring Well AB-26S Figure 67 Predicted Chromium in Monitoring Well AB-32S Figure 68 Initial (2015) Chromium Concentrations in Shallow Groundwater Zone Figure 69 Initial (2015) Chromium Concentrations in Deep Groundwater Zone Figure 70 Initial (2015) Chromium Concentrations in Bedrock Groundwater Zone Figure 71 Existing Conditions Scenario 1 - 2115 Predicted Chromium in Shallow Groundwater Zone Figure 72 Existing Conditions Scenario 1 - 2115 Predicted Chromium in Deep Groundwater Zone Figure 73 Existing Conditions Scenario 1 - 2115 Predicted Chromium in Bedrock Groundwater Zone Figure 74 Cap -in -Place Scenario 2 - 2115 Predicted Chromium in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin Figure 75 Cap -in -Place Scenario 2 - 2115 Predicted Chromium in Deep Groundwater Zone Figure 76 Cap -in -Place Scenario 2 - 2115 Predicted Chromium in Bedrock Groundwater Zone Figure 77 Predicted Hexavalent Chromium in Monitoring Well AB-22S Figure 78 Predicted Hexavalent Chromium in Monitoring Well AB-32S Figure 79 Initial (2015) Hexavalent Chromium Concentrations in Shallow Groundwater Zone Figure 80 Initial (2015) Hexavalent Chromium Concentrations in Deep Groundwater Zone Figure 81 Initial (2015) Hexavalent Chromium Concentrations in Bedrock Groundwater Zone Figure 82 Existing Conditions Scenario 1 - 2115 Predicted Hexavalent Chromium in Shallow Groundwater Zone Figure 83 Existing Conditions Scenario 1 - 2115 Predicted Hexavalent Chromium in Deep Groundwater Zone Figure 84 Existing Conditions Scenario 1 - 2115 Predicted Hexavalent Chromium in Bedrock Groundwater Zone Figure 85 Cap -in -Place Scenario 2 - 2115 Predicted Hexavalent Chromium in Shallow Groundwater Zone Figure 86 Cap -in -Place Scenario 2 - 2115 Predicted Hexavalent Chromium in Deep Groundwater Zone Figure 87 Cap -in -Place Scenario 2 - 2115 Predicted Hexavalent Chromium in Bedrock Groundwater Zone Figure 88 Predicted Cobalt in Monitoring Well AB-22S Figure 89 Predicted Cobalt in Monitoring Well AB-26S Figure 90 Predicted Cobalt in Monitoring Well AB-32S Figure 91 Initial (2015) Cobalt Concentrations in Shallow Groundwater Zone Figure 92 Initial (2015) Cobalt Concentrations in Deep Groundwater Zone Figure 93 Initial (2015) Cobalt Concentrations in Bedrock Groundwater Zone Figure 94 Existing Conditions Scenario 1 - 2115 Predicted Cobalt in Shallow Groundwater Zone Figure 95 Existing Conditions Scenario 1 - 2115 Predicted Cobalt in Deep Groundwater Zone Figure 96 Existing Conditions Scenario 1 - 2115 Predicted Cobalt in Bedrock Groundwater Zone Figure 97 Cap -in -Place Scenario 2 - 2115 Predicted Cobalt in Shallow Groundwater Zone Figure 98 Cap -in -Place Scenario 2 - 2115 Predicted Cobalt in Deep Groundwater Zone Figure 99 Cap -in -Place Scenario 2 - 2115 Predicted Cobalt in Bedrock Groundwater Zone Figure 100 Predicted Selenium in Monitoring Well AB-22S Figure 101 Predicted Selenium in Monitoring Well AB-26S Figure 102 Predicted Selenium in Monitoring Well AB-32S Figure 103 Initial (2015) Selenium Concentrations in The Shallow Groundwater Zone Figure 104 Initial (2015) Selenium Concentrations in Deep Groundwater Zone Figure 105 Initial (2015) Selenium Concentrations in Bedrock Groundwater Zone Figure 106 Existing Conditions Scenario 1 - 2115 Predicted Selenium in Shallow Groundwater Zone Figure 107 Existing Conditions Scenario 1 - 2115 Predicted Selenium in Deep Groundwater Zone Figure 108 Existing Conditions Scenario 1 - 2115 Predicted Selenium in Bedrock Groundwater Zone Figure 109 Cap -in -Place Scenario 2 - 2115 Predicted Selenium in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin Figure 110 Cap -in -Place Scenario 2 - 2115 Predicted Selenium in Deep Groundwater Zone Figure 111 Cap -in -Place Scenario 2 - 2115 Predicted Selenium in Bedrock Groundwater Zone Figure 112 Predicted Sulfate In Monitoring Well AB-22S Figure 113 Predicted Sulfate In Monitoring Well AB-26S Figure 114 Predicted Sulfate In Monitoring Well AB-32S Figure 115 Initial (2015) Sulfate Concentrations in Shallow Groundwater Zone Figure 116 Initial (2015) Sulfate Concentrations in Deep Groundwater Zone Figure 117 Initial (2015) Sulfate Concentrations in Bedrock Groundwater Zone Figure 118 Existing Conditions Scenario 1 - 2115 Predicted Sulfate in Shallow Groundwater Zone Figure 119 Existing Conditions Scenario 1 - 2115 Predicted Sulfate in Deep Groundwater Zone Figure 120 Existing Conditions Scenario 1 - 2115 Predicted Sulfate in Bedrock Groundwater Zone Figure 121 Cap -in -Place Scenario 2 - 2115 Predicted Sulfate in Shallow Groundwater Zone Figure 122 Cap -in -Place Scenario 2 - 2115 Predicted Sulfate in Deep Groundwater Zone Figure 123 Cap -in -Place Scenario 2 - 2115 Predicted Sulfate in Bedrock Groundwater Zone Figure 124 Predicted Vanadium In Monitoring Well AB-22S Figure 125 Predicted Vanadium In Monitoring Well AB-26S Figure 126 Predicted Vanadium In Monitoring Well AB-32S Figure 127 Initial (2015) Vanadium Concentrations in Shallow Groundwater Zone Figure 128 Initial (2015) Vanadium Concentrations in Deep Groundwater Zone Figure 129 Initial (2015) Vanadium Concentrations in Bedrock Groundwater Zone Figure 130 Existing Conditions Scenario 1 - 2115 Predicted Vanadium in Shallow Groundwater Zone Figure 131 Existing Conditions Scenario 1 - 2115 Predicted Vanadium in Deep Groundwater Zone Figure 132 Existing Conditions Scenario 1 - 2115 Predicted Vanadium in Bedrock Groundwater Zone Figure 133 Cap -in -Place Scenario 2 - 2115 Predicted Vanadium in Shallow Groundwater Zone Figure 134 Cap -in -Place Scenario 2 - 2115 Predicted Vanadium in Deep Groundwater Zone Figure 135 Cap -in -Place Scenario 2 - 2115 Predicted Vanadium in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin Groundwater Discharge Figure 1 Conceptual Groundwater Flow Model/Model Domain 0 Groundwater Flow and Transport Model Allen Steam Station Ash Basin W 7 Figure 2 Model Domain North -South Cross Section (A -A') through Inactive and Active Ash Basins Groundwater Flow and Transport Model Allen Steam Station Ash Basin B B' Figure 3 Model Domain East-West Cross Section (B-B') through the Active Ash Basin Groundwater Flow and Transport Model Allen Steam Station Ash Basin Figure 4 Flow Model Boundary Conditions Groundwater Flow and Transport Model Allen Steam Station Ash Basin Figure 5 Model Recharge Areas and Contaminant Source Zones (Constant Concentration Cells) Groundwater Flow and Transport Model Allen Steam Station Ash Basin Figure 6 Observation Wells in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin Figure 7 Observation Wells in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin Figure 8 Observation Wells in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin .. Z-6 LEGEND DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODELDOMAIN Z-10 I Z-11 I Z-12 I Z!7 I / Z-8:� - Z-12 �i Z-6 f a` Zi. 5 .r N 0 500 1,000 Feet Figure 9 Hydraulic Conductivity Zonation in S/M1 Model Layers (Model Layers 5-6) Groundwater Flow and Transport Model Allen Steam Station Ash Basin Z-4 LEGEND DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 S00 1,000 Feet Figure 10 Hydraulic Conductivity Zonation in M2 Model Layer (Model Layer 7) Groundwater Flow and Transport Model Allen Steam Station Ash Basin I `\ !!M I Z-7 LEGEND DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN } ;I ")Z-6 7Af N A 0 S00 1,000 Feet Figure 11 Hydraulic Conductivity Zonation in Transition Zone Model Layer (Model Layer 8) Groundwater Flow and Transport Model Allen Steam Station Ash Basin Figure 12 Hydraulic Conductivity Zonation in Bedrock Model Layers (Model Layers 9 and10) Me 630 620 aD 610 m 600 -o 590 0 580 570 560 Groundwater Flow and Transport Model Allen Steam Station Ash Basin Observed vs. Computed Target Values o� 0110 0 00 4 0 0 0 0 0 o oao 00 0 I 0 0 0 � 560 570 580 590 600 610 620 630 640 Observed Value (feet) Figure 13 Modeled Hydraulic Head vs. Observed Hydraulic Head Layer 6 0 Layer 8 Layer 9 Groundwater Flow and Transport Model Allen Steam Station Ash Basin Figure 14 Hydraulic Head in Shallow Groundwater Zone (Model Layer 6) Groundwater Flow and Transport Model Allen Steam Station Ash Basin Figure 15 Particle Tracking Results (see Table 6 for Advective Travel Times) Groundwater Flow and Transport Model Allen Steam Station Ash Basin Figure 16 1 Year Reverse Particle Tracking from Residential Wells Groundwater Flow and Transport Model Allen Steam Station Ash Basin Predicted Antimony Concentration at AB-22S 1.2 1.0 0.8 J 1 a� 0.6 •..r 0 +� 0.4 — l'R }, Existing Conditions c 0 2 _ Cap -in -Place _ 0 V Antimony IMAC 0.0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Ln rti a7 r-I m Ln r- a7 r-� m Ln r- a) r-I m Ln rti a� a) a7 0 0 0 0 0 r-� r-I r-� r-I r-� rU rU rU rU rti rIIj rU rIIj r i rU rIIj rU rIIj rU rU rIIj rU rti Notes: 1. µg/L = micrograms per liter Time (Years) 2.Antimony IMAC value = 1 µg/L 3. Antimony PPBC = 0.5 µg/L Figure 17 Predicted Antimony in Monitoring Well AB-22S Predicted Antimony Concentration at AB-26S 12.0 MIXI] :1 J 1 6.0 0 4.0 L a 2.0 U 0.0 0 0 O Ln rl- 61 61 61 61 Notes: ri ri r-I 1. µg/L = micrograms per liter 2.Antimony IMAC value = 1 µg/L 3. Antimony PPBC = 0.5 µg/L Groundwater Flow and Transport Model Allen Steam Station Ash Basin O 0 0 O 0 0 O O O 0 O O 0 rq M Ln 61 r- M Ln f 61 r-I ro Ln O p r- r-I r-I r-I r- rti rV rU rV rJ rV rV rV rV rV rV rV rV rV rV rV Time (Years) Figure 18 Predicted Antimony in Monitoring Well AB-26S Predicted Antimony Concentration at AB-32S 1.2 1.0 Groundwater Flow and Transport Model Allen Steam Station Ash Basin - Existing Conditions 0.8 - Cap -in -Place J 0.6 Antimony IMAC 0 4-1 0.4 L Q 0.2 U 0.0 -!—- 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Ln � C) � ro Ln � C m Ln � al � CO Ln � a, a) c, 0 0 0 0 o r r ri � rti rti rU rU r rl r rU rV rU rV ri rU rU rU rV rU rU rV rU rU Notes: 1. µg/L = micrograms per liter 2.Antimony IMAC value = 1 µg/L 3. Antimony PPBC = 0.5 µg/L Figure 19 Predicted Antimony in Monitoring Well AB-32S Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 0.5 (Background Concentration) 0.5 - 1.0 (Standard) 1.0 - 2.5 2.5 - 5.0 5.0 - 7.5 i 7.5 - 10.0 w 10.0 - 12.26 9 DUKE ENERGY 'a PROPERTY BOUNDARY f ASH BASIN WASTE m BOUNDARY w S LANDFILL/ASH STORAGE AREA BOUNDARY w ASH BASIN COMPLIANCE BOUNDARY Q ASH BASIN COMPLIANCE w BOUNDARY COINCIDENT 'o WITH DUKE ENERGY a PROPERTY BOUNDARY a MODEL DOMAIN 1. Ng/L = micrograms per liter 2. Antimony IMAC value = 1 Ng/L 3. Antimony PPBC = 0.5 Ng/L N A 0 500 1,000 Feet Figure 20 Initial (2015) Antimony Concentrations in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin N Z O �7 Z w N O g LEGEND b <= 0.5 (Background g Concentration) 0.5 - 1.0 (Standard) N' 1.0 - 2.5 2.5 - 5.0 rc 8 5.0 - 7.5 6 7.5 - 10.0 10.0 - 12.26 DUKEENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes: 1. Ng/L = micrograms per liter 2. Antimony [MAC value = 1 Ng/L 3. Antimony PPBC = 0.5 pg/L L J N A 0 500 1,000 Feet Figure 21 Initial (2015) Antimony Concentrations in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin r- LEGEND — 0.5 (Background Concentration) 0.5 - 1.0 (Standard) 1.0 - 2.5 2.5 - 5.0 J 5.0 - 7.5 6 7.5 -10.0 = 10.0 - 12.26 DUKEENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY pMODEL DOMAIN 1. Ng/L = micrograms per liter 2. Antimony IMAC value = 1 Ng/L 3. Antimony PPBC = 0.5 Ng/L LAKE 7A L N A 0 500 1,000 Feel Figure 22 Initial (2015) Antimony Concentrations in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin 0 a a a 0 Q } 1 AffiI F H� 1 Or low I LEGEND — 0.5 (Background Concentration) 0.5 - 1.0 (Standard) j 1.0 - 2.5 I / 2.5 - 5.0 5.0 - 7.5 7.5 - 10.0 - 10.0 - 12.26 DUKE ENERGY •/ PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE AN BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT NOteS: WITH DUKE ENERGY 1. Ng/L = micrograms per liter 0 500 1,000 PROPERTY BOUNDARY 2. Antimony ]MAC value = 1 Ng/L MODEL DOMAIN 3. Antimony PPBC = 0.5 ug/L Feet Figure 23 Existing Conditions Scenario 1 - 2115 Predicted Antimony in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin 0- o _ , a. N a 0 VEASH BASIN LEGEND - 0.5 (Background Concentration) 0.5 - 1.0 (Standard) j 1.0 - 2.5 + `� 2.5 - 5.0 5.0 - 7.5 7.5 - 10.0 - 10.0 - 12.26 I DUKE ENERGY _ _ PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT Notes: WITH DUKE ENERGY 1. Ng/L = micrograms per liter PROPERTY BOUNDARY 2. Antimony ]MAC value = 1 pg/L 3. Antimony PPBC = 0.5 Ng/L MODEL DOMAIN N A 0 500 1,000 Feet Figure 24 Existing Conditions Scenario 1 - 2115 Predicted Antimony in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin } 1 �1 11 r� f I rf e u i LEGEND a �= 0.5 (Background Concentration) 0.5 - 1.0 (Standard) j 1.0 - 2.5 25-5-0 5.0 - 7.5 7.5 - 10.0 - 10.0 - 12.26 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLJASH STORAGE AREA BOUNDARY - ASH BASIN COMPLIANCE AN BOUNDARY J1 ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT Notes: WITH DUKE ENERGY 1. pg/L = micrograms per liter PROPERTY BOUNDARY 2. Antimony IMAC value = 1 pg/L 0 500 1,000 3. Antimony PPBC = 0.5 pg/L � MODEL DOMAIN Feet Figure 25 Existing Conditions Scenario 1 - 2115 Predicted Antimony in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin i� LEGEND �= 0.5 (Background Concentration) 0.5 - 1.0 (Standard) j 1.0 - 2.5 I / 2.5 - 5.0 5.0 - 7.5 7.5 - 10.0 - 10.0 - 12.26 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY AN ASH BASIN COMPLIANCE J JN4 BOUNDARY COINCIDENT Notes: - WITH DUKE ENERGY 1. ug/L = micrograms per liter 0 500 1,000 PROPERTY BOUNDARY 2. Antimony [MAC value = 1 pg/L 3. Antimony PPBC = 0.5 pg/L Feet MODEL DOMAIN Figure 26 Cap -in -Place Scenario 2 - 2115 Predicted Antimony in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin c N Z O �7 Z w N O g LEGEND b <= 0.5 (Background g Concentration) 0.5 - 1.0 (Standard) N' 1.0 - 2.5 2.5 - 5.0 rc 8 5.0 - 7.5 6 7.5 - 10.0 10.0 - 12.26 DUKEENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY pMODEL DOMAIN Notes: 1. Ng/L = micrograms per liter 2. Antimony IMAC value = 1 pg/L 3. Antimony PPBC = 0.5 Ng/L N A 0 500 1,000 Feet Figure 27 Cap -in -Place Scenario 2 - 2115 Predicted Antimony in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND �= 0.5 (Background s Concentration) 0.5 - 1.0 (Standard) 1.0 - 2.5 j 25-5.0 IL 8 5.0 - 7.5 10.0 - 12.26 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes: 1. pg/L = micrograms per liter 2. Antimony ]MAC value = 1 pg/L 3. Antimony PPBC = 0.5 pg/L PC N A 0 500 1,000 Feet Figure 28 Cap -in -Place Scenario 2 - 2115 Predicted Antimony in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin Predicted Arsenic Concentration at AB-22S 20.0 Existing Conditions 15.0 - Cap -in -Place 16.0 Arsenic 2L 14.0 12.0 10.0 8.0 6.0 LAKIR PAIL 0.0 C CD CD CD CD M CD CD Notes: �q �q rU rU 1. µg/L = micrograms per liter 2. Arsenic 2L Standard = 10 µg/L 3. Arsenic PPBC = 2.3 µg/L C CD CD C CD CD 0 d1 rl m Ln r� a) � o �q �q �q �q rU N rl rl N rl rl N Time (Years) Figure 29 Predicted Arsenic in Monitoring Well AB-22S 20.0 18.0 16.0 14.0 12.0 10.0 8.0 6.0 I Kf Predicted Arsenic Concentration at AB-26S Existing Conditions _ Cap -in -Place Arsenic 2L 2.0 0.0 0 0 0 0 Ln r� a) r-I 0) al 0) 0 " N Notes: 1. µg/L = micrograms per liter 2. Arsenic 2L Standard =10 µg/L 3. Arsenic PPBC = 2.3 µg/L Groundwater Flow and Transport Model Allen Steam Station Ash Basin 0 0 0 0 0 0 0 0 0 0 0 0 0 m Ln rti a) IH m Ln r- rn r-I m Ln r- 0 0 0 0 N N N N N N N N N N N N N N N N N Time (Years) Figure 30 Predicted Arsenic in Monitoring Well AB-26S Predicted Arsenic Concentration at AB-32S 20.0 18.0 16.0 14.0 12.0 J 10.0 o 8.0 6.0 4.0 V 2.0 0.0 0 0 0 Ln r rn rn a� r-I r-� Notes: 1. µg/L = micrograms per liter 2. Arsenic 2L Standard = 10 µg/L 3. Arsenic PPBC = 2.3 µg/L Groundwater Flow and Transport Model Allen Steam Station Ash Basin 0 0 0 0 0 0 0 0 0 0 0 0 0 0 "i m Ln C) �4 m Ln rI_ C) r-I m Ln rI_ 0 0 0 0 0 r-i T--� r-i T rU rU rU rU rU rti rU rU rti rU rti rU rti rti rU rU rU rU Time (Years) Figure 31 Predicted Arsenic in Monitoring Well AB-32S Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND a = 2.3 (Background Concentration) 2.3 - 10 (Standard) 10-25 25 - 50 50 -100 100- 150 150 - 205 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes: 1. pg/L = micrograms per liter 2. Arsenic 2L Standard = 10 pg/L 3. Arsenic PPBC = 2.3 pg/L N A 0 500 1,000 monsoons Feet Figure 32 Initial (2015) Arsenic Concentrations in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin I, I LEGEND G (Background Concentration) 2.3 - 10 (Standard) 10 - 25'� 25 - 50 50 -100 100- 150 150 - 205 = DUKE ENERGY - PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY AI ASH BASIN COMPLIANCE N BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT Notes: WITH DUKE ENERGY 1. pg/L = micrograms per liter .' 0 500 1,000 PROPERTY BOUNDARY 2. Arsenic 2L Standard = 10 Ng/L � MODEL DOMAIN 3. Arsenic PPBC = 2.3 pg/L Feet Figure 33 Initial (2015) Arsenic Concentrations in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin u I I = 1 1 LEGEND G (Background Concentration) 2.3 - 10 (Standard) 10-25 25 - 50 50 -100 loo- 150 150 - 205 = DUKE ENERGY - PROPERTY BOUNDARY P ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE + AREA BOUNDARY AI ASH BASIN COMPLIANCE N BOUNDARY ASH BASIN COMPLIANCEr2. es: BOUNDARY COINCIDENT _ WITH DUKE ENERGY g/L = microgram110pg/L PROPERTY BOUNDARYrsenic 2L Standa1 0 500 1,000 rsenic PPBC = 24. MODEL DOMAIN - Feet Figure 34 Initial (2015) Arsenic Concentrations in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND <= 2.3 (Background g 'Concentration) 2.3 - 10 (Standard) 10-25 j 25 - 50 L 8 50 -100 100- 150 150 - 205 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN I ----\ - - 4"P. Notes: 1. Ng/L = micrograms per liter 2. Arsenic 2L Standard = 10 pg/L 3. Arsenic PPBC = 2 3 Ng/L Figure 35 Existing Conditions Scenario 1 - 2115 Predicted Arsenic in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND [ �= 0.5 (Background nConcentration) 0.5 - 1.0 (Standard) 1.0-2.5 2-5 - 5-0 2 s.o 7.s ° 7.5 - 10.0 w 10.0 - 12.26 u 0 DUKE ENERGY a PROPERTY BOUNDARY a ASH BASIN WASTE m BOUNDARY ti 5 LANDFILLIASH STORAGE u w AREA BOUNDARY w ASH BASIN COMPLIANCE 'a BOUNDARY ASH BASIN COMPLIANCE w BOUNDARY COINCIDENT 3 WITH DUKE ENERGY a PROPERTY BOUNDARY ODEL DOMAIN Notes: 1. Ng/L = micrograms per liter 2. Arsenic 2L Standard = 10 pg/L 3. Arsenic PPBC = 2.3 Ng/L N A 0 500 1,000 Feet Figure 36 Existing Conditions Scenario 1 - 2115 Predicted Arsenic in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin f LEGEND <= 2.3 (Background g 'Concentration) 2.3 - 10 (Standard) 10-25 25 - 50 rc 8 50 -100 100- 150 150 - 205 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ — BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes: 1. pg/L = micrograms per liter 2. Arsenic 2L Standard = 10 pg/L 3. Arsenic PPBC = 2.3 pg/L I I I I I I I P e N A 0 500 1,000 Feet Figure 37 Existing Conditions Scenario 1 - 2115 Predicted Arsenic in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin Figure 38 Cap -in -Place Scenario 2 - 2115 Predicted Arsenic in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND a = 2.3 (Background Concentration) 2.3 - 10 (Standard) 10-25 25 - 50 50 -100 100- 150 150 - 205 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE c BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes: 1. pg/L = micrograms per liter 2. Arsenic 2L Standard = 10 pg/L 3. Arsenic PPBC = 2.3 pg/L Nor A 0 500 1,000 monsoons Feet Figure 39 Cap -in -Place Scenario 2 - 2115 Predicted Arsenic in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin eli LEGEND <= 2.3 (Background g 'Concentration) 2.3 - 10 (Standard) 10-25 j 25 - 50 L 8 50 -100 100- 150 150 - 205 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ — BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes: / V 1. Ng/L = micrograms per liter 0 500 1,000 2. Arsenic 2L Standard = 10 pg/L 3. Arsenic PPBC = 2.3 pg/L Feet Figure 40 Cap -in -Place Scenario 2 - 2115 Predicted Arsenic in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin Predicted Barium Concentration at AB-22S 1 r, Existing Conditions 600.0 - Cap -in -Place 500.0 - Barium 2L J •..r 400.0 p 300.0 fC L 200.0 G 100.0 "'• U 0.0 C C C CDLn CD CD Ln 4 C Ln CDLn M O O rq rq N iV N N fV N N N Notes: 1. µg/L = micrograms per liter Time (Years) 2. Barium 2L Standard = 700 µg/L 3. Barium PPBC = 99 µg/L Figure 41 Predicted Barium in Monitoring Well AB-22S Predicted Barium Concentration at AB-26S :rr r 700.0 600.0 -Existing Conditions 500.0 Cap -in -Place Barium 2L 400.0 HIIIXr] 200.0 100.0 0.0 0 0 0 0 0 0 0 ai a) CD 0 0 0 Notes: r_� rti r i r i r i 1. µg#L = micrograms per liter 2. Barium 2L Standard = 700 µg/L 3. Barium PPBC = 99 µg/L Groundwater Flow and Transport Model Allen Steam Station Ash Basin 0 0 0 0 0 0 0 0 0 0 o � � r ram., r�.i r�.i rNi ri ry ri ri ri ri ri ry ri ri Time (Years) Figure 42 Predicted Barium in Monitoring Well AB-26S Groundwater Flow and Transport Model Allen Steam Station Ash Basin Predicted Barium Concentration at AB-32S 800.0 Existing Conditions 700.0 Cap -in -Place 600.0 — — Barium 2L I.71I1Xr] J 400.0 300.0 t0 L 200.0 Q 100.0 U Jxon= 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Ln rl- rn r-I m Ln r� a) r m Ln r- 01 r m Ln � M M a) 0 0 0 0 0 r rI r r r-I rU rU rI4 rU r rl r-I rU rV rV rU rV rV rU rU rU rU rU rU rU rU Notes: 1. µg/L = micrograms per liter Time (Years) 2. Barium 2L Standard = 700 µg/L 3. Barium PPBC= 99 µg/L Figure 43 Predicted Barium in Monitoring Well AB-32S Groundwater Flow and Transport Model Allen Steam Station Ash Basin ey I I u P P 4 _I LEGEND �= 99 (Background Concentration) 99 - 200 200 - 300 300 - 400 400 - 500 500 - 600 600 - 700 (Standard) DUKE ENERGY - PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY AI ASH BASIN COMPLIANCE N BOUNDARY ASH BASIN COMPLIANCE Notes: BOUNDARY COINCIDENT WITH DUKE ENERGY 1. pg/L = micrograms per liter PROPERTY BOUNDARY 2. Barium 2L Standard = 700 pg/L 0 500 1,000 3. Barium PPBC = 99 pg/L � MODEL DOMAIN Feet Figure 44 Initial (2015) Barium Concentrations in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin 11 11 1 I u I LEGEND — 99(Background Concentration) 99 - 200 200 - 300 300 - 400 400 - 500 500 - 600 600 - 700 (Standard) DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY AI ASH BASIN COMPLIANCE N BOUNDARY ASH BASIN COMPLIANCE Notes: BOUNDARY COINCIENERGY 1. /L = micrograms per liter WITH DUKE ENERGY ug 9 PROPERTY BOUNDARY 2. Barium 2L Standard = 700 Ng/L - - 0 500 1,000 3. Barium PPBC = 99 Ng/L MODEL DOMAIN _ y y Feet Figure 45 Initial (2015) Barium Concentrations in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 99 (Background Concentration) 99 - 200 200 - 300 300 - 400 400 - 500 500 - 600 600 - 700 (Standard) DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE c BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN 1` l 1. Ng/L = micrograms per liter�,{j 2. Barium 2L Standard = 700 pg/L 3. Barium PPBC = 99 pg/L N A 0 500 1,000 monsoons Feet Figure 46 Initial (2015) Barium Concentrations in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin l LEGEND — 99(Background Concentration) 99 - 200 200 - 300 300 - 400 400 - 500 500 - 600 600 - 700 (Standard) DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY _ ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE E BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1,000 Feet Figure 47 Existing Conditions Scenario 1 - 2115 Predicted Barium in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 99(Background Concentration) 99 - 200 200 - 300 300 - 400 400 - 500 500 - 600 600 - 700 (Standard) DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN 3. Barium PPBC = 99 Ng/L Feet Figure 48 Existing Conditions Scenario 1 - 2115 Predicted Barium in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin f LEGEND �= 99 (Background g Concentration) 99 - 200 200 - 300 f 300 - 400 IL 8 400 500 500 - 600 600 - 700 (Standard) DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes: 1. pg/L = micrograms per liter 2. Barium 2L Standard = 700 pg/L 3. Barium PPBC = 99 pg/L 0 r' Feet Figure 49 Existing Conditions Scenario 1 - 2115 Predicted Barium in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin ey I I u P P 4 _I LEGEND �= 99 (Background Concentration) 99 - 200 200 - 300 300 - 400 400 - 500 500 - 600 600 - 700 (Standard) DUKE ENERGY - PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY AI ASH BASIN COMPLIANCE N BOUNDARY ASH BASIN COMPLIANCE Notes: BOUNDARY COINCIDENT WITH DUKE ENERGY 1. Ng/L = micrograms per liter PROPERTY BOUNDARY 2. Barium 2L Standard = 700 pg/L 0 So0 1,000 3. Barium PPBC = 99 pg/L MODEL DOMAIN _ Feet Figure 50 Cap -in -Place Scenario 2 - 2115 Predicted Barium in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 99(Background Concentration) 99 - 200 200 - 300 300 - 400 400 - 500 500 - 600 600 - 700 (Standard) DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE c BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes: 1. pg/L = micrograms per liter 2. Barium 2L Standard = 700 Ng/L 3. Barium PPBC = 99 pg/L N A 0 S00 1,000 monsoons Feet Figure 51 Cap -in -Place Scenario 2 - 2115 Predicted Barium in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 99(Background Concentration) 99 - 200 200 - 300 300 - 400 400 - 500 500 - 600 600 - 700 (Standard) DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE c BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Figure 52 Cap -in -Place Scenario 2 - 2115 Predicted Barium in Bedrock Groundwater Zone Predicted Boron Concentration at AB-22S ►11IIXII 600.0 500.0 J 1 400.0 300.0 L 200.0 u 100.0 0.0 rl-C, C, C, C, CD Notes: � � � rU 1. µg/L = micrograms per liter 2. Boron 2L Standard = 700 µg/L 3. Boron PPBC = 50 µg/L Groundwater Flow and Transport Model Allen Steam Station Ash Basin Existing Conditions - Cap -in -Place Boron 2L T 0 0 0 0 0 0 0 0 CD CD CD CD Time (Years) Figure 53 Predicted Boron in Monitoring Well AB-22S 1,000.0 900.0 500.0 700.0 600.0 J 500.0 LI00.0 0 -1 300.0 L +j 200.0 c� c u 100.0 Predicted Boron Concentration at AB-26S 0 0 0 0 0 0 0 0 0 0 C) C) C) CD CO 0 CD C Notes: 1. µg/L = micrograms per liter Time (Years) 2. Boron 2L Standard = 700 µg/L 3. Boron PPBC = 50 µg/L Groundwater Flow and Transport Model Allen Steam Station Ash Basin Existing Conditions Cap -in -Place Boron 2L 0 0 0 0 0 0 0 � CO Ln nl PV N eV PV PV eV Figure 54 Predicted Boron in Monitoring Well AB-26S Predicted Boron Concentration at AB-32S 700.0 600.0 500.0 J 400.0 300.0 L C 200.0 0 100.0 0.0 0 0 0 0 Ln r- a) r-I rn rn a) 0 � ri Notes: 1. µg/L = micrograms per liter 2. Boron 2L Standard = 700 µg/L 3. Boron PPBC = 50 µg/L Groundwater Flow and Transport Model Allen Steam Station Ash Basin Existing Conditions - Cap -in -Place Boron 2L 0 0 0 0 0 0 0 0 0 0 0 0 0 m Ln rl- M �_I m Ln � a) r-I m Ln r- 0 0 0 0 rU rU rU rU rN rU ri ri ri rU ri ri rU ri rU ri rU Time (Years) Figure 55 Predicted Boron in Monitoring Well AB-32S Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 50(Background Concentration) 50 - 200 200 - 400 400 - 700 (Standard) 700- 1,500 1,500 - 2,500 2,500 - 3,044 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE c BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN e- Notes: 1. Ng/L = micrograms per liter 2. Boron 21- Standard = 700 pg/L 3. Boron PPBC = 50 Ng/L N A fl Sfl0 1,000 Feet Figure 56 Initial (2015) Boron Concentrations in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 50(Background Concentration) 50 - 200 200 - 400 400 - 700 (Standard) 700- 1,500 1,500 - 2,500 2,500 - 3,044 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE c BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN 1` t Notes: 1. pg/L = micrograms per liter 2. Boron 2L Standard = 700 pg/L 3. Boron PPBC = 50 pg/L N A 0 S00 1,000 monsoons Feet Figure 57 Initial (2015) Boron Concentrations in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 50 (Background Concentration) 50 - 200 200 - 400 400 - 700 (Standard) 700- 1,500 1,500-2,500 2,500 - 3,044 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WTH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAdN r Notes: 1. Ng/L = micrograms per liter 2. Boron 2L Standard = 700 Ng/L 3. Boron PPBC = 50 pg/L 1 N A 0 500 1,000 monsoons Feel Figure 58 Initial (2015) Boron Concentrations in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 50(Background Concentration) 50 - 200 200 - 400 400 - 700 (Standard) 700- 1,500 1,500 - 2,500 2,500 - 3,044 _ DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ — BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes: 1. pg/L = micrograms per liter 2. Boron 2L Standard = 700 pg/L 3. Boron PPBC = 50 ug/L r SLAKE' N A 0 500 1,000 Feet Figure 59 Existing Conditions Scenario 1 - 2115 Predicted Boron in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin 0 z 0 LEGEND / — 50(Background Concentration) 50 - 200 200 - 400 400 - 700 (Standard) 700- 1,500 1,500 - 2,500 2,500 - 3,044 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes: 1. pg/L = micrograms per liter 2. Boron 2L Standard = 700 pg/L 3. Boron PPBC = 50 ug/L r 7 . 1 N A 0 500 1,000 Feet Figure 60 Existing Conditions Scenario 1 - 2115 Predicted Boron in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin r LEGEND — 50(Background Concentration) 50 - 200 200 - 400 400 - 700 (Standard) 700- 1,500 1,500 - 2,500 2,500 - 3,044 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ — BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN } N ANotes: 1. Ng/L = micrograms per liter 0 500 1,000 2. Boron 2L Standard = 700 pg/L 3. Boron PPBC = 50 Ng/L Feet Figure 61 Existing Conditions Scenario 1 - 2115 Predicted Boron in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 50(Background Concentration) 50 - 200 200 - 400 400 - 700 (Standard) 700- 1,500 1,500 - 2,500 2,500 - 3,044 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE c BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN e- Notes: 1. pg/L = micrograms per liter 2. Boron 2L Standard = 700 pg/L 3. Boron PPBC = 50 Ng/L N A 0 S00 1,000 monsoons Feet Figure 62 Cap -in -Place Scenario 2 - 2115 Predicted Boron in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin M i LEGEND — 50 (Background hL Concentration) 50 - 200 200 - 400 400 - 700 (Standard) 700 - 1,500 1,500 - 2,500 2,500 - 3,044 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODELDOMAIN Notes: 1. Ng/L = micrograms per liter 2. Boron 2L Standard = 700 Ng/L 3. Boron PPBC = 50 Ng/L I 1 1 1 r 1 N A 0 500 1,000 Feet Figure 63 Cap -in -Place Scenario 2 - 2115 Predicted Boron in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 99(Background Concentration) 99 - 200 200 - 300 300 - 400 400 - 500 500 - 600 600 - 700 (Standard) DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE c BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Figure 64 Cap -in -Place Scenario 2 - 2115 Predicted Boron in Bedrock Groundwater Zone Predicted Chromium Concentration at AB-22S 14.0 a� 3 8.4 0 +� 6.4 c Existing Conditions r- 4.4 Cap -in -Place V 2.4 Chromium 2L 4.4 0 0 0 0 0 0 Ln a, rl- a7 r-� m Ln a, a7 0 0 0 rl r-I rl N N N Notes: 1. µg/L = micrograms per liter 2. Chromium 2L Standard = 10 µg/L 3. Chromium PPBC = 16 µg/L 0 0 0 0 0 0 0 0 0 0 0 � � � � � rri � N N N N N N N N N Time (Years) Figure 65 Predicted Chromium in Monitoring Well AB-22S Groundwater Flow and Transport Model Allen Steam Station Ash Basin 0 0 rU N N N Predicted Chromium Concentration at AB-26S 16.4 Groundwater Flow and Transport Model Allen Steam Station Ash Basin 14.4 12.4 14.4 8.4 0 L6.4 - Existing Conditions 4-1 4.4 Cap -in -Place U u 2.4 Chromium 2L 4.0 - 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Ln r- a) r-� m Ln r- a7 a7 a) 0 0 0 0 07 r-I m Ln r- a7 r-� m Ln rti 0 r-I r-� r-� r-� r-I rU rU rU rU Notes: �q ry ry rIIj ry ry r�j ry r�j ry r�j r�j ry r�j r�j 1. µg/L = micrograms per liter 2. Chromium 2L Standard = 10 µg/L Time (Years) 3. Chromium PPBC = 16 µg/L Figure 66 Predicted Chromium in Monitoring Well AB-26S Predicted Chromium Concentration at AB-32S 4-0 W 4.4 U Cap -in -Place r- U 2.4 Chromium 2L 4.4 a o o a o Ln 0) ai rn o 0 � ry rU Notes: 1. µg/L = micrograms per liter 2. Chromium 2L Standard = 10 µg/L 3. Chromium PPBC = 16 µg/L o a o o a o o a o 0 0 0 rM n - CrrIj rti ry rti rU rU rti rU rU rti Time (Years) Figure 67 Predicted Chromium in Monitoring Well AB-32S Groundwater Flow and Transport Model Allen Steam Station Ash Basin o a o m Ln rU rU rti rti rti rU Groundwater Flow and Transport Model Allen Steam Station Ash Basin R K a K N o o a x LEGEND — 10 (Standard) 10- 12 12 - 14 14 - 16 (Background Concentration) 16 - 18 0 O _ _ DUKE ENERGY a PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY 5 LANDFILL/ASH STORAGE AREA BOUNDARY u� w ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE w — BOUNDARY COINCIDENT o WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN r- Notes: 1. pg/L = micrograms per liter 2. Chromium 2L Standard = 10 pg/L 3. Chromium PPBC = 16 pg/L r I I 1 r� I 1 tt — — — — — — — — — — 1 \y N A 0 500 1,000 Feet Figure 68 Initial (2015) Chromium Concentrations in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 10 (Standard) 10 - 12 12 - 14 14 - 16 (Background Concentration) 16 - 18 18 - 19 - 19 - 19.6fi _ — DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT — — WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes: 1. pg/L = micrograms per liter 2. Chromium 2L Standard = 10 pg/L 3. Chromium PPBC = 16 Ng/L l I I I I I I I I I I \ \ r\ I i tt /� ♦y --———— — — — — ll N A 0 500 1,000 Feet Figure 69 Initial (2015) Chromium Concentrations in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin ow- R a a N 2 c LEGEND — 10 (Standard) 10 - 12 12 - 14 14 - 16 (Background Concentration) 16 - 18 21 - 118-19 9 - 19.66 C DUKE ENERGY a PROPERTY BOUNDARY g a ASH BASIN WASTE m BOUNDARY x N S LANDFILL/ASH STORAGE AREA BOUNDARY u� w ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE w — — BOUNDARY COINCIDENT o W9TH DUKE ENERGY a PROPERTY BOUNDARY MODEL DOMAIN V \1 /— Notes: 1. pg/L = micrograms per liter 2. Chromium 2L Standard = 10 pg/L 3. Chromium PPBC = 16 pg/L N A 0 500 1,000 Feet Figure 70 Initial (2015) Chromium Concentrations in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin ,1 i I 4 r 7 r I J I I I t r I = J I LEGEND — 10 (Standard) 10 - 12 12-14 ` (- �' 14 - 16 (Background Concentration) 6 8 a 16 - 18 i 18 - 19 y ISO 19 - 19.66 LAKE WYLE O DUKE ENERGY `< PROPERTY BOUNDARY ASH BASIN WASTE m BOUNDARY ' z s LANDFILLIASH STORAGE AREA BOUNDARY w w ASH BASIN COMPLIANCE ! BOUNDARY n 1 ASH BASIN COMPLIANCE BOUNDARY COINCIDENT Notes: WTH DUKE ENERGY 1. pg/L = micrograms per liter 0 500 1,000 Q PROPERTY BOUNDARY 2 Chromium 2L Standard T MODEL DOMAIN 3. Chromium PPBC = 16 pg/L Feet I Figure 71 Existing Conditions Scenario 1 - 2115 Predicted Chromium in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin �1 ! �1 1 1 �r � r I I I I I I I I I I = r 1 = r� - r LEGEND <- 10 (Standard) 10 - 12 12 - 14 14 - 16 (Background Concentration) r 8 — f a 16 - 18 i 18 - 19 y ISO 19 - 19.66 LAKE WYLE O DUKE ENERGY `< PROPERTY BOUNDARY ASH BASIN WASTE m BOUNDARY z s LANDFILLIASH STORAGE AREA BOUNDARY w w ASH BASIN COMPLIANCE ! BOUNDARY n 1 ASH BASIN COMPLIANCE BOUNDARY COINCIDENT NOteS: WITH DUKE ENERGY 1. pg/L = micrograms per liter 0 500 1,000 g PROPERTY BOUNDARY 2 Chromium 2L Standard T MODEL DOMAIN 3. Chromium PPBC = 16 pg/L Feet I Figure 72 Existing Conditions Scenario 1 - 2115 Predicted Chromium in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin �1 ! �1 1 1 zj- �i I I I I I I I I 1 1 I = r = r� - r LEGEND 1 - <- 10 (Standard) 10 - 12 w 12 - 14 l 14 - 16 (Background ' Concentration) r g _ 1 16 - 16 Q w � 18-19 y 19. 19.66 U OLAKE WYLE DUKE ENERGY - `< PROPERTY BOUNDARY ASH BASIN WASTE m BOUNDARY N 5 LANDFILLIASH STORAGE AREABOUNDARY w w ASH BASIN COMPLIANCE BOUNDARY n r ASH BASIN COMPLIANCE w BOUNDARY COINCIDENT Notes: WITH DUKE ENERGY 1. pg/L = micrograms per liter 0 500 1,000 e PROPERTY BOUNDARY 2. Chromium 2L Standard = 10 pg/L MODEL DOMAIN 3. Chromium PPBC = 16 pg/L Feet a Figure 73 Existing Conditions Scenario 1 - 2115 Predicted Chromium in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 10 (Standard) s 10- 12 12 - 14 14 - 16 (Background Concentration) 0 a a 16 - 18 i 18 - 19 y ISO 19 - 19.66 U O DUKE ENERGY `< PROPERTY BOUNDARY ASH BASIN WASTE m BOUNDARY z s UANDFILLIASH STORAGE a AREA BOUNDARY w ASH BASIN COMPLIANCE ! BOUNDARY 0 1 ASH BASIN COMPLIANCE BOUNDARY COINCIDENT o WITH DUKE ENERGY g PROPERTY BOUNDARY T MODEL DOMAIN I ffW Notes: 1. pg/L = micrograms per liter 2. Chromium 2L Standard = 10 pg/L 3. Chromium PPBC = 16 pg/L N k 0 500 1,000 Feet Figure 74 Cap -in -Place Scenario 2 - 2115 Predicted Chromium in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 10 (Standard) 10- 12 12 - 14 14 - 16 (Background Concentration) 16 - 18 18 - 19 _ 19 - 19.66 _ — DUKEENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN !— Notes: 1. pg/L = micrograms per liter 2. Chromium 2L Standard = 10 pg/L 3. Chromium PPBC = 16 pg/L �I I I I I I I I I 1 r I I 1 1 I i 1 tt / ♦y --———— — — — — ll N A 0 500 1,000 Feet Figure 75 Cap -in -Place Scenario 2 - 2115 Predicted Chromium in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin �1 ! �1 1 1 zj- �l I I I I I I I 1 I = r = r� - r LEGEND 1 - <- 10 (Standard) 10 - 12 w 12 - 14 14 - 16 (Background ' Concentration) r g _ 1 16 - 16 LAKE WYLE w � 18-19 y 19. 19.66 U O DUKEENERGY `< PROPERTY BOUNDARY ASH BASIN WASTE m BOUNDARY N 5 LANDFILLIASH STORAGE AREABOUNDARY w w ASH BASIN COMPLIANCE BOUNDARY n r ASH BASIN COMPLIANCE w BOUNDARY COINCIDENT a WITH DUKE ENERGY Notes: a PROPERTY BOUNDARY 1. pg/L = micrograms per liter 0 500 1,000 2. Chromium 2L Standard = 10 pg/L MODEL DOMAIN 3. Chromium PPBC = 16 pg/L Feet a Figure 76 Cap -in -Place Scenario 2 - 2115 Predicted Chromium in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin Predicted Hexavalent Chromium Concentration at AB-22S 2.0 1.8 — Existing Conditions 1.6 Cap -in -Place — Chromium VI DHHS HSL 1.4 1.2 J 1.0 0.8 O [C 0.6 L 0.4 V V 0.2 0.0 0 a a 0 0 o a o 0 o a o 0 0 a o 0 Ln rl- a7 07 07 r-� rn 0 0 Ln rl- C) 0 0 0 �4 m Ln rl- C) �4 m Ln rl- �q � � rU r l N N ri ri ri ri ri ri ri ri ri ri ri ri ri ri Notes: 1. µg/L = micrograms per liter 2. Hexavalent chromium DHHS HSL value = 0.07 µg/L Time (Years) 3. Hexavalent chromium PPBC= 0.05 µg/L Figure 77 Predicted Hexavalent Chromium in Monitoring Well AB-22S Groundwater Flow and Transport Model Allen Steam Station Ash Basin Predicted Hexavalent Chromium Concentration at AB-32S 2.0 1.8 1.6 1.4 1.2 J 1.0 0.8 0 0.6 0.4 0 V 0.2 00 — — — : — : : : — — rl r-I c-I N N N N N Notes: 1. µg/L = micrograms per liter 2. Hexavalent chromium DHHS HSL value = 0.07 µg/L 3. Hexavalent chromium PPBC= 0.05 µg/L Existing Conditions Cap -in -Place Chromium VI DHHS HSL I 0 O 0 0 O 0 O 0 rl r4 rl N N N N N N N N N N N N Time (Years) Figure 78 Predicted Hexavalent Chromium in Monitoring Well AB-32S Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND N � <=0.07 (Standard) 0.07 - 5 N 5-10 LL 10-15 8 15-25 i 25 - 35 35 - 43.02 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ — BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN °1 1 r V N Notes: A 1. Ng/L = micrograms per liter 0 500 1,000 2. Hexavalent chromium DHHS HSL value = 0.07 pg/L 3. Hexavalent chromium PPBC = 0.05 pg/L Feel Figure 79 Initial (2015) Hexavalent Chromium Concentrations in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin 1 u �a �r P LEGEND _ c=0.07 (Standard) 0.07 - 5 1 5-10 10 - 15 + �I 15-25 25 - 35 35 - 43,02 _ DUKE ENERGY �- PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY AI ASH BASIN COMPLIANCE N BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT Notes: WITH DUKE ENERGY 1. pg/L = micrograms per liter 0 500 1,000 PROPERTY BOUNDARY 2. Hexavalent chromium DHHS HSL value = 0.07 pg/L MODEL DOMAIN 3. Hexavalent chromium PPBC = 0.05 pg/L Feet Figure 80 Initial (2015) Hexavalent Chromium Concentrations in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin °1 1 1 1 ram!! rJ � f LEGEND — 0.07 (Standard) 0.07-5 5-10 10-15 15-25 25 - 35 35 - 43.02 — — DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN V N Notes: A 1. Ng/L = micrograms per liter 0 500 1,000 2. Hexavalent chromium DHHS HSL value = 0.07 pg/L 3. Hexavalent chromium PPBC = 0.05 Ng/L Feel Figure 81 Initial (2015) Hexavalent Chromium Concentrations in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin °1 1 1 1 ram!! rJ F LEGEND — 0.07 (Standard) 0.07-5 5-10 10-15 15-25 25 - 35 35 - 43.02 — — DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN V ■nN1 Notes: 1. pg/L = micrograms per liter 0 500 1,000 2. Hexavalent chromium DHHS HSL value = 0.07 pg/L NOMENEME::= 3. Hexavalent chromium PPBC = 0.05 pg/L Feel Figure 82 Existing Conditions Scenario 1 - 2115 Predicted Hexavalent Chromium in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin °1 1 ! 1 r LEGEND W S — 0.07 (standard) 0.07-5 N 5-10 U 10-15 rc 8 15-25 i 25 - 35 35 - 43.02 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ — BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN i I I I I I I I J r N Notes: A 1. Ng/L = micrograms per liter 0 500 1,000 2. Hexavalent chromium DHHS HSL value = 0.07 Ng/L MONEENNE::= 3. Hexavalent chromium PPBC = 0.05 pg/L Feel Figure 83 Existing Conditions Scenario 1 - 2115 Predicted Hexavalent Chromium in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin °1 1 1 1 ram!! rJ � f LEGEND — 0.07 (Standard) 0.07-5 5-10 10-15 15-25 25 - 35 35 - 43.02 — — DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN V JjN�1 Notes: 1. pg/L = micrograms per liter 0 500 1,000 2. Hexavalent chromium DHHS HSL value = 0.07 Ng/L NOMENEME::= 3. Hexavalent chromium PPBC = 0.05 pg/L Feel Figure 84 Existing Conditions Scenario 1 - 2115 Predicted Hexavalent Chromium in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin °1 1 1 1 ram!! rJ F LEGEND S � <=0.07 (Standard) 0.07 - 5 N 5-10 U 10-15 rc 8 15-25 i 25 - 35 35 - 43.02 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ — BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN V • � N Notes: A 1. pg/L = micrograms per liter fl 500 1,000 2. Hexavalent chromium DHHS HSL value = 0.07 pg/L 3. Hexavalent chromium PPBC = 0.05 Ng/L io Feet Figure 85 Cap -in -Place Scenario 2 - 2115 Predicted Hexavalent Chromium in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin Figure 86 Cap -in -Place Scenario 2 - 2115 Predicted Hexavalent Chromium in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin 11 4 r a I I I I r i 0 a I _ 1 LEGEND — 0.07 (Standard) 0.07-5 ' yf I IJ 5-10 o r e 10-15 15-25 25 - 35 35 - 43.02 1t� — — DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY - LANDFILLIASH STORAGE AREA BOUNDARY _ ASH BASIN COMPLIANCE N BOUNDARY ASH BASIN COMPLIANCE "_ N _ BOUNDARY COINCIDENT Notes: E WITH DUKE ENERGY 1. pg/L = micrograms per liter fl 500 1,000 PROPERTY BOUNDARY 2. Hexavalent chromium DHHS HSL value = 0.07 pg/L � MODEL DOMAIN 3. Hexavalent chromium PPBC = 0.05 pg/L Feel Figure 87 Cap -in -Place Scenario 2 - 2115 Predicted Hexavalent Chromium in Bedrock Groundwater Zone Predicted Cobalt Concentration at AB-22S 12.0 10.0 :1 J 1 6.0 0 4.0 L 2.0 0 U 0.0 O O O Ln rl- 61 ff1 ff1 ff1 Notes: 1. µg/L = micrograms per liter 2. Cobalt IMAC value = 1 µg/L 3. Cobalt PPBC = 0.74 µg/L Groundwater Flow and Transport Model Allen Steam Station Ash Basin O O O O O O O Q O O O O O O O 0 O O r-I r-I r-I r-I r-I nl N N N N N N N N N N N N N N N Time (Years) Figure 88 Predicted Cobalt in Monitoring Well AB-22S ons C r- N N Predicted Cobalt Concentration at AB-26S 12.0 10.0 W J 1 6.0 0 4-1 4.0 L 4-1 2.0 0 U Groundwater Flow and Transport Model Allen Steam Station Ash Basin ions 0.0 -h Ln (l- al r-I rn Ln r- 61 ri rn Ln rI% a) r-I rn Ln (I% a) a) 61 O O 0 O 0 ri ri r-I r-I ri N N N N r-I r-I r-I N N N N N N N N N N N N N N Notes: 1. µg/L = micrograms per liter 2. Cobalt IMAC value = 1 µg/L Time (Years) 3. Cobalt PPBC = 0.74 µg/L Figure 89 Predicted Cobalt in Monitoring Well AB-26S Predicted Cobalt Concentration at AB-32S 25.0 20.0 15.0 Groundwater Flow and Transport Model Allen Steam Station Ash Basin Existing Conditions Cap -in -Place Cobalt IMAC 0.4 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Ln rl- ¢, r-q m Ln rl- C) r- m Ln rl- al ri rn Ln rl- 61 61 a) O O 0 O 0 r-I r- r-I r-I r-I N N N N r-I r-I r- N N N N N N N N N N N N N N Notes: 1. µg/L = micrograms per liter Time (Years) 2. Cobalt IMAC value = 1 µg/L 3. Cobalt PPBC = 0.74 µg/L Figure 90 Predicted Cobalt in Monitoring Well AB-32S Groundwater Flow and Transport Model Allen Steam Station Ash Basin M i i u I I I I I f 1 1 1 I LEGEND {background Concentration) 0.74 - 1 (Standard) 1-5 ^' 5-10 to- 15 15-20 20 - 22,84 DUKE ENERGY - PROPERTY BOUNDARY P ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY AI ASH BASIN COMPLIANCE N BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT Notes: WITH DUKE ENERGY 1. Ng/L = micrograms per liter I fl Sfl0 1,000 PROPERTY BOUNDARY 2. Cobalt IMAC value = 1 pg/L MODEL DOMAIN 3. Cobalt PPBC = 0.74 Ng/L Feet Figure 91 Initial (2015) Cobalt Concentrations in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin Figure 92 Initial (2015) Cobalt Concentrations in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 0.74 (Background Concentration) 0.74 - 1 (Standard) 1-5 5-10 10 - 15 15-20 20 - 22,84 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN -------A 4 N Notes: A 1. Ng/L =micrograms per liter 2. Cobalt IMAC value = 1 pg/L fl 500 1,000 3. Cobalt PPBC = 0.74 Ng/IL Feet Figure 93 Initial (2015) Cobalt Concentrations in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 0.74 (Background Concentration) 0.74 - 1 (Standard) 1-5 5-10 10 - 15 15-20 20 - 22.84 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN IF-'P'W� Notes: M- 1. pg/L = micrograms per liter 2. Cobalt [MAC value = 1 pg/L 3. Cobalt PPBC = 0.74 pg/L N A 0 500 1,000 Feet Figure 94 Existing Conditions Scenario 1 - 2115 Predicted Cobalt in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin 0 K LEGEND �= 0.74 (Background g Concentration) - 1 (Standard) 1-5 5-10 8 10-15 i 15-20 20 - 22.84 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN • `�' N Notes: 1. pg/L = micrograms per liter 0 500 1,000 2. Cobra value = 1 pg/L 3. Cobalt PPBC = 0.74 pg/L N, Feel Figure 95 Existing Conditions Scenario 1 - 2115 Predicted Cobalt in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin eli LEGEND �= 0.74 (Background g 'Concentration) 0.74 - 1 (Standard) 1-51 5 j 5-10 IL 8 10-15 15-20 20 - 22.84 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes: 1. pg/L = micrograms per liter 2. Cobalt IMAC value = 1 Ng/L 3. Cobalt PPBC = 0.74 pg/L I I I I I I I Feet Figure 96 Existing Conditions Scenario 1 - 2115 Predicted Cobalt in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 0.74 (Background Concentration) 0.74 - 1 (Standard) 1-5 5-10 10 - 15 15-20 20 - 22,84 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE c BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN 4 Notes: 1. Ng/L = micrograms per liter 2. Cobalt IMAC value = 1 Ng/L 3. Cobalt PPBC = 0.74 Ng/L N A 0 500 1,000 monsoons Feet Figure 97 Cap -in -Place Scenario 2 - 2115 Predicted Cobalt in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 0.74 (Background Concentration) 0.74 - 1 (Standard) 1-5 5-10 10 - 15 15-20 20 - 22,84 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE c BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN 1` t 4 Notes: 1. Ng/L = micrograms per liter 2. Cobalt IMAC value = 1 pg/L 3. Cobalt PPBC = 0.74 Ng/L N A 0 S0o 1,000 Feet Figure 98 Cap -in -Place Scenario 2 - 2115 Predicted Cobalt in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin 1` 1 II u p u I I I I I LEGEND — 0.74 (Background Concentration) 0.74 - 1 (Standard) 1-5 ^' 5-10 d 10 - 15 15-20 20 - 22,84 DUKE ENERGY - PROPERTY BOUNDARY P ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY AI ASH BASIN COMPLIANCE N BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT Notes: 3 _. w17H DUKE ENERGY 1. Ng/L = micrograms per liter I fl Sfl0 1,000 PROPERTY BOUNDARY 2, Cobalt IMAC value = 1 pg/L MODEL DOMAIN 3. Cobalt PPBC = 0.74 Ng/L Feet Figure 99 Cap -in -Place Scenario 2 - 2115 Predicted Cobalt in Bedrock Groundwater Zone Predicted Selenium Concentration at AB-22S 25.0 20.0 .... 15.0 J 1 0 10.0 4-1 c 5.0 0 U 0.0 0 0 0 0 Ln rl- C, a, c, C) 0 Notes: r- r-� r-I rU 1. µg/L = micrograms per liter 2. Selenium 2L Standard = 20 µg/L 3. Selenium PPBC = 0.5. µg/L Groundwater Flow and Transport Model Allen Steam Station Ash Basin - Existing Conditions Cap -in -Place Selenium 2L 0 0 0 0 0 0 0 0 0 0 0 0 0 ro Ln � C, ro Ln � C, � ro Ln � 0 0 0 0 � � ry rti rU rti rU rU rV rV rU rV ri rV rU rnl rV rU rV Time (Years) Figure 100 Predicted Selenium in Monitoring Well AB-22S 25.0 Predicted Selenium Concentration at AB-26S Existing Conditions 20.0 -- Cap -in -Place Selenium 2L 15.0 J 1 10.0 L 4-J 5.0 0 U Groundwater Flow and Transport Model Allen Steam Station Ash Basin 0.0 -r- 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Ln rti a7 r-I m Ln r- a7 ri rm Ln r- a) r1 m Ln r% a) a) a7 O O 0 O O ri r-I r-I r-I ri nl N N N r-I r-I rl N N N N N N N N N N N N N N Notes: 1. µg/L = micrograms per liter Time (Years) 2. Selenium 2L Standard = 20 µg/L 3. Selenium PPBC = 0.5. µg/L Figure 101 Predicted Selenium in Monitoring Well AB-26S PA61f 20.0 15.0 c 10.0 0 L 5.0 ca c 0 V Groundwater Flow and Transport Model Allen Steam Station Ash Basin Predicted Selenium Concentration at AB-32S Existing Conditions Cap -in -Place Selenium 2L 0.0 0 o a o a a o a a o a a o a a a a Ln r- 07 r-I rn Ln r- rn r1 rn Ln � a) r1 rn Ln � a7 al 01 O 0 Q O O r-I r r-I r-I r fV N ftil N r-I ri r-I fV fV fV fV fV fV fV fV fV fV fV fV fV fV Notes: 1. µg/L = micrograms per liter 2. Selenium 2L Standard = 20 µg/L Time (Years) 3. Selenium PPBC = 0.5. µg/L Figure 102 Predicted Selenium in Monitoring Well AB-32S Groundwater Flow and Transport Model Allen Steam Station Ash Basin 1` 1 u I I I LEGEND I , {background Concentration) 0.70 - 2 2-4 4-6 6-8 8-12 12 - 20 (Standard) DUKE ENERGY - - PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLMSH STORAGE AREA BOUNDARY AI ASH BASIN COMPLIANCE N BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT Notes: WITH DUKE ENERGY 1. pg/L = micrograms per liter0 500 1,000 PROPERTY BOUNDARY 2. Selenium 2L Standard = 20 pg/L 3. Selenium PPBC = 0.5. pg/L MODEL DOMAIN Feet Figure 103 Initial (2015) Selenium Concentrations in The Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin I �1 I� u _ I 1 LEGEND I , {background Concentration) 0.70 - 2 2-4 4-6 -- — — — � 6-8 8-12 12 - 20 (Standard) DUKE ENERGY - - PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY AI ASH BASIN COMPLIANCE N BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT Notes: _ WITH DUKE ENERGY PROPERTY BOUNDARY 1. =micrograms per liter 0 500 1,000 Selenium 2. Selenium 2L Standard = 20 Ng/L � MODEL DOMAIN 3. Selenium PPBC = 0.5. ug/L Feet Figure 104 Initial (2015) Selenium Concentrations in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin uJAL _ I I 1 LEGEND I , �= 0.70 {background Concentration) 0.70 - 2 2-4 4-6 -- — — — � 6-8 8-12 12 - 20 (Standard) DUKE ENERGY - - PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY AI ASH BASIN COMPLIANCE N BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT Notes: WITH DUKE ENERGY 1. pg/L = micrograms per liter 0 500 1,000 PROPERTY BOUNDARY 2. Selenium 2L Standard = 20 Ng/L MODEL DOMAIN 3. Selenium PPBC = 0.5. pg/L Feet Figure 105 Initial (2015) Selenium Concentrations in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin a. N 2 O N 2 W N E LEGEND <= 0.70 (Background s Concentration) 0.70 - 2 N W W 2-4 LL' 4-6 6-8 8-12 12 - 20 (Standard) _ DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY _ ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ E BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes:' 1. pg/L = micrograms per liter 2. Selenium 21 Standard = 20 pg/L 3. Selenium PPBC = 0.5. Ng/L N A 0 500 1,000 Feet Figure 106 Existing Conditions Scenario 1 - 2115 Predicted Selenium in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND �= 0.70 (Background g Concentration) 0.70 - 2 F 2-4 rc 4-6 8 6-8 8-12 12 - 20 (Standard) DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N r es:'g/L= micrograms per liter 0 500 1,000 elenium 2L Standard = 20 Ng/Lelenium PPBC = 0.5. Ng/L Feet Figure 107 Existing Conditions Scenario 1 - 2115 Predicted Selenium in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND �= 0.70 (Background g Concentration) 0.70 - 2 2 a j 4-fi IL 8 8-12 12 - 20 (Standard) DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes: 1. pg/L = micrograms per liter 2. Selenium 2L Standard = 20 pg/L 3. Selenium PPBC = 0.5. pg/L N A 0 500 1,000 Feet Figure 108 Existing Conditions Scenario 1 - 2115 Predicted Selenium in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND �= 0.70 (Background g Concentration) 0.70 - 2 2 a j � 4-fi IL 6-8 8-12 12 - 20 (Standard) DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN sIgo Notes: 1. pg/L = micrograms per liter 2. Selenium 2L Standard = 20 pg/L 3. Selenium PPBC = 0.5. pg/L no N A 0 500 1,000 Feet Figure 109 Cap -in -Place Scenario 2 - 2115 Predicted Selenium in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin 11 11 4 u I I I 1 LEGEND I , {background Concentration) 0.70 - 2 2-4 4-6 -- — — — � 6-8 8-12 12 - 20 (Standard) DUKE ENERGY - PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY AI ASH BASIN COMPLIANCE N BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT Notes: WITH DUKE ENERGY 1. pg/L = micrograms per liter I 0 500 1,000 PROPERTY BOUNDARY 2. Selenium 2L Standard = 20 Ng/L- MODEL DOMAIN 3. Selenium PPBC = 0.5. Ng/L Feet Figure 110 Cap -in -Place Scenario 2 - 2115 Predicted Selenium in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin eli LEGEND �= 0.70 (Background g Concentration) 0.70 - 2 2 a j � 4-fi IL 6-8 8-12 12 - 20 (Standard) DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN sIgo • `�' N T crograms per liter 0 500 1,000 2L Standard = 20 pg/L PPBC = 0.5. ug/L Feet Figure 111 Cap -in -Place Scenario 2 - 2115 Predicted Selenium in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin Predicted Sulfate Concentration at A13-22S 300,000 250,000 200,000 i Existing Conditions J Cap -in -Place 150,000 Sulfate 2L r- 0 -J 100,000 L 4-J i..i 50,000 U 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Ln rti rn r1 rm Ln r- a) ri rn Ln r- rn r m Ln r� a) M 61 0 0 0 0 0 ri r-1 ri ri r-1 N N N N Notes: r- ci r1 N N N N N N N N N N N N N N 1. µg/L = micrograms per liter 2. Sulfate 2L Standard = 2500000 µg/L Time (Years) 3. Sulfate PPBC = 30,300 µg/L Figure 112 Predicted Sulfate In Monitoring Well AB-22S Predicted Sulfate Concentration at A13-26S 300,000 250,000 200,000 J 1 150,000 C 0 4- 100,000 L 4-J i..i C 50,000 U 0 0 0 0 0 Ln r- a) r-1 a) rn a) 0 r r-1 r rV Notes: 1. µg/L = micrograms per liter 2. Sulfate 2L Standard = 250,000 µg/L 3. Sulfate PPBC = 30,300 µg/L Groundwater Flow and Transport Model Allen Steam Station Ash Basin 0 0 0 0 0 0 0 0 0 0 0 0 0 m Ln rl- rn T.-I m Ln r- a) r1 m Ln rti 0 0 0 a r1 r rl rl r rV rU rV rU ri rV rV rV rV rV rV rV rV rV rV rV rV Time (Years) Figure 113 Predicted Sulfate In Monitoring Well AB-26S 300,000.0 250,000.0 200,000.0 J 150,000.0 c 0 100,000.0 L G50,000.0 U Groundwater Flow and Transport Model Allen Steam Station Ash Basin Predicted Sulfate Concentration at A13-32S Existing Conditions Cap -in -Place �Sulfate 2L O O O O O O O O O O O O O O O O O Ln r- 0) r-� m Ln � 0) r-� m Ln r� rn r-1 m Ln r- 61 61 61 O O O O O rl c- rl c- c- N N N N Notes: 1. µg/L = micrograms per liter Time (Years) 2. Sulfate 2L Standard = 250,000 µg/L 3. Sulfate PPBC = 30,300 µg/L Figure 114 Predicted Sulfate In Monitoring Well AB-32S Groundwater Flow and Transport Model Allen Steam Station Ash Basin 11 1, I l I u I I I I I — � s 6 r �I LEGEND �= 30,300 (Background Concentration) 30,300 - 50,000 50,000 - 100,000 100,000 - 200,000 200,000 - 250,000 250,000 - 300,000 300,000 - 336,186 _ DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY AI ASH BASIN COMPLIANCE N BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT Notes: WITH DUKE ENERGY 1. pg/L = micrograms per liter I fl Sfl0 1,000 PROPERTY BOUNDARY 2. Sulfate 2L Standard = 250,000 pg/L MODEL DOMAIN 3. Sulfate PPBC = 30,300 pg/L Feet Figure 115 Initial (2015) Sulfate Concentrations in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin 1� I� ' _ I u I I I I I I I LEGEND �= 30,300 (Background Concentration) 30,300 - 50,000 50,000 - 100,000 100,000 - 200,000 200,000 - 250,000 250,000 - 300,000 300,000 - 336,186 _ DUKE ENERGY - PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY AI ASH BASIN COMPLIANCE N BOUNDARY ASH BASIN COMPLIANCE BOUNDARY OOINCIDENT Notes: WITH DUKE ENERGY 1. Ng/L = micrograms per liter .'1 0 500 1,000 PROPERTY BOUNDARY 2. Sulfate 2L Standard = 250,000 pg/L MODEL DOMAIN 3_ Sulfate PPBC = 30,300 Ng/L Feet Figure 116 Initial (2015) Sulfate Concentrations in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin �1 I _ I u I I I I a l r,. I LEGEND �= 30,300 (Background Concentration) 30,300 - 50,000 50,000 - 100,000 100,000 - 200,000 200,000 - 250,000 250,000 - 300,000 300,000 - 336,186 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY _ ASH BASIN COMPLIANCE N BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT Notes: WTH DUKE ENERGY 1. pg/L = micrograms per liter I fl Sfl0 1,000 PROPERTY BOUNDARY 2. Sulfate 2L Standard = 250,000 pg/L MODEL DOMAIN 3. Sulfate PPBC = 30,300 pg/L Feet Figure 117 Initial (2015) Sulfate Concentrations in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin J' I u I � I I I I I 1 � � I r I LEGEND \ — 30,300(Background Concentration) ' 30,300 - 50,D00 +�-- 50,000 - 100,000 100,000 - 200,000 200,000 - 250,000 �I - 250,000 - 300,000 s 300,000 - 336,186 DUKE ENERGY p . •�, PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE _ AREA BOUNDARY ASH BASIN COMPLIANCES AN BOUNDARY J, ASH BASIN COMPLIANCEN1 _ BOUNDARY COINCIDENT Notes: WITH DUKE ENERGY 1. pg/L =micrograms per liter 0 500 1,000 PROPERTY BOUNDARY 2. Sulfate 2L Standard = 250,000 pg/L 3. Sulfate PPBC = 30,300 pg/L � MODEL DOMAIN Feel Figure 118 Existing Conditions Scenario 1 - 2115 Predicted Sulfate in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin I I I I I I I r I LEGEND �= 30,300 (Background Concentration) 30,300 - 50,D00 ' 50,000 - 100,000 100,000 - 200,000 200,000 - 250,000 250,000 - 300,000 s 300,000 - 336,186 - f DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY - LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE AN BOUNDARY J, ASH BASIN COMPLIANCEN1 _ BOUNDARY COINCIDENT Notes: WITH DUKE ENERGY 1. pg/L = micrograms per liter 0 500 1,000 PROPERTY BOUNDARY 2. Sulfate 2L Standard = 250,000 pg/L MODEL DOMAIN 3. Sulfate PPBC = 30,300 Ng/L Feel Figure 119 Existing Conditions Scenario 1 - 2115 Predicted Sulfate in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 30,300 (Background Concentration) 30,300 - 50,D00 50,000 - 100,000 100,000 - 200,000 200,000 - 250,000 250,000 - 300,000 300,000 - 336,186 y DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN ,W Notes: 1. pg/L = micrograms per liter 2. Sulfate 2L Standard = 250,000 Ng/L 3. Sulfate PPBC = 30,300 pg/L I I I I I I I I 4 f I r lLAKE' A N A 0 500 1,000 Feet Figure 120 Existing Conditions Scenario 1 - 2115 Predicted Sulfate in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 30,300 (Background Concentration) 30,300 - 50,D00 50,000 - 100,000 100,000 - 200,000 200,000 - 250,000 250,000 - 300,000 300,000 - 336,186 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN v N Notes:' A 1. Ng/L = micrograms per liter 0 500 1,000 2. Sulfate 2L Standard = 250,000 Ng/L 3. Sulfate PPBC = 30,300 pg/L Feet Figure 121 Cap -in -Place Scenario 2 - 2115 Predicted Sulfate in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 30,300 (Background Concentration) 30,300 - 50,000 50,000 - 100,000 100,000 - 200,000 200,000 - 250,000 250,000 - 300,000 300,000 - 336,186 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY _ ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes: 1. ug/L = micrograms per liter 2. Sulfate 2L Standard = 250,000 pg/L 3. Sulfate PPBC = 30,300 pg/L N A 0 500 1,000 monsoons Feet Figure 122 Cap -in -Place Scenario 2 - 2115 Predicted Sulfate in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND — 30,300 (Background Concentration) 30,300 - 50,D00 50,000 - 100,000 100,000 - 200,000 200,000 - 250,000 250,000 - 300,000 300,000 - 336,186 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes: 1. pg/L = micrograms per liter 2. Sulfate 2L Standard = 250,000 pg/L 3. Sulfate PPBC = 30,300 pg/L Feet Figure 123 Cap -in -Place Scenario 2 - 2115 Predicted Sulfate in Bedrock Groundwater Zone Predicted Vanadium Concentration at AB-22S J c 0 L U r- 0 U 25.0 20.0 15.0 10.0 5.0 0.0 0 0 0 Ln r- a) 61 61 61 Notes: r-� r-1 r-� 1. µg/L = micrograms per liter 2. Vanadium IMAC value = 0.3 µg/L 3. Vanadium PPBC = 22.5 µg/L 0 0 0 0 0 0 0 0 0 0 ni ni r i ni ni Groundwater Flow and Transport Model Allen Steam Station Ash Basin Existing Conditions Cap -in -Place Vanadium IMAC 0 0 0 0 0 0 0 0 0 r-I � - r-1 r-1 ' r-rJ rV rV rV ri ri ri ri ri ri ri ri ri Time (Years) Figure 124 Predicted Vanadium In Monitoring Well AB-22S 30.0 25.0 20.0 J 1 15.0 s` 0 4-1 10.0 L a 5.0 U Groundwater Flow and Transport Model Allen Steam Station Ash Basin Predicted Vanadium Concentration at AB-26S Existing Conditions Cap -in -Place Vanadium IMAC 0.0 - 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Ln r� a) r-q m Ln rl- a) r-q m Ln r� M rn Ln r� a, a) a, o 0 0 0 0 r-q r-q r-q r rU r., rti r., rl rl rl rU N rV rV nl rU rV nl rU rV rV rV rU rV Notes: 1. µg/L = micrograms per liter Time (Years) 2. Vanadium IMAC value = 0.3 µg/L 'I lfanarlii im PPRf = ?? S i iQfl Figure 125 Predicted Vanadium In Monitoring Well AB-26S 25.0 PDXII 15.0 J 10.0 L 5.0 c U Predicted Vanadium Concentration at AB-325 0 0 0 0 Ln r- a) r-1 r-I r-I r-I N Notes: 1. µg/L = micrograms per liter 2. Vanadium IMAC value = 0.3 µg/L 3. Vanadium PPBC = 22.5 µg/L Groundwater Flow and Transport Model Allen Steam Station Ash Basin Existing Conditions Cap -in -Place Vanadium IMAC — — — r-W 0 0 0 0 0 0 0 0 0 0 0 0 0 m Ln r- rn r-� m Ln r- a) r1 m Ln rti 0 0 0 0 r r rl rl r rU rU r.l r.l ry rU ry rN rU rU rU ry rU rti ry rU rU Time (Years) Figure 126 Predicted Vanadium In Monitoring Well AB-32S Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND 7-1 c 0.3 (Standard) 030-5.0 5-10 10-15 15 - 22.5 (Background Concentration) 22.5 - 28 28 - 35.5 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE c BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes: 1. pg/L = micrograms per liter 2. Vanadium IMAC value = 0.3 Ng/L 3. Vanadium PPBC = 22.5 Ng/L N A 0 S00 1,000 monsoons Feet Figure 127 Initial (2015) Vanadium Concentrations in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin fJ LEGEND — 0.3 (standard) 03-5 5-10 10 - 15 15 - 22.5 (Backgroun Concentration) 22.5 - 28 28 - 35.5 DUKE ENERGY PROPERTY BOUNDAF ASH BASIN WASTE BOUNDARY LANDFILLlASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE c BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes: 1. Ng/L = micrograms per liter 2. Vanadium IMAC value = 0.3 Ng/L 3. Vanadium PPBC = 22.5 pg/L N A 0 500 1,000 Feet Figure 128 Initial (2015) Vanadium Concentrations in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin I / 1 r�l V p I I I I I 9 i I a� I r I LEGEND =0.3 (Standard) 0.3 - 5 + d 5-10 ` l" 10 - 15 15 - 22.5 (Background - Concentration) 22.5 - 28 - 28 - 35.5 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILUASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE N BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT Notes: WITH DUKE ENERGY 1. Ng/L = micrograms per liter - �'' I 0 500 1,D00 PROPERTY BOUNDARY 2. Vanadium IMAC value = 0.3 Ng/L MODEL DOMAIN 3. Vanadium PPBC = 22.5 Ng/L Feet Figure 129 Initial (2015) Vanadium Concentrations in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin I LEGEND —0.3 (Standard) 0.30 - 5.0 5-10 10 - 15 15 - 22.5 (Background Concentration) — 22.5 - 28 28 - 35.5 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT V14TH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes: 1. pg/L = micrograms per liter 2. Vanadium IMAC value = 0.3 pg/L 3. Vanadium PPBC = 22.5 Ng/L W N A 0 500 1,000 Feet Figure 130 Existing Conditions Scenario 1 - 2115 Predicted Vanadium in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin I LEGEND —0.3 (Standard) 0.30 - 5.0 5-10 10 - 15 15 - 22.5 (Background Concentration) — 22.5 - 28 28 - 35.5 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT V14TH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes: 1. Ng/L = micrograms per liter 2. Vanadium IMAC value = 0.3 Ng/L 3. Vanadium PPBC = 22.5 Ng/L W N A 0 500 1,000 Feet Figure 131 Existing Conditions Scenario 1 - 2115 Predicted Vanadium in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin 0 LEGEND —0.3 (Standard) 0.30 - 5.0 5-10 10 - 15 15 - 22.5 (Background Concentration) — 22.5 - 28 28 - 35.5 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT V14TH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes: 1. pg/L = micrograms per liter 2. Vanadium IMAC value = 0.3 Ng/L 3. Vanadium PPBC = 22.5 pg/L W N A 0 500 1,000 Feet Figure 132 Existing Conditions Scenario 1 - 2115 Predicted Vanadium in Bedrock Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND —0.3 (Standard) 0.30 - 5.0 5-10 10 - 15 15 - 22.5 (Background Concentration) 22.5 - 28 - 28 - 35.5 _ DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT V14TH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN C I I I I I I I I _ I Notes: 1. pg/L = micrograms per liter 2. Vanadium IMAC value = 0.3 Ng/L 3. Vanadium PPBC = 22.5 pg/L l 1 1 ra, I 4 N A 0 500 1,000 Feet Figure 133 Cap -in -Place Scenario 2 - 2115 Predicted Vanadium in Shallow Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin LEGEND —0.3 (Standard) 030-5.0 5-10 10 - 15 15 - 22.5 (Background Concentration) 22.5 - 28 28 - 35.5 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY _ ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE E BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Notes: 1. Ng/L = micrograms per liter 2. Vanadium IMAC value = 0.3 pg/L 3. Vanadium PPBC = 22.5 pg/L N A 0 500 1,000 Feet Figure 134 Cap -in -Place Scenario 2 - 2115 Predicted Vanadium in Deep Groundwater Zone Groundwater Flow and Transport Model Allen Steam Station Ash Basin I LEGEND —0.3 (Standard) 0.30 - 5.0 5-10 10 - 15 15 - 22.5 (Background Concentration) — 22.5 - 28 28 - 35.5 _ DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT V14TH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN °1 1 I 1 1 Notes: 1. Ng/L = micrograms per liter 2. Vanadium IMAC value = 0.3 Ng/L 3. Vanadium PPBC = 22.5 Ng/L M N A 0 500 1,000 Feet Figure 135 Cap -in -Place Scenario 2 - 2115 Predicted Vanadium in Bedrock Groundwater Zone