NC0004774_7. Buck Email Attachments_20160802

April 18, 2016
Via Electronic Mail
N.C. Division of Water Resources
Groundwater Protection Section
N.C. Department of Environmental Quality
Attn: Debra Watts
1636 Mail Service Center
Raleigh, NC 27699-1611
buckcomments (ancdenr. gov
Re: Comments on Buck Coal Ash Prioritization
Dear Ms. Watts:
The Yadkin Riverkeeper submits the following comments urging the Department
of Environmental Quality ("DEQ") to designate Duke Energy's Buck coal ash site as a
high priority in light of the serious risks that the Buck facility poses to nearby
groundwater and the Yadkin River. We will not reproduce the thorough technical and
legal analysis by the Southern Environmental Law Center and our experts. Instead, we
speak to the risks the site poses to our members.
For months now, I have been unable to clearly answer our members in the
Dukeville community when they ask why, if Buck was high risk for a majority of the
factors considered by regional staff, DEQ chose to bound it as a low to intermediate site.
Those residents have seen Duke drilling wells in recent months and have asked how a
final determination can be made when Duke has yet to gather data on almost the entire
southern side of the Buck site where many of their properties adjoin the coal ash ponds. l
would put the same question to DEQ.
I write on behalf not only of the Dukeville community members but for our
members throughout the Yadkin watershed and the state who have written to urge DEQ
to rank this as a high priority site. They wrote because Buck site also poses a high risk to
the Yadkin River and High Rock Lake. Nearly 300,000 people rely on drinking water
intakes downstream of the Buck coal ash pits. A natural -flowing stream -which
community members remember playing in before it was dammed -now runs directly
through the largest coal ash basin at Buck.

Seeps at Buck discharge over 70,000 gallons of water per day according to Duke
Energy's own reports, and these reports did not even consider all of the known seeps at
Buck. These seeps are contaminated with high levels of pollutants like chromium, boron,
aluminum, and lead. And Duke Energy's own reports conclude that pollutants such as
vanadium, hexavalent chromium, antimony, and cobalt will continue to discharge into the
Yakin River for the foreseeable future if the ash is capped in place. Finally, Duke Energy
has a long history of mistakes and spills at Buck, and cannot be trusted to properly
manage the ash in the leaking, unlined pits for eternity.
As the Yadkin Riverkeeper I have personally witnessed the groundwater seepage
flowing from the Buck site into the Yadkin. In November of 2014, Yadkin Riverkeeper
and Waterkeeper Alliance members took samples along the Yadkin riverbank from
nearly a quarter mile of orange, crusted, metallic seeps. Our members include lakeside
property owners, fishermen and hunters who frequent the Yadkin River and High Rock
lake in the vicinity of Buck Steam Station and the ongoing contamination has raised
concerns for people who have boated, hunted and fished this area their entire lives. We
have received numerous questions as to the safety of the fish in Buck and of the
possibility of a dam failure -clear illustrations that the threat Buck represents has a
chilling effect on community members ability to recreate on and enjoy the river and lake.
The dams at Buck are a serious threat to downstream communities. EPA and
DEQ have repeatedly found that the dams at Buck have a high or significant hazard
potential, and that dam failure could close significant economic loss and environmental
damage. Five million tons of ash is stored at Buck, far more than what was stored and
catastrophically released at Dan River. Duke Energy has known about dam safety issues
at Buck —including cracks, leaks, and structures that are "approaching the end of [their]
safe performance life" —for decades. Yet Duke Energy still has not fixed these problems.
DEQ must prioritize Buck as high risk based on the current poor conditions of these
dams, rather than banking on long -overdue repairs.
The public has overwhelmingly voiced their support for designating Buck a high
priority. DEQ must not disregard the public's demands and the dozens of high risk
factors at Buck by dismissing Buck as a low priority.
Regards,
Will Scott
Yadkin Riverkeeper

BLACKROCK
5102 Wrightsville Avenue
Wilmington, NC 28403
April 18, 2016
Via email buckcomments(uncdenr.gov
Attn: Ms. Debra Watts
RE: Public Comments for Prioritization Risk Classification
Buck Station
Dear Ms. Watts:
As a professional engineering firm with over fifteen years of practice in coal ash
management, Blackrock Engineers, Inc. ("BlackRock") designed and supervised
improvements for the first lined Ash Pond Closure for Carolina Power & Light beginning
in 2003. BlackRock is submitting the following independent public comments regarding
proposed classification of the subject facility for consideration by the North Carolina
Department of Environmental Quality (DEQ) in the proposed final risk classification.
1. State Law and Relevant Risk Factors.
We understand that DEQ is required to prioritize the subject facility according to the
North Carolina Coal Ash Management Act (the "Law") adopted in August 2014. The
criteria for classification (1 30A-209.21 1) include "any factor the Department deems
relevant to the establishment of risk." In our judgment, it is relevant that the U.S.
Environmental Protection Agency published a Final Rule for Disposal of Coal
Combustion Residuals (40 CFR Part 257,"CCR Rules") which became effective on
October 14, 2015. While the State Law was effective in compelling early assessment
activities, it is relevant that the compliance timeframes, remediation and closure
performance standards in the CCR Rules be considered in the current risk classification
process. For example, completion of the Closure Plan prepared by a professional
engineer is required for all CCR Ponds on or before October 17, 2016 which includes
the following CCR Rule performance demonstrations:
"the CCR unit must be closed in a manner that will control, minimize or
eliminate, to the maximum extent practicable, post -closure infiltration of liquids
into the waste and releases of CCR, leachate, or contaminated run-off to the
ground or surface waters."
"The CCR unit must be closed in a manner that will preclude the probability of
future impoundment of water, sediment, or slurry."

Public Comments for Prioritization Risk Classification
Page 2 of 3 April 18, 2016
iii. "The CCR unit must be closed in a manner that will provide for major slope
stability, which is discussed is Unit M.1 of this document for closure plans."
iv. "The CCR unit must be closed in a manner that will minimize the need for
further maintenance of the unit."
2. Remedial Action to Reduce Risk.
New technologies continue to emerge that can improve existing conditions and mitigate
circumstances. The CCR Rules were developed to apply a set of national standards for
closure of CCR impoundments and development of CCR landfills. Aside from the high
risk of sites that may be eroded by adjacent stream or flood flow, or other structural or
environmental conditions that cannot be effectively remediated, the CCR Rules provide
a process for reasonable assessment and remediation actions. Remedial and closure
activities planned and implemented by the owner to comply with the CCR Rules could
reduce the relevant risk factors. It stands to reason, if existing conditions can be
mitigated according to conditions and milestones established by DEQ in the final
classification, then a lower risk classification may be supported. Given that
amendments to the Law are needed to be consistent with the more recent and
comprehensive Federal CCR Rules, DEQ should use conditionally prioritize the risk
classifications in the same manner used to add conditions to permits to ensure
compliance with pertinent rules. By way of example, the CCR Rules require remedial
actions for in -place closure of CCR to meet the following performance requirements:
"(i) Free liquids must be eliminated by removing liquid wastes or solidifying the
remaining wastes and waste residues.
(ii) Remaining wastes must be stabilized sufficient to support the final cover
system."
3. Public Safety
The closure of the subject site by removal of all waste creates a risk to the workers on
the site. Typical existing conditions in an ash basin include soft, weak sluiced materials
that create an unstable working surface. To date, excavation and removal activities
have been limited to shallow basins approximately 20 to 30 feet deep. Requiring
removal from deeper basins will increase risk to worker safety and could result injuries
or fatalities. The removal of ash should be required only when the alternatives to in -
place remediation are not feasible or do not meet performance requirements.
For sites that demonstrate and are determined to be eligible for cap in -place closure,
stabilization of the remaining waste must be completed to ensure the long-term integrity
of the cap and all structures within the basin, including overfill landfills.
Leading through innovation, BlackRock has created new technologies for stabilizing the
remaining pond ash deposits and remediating existing site conditions. Appropriate and

Public Comments for Prioritization Risk Classification
Page 3 of 3
April 18, 2016
effective new methods and systems can be used to reduce existing risks and avoid the
new risks and massive public cost for removing millions of tons of waste. As described
in our comments, the current prioritization process should consider conditions for
effective use of technology for risk reduction as provided for by the Law and CCR
Rules.
Respectfully Submitted,
BlackRock Engineers, Inc.
i
Gary W. Ahlberg, P.E.
President

Re: Elected Leaders for Coal Ash Cleanup
Buck Steam Station
We, the undersigned elected officials, are concerned about the danger coal ash presents for our communities.
Coal ash is currently found in leaking, unlined pits across the state and contains a toxic slurry of heavy metals
that threaten nearby communities. We ask that state government leaders and state regulators take
appropriate action to require the removal of coal ash out of all unlined pits and into safer lined storage away
from our waterways. Please ensure that coal ash ponds and landfills do not put at risk the safety, health, and
economic well-being of downstream communities, receiving communities, and communities along
transportation routes.
Signed,
Jody Everhart, Spencer Mayor
Jim Gobbel, Spencer Mayor Pro -Tern
James Boone, Spencer City Council
Kevin Jones, Spencer City Council
Tonya Lanier, Spencer City Council
Arin Wilhelm, Granite Quarry City Council
Jim Lafevers, Granite Quarry Mayor Pro-Tem
L. Wayne Alley, Lexington Mayor Pro-Tem
Tobin H. Shepherd, Lexington City Council

North Carolina Division of Water Resources
Groundwater Protection Section,
N.C. Department of Environmental Quality
Attn: Debra Watts
1636 Mail Service Center
Raleigh, NC 27699-1611
Email: [e-mail]
To: NC Department of Environmental Quality
From: Chip and Billie Cole, Kernersville NC
Re: Comments on Duke Energy's leaking coal ash pits
I am writing to ask DEQto rank the Buck power plant coal ash as 'high priority' and make Duke Energy
move all of the coal ash there to safer dry, lined storage away from waterways. I understand that
capped storage is not acceptable and will not protect families from coal ash contamination.
The Dan River coal ash spill was a terrible event and should not be repeated. The same problems that
caused the Dan River spill, cracked, leaking and failing metal storm -water pipes, are now happening at
the Buck facility. For years, Duke Energy reported dumping tens of thousands of pounds of vanadium
and chromium into its coal ash ponds and the Buck facility. A spill here would be devastating to the
surrounding community and to the environment. Seeps and illegal discharges at the coal ash pits
continue to pollute the Yadkin River and even without a dam break, this will continue to be an accident
waiting to happen.
Please protect North Carolinian's drinking water and environment by ranking Buck as a 'high priority'
and moving all of its toxic coal ash to dry, lined storage away from our waterways. Do not allow capping
in place for this dangerous site!
Thank you for your action.
Charles W. (Chip) Cole and Billie H Cole
5660 Regents Park Road
Kernersville, NC 27284

RECEIVED
®tflce of fine Secretpty
7711 Lasater Road MAR 2 9 Z016
Clemmons, NC 27012
March 23, 2016 Dep°llmentofEnvlronment
and Naturai Resources
North Carolina Department Of Environmental Quality
Donald R. van der Vaart, Secretary
NCDEQ
1601 Mail Service Center
Raleigh, NC 27699-1601
Re: Coal Ash Pond Risk Classification- Buck Steam Plant- Official Comment
Dear Secretary van der Vaart,
Please accept this letter as my official comments for the Coal Ash Risk/Hazard Classification
record. I was unable to attend the recent Hearing so I am submitting these official comments
for the record. I and my family rely on clean water for drinking, cooking, bathing, boating,
swimming and other recreation. Unfortunately, we have lost our faith in the State Of North
Carolina's willingness and ability to protect our water. One case in point is groundwater,
surface water and river water at or near the coal ash ponds and down river from those ponds
throughout the state. From everything I have read and studied, the Buck Plant is clearly one
that needs to be classified no lower than Intermediate.
State health officials advised that it was not safe for health reasons to drink the water in many
of the wells tested near the Buck Steam Station due to the presence of harmful pollutants like
vanadium and the carcinogen hexavalent chromium. For one family's drinking water well near
the Buck site, the carcinogen hexavalent chromium levels detected are more than 300 times
higher than North Carolina's health -based standard. Boron, chromium, and other harmful
pollutants have been found in Duke's monitoring wells. All three coal ash ponds at the Buck
Plant have exceedances at or beyond the compliance boundary and there are several
exceedances of groundwater standards within 500 feet of a water supply well.
Duke Energy reported for years dumping tens of thousands of pounds of vanadium and
chromium into its unlined, leaking coal ash ponds at its Buck plant. And for years, those pits
have been discharging through numerous unpermitted flows, seeps, leaks, and channels,
including engineered discharges from the coal ash pits into the Yadkin River. Over 293,000
people rely on drinking water intakes downstream from coal ash pits at the Buck site.
about:blank
1 of 2 3/23/201611:11 AM

about:blank
Recently, DEQ identified no downgradient wells, but there are approximately 258 persons using
groundwater wells near Buck that are side gradient from the ash pits. Yet, DEQ has stated there
is insufficient modeling' for side gradient wells in the immediate vicinity of the impoundments.
To err on the side of caution, this should move the range on this key factor from low to
intermediate.
Additionally, DEQ has rated the dam safety classification as high, and makes the assumption that
after the repairs are made, the risk will be low. This is a faulty assumption that we have seen at
other sites in North Carolina and throughout the Southeast. Dam repairs, while implemented
with the best intentions, often fail to address fundamental issues with the dam. The ponds at
Buck were also rated high due to the fact that all three ponds sit below the'groundwater table,
and therefore will remain saturated unless excavated and lined.
Ponds at the Buck Steam Station should be classified as no lower than Intermediate. Our health
and well-being is at risk.
Sincerely,
1 I �
Gus Preschle
of 2 3/23/201611:11 AM

Julie Holder
8035 Changing Seasons Cir.
Fayetteville, NY 13066
[phone]
NC Division of Water Resources
Groundwater Protection Section
NC Department of Environmental Quality
Attn: Debra Watts
1636 Mail Service Center
Raleigh, NC 27699-161 1
Dear Ms. Watts:
The purpose of my letter is to strongly urge you to rank the Buck Power
Plant as a high priority and require that Duke Energy not just cap the coal
ash in place, but completely remove it to safer storage.
My family has lived on Leonard Road for many generations and their
health is now being compromised due to high levels of chemicals that are
leeching into their drinking water. It is my understanding that the levels of
the chemicals that have been deemed safe are far higher than what are
being reported in the drinking water of those families whose wells have
been affected. It is the state's responsibility to ensure that its residents
have safe and clean drinking water.
Merely capping the contaminants in place will guarantee that they stay in
place and they would continue to poison the drinking water. Removing
the ash is a safer alternative and can be used in other ways. "Coal ash is
commonly re -used in a number of ways. For example, it is used as
structural fill or fill for abandoned mines; as a top layer on unpaved roads;
as an ingredient in concrete, wallboard, and in school running tracks; as
an agricultural soil additive; and as "cinders" to be spread on snowy
roads." (southeastcoalash.org)
I am also insisting that a water line be run to the affected areas. I
understand that Duke Energy has been providing drinking water to those
who have been affected. I do not believe that this is something that will
continue for much longer. There are over 290,000 people who rely on
water in that area. The provided water is not only used for drinking.
Families are also using it for bathing and cooking. How much longer will
Duke Energy be willing to provide this water? It would be less expensive in

the long term to provide clean water to these families in the form of a
water line.
As it stands now, property values in the area have seen a dramatic
decline. Who wants to live in a house where you can't get a glass of
water from your sink without the water having an odor or discoloration?
Running the water line would not only provide clean water for your
constituents' use, but increase the property values as well. To take the
property value problem a step further, sales of homes in that area will
come to a halt if something isn't done soon to correct it.
Since graduating from NC State University, I have lived in Texas, Virginia,
and upstate New York. I used to be proud to tell people I am a native
North Carolinian. Now I'm ashamed as the state seemingly supports the
poisoning of its residents through contaminated drinking water.
I would love to be proud of my home state once again.
Sincerely,
Julie Holder

COAL ASH, RACE & CLASS IN NORTH CAROLINA
Libbie Weimer, MCRP
April 181h, 2016
The following document presents profiles of the fourteen coal ash sites and two permitted coal ash landfills in North Carolina. The report begins with summaries
of data collected across all sites. Then, the report details the sites. For each site, the report presents information about the residents within three study
distances— 1km, 3km and 5km from the edge of the pond or landfill. For each site and each study distance, the profile contains data on 1) demographics
including population and population density, race and ethnicity, and income; 2) cumulative impacts from other toxic facilities including number of facilities and
pounds of onsite toxic releases from those facilities. Each site profile summarizes this information in the final measure, 3) an environmental justice index score
that compares the 1 km, 3 km, and 5 km study level information to three regions: the state, the county, and the locality. The environmental justice index
incorporates impacts on low-income communities, communities of color and cumulative impacts into one score for each site.
For a more detailed explanation of the all methods used to create these profiles, please see the appendix. The accuracy of the results is limited by the data
available in the U.S Census. Due to racial and economic segregation, the report may overestimate or underestimate the impact of coal ash on communities of
color and/or low-income communities. While this problem exists with all small -area studies, unfortunately, the census is especially ill -suited for research
involving rural communities. The limitations of this analysis highlight the importance of ground-truthing the data by collaborating with members of the
communities profiled in this report.

REPORT SUMMARIES
A
Asheville
Dan River
y •Roxboro
8elews Creek A Mayo
Buck
Marshall Cape Fe � _4 Brickhaven
Riverbend Colon Mill
A Lee
Cliffside Alter
Weatherspoor
Legend Sutton
A Operational Coal Plants
Closed Coal Plants
0 40 80 160
Structural Fill Sites Miles
Figure 1. Locations of the fourteen coal ash ponds and two permitted coal ash landfill sites, with North Carolina county borders shown for reference.

POPULATION
Selews
Allen Asheville Creek
30K
25K
20K
10K
5K
OK
.
E
E
E E E
E
[rt1 U')
[r]
U3
Site Name ( Analysis Level
Suck Cape Fear Cliffs ide Ilan River Lee Marshall Mayo Riverbend Roxboro Sutton Weathers..
1000
900
^u00
700
600 �.
4D0
300
200
100
—��■ _ 0
E E E E E E E E E E E E E E E E E E
Y Y Y s Y Y Y Y Y Y Y Y Y Y Y Y Y Y

RACE/ETHNICITY
Site Name ! Analysis Level
Bel ews
Allen Asheville Creek Buck Cape Fear ClifFside Dan River Lee Marshall Mayo Riverbend Roxboro Sutton Weathers,.
0.6
0.2
0.0
0.4
0.3
1'
ST
m
0.2
0.9
0.0
0.3
Q
0.2
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0.0
NG State % Black
inD
MENNEN
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Site Name d Arralysis Level
Belem
Allen Asheville Creek Buck Ca e�Fear CliFlside Dan River Lee m shall Mayo Riverbend Roxboro Sutton Weathers-
St€a
INCOME
80
70K
as
E
60K
Sal(
40'K
30 K
20K
10K
teMedian Income
OK I I I I I I I 1 I 1111111111111 1"!
E E E E E E E G E E E G c E� c E E E E E E G E E E E E E E G G G G E_ E_ E_ G E E_ E_ G
Y Y Y s Y Y Y Y Y Y Y Y s1 Y - - Y - - - Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y
I ['T] Lh I M Lr) I n V) I n V3 r &y U-i I M Ui r rf] U9 I M Ln r n 03 1 n 03 1 n Ul I - Ui r n V3 r M Ln

BUCK STEAM STATION
DEMOGRAPHIC ANALYSIS
POPULATION Population Count
Site Name 1km 3km
Buck 550 1,542
Population Density
(people per sq. mL)
5km 1km 3km
6,273 98 163
5km
187
RACE/
% Non -white
% Black
% Latino
ETHNICITY
Site Name
1km 3km 5km
1km 3km
5km
1km
3km 5km
Buck
11.5% 12.8% 21.1%
6.4% 7.6%
14.8% 3.7%
4.0% 5.4%
INCOME
Median Income Estimate
Site Name
1km 3km
5km
Buck
$ 58,358 $ 55,880
$ 49,739
CUMULATIVE
IMPACTS
SITE NAME
REFERENCE COUNT(IES)
ONE OR MORE TRI
% OF COUNT(IES)'
% OF COUNT(IES)' TRI
(*ACTIVE COAL
SITES W/IN 5KM
TRI SITES W/IN
ONSITE RELEASES
PLANT)
BUFFER
5KM BUFFER
W/IN 5KM BUFFER
Buck
Davidson
N
4%
0%
Closest City: Spencer
Plant Status: Closed
Coal Ash Pond Acreage: 178
DEQ Site Prioritization: Low -to -Intermediate

ENVIRONMENTAL JUSTICE INDEX — BUCK
Indicator
Race/Ethnicity
Income
C
Reference
Census
Region
State
County
Census Tract
State
County
Tract
Demographic
Information
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0
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550
63 35 20
58,358
1 km
0
0
0
1,542
198 118 61
55,880
3 km
x x
x
x
x
5
0
5
6,273
1,325 930 339
49,739
5 km
MEAN
1.67

North Carolina League of SOO
CONSERVATION VOTERS
PO Box 12671
Raleigh, NC 27605
www.ncicv.org 1 919.839.0006
To: Debra Watts, NC Division of Water Resources, Groundwater
Protection Section, NC Department of Environmental Quality
From: Members of the NC League of Conservation Voters
Date: April 18, 2016
Re: Reclassify Buck Steam Station as "high risk"
Dear Ms. Watts:
We are writing to ask the NC Department of Environmental Quality to protect North
Carolina's clean water and communities from the dangers posed by arsenic, chromium
and other pollutants by re-classifying Buck Steam Station as "high risk."
The NCDEQ cited Duke Energy for broken, failing corrugated metal stormwater pipes at
Buck that are cracked and leaking, the same problem that caused the Dan River coal ash
spill in February 2014. Coal ash pits at the Buck facility are discharging through
numerous unpermitted flows, seeps, leaks, and channels, including engineered discharges
from the coal ash pits into the Yadkin River. This is unacceptable
For years, Duke Energy reported dumping tens of thousands of pounds of vanadium and
chromium into its unlined, leaking coal ash ponds at Buck. Boron, chromium, and other
harmful pollutants have all been found in Duke's own monitoring wells in levels that far
exceed the health -based standards. For example, chromium has been detected at 180%
above the standard.
We simply cannot allow any additional delay in moving the dangerous coal ash from its
current leaking, unlined ponds at Buck. Over 293,000 people rely on drinking water
intakes downstream — and they are relying on you to act now. Please reclassify the Buck
Steam Station as "high risk."
Signed,
89 NCLCV members

Full Name
ZIP
Steve Adams
27292-1822
kenneth anderson
27408
Jake Anderson
27106
Mona Borkowski
28146
T. Bradley
27103
Jennifer Brandon
27295
Janet Brown
27104
Denise Cameron
27313
Teri Capshaw
27104
Patrick Carney
28269
deb carr
27523
ISABEL CERVERA
28041
Sarah Charles
27265
Diane Clark
27235
Ronald Clayton
27203
Nina Cline-Ziolkowski
27284
Debbie Collins
28670
J. C. Cranford
27262
Rosemarie Davis
27409
Weldine Dossett
27403
Robin Dunn
27410
Lou East
27358
Colleen Farley
27408
Michael Felmet
27106-4787
karl fields
27401
Anthony Flores
27409
Sandra Forrest
28654-9755
Johnny Foust
27106
John Freeze
27205
Richard Fullerton
27103-5504
Kathleen Gale
28443
Sylvia Gaspar
27106
Jennifer Harris
27012
Amy Hartzog
27055
Allison Hassell
27408
Ruth Heath
27284
eunice heilig
27104
Nick Hood
27012
Beverly Hussein
27263

stan ignatovich
28270
Alison Inman
27407
aramati ishaya
27103
J. Jewell
27012
Kenneth Johns
28127
Anne Jones
27455
Tina Jones
25060
William Kastern
27317
Georgiann Kiricoples
27103
Denise Lee
28007
Amelia Long
27106
thomas lux
28676
mark march
27106
Samantha Martin
27401
Frederick Mayer
28443
Brandy Meadows
28405
Carol Moldoveanu
27106
Karen Nehlsen
27410
Susan Neorr
27455
Dale Nichols
27055
Faith Olson
27410
Ellen Osborne
27313
virginia palmer
27239
Elizabeth Parson
27317
Samuel Peck
27455
Joe Phillips
27235
Janice Phillips
27284
Katherine Pinyan
27357
Melanie Porter
28124-9570
Sandra Resner
27409
Shirley Rodman
27410
Marvin Scherl
27019
Marla Schexnider
27203
Richard Schmidt
27455
James Seramba
27284
Brad Smith
27403
Elizabeth Snyder-Baldonado
27107
Martha Spencer
28712
Paula Stober
27410
Carol Svatek
27239
Carol Thompson
27403

Katie Todd
27703
LUCY TYNDALL
27265
Jean Ulrich
27103
Brandon Van Every
27106
Rae Ann Walker
27284
Ronald Walters
27401
Mitchell Ward
27408
Ebony Welborn
27413
Jeaneane Williams
27410

National Ash Management Advisory Board
Dr. John L. Daniels, P.E. Dr. Jeffrey C. Evans, P.E. Dr. William E. Wolfe, P.E.
Chair Groundwater Subcommittee Chair Closure Plan Subcommittee Chair
Dr. Susan E. Burns, P.E., Member
Mr. Bob Deacy, Member
Dr. Garrick E. Louis, Member
Dr. Patricia D. Galloway, P.E.
Member and
Project Management Oversight Board Chair
Dr. Robert B. Jewell, Member
Dr. Lawrence L. Sutter, Member
Dr. Krishna R. Reddy, P.E., Member
Dr. Joyce S. Tsuji, DABT, Member
April 5, 2o16
Mr. Tom Reeder
Assistant Secretary
North Carolina Department of Environmental Quality
217 West Jones Street
Raleigh, NC 27603
RE: National Ash Management Advisory Board Comments on Proposed Risk Classifications
Dear Mr. Reeder,
This letter is written in response to the North Carolina Department of Environmental Quality's (DEO) request for
public comment on its proposed risk classifications of coal ash impoundments. Our comments are directed at
impoundments which have proposed classifications of low -intermediate, intermediate, and high, according to DEQ's
application of the Coal Ash Management Act (CAMA).
This letter has been compiled, reviewed and endorsed by the National Ash Management Advisory Board (NAMAB).
Note that Duke Energy is required to actively maintain the NAMAB for compliance with its Plea Agreement, as per
United States of America v. Duke Energy Business Services, LLC, and settlement in the United States District
Court for the Eastern District of North Carolina, Western Division. The NAMAB is an independent group of
experts chartered through Duke Energy and managed by the University of North Carolina at Charlotte (UNC
Charlotte). Board members provide advice to Duke Energy, but they are contracted with and report to UNC
Charlotte.
The NAMAB has been integrally involved in the review of groundwater assessment plans, comprehensive site
assessments, and corrective action plans, which have been submitted to DEQ Likewise, it has participated in the
review of stability and engineering related assessments and with the implementation of NAMAB-recommended
health and environmental assessments of risk. While licensed professionals are responsible for these work products,
the group is sufficiently aware of the site -specific conditions to which the CAMA risk classification criteria are being
applied. For example, licensed engineers and geologists, with support from health and environmental risk assessors,
have determined that there is no imminent hazard. Those same professionals have determined that existing
conditions at these sites do not present a substantial likelihood that death, serious illness, severe personal injury, or a
substantial endangerment to health, property, or the environment will occur.
In the abstract, a risk classification system is logical. In reality, DEQs risk classification cannot be de -coupled from
the prescriptive remedy approach defined by CAMA. A risk classification of intermediate or high (for instance high
priority as prescribed in the case of Asheville, Dan River, Riverbend and Sutton) by law requires excavation and re -
disposal to a new location without a scientific basis, and without consideration of broader immediate and life cycle
impacts to communities and the environment. Moreover, aggressive closure schedules preclude the pursuit of
beneficial use opportunities.

Excavation of coal ash is one method of addressing site's groundwater or stability concerns. However, based on
holistic and life cycle considerations, it may not be a safe, effective and sustainable alternative. Other alternatives
either individually or in combinations, such as capping, monitored natural attenuation, slurry cutoff walls, in -place
stabilization/fixation, pumping wells, permeable reactive barriers and volume reduction of impounded ash through
escalation of beneficial use, should be considered and compared on an impoundment by impoundment basis to
develop an effective, safe and sustainable remedial strategy. The efficacy of these alternative methods increases with
the amount of ash in any given location, i.e., the larger the impoundment, the smarter we need to be. The
environmental and geotechnical remediation business is very mature and has evolved beyond a "dig and haul"
mentality as the best and most environmentally protective solution.
The additional risk imposed by excavating and transporting ash from one location to another can exceed the potential
risk posed by leaving the ash in place. Risk drivers include the statistical certainty of traffic fatalities and injuries, as
tabulated by the National Highway Traffic Safety Administration. Likewise, excavation results in ecological
disturbance, ongoing site releases from ash disturbance for years and broader environmental impacts from resource
use and emissions, as noted by the U.S. Environmental Protection Agency (EPA). These risks and impacts should be
calculated and considered before embarking on the mass movement of tens of millions of tons of material.
Licensed engineers and scientists have the education and experience needed to select and design the means, methods
and timeline for closure activities. It may be appropriate for legislation to define the initiation of closure activities,
but it should not stipulate a prescriptive approach with specific completion dates. The latter depends on site -specific
details that are encountered as data are collected and professionally evaluated. This logic is understood by the
environmental professionals as well as the EPA in reference to its approach to evaluating corrective action:
"EPA understands that there are a variety of activities that may be necessary in order to select the appropriate remedy (e.g.,
discussions with affected citizens, state and local governments; conducting on -site studies or pilot projects); and, once selected, to
implement the remedy (e.g., securing on -site utilities if needed, obtaining any necessary permits, etc.). That is why EPA does not
find it appropriate to set specific timeframes for selecting the remedy or to begin implementing the selected remedy."
This logic was incorporated into CAMA, given the provision for the Coal Ash Management Commission (CAMC).
The CAMC existed to perform several tasks, one of which was to "Review and make recommendations on statutes and
rules related to the management of coal ash". That provision was intended to allow for a statutory response to evolving
data and analysis as has accumulated to date.
Unless the CAMA language for intermediate and high risk (and for that matter, for high priority sites) is changed,
the appropriate risk classification for virtually all impoundments is "Low". This is because a risk classification of
"Low" allows for all options to be considered, including full excavation, supported by the science and engineering and
protective of human health and the environment. This will allow DEQto review and approve a rational closure
option that is protective of the public and environment, based on site -specific conditions.
We would be pleased to meet with you or other DEQstaff at any time. Our board is composed of highly credentialed
and published experts with many years of experience on the relevant subjects from here and abroad. And we are
independent.
Respectfully,
Dr. John L. Daniels, P.E., Chair
(Professor and Chair of Civil and Environmental Engineering, UNC Charlotte)

Signed on behalf of entire NAMAB:
Dr. Jeffrey C. Evans, P.E., Groundwater Subcommittee Chair
(Professor and Chair of Mechanical Engineering, Bucknell University)
Dr. William E. Wolfe, P.E., Closure Plan Subcommittee Chair
(Professor Emeritus of Civil, Environmental and Geodetic Engineering, The Ohio State University)
Dr. Patricia D. Galloway, P.E., member and Project Management Oversight Board Chair
(President and CEO of Pegasus Global Holdings, Inc.)
Dr. Susan E. Burns, P.E., member
(Georgia Power Distinguished Professor of Civil and Environmental Engineering, Georgia Institute of Technology)
Dr. Robert B. Jewell, member
(Senior Research Engineer, University of Kentucky)
Dr. Lawrence L. Sutter, member
(Professor of Materials Science and Engineering, Michigan Technological University)
Dr. Garrick E. Louis, member
(Associate Professor of Systems Engineering, University of Virginia and Science Advisor, U.S. Department of State)
Mr. Bob Deacy, member
(Senior Vice President, Tennessee Valley Authority)
Dr. Krishna R. Reddy, P.E., member
(Professor of Civil and Environmental Engineering, University of Illinois at Chicago)
Dr. Joyce S. Tsuji, DABT, member
(Principal and Board -Certified Toxicologist, Exponent, Inc.)

April 18, 2016
Via Electronic Mail
N.C. Division of Water Resources
Groundwater Protection Section
N.C. Department of Environmental Quality
Attn: Debra Watts
1636 Mail Service Center
Raleigh, NC 27699-1611
buckcomments (ancdenr. gov
Re: Comments on Buck Coal Ash Prioritization
Dear Ms. Watts:
The Yadkin Riverkeeper submits the following comments urging the Department
of Environmental Quality ("DEQ") to designate Duke Energy's Buck coal ash site as a
high priority in light of the serious risks that the Buck facility poses to nearby
groundwater and the Yadkin River. We will not reproduce the thorough technical and
legal analysis by the Southern Environmental Law Center and our experts. Instead, we
speak to the risks the site poses to our members.
For months now, I have been unable to clearly answer our members in the
Dukeville community when they ask why, if Buck was high risk for a majority of the
factors considered by regional staff, DEQ chose to bound it as a low to intermediate site.
Those residents have seen Duke drilling wells in recent months and have asked how a
final determination can be made when Duke has yet to gather data on almost the entire
southern side of the Buck site where many of their properties adjoin the coal ash ponds. l
would put the same question to DEQ.
I write on behalf not only of the Dukeville community members but for our
members throughout the Yadkin watershed and the state who have written to urge DEQ
to rank this as a high priority site. They wrote because Buck site also poses a high risk to
the Yadkin River and High Rock Lake. Nearly 300,000 people rely on drinking water
intakes downstream of the Buck coal ash pits. A natural -flowing stream -which
community members remember playing in before it was dammed -now runs directly
through the largest coal ash basin at Buck.

Seeps at Buck discharge over 70,000 gallons of water per day according to Duke
Energy's own reports, and these reports did not even consider all of the known seeps at
Buck. These seeps are contaminated with high levels of pollutants like chromium, boron,
aluminum, and lead. And Duke Energy's own reports conclude that pollutants such as
vanadium, hexavalent chromium, antimony, and cobalt will continue to discharge into the
Yakin River for the foreseeable future if the ash is capped in place. Finally, Duke Energy
has a long history of mistakes and spills at Buck, and cannot be trusted to properly
manage the ash in the leaking, unlined pits for eternity.
As the Yadkin Riverkeeper I have personally witnessed the groundwater seepage
flowing from the Buck site into the Yadkin. In November of 2014, Yadkin Riverkeeper
and Waterkeeper Alliance members took samples along the Yadkin riverbank from
nearly a quarter mile of orange, crusted, metallic seeps. Our members include lakeside
property owners, fishermen and hunters who frequent the Yadkin River and High Rock
lake in the vicinity of Buck Steam Station and the ongoing contamination has raised
concerns for people who have boated, hunted and fished this area their entire lives. We
have received numerous questions as to the safety of the fish in Buck and of the
possibility of a dam failure -clear illustrations that the threat Buck represents has a
chilling effect on community members ability to recreate on and enjoy the river and lake.
The dams at Buck are a serious threat to downstream communities. EPA and
DEQ have repeatedly found that the dams at Buck have a high or significant hazard
potential, and that dam failure could close significant economic loss and environmental
damage. Five million tons of ash is stored at Buck, far more than what was stored and
catastrophically released at Dan River. Duke Energy has known about dam safety issues
at Buck —including cracks, leaks, and structures that are "approaching the end of [their]
safe performance life" —for decades. Yet Duke Energy still has not fixed these problems.
DEQ must prioritize Buck as high risk based on the current poor conditions of these
dams, rather than banking on long -overdue repairs.
The public has overwhelmingly voiced their support for designating Buck a high
priority. DEQ must not disregard the public's demands and the dozens of high risk
factors at Buck by dismissing Buck as a low priority.
Regards,
Will Scott
Yadkin Riverkeeper

Flqure 4. Numerical Model Boundary CondMo'ns
As stated by Groundwater Management Associates, "northward flow is required by their
model [Duke Energy's model] because a `no -flow' boundary encloses three -fourths of the model
domain on the west, south, and east."64 In some areas, this "no flow" boundary begins a mere
several hundred feet from Duke Energy's property boundary. Duke Energy cannot stop the flow
of water and coal ash pollution simply by drawing an imaginary line in its model that cuts out
many of the residents near Buck.
In addition, Duke assumed that residential wells have a constant pumping rate. In reality,
wells could pump at much higher levels some times of the day than others. This could alter the
amount of pull that these wells exert and the distance that they reach by an enormous amount,
especially since the wells are drawing water through tiny fractures in the bedrock.
Duke's inadequate assessment of pumping is compounded by the fact that none of
Duke's monitoring wells are equipped with continuous water elevation monitors. These
64 Groundwater Management Associates, Expert Report for Buck Steam Station at 25 (Feb. 29, 2016).
01)

monitors are readily accessible and provide sophisticated, real-time water elevation
measurements, yet Duke chose not to install them. Instead, Duke is relying exclusively on a
couple of isolated water elevation measurements taken at a time of Duke Energy's choosing.
This means that there are canyon -sized spans of time when there is absolutely no information on
water elevation levels. The water levels measurements might have been dramatically different
had Duke Energy taken them at a time of high use, when hundreds of wells clustered around the
ponds are pumping in unison.
Duke's failure to fully analyze this significant pumping effect undermines its self-serving
groundwater flow conclusions.
5. None of Duke's bedrock monitoring wells draw water from the same level
as residential drinking water wells.
Not only did Duke neglect to install any bedrock monitoring wells near neighbors' wells,
the handful of distant bedrock wells it attempts to rely on are improperly constructed. Although
Riverkeepers pointed out this problem months ago, Duke has persisted in relying on these
incomparable monitoring wells in its CAP.65
To serve as the basis for determining groundwater levels and directional flow as
compared to residential wells, monitoring wells must draw water from the same range of depths
as residential wells. The depth of the well and the length of the opening in the well are two
related but distinct concepts: a well could be 200 feet deep, but only open from a depth of 100-
105 feet, with the rest enclosed in casing. In this example, contaminated groundwater flowing
through a crevice in the bedrock at a depth of 50, 110, or 210 feet would not be detected in the
well. To serve as a useful comparison to residential wells, the openings through which Duke's
monitoring wells withdraw groundwater must be at a depth and length similar to the openings in
nearby residential drinking water wells.
Contrary to this well -established principle, Duke's bedrock monitoring wells at Buck
extend no deeper than 200 feet below the ground surface, while some residential wells extend
600 or more feet below the ground surface. In an unpredictable, fractured -bedrock aquifer
system such as the one underlying the Buck site, it is not possible to evaluate the likelihood of
contamination to drinking water wells by studying groundwater exclusively at much shallower
depths.
Duke's bedrock monitoring wells at Buck also draw water from vertical openings that are
only five feet long,66 while the vertical openings on residential wells near Buck range around 20
to 500 feet in length.67 Duke inserted casing into its wells to ensure that the wells drew from a
mere five foot interval. As a result, Duke's monitoring wells deliberately close off many
fractures in the bedrock that could be a source of additional flow and contamination from Duke's
65 See CAP 1 Figure 3-5.
66 CSA Table 6-9.
67 CSA Table 4-1.
23

coal ash ponds. For example, all of the highlighted fractures listed below —many of which Duke
identified as having pollution staining —were closed off and ignored by Duke.68
68 Groundwater Management Associates, Expert Report for Buck Steam Station at 5 (Feb. 29, 2016).
24

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26

these dissimilar wells, or to translate those levels into directional flow of the aquifer at the depths
from which residents are drawing their drinking water.
6. Duke has made no attempt to measure the water level in residential wells.
Not only is it difficult to compare residential and monitoring wells because Duke has
improperly designed its monitoring well system, it is further impossible to do so because Duke
has not even gathered water level data from residential wells. In the year and a half that Duke
has had to complete its groundwater assessment since the passage of the Coal Ash Management
act, the company still has made no reported effort to measure the water level in residential wells.
Data on the water levels in residential wells could help determine whether groundwater flows
from the coal ash lagoons into the residential wells. This is especially true if Duke Energy had
installed bedrock monitoring wells at the appropriate depth on -site to allow for a true apples -to -
apples comparison. Duke's failure to gather and evaluate this residential data further compounds
its failure to install monitoring wells on the south side of the Buck site.
7. Duke still has not evaluated the contaminants detected in residential wells.
Despite the fact that Duke collected other data on contamination in residential wells, it
makes no attempt to analyze that data in its CSA or CAP.69 Instead, Duke's CSA merely lists
the residential well data in comparison to the relevant health based standards.70 Although the
CSA refers to a conceptual site model that is purportedly contained in CSA Figures 12-1 and 12-
2, this model is not included in the CSA figures and has not been presented to the public. And
Duke's CAP completely ignores the data gathered from residential wells within a half mile of the
Buck site. Duke cannot be permitted to benefit from intentionally withholding any analysis of
whether the contamination in residential wells is transmitted from the Buck ponds.
8. Duke delayed disclosing any additional sampling until after DEQ's
proposed designations, and even then prepared a report that did not
account for this additional sampling.
As even DEQ pointed out in its conditional approval of Duke's groundwater assessment
plan for Buck, Duke's analysis "should include at least two rounds of groundwater samples
collected and analyzed in 2015."71 Yet Duke's fist CAP reports and analyzes only a single round
of sampling of its newly installed monitoring wells. Duke had almost a half year to conduct a
second round of sampling after this first sampling event, and yet it delayed making this
information public until after DEQ's initial prioritization. Duke's failure to act during the
critical window before DEQ's initial prioritization should not serve as grounds for downgrading
the Buck risk determination.
Even in its second CAP, although Duke references some additional rounds of sampling, it
does not even attempt to evaluate this data or alter its presumed background levels. Instead, the
second CAP simply states that "[v]ariations from Round I to Round 2 cannot be further
69 Groundwater Management Associates, Expert Report for Buck Steam Station at 16 (Feb. 29, 2016).
70 See CSA Appendix B.
71 Attachment 1 to Conditional Approval, at 1 (Feb. 24, 2015).
27

interpreted at this time as the data set consists of only two comprehensive sampling events and
therefore does not fully consider seasonal fluctuations or other temporal changes."72 In other
words, the data that Duke has collected to date is inadequate to show that its contamination is not
impacting residential wells, given the fluctuations that occur over time.
DEQ cannot default to a low risk ranking in light of the single sampling event that Duke
Energy's conclusions are based on and the glaring information voids that remain.
9. Duke did not model excavation in its second CAP.
As expert hydrogeologists at Groundwater Management Associates have noted, "Duke
did not evaluate excavation of the ash pits and disposal of that ash in a fully lined repository
within CAP Part 2."73 This is irresponsible and unexplainable, especially since "removal of ash
from the unlined pits and placement of the ash in an engineered, lined, and water -free repository
is the most certain and protective remedial option. ,74 Duke Energy's failure to give excavation
serious consideration in the CAP 2 undermines its assessment at Buck.
10. Duke's entire CAP hinges on so-called "background" wells that Duke
itself admits may not represent background conditions. 75
The foundation of Duke's CAP is its background analysis. Yet Duke itself admits that of
the four background well sets that it attempts to rely on—BG 1 S/D, BG 2S/D, BG 3S/D, and
MW-6S/D—both DEQ and Duke have recognized that three out of four of these wells are likely
located within the influence of the coal ash, and therefore cannot be considered background
wells, and the only remaining deep background well was dry. As Duke and DEQ have
explained, "background wells BG-3S/D and MW-6S/D may not truly represent background
conditions; therefore, installation of additional background wells may be warranted, ,76 and
"[b]ackground monitoring well locations BG-2S/D and BG-3S/D are located in areas which
likely fall within the influence of the ash storage areas."77 BG-3S/D and BG 6S/D are located in
close proximity to properties with residential wells. Duke has not drilled replacement
background wells in the numerous months that have passed since this recognition in its CSA, nor
in the more than a year that has passed since DEQ first raised this concern. The only action that
Duke has taken in response to these concerns is to shift BG-2S/D slightly south. The only
remaining deep "background" well, BG-1D/BG-1BR, was dry, and therefore could not be
sampled to determine background concentrations for all contaminants.78
For all of its new so-called background wells, Duke relied on a single sampling event —
three samples total between all of the supposed background wellsby the time it came up with
its proposed background concentrations. In many cases, Duke then took the single highest
contaminant level reported in those wells and defined that as its proposed "background" levels.
72 CAP 2 at 13.
73 Groundwater Management Associates, Expert Report for Buck Steam Station at 32 (Feb. 29, 2016).
74 Groundwater Management Associates, Expert Report for Buck Steam Station at 32 (Feb. 29, 2016).
75 Groundwater Management Associates, Expert Report for Buck Steam Station at 6 (Feb. 29, 2016).
76 CAP 1 at 3
77 DEQ Response to Duke's Initial Groundwater Assessment Workplan for Buck at 9 (Nov. 4, 2014).
71 CAP 1 at 43.

Duke Energy's proposed background concentrations are therefore not statistically significant or
scientifically sound, and very likely overestimate the background contamination at Buck. Duke
itself recognized that its analysis is not based on a "sufficient" or "statistically valid" data set.79
Although Duke revealed that it had collected three additional rounds of background
samples in its second CAP, it chose not to revise its proposed background levels based on this
new data. Instead, Duke stated that "Background monitoring wells will continue to be sampled
and PPBCs recalculated as the data set increases with additional sampling rounds."80 This is
especially troubling, given that many of the pollutants detected in background well 2—the well
furthest from the coal ash ponds —decreased dramatically after the first testing event. Iron in
BG-2S, for example, decreased from1,900 ppb in the first sampling event to 57 ppb in the most
recent sampling event.81 Manganese in that same well decreased from 54 to 14 ppb.82 All of
which indicates that background levels might be much lower than what Duke initially proposed.
And as discussed above in section V.A.l.b.i, many residential wells already exceed the inflated
background levels that Duke originally put forward and has not revised to date.
Duke's failure to obtain adequate or representative background samples in advance of the
initial risk designation is inexcusable, and should not serve as the basis for a low risk
designation.
11. Duke identified a background level of hexavalent chromium that cannot be
reconciled with the background level of total chromium identified.
Hexavalent chromium, a potent carcinogen, is a subset of total chromium. It is physically
and logically impossible for there to be more hexavalent chromium in a system than total
chromium. Yet that is exactly what Duke's first CAP reports: a background level of total
chromium of 1.9 parts per billion ("ppb"), and a background level of hexavalent chromium at 78
ppb.83 In other words, Duke pretends that there is more than 40 times more hexavalent
chromium than chromium under background conditions at Buck. This absurdity cannot be true.
The only "background" well that Duke sampled that reported 78 ppb of hexavalent
chromium was BG-1BR, which as noted above, Duke also reported as a dry well. Duke has not
explained how it was able to obtain a sample of hexavalent chromium from a dry well. And to
add to the implausibility, even the total chromium level for this very sample was less than half of
the hexavalent chromium level —which, again, is not physically possible.
And instead of attempting to resolve this inconsistency in its second CAP, Duke doubled
down and maintained its insistence that the background level for hexavalent chromium is 78 ppb.
Duke cannot be permitted to rely on a background level of hexavalent chromium that is
completely inconsistent with the rest of its CAP.
79 CAP 1 at 3, 22.
80 CAP 2 at 14.
81 CAP 2, Table 2-5.
82 CAP 2, Table 2-5.
83 CAP 1 at 23.
29

12. Duke assumes that the ash basins are not sitting in the groundwater under
a cap -in -place scenario, yet the available evidence shows that the ash
basins do in fact extend down into the groundwater.
Duke's CAP "assumes ash left in the ash basin system and ash storage area is above the
water table" under a cap -in -place scenario. CAP at 7. Yet Duke's CAP also shows that the ash
basins extend deep into the groundwater table, see, e.g., CAP Figure 3-2.1, 3-2.2, and that even
under the 33 foot reductions in the groundwater table that Duke assumes, "the groundwater level
will remain in the ash" in Cells 2 and 3 .84 Duke offers no support for its assumption that
groundwater levels would be reduced 33 feet. And it makes no attempt to reconcile the blatant
contradiction between its assumption that the ash is above the water table under cap -in -place,
and its conclusion that the ash is below the water table under that same scenario. Duke's
conclusions about the diminished presence of contaminants in the groundwater under a cap -in -
place scenario therefore cannot be trusted or relied upon.
13. Duke relies on single samples when it suits them.
Duke claims that "...one isolated exceedance..." of a groundwater -quality standard is not
enough of a reason to continue evaluating that contaminant. On this basis, Duke ceased
evaluating a number of pollutants at Buck, including arsenic. At the same time, Duke relied on a
single detection in a `background' well to create "proposed provisional background
concentrations" (PPBCs).85 Similar inconsistencies permeate Duke's analyses.
For all of these reasons, Duke Energy's reports today are deliberately incomplete and
internally contradictory. Duke's Energy's efforts to hide the truth must not translate into a low
risk designation at Buck.
C. Cap -in -Place Will Prolong and Exacerbate Groundwater Contamination at
Buck.
If Buck is categorized as low priority, Duke will have the option to cover up the coal ash
pollution with a "cap," rather than excavating and cleaning up the Buck site. Yet history shows
that cap -in -place will not resolve any of the groundwater problems at Buck, and recent studies
conclude that cap -in -place could even increase the contamination. It is unacceptable to give
Duke Energy the option to put forward a closure plan that would leave its ash submerged in the
groundwater forever. For this reason, DEQ cannot responsibly classify Buck as a low priority.
Duke's own studies show that cap in place will prolong contamination at
Buck.
As Duke itself admits, numerous pollutants will continue to exceed health -based
groundwater standards if the coal ash pollution at Buck is merely capped in place: "The refined
model predicts that under the Existing Conditions and Cap -in -Place scenarios, antimony, cobalt,
84 CAP 1 at 62 (emphasis added).
85 Groundwater Management Associates, Expert Report for Buck Steam Station at 6 (Feb. 29, 2016).
M

and vanadium exceed their respective IMACs at the Yadkin River (i.e., Compliance Boundary)
model interface for all groundwater flow layers. Also, hexavalent chromium is predicted to
exceed the NCDHHS HSL at the Yadkin River for all groundwater flow layers."86
For hexavalent chromium, vanadium, and cobalt, Duke Energy falsely claims that
because "the background concentrations used for modeling also exceed the applicable IMACs or
NCDHHS HSL ... the actual impact of the site sources on groundwater quality is unknown. ,87
Yet the contamination levels that Duke Energy itself predicts will remain for decades into the
future under cap in place are far above the self-serving background levels that Duke Energy
chose to use.88 This is another blatant attempt by Duke Energy to disguise contamination that its
own studies show is coming from Duke's coal ash ponds, and will continue to do so for the
foreseeable future.
2. Cap -in -place has Repeatedly Failed to protect groundwater
Around the country and in North Carolina specifically, "cap in place" has failed to
remedy coal ash pollution.
a. Roxboro
At Roxboro, a lined coal ash landfill has been constructed on top of an unlined coal ash
landfill and unlined coal ash lagoon. Duke Energy has claimed this lined landfill acts as a cap
over the unlined ash and that groundwater monitoring data around this lined landfill area
demonstrate the success of a cap -in -place closure plan. Duke has stated that the lined landfill
was designed to minimize recharge to the aquifer and act as a corrective action to improve
groundwater quality. And Duke's Corrective Action Plan Part 1 (Roxboro CAP Pt. 1) claims
that in monitoring wells GMW-06, GMW-10, and GMW-11, "the lined landfill is reducing the
migration of constituents to Site groundwater."89
In fact, groundwater monitoring data show that this "Cap in Place" approach has
failed to protect groundwater at Roxboro.
First, Duke's assertion ignores the increasing concentration trends for boron, sulfate,
and selenium detected in samples from wells GMW-06, GMW-09 and GMW-I I collected since
2011. Concentrations were very high initially, likely due to improper well development or
sampling techniques early on, and began decreasing prior to installation of the cap/lined landfill,
but in recent years, the concentrations have increased. Graphs of boron, sulfate and selenium
results from wells GMW-06, GMW-09 and GMW-I I are included with the attached expert
report of Mark Hutson.90 The graphs show increasing concentration trends since 2011-12 for
boron, sulfate and selenium in well GMW-06, and for selenium, sulfate, and total dissolved
solids in GMW-11. In well GMW-06, boron has been steadily increasing for years and in
86 CAP 2 at 29
87 CAP 2 at 29.
88 CAP 2, Appendix B.
89 Roxboro CAP Pt. 1 at 1-8 (emphasis added).
90 Attachment 7, Expert Report of Mark Hutson, Roxboro Steam Electric Plant, at 26-27 (Mar. 2016).
31

September 2015 reached 2,460 ppb, well over three times the groundwater standard. CAP Pt. 1
at Table 2-9.
Contrary to Duke's claims, wells GMW-06 and GMW-I I show no consistent decreasing
trend for sulfate, a pollutant that has been above standards around the lined landfill since it was
constructed. Selenium in GMW-06 has also shown no consistent decreasing trend, and in fact
has been increasing in recent years and was last measured at 94.3 ppb, a concentration virtually
identical to that measured in 2002 when the lined landfill project began.
Moreover, there is another downgradient monitoring well ignored by Duke, GMW-08,
that disproves Duke's claim that the capping effect of the lined landfill is protecting
groundwater. Duke has mislabeled this well as an upgradient or sidegradient well in its
submissions to the state (for example, CSA Section 2.10.2), but that is plainly incorrect. The
CSA's Bedrock Water Level Map (Figure 6-5) shows that well GMW-08 is located
downgradient of both the unlined and lined landfills. Analytical results from GMW-08 show
concentrations of boron, chloride, iron, manganese, sulfate, and total dissolved solids (TDS) that
are greater than 2L standards and are increasing. The location of GMW-8 downgradient of the
landfills is consistent with the observed elevated and increasing concentrations of ash -related
constituents.
In particular, boron in GMW-08 has increased dramatically since 2011, reaching
shockingly high levels above 4,000 ppb, and as high as 4,240 ppb, in the sampling data from
April and September 2015 included in the CAP Pt. 1 (Table 2-10). Similarly, sulfate
concentrations in GMW-08 have increased steadily over the past several years and are now far
higher than they were at their previous peak around the time the landfill was constructed; they
are now as high as 780 mg/L, over three times the 2L standard. Id. And total dissolved solids
concentrations in GMW-08 have been increasing as well, and are now almost twice as high as in
2002 and are four times higher than the 2L standard.
Thus, contrary to Duke Energy's claims, multiple monitoring wells downgradient of the
lined landfill at Roxboro show steadily increasing concentrations of coal ash pollutants, and
many others show no consistent decrease in pollutant concentrations. This is unsurprising, given
that the CAP Pt. 1 and CSA show that the unlined coal ash at Roxboro sits deep in the
groundwater, where it will continue to leach out pollutants even if it is capped in place.
The data from monitoring wells around the lined landfill demonstrate that "Cap in Place"
does not protect groundwater and Hyco Lake from continued coal ash pollution.
b. Belews Creek, NC
At Belews Creek, the Pine Hall Road coal ash landfill is unlined and was closed with
synthetic cap in 2008. The Pine Hall Road landfill was listed by EPA as a potential damage case
in 2010 due to continuing groundwater contamination, including exceedences for arsenic, boron,
iron, manganese, nitrate, selenium, and sulfate.91
91 http://www.astswmo.org/Files/Policies_ and_ Publications/Cross-program/Coal_Combustion_Residuals/2011.11-
NODA Comments/North Carolina NODA Comments.pdf
32

Since that time, the monitoring wells around the capped Pine Hall Road landfill have
continued to show extremely high levels of contamination. In 2013, Boron levels were as high
as 30,700 ppb.92 The health -based standard for Boron is 700 ppb. Selenium levels were as high
as 352 ppb, over 17 times the health -based standard of 20 ppb.93 Arsenic was as high as 39 ppb,
far above the health based standard of 10 ppb.94 Duke Energy's explanation for these
extraordinary levels is that they are "consistent with historical readings" at the wells —which is
another way of saying that the contamination is persisting long after the cap was put in place.95
Moreover, an alarming number of the contaminant levels detected in 2013 were the "highest
concentration measured over the period of monitoring," meaning that the pollution in many of
the wells was continuing to increase after the cap was installed.96
Cap in place has already proven to be a failure at Belews Creek.
C. Chesapeake Energy Center, VA
An unlined coal ash landfill has been capped by installing a synthetically lined landfill on
top of it, so the liner is supposed to serve as a cap on top of the old coal ash. "The landfill, built
over an older and unlined ash pond, was lined with polyethylene, but as The Pilot's Jeff Sheler
has reported, tests of wells at the site have repeatedly detected arsenic and other pollutants at
levels exceeding government safety standards." "Company reports to the state Department of
Environmental Quality obtained by The Virginian -Pilot showed that arsenic in one well in 2006
was 40 times the standard," Sheler wrote. "Results in May 2013 and April 2014 showed levels
30 times the standard. Levels of cobalt and sulfide also exceeded government standards. Other
pollutants, including barium, beryllium, lead, selenium and zinc, were detected at `significant
levels above background. 99
597
d. Colstrip, MT
"Built in 1976 with a clay buffer, the Stage 1 Pond began oozing pollutants as far back as
1979 and has continued to do so even though it was "capped" covered over with a liner
in 1997."98
e. B.C. Cobb, MI
Years after lowering water levels, capping, and constructing a slurry wall around a coal
ash lagoon, groundwater monitoring shows extremely high boron concentrations (10,400 µg/L)
and lithium concentrations (215 µg/L) continuing to enter the North Branch of the Muskegon
River.
92 Duke Semiannual Groundwater Monitoring Report for the Pine Hall Road Landfill, tbl.2 (Dec. 20, 2013).
93 Duke Semiannual Groundwater Monitoring Report for the Pine Hall Road Landfill, tbl.2 (Dec. 20, 2013).
94 Duke Semiannual Groundwater Monitoring Report for the Pine Hall Road Landfill, tbl.2 (Dec. 20, 2013).
95 Duke Semiannual Groundwater Monitoring Report for the Pine Hall Road Landfill, tbl.6 (Dec. 20, 2013).
96 Duke Semiannual Groundwater Monitoring Report for the Pine Hall Road Landfill, tbl.6 (Dec. 20, 2013
97 http://hamptonroads.com/2014/08/protecting-chesapeake-dominion-shuts-plant
98 http://www.publicintegrity.org/2009/02/19/2942/coal-ash-hidden-story
33

f. Energies Oak Creek, WI
Buried coal ash that was paved over with an industrial site on top spontaneously
collapsed into Lake Michigan in 2011. http://www.publicintegrity.org/2011/11/01/7240/coal-
ash-spills-lake-michigan-after-bluff-collapse
3. Studies show that cap -in -place can increase, rather than decrease,
leaching of contaminants.
Far from protecting groundwater, capping in place can increase harmful contamination by
creating an oxygen -free environment that makes arsenic leaching worse. Arsenic in coal ash has
higher leaching potential in an anaerobic environment than in an aerobic environment because of
the different potential for reduction -oxidation reactions. A recent study found dissolved arsenic
concentrations under anaerobic conditions were as much as 50 times higher than they were under
aerobic conditions.99 Research at coal ash ponds and the TVA Kingston spill site have similarly
found that oxygen conditions at a site affect the amount of arsenic leaching. The study authors
conclude that "capping methods that might induce anaerobic conditions should be avoided in the
closure of unlined impoundments."100 Covering ash that remains in unlined pits, in the
groundwater, could deprive the ash of oxygen, and the resulting anaerobic conditions could
increase arsenic pollution of groundwater.
4. Duke Energy itself has differentiated cap in place from "clean closure, "
and has not found cap in place acceptable in South Carolina.
Duke Energy's own representatives distinguish between "closure -in -place vs. clean
closure," cautioning that "[1]et's not use the term `clean closure' externally. It implies that other
methods are not." 101
In its briefing to the Public Service Commission in South Carolina, Duke explained that
the advantages of its coal ash excavation plans for Robinson and for its W.S. Lee facility on the
Saluda River include the fact that they will "eliminate[] the existing impoundments," ensuring
"groundwater is protected. That landfill will be lined and capped, leachate will be collected, and
we will continue to perform groundwater monitoring to ensure that these controls function as
designed."lot
In South Carolina — a state where the environmental agency has not hampered citizen law
enforcement against coal ash pollution — Duke has been forced to recognize that even in sparsely
populated areas, it cannot safely close its ash basins without eliminating all its unlined
impoundments and separating the coal ash from groundwater through storage in a properly
designed, synthetically lined landfill.
99 Attachment 8, Grace E. Schwartz et al. Leaching potential and redox transformations of arsenic and selenium in
sediment microcosms with fly ash, Applied Geochemistry 67 (2016): 177-185. DOI:
10.1016/j . apgeochem.2016.02.013.
ioo Id. at 184.
101 Attachment 9, Email from Erin Culbert, Duke Energy, to David Mitchell et al., Duke Energy (Jan. 25, 2013).
102 S.C. Pub. Serv. Comm'n, Ex Parte Briefing Transcript, at 18 (Feb. 10, 2016).
34

D. The Buck Impoundments are Not Eligible for Closure By Capping in Place
under CAMA.
CAMA prohibits DEQ from approving a cap -in -place closure plan "unless the
Department finds that the proposed closure plan includes design measures to prevent, upon the
plan's full implementation, post -closure exceedances of groundwater quality standards beyond
the compliance boundary that are attributable to constituents associated with the presence of the
impoundment."103 Modeling completed by Duke Energy and submitted in its CAPS confirms
that capping the Buck ash ponds and leaving them in place will result in exceedances of North
Carolina's groundwater standards attributable to the ash ponds decades to come.104 Moreover,
the model significantly underestimates the level of contamination that will occur because the
model falsely assumes that groundwater cannot enter the ash basins horizontally through the
sides of the basin, as explained above. In reality, ash will remain saturated in the groundwater
table if the Buck basins are only capped and not excavated. As a result, the capped ash will
continue to be a source of groundwater contamination, resulting in even higher levels of
contamination than are predicted in the model.
Even Duke Energy's deeply flawed and biased modeling confirms that excavation of coal
ash outperforms cap -in -place as a closure method. Excavation and placing the ash in lined
storage is the only way to separate the ash from groundwater and prevent it from being a source
of groundwater contamination in perpetuity.
E. "Monitored Natural Attenuation" Cannot Be Used for Groundwater
Contamination at Buck.
CAMA Requires Duke Energy to Comply with the Groundwater Standard
CAMA requires compliance with North Carolina's groundwater protection rules found at
15A N.C. Admin. Code 2L .0 10 1 et. seq. ("2L Rule"). Under the 2L Rule, any polluter that
contaminates groundwater must develop a corrective action plan "using the best available
technology for restoration of groundwater quality to the level of the standards ....i105 This
general mandate is subject to limited exceptions for a specific category of polluters who qualify
for flexible remediation standards under 2L .0106(k) (allowing restoration to less than the
standard), 2L .0106(1) (allowing restoration through natural attenuation), or 2L .0106(m)
(allowing termination of corrective action without achieving the standard).106 Each of those
sections, in turn, applies only to a "person required to implement an approved corrective action
plan for a non permitted site ...."107 Under the plain text of the 2L Rule, facilities with state -
issued NPDES permits do not qualify for the flexible remediation options afforded by 2L
.0106(k), (1), and (m) because they are permitted.
'03 N.C. Gen. Stat. § 130A-309.214(a)(3).
104 CAP 2 at 29.
'0' 15A N.C. Admin. Code 2L .01060).
106 See id.
107 See 2L .0106(k), (1), (m). Flexible remediation is also available under 2L .0106(r) & (s). Those sections only
apply to underground storage tanks and are inapplicable to the coal ash ponds at issue in this litigation.
35

In the past, Duke Energy has argued that its NPDES-permitted coal ash basins are
nonetheless eligible for the flexible remediation measures reserved for "non permitted sites"
because under the 2L Rule, older basins first issued permits before December 30, 1983, are
"deemed not permitted" for some purposes.108 But recent legislative changes altered these rules
mandating that "[w]here operation of a disposal system permitted under this section results in
exceedances of the groundwater quality standards at or beyond the compliance boundary the
[EMC] shall require the permittee to undertake corrective action, without regard to the date that
the system was first permitted, to restore the groundwater quality ...." 109 In other words, the
only question now is whether a facility has a permit, not when it was issued.
Under this recent revision to North Carolina's water pollution control statute, Duke
Energy must restore groundwater around its permitted coal ash disposal sites at the Buck facility
to the applicable standard, without regard to the date the impoundments were first permitted. To
further clarify the application of flexible remediation to coal ash ponds, the General Assembly
recently declared that the benefits afforded by its risk -based remediation statute "shall not apply
to contaminated sites subject to remediation pursuant to ... [t]he Coal Ash Management Act of
2014."110 Asa permitted facility subject to remediation under CAMA, Duke is barred from
using flexible remediation, such as monitored natural attenuation, as a groundwater remediation
method and instead must implement the best available technology to restore groundwater to the
standards.
2. The Pollutants Duke Energy Projects Will Violate Groundwater Standards
Do Not Attenuate at the Buck Site
Even if natural attenuation was available to Duke as a remediation alternative generally,
it cannot be used in this specific instance because the constituents violating groundwater
standards at the compliance boundary at Buck do not naturally attenuate. Under the 2L Rule, to
utilize natural attenuation an entity must demonstrate "that the contaminant has the capacity to
degrade or attenuate under the site -specific conditions." III Duke's "Existing Conditions"
groundwater modeling shows that antimony, boron, chromium, cobalt, manganese, hexavalent
chromium, sulfate, and vanadium will continue to expand if the ash is left in place,
demonstrating that these constituents will not degrade.112 Because Duke cannot make the
requisite showing under the 2L Rules that attenuation of these contaminants is possible, Duke is
barred from relying on natural attenuation as a remediation method at Buck.
Duke Energy has proposed "monitored natural attention" as a solution for the continuing
groundwater pollution at Buck.113 This supposed solution is no solution at all and is illegal
under North Carolina law.
10' See 2L .0106(e).
109 N.C. Sess. Laws 2014-122, § 12(a) (codified at N.C. Gen. Stat. § 143-215.1(k)) (emphasis added).
no Id. (codified at N.C. Gen. Stat. § 130A-310.67(4)).
1" 15A N.C. Admin. Code 2L .0106(l)(2).
112 See CAP 2, Appendix B at 19-23.
113CAP 2at3.
9.1

First, this is a proposal to let the pollutants continue to flow into groundwater and the
Yadkin River for decades to come and thus flush them downstream and downgradient. Duke
Energy's reports misleadingly describes the boron plume at Buck as restricted to the area under
and immediately around the basins, but that is only because the groundwater discharges directly
into the Yadkin River and other surface water features. Thus, boron and other pollutants
continue to migrate freely from the coal ash impoundments into public waters — they just move
from groundwater to surface water. For this reason, the monitored natural attenuation proposal
does nothing to protect groundwater or surface water. Instead, this proposal intentionally
pollutes both surface and groundwater and sends it downstream and downgradient.
Groundwater, along with the buried stream at Buck, will continue to flow through and be
polluted by coal ash for decades to come.
Second, many of the coal ash pollutants, including toxic heavy metals, do not "attenuate"
or degrade. They will continue to flow into the groundwater, the Yadkin River, and other
surface waters directly.114
Third, for all these reasons and others, NCAC 02L .0106 (1) does not allow for this
approach to the coal ash pollution at Buck.115
F. The Buck Impoundments Also Are Not Eligible for Closure by Capping in
Place Under the CCR Rule.
On October 19, 2015, the EPA's Disposal of Coal Combustion Residuals rule (the "CCR
Rule") became effective, providing the first comprehensive federal regulation of coal ash
disposal. DEQ asserts that "[t]he requirements set forth in CAMA ... will complement or
exceed" the CCR Rule's requirements, but this is only true if DEQ demands more than cap -in -
place where groundwater is already contaminated by unlined impoundments.
The tension between the new federal mandates and capping -in -place at Duke's sites
exists in the CCR Rule's Groundwater Monitoring and Corrective Action section.116 This
section provides that if monitoring detects a statistically significant exceedance of the
groundwater protection standards established for a constituent in Appendix IV of the CCR Rule,
then, barring certain exceptions, the owner or operator of an unlined surface impoundment must
engage in two tracks of remedial measures.117 First, the owner or operator of the unlined
impoundment must begin the CCR Rule's normal remedial process, including the assessment of
corrective measures, selection of remedy, and implementation of a corrective action
plan.118 Second, within six months of the detection, the waste streams into the impoundment
must cease and the process of closing or retrofitting the impoundment must begin.119 The CCR
Rule's preamble makes clear that this close or retrofit requirement for leaking unlined
114 Attachment 10, Expert Report of Mark Hutson, Mayo Steam Electric Plant, at 12; Attachment 11, SELC et al.
Comments on Mayo CAP Part 1 (Dec. 29, 2015).
115 Id
116 40 C.F.R. §§ 257.90-98.
117Id. § 257.95(g).
1 ' Id. §§ 257.95(g)(3)(i), 257.96-98.
119Id. §§ 257.95(g)(5), 257.101(a)(1).
37

impoundments is "in addition to complying with all of the corrective action
requirements." 120 Thus it is not enough to satisfy only § 257.102's closure requirements —the
requirements for remedies and implementation of the corrective action plan under §§ 257.97-98
must also be met.
This point is critical because Duke's own data show that capping -in -place will not meet
the CCR Rule's requirements for remedy selection or corrective action plan
implementation. Among other things, the remedy selected must "[b]e protective of human health
and the environment," ..[a]ttain the groundwater protection standard" set forth in § 257.95(h) (the
MCL or other level, as specified therein), "[c]ontrol the source(s) of releases so as to reduce or
eliminate, to the maximum extent feasible, further releases of' Appendix IV constituents, and
"[r]emove from the environment as much of the contaminated material that was released from
the CCR unit as is feasible." 12 1 The remedy will not be considered complete until groundwater
protection standards are met for three consecutive years.122
The CCR rule measures compliance with groundwater protection standards at the site's
waste boundary,123 a much closer limit that is within the compliance boundary. Therefore,
capping -in -place also will not meet the CCR Rule's requirement that the remedy selected attains
compliance with groundwater protection standards, let alone for three consecutive years. Nor
will capping -in -place satisfy the requirements that the remedy control the source material and
remove as much contaminated material as is feasible —indeed, the cap -in -place plan seems to
call for removing as little as is feasible. And leaving the toxic ash in vulnerable communities
adjacent to precious waterways will certainly not protect human health and the
environment. The only remedy that will meet the CCR Rule's requirements, and the only
remedy DEQ should consider for these sites, is removal of the ash and placement in dry lined
storage facilities.
G. Experience Has Shown that Excavation and Removal is Effective in
Reducing Groundwater Pollution.
Experience from coal ash excavation sites in South Carolina demonstrates that excavation
to dry lined storage is the effective means of eliminating serious groundwater contamination
from unlined coal ash lagoons. Excavation and removal to dry lined storage also eliminates the
threat of catastrophic failure and the unlined riverside storage of millions of tons of toxics-laden
waste.
The Wateree plant of SCE&G is on the banks of the Catawba-Wateree River — a river
that runs through both South and North Carolina — near Columbia, South Carolina. Duke Energy
also stores coal ash on that river, at its Marshall, Riverbend, and Allen facilities.
In January 2012, the Southern Environmental Law Center filed suit against SCE&G on
behalf of the Catawba Riverkeeper Foundation to require removal of coal ash from unlined pits
120 80 Fed. Reg. 21406 (emphasis added).
12' 40 C.F.R. §§ 257.97(b)(1)-(4).
122 40 C.F.R. § 257.98(c)(2).
"' See 40 C.F.R. § 257.91(a)(2).

on the banks of the River. For years, these coal ash pits had contaminated the groundwater — and
thereby the adjacent Catawba-Wateree River — with large amounts of arsenic. In one test,
groundwater in one of the monitoring wells contained arsenic at 5,000 parts per billion (ppb), or
500 times South Carolina's standard of 10 ppb for arsenic.124
In August of 2012, SELC and the Catawba Riverkeeper Foundation negotiated a
settlement with SCE&G that requires removal of the coal ash from the riverside pits to safe, dry,
lined storage away from the waterway. Since ash removal began in earnest, arsenic groundwater
contamination has plummeted at the site.
As of its January 2016 report, SCE&G has removed over 876,000 tons of coal ash from
the site, or about one-third of the coal ash.125 At the same time, groundwater contamination at
the site has dropped significantly. In one monitoring well, arsenic had contaminated the
groundwater at 432 ppb, or 43 times the legal limit. In the latest report, arsenic groundwater
contamination has dropped to 2.9 ppb, or a 99 percent decrease.126 In another monitoring well,
arsenic contamination had been over 1,000 ppb, ranging as high as 5,000 ppb. In the latest
report, arsenic contamination had dropped to 58.6 ppb, or at least a 95 percent reduction in
arsenic contamination.127 Other pollutants, including lead, cadmium, and sulfate, are also
reported at lower levels.
124 Attachment 12, SCE&G Wateree Semi -Annual Status Report (relevant pages) July — December 2015, at 12.
125 Id. at 2.
126 Id. at 6-7.
127Id. at 12.
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#11
In June of 2012, the Southern Environmental Law Center filed suit against Santee Cooper
for its coal ash pollution at its Grainger facility on the Waccamaw River in Conway, South
Carolina. In this instance, SELC represented the Waccamaw Riverkeeper, a program of the
Winyah Rivers Foundation; the South Carolina Coastal Conservation League; and the Southern
Alliance for Clean Energy. The Waccamaw River — like the Catawba-Wateree River — flows
through both North and South Carolina. The Waccamaw River is also part of the Winyah Bay
Watershed, which encompasses both states, including the Lumber River on which Duke Energy
stores coal ash at its Weatherspoon facility.
In November 2013, the parties announced the settlement of this suit, under which the two
ash ponds at Grainger are undergoing clean closure with beneficial use of the ash in the cement
industry. To date, over 340,000 tons of ash have been beneficially used. When the project is
completed by 2020 (or earlier based on the current excavation schedule), approximately 1.3
million tons of material will have been beneficially used. And Santee Cooper reports that its
water quality monitoring efforts (both groundwater and river water) show that the Grainger
excavation project has not affected water quality in the Waccamaw River and that contaminants
in the groundwater are reducing over time as the coal ash is being removed.
40

As of its January 2016 report, Santee Cooper had removed about 450,000 tons of ash.128
The Grainger site has consistently reported some of the highest arsenic groundwater
contamination in the region. However, as the ash is being removed, the arsenic groundwater
contamination has been decreasing. One monitoring well reported arsenic in 2013 at 1,097.9
ppb, or over 109 times the South Carolina standard of 10 ppb.129 By the end of 2015, the arsenic
contamination in that monitoring well had dropped to 558.9 ppb —still very high, but about one
half the level before excavation began.130 At another monitoring well, in September 2013,
arsenic groundwater contamination was measured at 941.9 ppb, or over 94 times the South
Carolina standard. 131 By the end of 2015, arsenic contamination had dropped to 198.4 ppb —
about an 80% reduction from pre -excavation. 1 32 One other monitoring well also showed an 80%
reduction, from 450 in 2013 to 108.5 by the end of 2015.133
Arsenic levels at Grainger
lnnitoring
Well
—*__1
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—41-3
#4
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—6—i2
128 Attachment 13, Grainger Generating Station Ash Pond Closure: Ash Removal Report (Jan. 11, 2016);
Attachment 14, Grainger Generating Station Ash Pond Closure: Ash Removal Report (Jan. 14, 2015).
129 Attachment 15, Grainger Generating Station, NPDES Groundwater Semi-annual & Compliance Report, at 5
(Nov. 22, 2013).
130 Attachment 16, Grainger Generating Station, NPDES Groundwater Semi-annual Report for 2015 — Addendum, at
4 (Mar. 1, 2016).
131 Grainger Generating Station, NPDES Groundwater Semi-annual & Compliance Report, at 5 (Nov. 22, 2013).
132 Grainger Generating Station, NPDES Groundwater Semi-annual Report for 2015 — Addendum, at 4 (Mar. 1,
2016).
133 Grainger Generating Station, NPDES Groundwater Semi-annual & Compliance Report, at 5 (Nov. 22, 2013);
Attachment 17, NPDES Groundwater Semi-annual Report for 2015, at 8 (Nov. 24, 2015).
41

As excavation continues, the measurements of arsenic contamination in groundwater may
vary. But the trend is clear. As ash is removed, groundwater contamination from arsenic has
been decreasing.
For all of these reasons, DEQ needs to prioritize Buck as a high or at least intermediate
priority, to ensure that Duke will move its ash out of the groundwater and protect the families
that rely on this valuable resource at Buck.
VI. Coal Ash Contamination Is a High Risk to Surface Water at Buck.
A. DEQ's and Duke's own reports admit that the Buck coal ash is a
major threat to the Yadkin River and High Rock Lake.
Buck is a high risk to downstream water intakes.
Over 293,000 people rely on drinking water intakes downstream in the Yadkin River
watershed from leaking, unlined coal ash pits at Duke Energy's Buck site. The nearest water
supply protected area is a mere 13 miles downstream from Buck.134 In other watersheds, public
water supplies even further downstream have been damaged by coal ash pollution. For example,
at the Belews Creek site, the city of Eden, which is approximately 34 miles downstream from
Belews, found carcinogens in their water supply that were ultimately linked back to Duke
Energy's coal ash.
The water supplies are doubly at risk: they are at risk of contamination by the ongoing,
daily leaks at the Buck plant, and they are also at risk in the event of catastrophic failure at Buck
that releases more contaminants into the water.
DEQ recognized that exposing 293,000 people to coal ash contamination is not a low
risk. Yet DEQ classified Buck as an intermediate risk base on this factor, rather than a high
risk.135 More importantly, this risk did not have had any impact on DEQ's ultimate proposed
rating for surface water, which was "low." DEQ must accept the true risk to people downstream
of Buck, and acknowledge that surface water is a high risk at Buck.
2. Buck is a high risk to waters that are used for recreation, fishing,
drinking, and swimming.
DEQ acknowledged that the ash at Buck is an intermediate risk based on the
characteristics of the water body that the ash discharges into.136 High Rock Lake, immediately
downstream of Buck, is a Class B water body that serves as a popular recreational area for
fishing, boating, and swimming.137
134 DEQ, Coal Combustion Residual Impoundment Risk Classifications at 97 (Jan. 2016).
135 DEQ, Coal Combustion Residual Impoundment Risk Classifications at 97 (Jan. 2016).
136 DEQ, Coal Combustion Residual Impoundment Risk Classifications at 97 (Jan. 2016).
137 http://ncdenr.maps.arcgis.com/apps/webappviewer/index.html?id=6el25ad7628f494694e259c80dd64265
42

3. Five million tons of coal ash at Buck is a high risk to the Yadkin River.
DEQ cannot deny that the sheer volume of ash stored at Buck is a high risk. As
explained above in section V.A.6, a release of even a small portion of this ash would be
catastrophic to the river and the people who rely on it. As discussed in section VII below, there
are many serious concerns about the dams that separate this ash from the river.
4. The Buck coal ash sits in a natural stream, and cannot be low risk.
DEQ identified all three basins at Buck as being located in a natural stream or drainage
basin.138 Yet DEQ called this factor "low/intermediate risk" for Buck for all three basins.
Duke Energy's own maps show a natural flowing stream running directly through the
heart of the largest ash basin at Buck. Ash sitting directly in a blue -line stream is a high risk, and
DEQ must revise its ultimate risk rating to account for this.
5. DEQ incorrectly applied a dilution factor to the significant discharges at
Buck.
DEQ proposes to say that dilution would render Buck a low risk for this factor. First,
dilution of coal ash contamination is a euphemism for the flushing of coal ash pollution
downstream.
Second, DEQ provides no evidence of dilution, other than the flow rate of the Yadkin
River itself. The flow rate of a river is little comfort, without any evaluation of how much
pollution is entering the river.
Third, DEQ based its dilution factors in part on the average flow of the Yadkin River as a
whole. This does not represent the worst -case scenario, which is instead the lowest -flow period
in the lowest -flow area near Buck. Many areas around Buck have much slower flow rates,
including the "frog pond" to the west of the coal ash ponds, which the natural stream running
through the coal ash at Buck discharges directly into. In addition, coal ash also discharges
directly into other lower -flow tributaries of the Yadkin River, such as the tributary to the east of
the coal ash ponds. DEQ is charged with protecting these resources, and cannot glaze over them
by "averaging" them with the entire rest of the Yadkin River.
B. DEQ failed to consider other evidence of heightened risks to the Yadkin
River and High Rock Lake, much of which is contained in Duke's and DEQ's
own reports.
DEQ did not consider the sheer volume of leaks at Buck.
Seeps emanating from the Buck coal ash pits pose a significant threat to the Yadkin River
and those who use and enjoy it. According to Duke's own assessment, seeps at Buck discharge
138 DEQ, Coal Combustion Residual Impoundment Risk Classifications at 96 (Jan. 2016).
43

over 70, 000 gallons per day.139 Duke has identified as many as 14 different seeps at Buck, but
these estimates are based on 10 seeps only, so the actual discharges may be much greater. These
discharges may also be greater at different times of the year, such as winter when there is
increased water recharge and flow. 140
In November of 2014, Riverkeepers discovered a quarter -mile long stretch of seeps along
the banks of the Yadkin River, directly adjacent to the Buck coal ash ponds. The seeps were
revealed when work on a dam downstream caused the water level in the Yadkin River to drop,
exposing a long series of seeps that are normally just below the surface. No such seeps were
visible across the river or upstream of the coal ash ponds. These seeps discharge untold
additional thousands of gallons into the Yadkin River every single day, none of which is
documented or measured by Duke. The estimates of seep discharges that Duke has presented are
therefore likely vast underestimates.
Figure 5: Image of Seeps Flowing from Duke Energy's Coal Ash Site into the Yadkin
River
Seeps at Buck also discharge onto private property adjacent to the coal ash lagoons.
Duke admits that contamination from coal ash in these seeps extends outside the Buck
compliance boundary. 141 Duke claims that groundwater contamination derived from their ash
sources extends to "the area north of the compliance boundary near the Yadkin River..." and
139 Groundwater Management Associates, Expert Report for Buck Steam Station at 4 (Feb. 29, 2016).
140 Groundwater Management Associates, Expert Report for Buck Steam Station at 4 (Feb. 29, 2016).
14' Groundwater Management Associates, Expert Report for Buck Steam Station at 4 (Feb. 29, 2016).
44

"Some of these [2L or IMAC] exceedances were measured outside the compliance
boundary. .."142 DEQ must take this high -risk factor into account in its decision.
2. Duke's and DEQ s own reports confirm that the seeps at Buck are
contaminated.
In March of 2014, DEQ sampled and tested water discharging at several seeps and
springs located on Duke's property. NCDENR identified six substances in sampled discharges at
concentrations exceeding the applicable 15A NCAC 2L groundwater standards, four of which
exceeded the Class WS 15A NCAC 2B surface -water standards. In September and November of
2014, Duke sampled and analyzed 11 discharges.143 However, the CSA does not mention
Duke's 2014 sampling and analysis, and instead is focused on their sampling and analyses
performed in June and August of 2015. Although Duke claimed that most of the seeps or springs
were `dry' in mid-2015, they reported that concentrations of 10 targeted COIs exceeded the 15A
NCAC 2L or IMAC groundwater -quality standards in water samples.144
3. Additional sampling shows that seeps at Buck contain high levels of coal
ash contaminants.
The Riverkeepers have also taken samples of these seeps, and testing conducted by a
certified, independent laboratory reveals that Duke's unauthorized discharges from these
unpermitted point sources contain pollutants such as aluminum, barium, boron, chromium, iron,
lead, manganese, and zinc.
Table 1: Pollutants Found in Un ermitted
Seeps
Pollutant
Standard Highest Exceedances at
(ppb) Unpermitted Seeps and
Pi e ( b)
Highest Documented
Exceedance (Percent of
Standard)
Aluminum
50-200 ,000
1000%
Barium
700 6,320
902%
Boron
700 1'050
150%
Chromium
10 132
1320%
Iron
300 734NO
24406%
Lead
15 242
,613%
fiL5612,
Manganese
50 2
4. Duke's own analysis concludes that coal ash contaminants are flowing
into the Yadkin River.
Duke's own reports admit that many contaminants in the groundwater beneath its unlined
coal ash lagoons at Buck flow into the Yadkin River, and will continue to do so for hundreds of
142 (emphasis added, CSA, page ES-15).
143 Duke, Discharge Assessment Plan (Dec. 2014).
144 Groundwater Management Associates, Expert Report for Buck Steam Station at 12-13 (Feb. 29, 2016).
45

years into the future even under a cap -in -place scenario.145 As Duke admits at the outset of its
latest report, "COI [i.e., contaminant] transport from the source areas is generally in a northerly
direction toward the Yadkin River and the eastern and western unnamed tributaries, which
discharge to the Yadkin River." 146 While this fails to acknowledge that groundwater also flows
radially outward to the south of the coal ash lagoons, it confirms that contaminants are flowing to
the Yadkin River. And many of these contaminants will exceed North Carolina's health -based
standards "at the compliance boundary and at the Yadkin River.i147 For example, Duke first
CAP concludes that chromium remains above the health -based standard of 10 ppb—and
therefore above Duke's background level of 1.9 ppb—through the next 250 years in the shallow
and transition zone layers, and these layers "discharge to the Yadkin River to the north and east
of Cells 2 and 3."148 Similarly, "[v]anadium in groundwater discharges to the Yadkin River
north of Cell I in the all groundwater flow layers and to the north and east of Cell 3 in all
groundwater flow layers."149 Duke's second CAP similarly admits that antimony, cobalt,
vanadium, and hexavalent chromium continue to discharge into the Yadkin River at levels above
health based standards, under both the do-nothing and the cap -in -place scenarios.150
Continued contamination of the Yadkin River for the next 250 years, even according to
Duke's own reports, is another reason that Buck cannot be designated as low risk. Yet DEQ did
not even consider continued discharges into the Yadkin River as an independent factor in its
analysis.
5. DEQ disregarded Duke Energy's long history of accidental spills into the
Yadkin River and cover-ups.
In the last several years that Duke Energy operated the Buck Steam Station, there were at
least six known accidental spills at the plant, and possibly many more unknown failures. At least
one of these spills resulted in a fish kill in the frog pond to the west of the coal ash lagoons.151
Alarmingly, Duke Energy took steps to conceal the cause of some of these spills. As
Duke Energy's managing environmental director stated following one of these spills "let's make
sure we don't tell the EM Director for the county and county manager that the cause of the
release was an operator on loan from Marshall Steam Station, who is inexperience with Buck,
made an inadvertent, incorrect decision."152
In another instance, Duke Energy's staff partially dewatered the coal ash lagoons at
Buck, stating that the "TSS [total suspended solid] risk is low with next test in first week of
145 CAP 1 at 8, 64.
146 CAP 2 at 2.
141 CAP 1 at 64.
141 CAP 1 at 64. In Duke's second CAP, it "refined" its model for chromium to show that chromium no longer
exceeds the 2L standard at the compliance boundary under the cap in place scenario. But chromium continues to
exceed Duke Energy's own proposed background levels for this pollutant decades into the future at Duke's
compliance boundary. CAP 2, Appendix B.
149 CAP 1 at 65.
"0CAP 2at29.
151 Attachment 18 , Email from Don Faulkner, Duke Energy, to Charlie Gates (July 11, 2012).
152 Attachment 19, Email from David Mitchell, Duke Energy, to Dayna Herrick, Duke Energy (Apr. 5, 2011).
46

December." 153 When questioned about this statement, a former Duke Energy interpreted this to
mean that if they "disturb" the ash in November through dewatering, causing the total suspended
ash solids to become "elevated" in the discharges, "it will be lowered within compliance by the
time they — the time they reach the first week in December when they pull their compliance
samples."154 In other words, Duke Energy has in the past aimed to strategically release
discharges at times of the month when they are least likely to have to monitor and report those
discharges.
Based on these past errors and concealments, DEQ cannot take Duke Energy's
pronouncements at face value, and it cannot assume that Duke Energy will engage in best
practices going forward. All of this supports excavation and proper lining or recycling of the ash
at Buck, rather than leaving the ash in unlined pits in Duke Energy's care for eternity.
VIL Dam Safety
A. Buck poses a high risk of dam failure and ensuing destruction under the
factors that DEQ considered.
The hazard classification for the Buck dams has always been high.
The dams at Buck tower as high as 71 feet tall, and hold significant quantities of ash and
ash water back from the Yadkin River.
EPA has assigned a hazard -potential rating of "Significant" to each of the three dams that
form the Buck coal ash lagoons because structural failure of one or more of the dams would
likely cause significant economic loss, environmental damage, and damage to infrastructure.
DEQ previously assigned a hazard -potential rating of "High" to each dam at Buck because
significant environmental damage could occur if the dams fail.
Yet in its January 2016 report, DEQ proposed to classify two of the dams at Buck as
low/intermediate risk, and only one as intermediate/high risk. DEQ offered no explanation for
its departure from its previous risk designations for the Buck dams. Again, DEQ also excluded
this high risk from its ultimate dam safety risk rating proposal, and instead focused solely on the
risk that might occur if Duke Energy ever makes long -overdue repairs at Buck.
2. The dams at Buck are high risk because they are not only close to waters
of the state, but waters of the state actually flow through one of the basins.
DEQ accurately classified the main dam —the dam that separates basin three from the
Yadkin River —as a high risk dam based on its proximity to the Yadkin River. Yet this
incredibly close proximity apparently had no effect on DEQ's ultimate proposed dam safety
ranking, since DEQ proposed to call this dam a low priority.
153 Attachment 20, Email from Jeff Newell, Duke Energy, to David Weickle, Shield Engineering (Nov. 11, 2009).
154 Deposition of Allen Stowe at 52:22-53:1 (Jan. 29, 2016).
47

DEQ incorrectly classified the dams surround basin 1 as intermediate risk, falsely stating
that there is approximately 1,500 feet of land between the embankment and waters of the state.155
To the contrary, a water of the state flows directly through basin I and the Additional Primary
Dam that contains the ash in basin 1. Not only is the dam near a water of the state, it is on top of
a water of the state. This natural stream is shown on almost every map that Duke Energy has
created of the Buck site. This dam should therefore be classified as a high risk as well.
3. The amount of ash stored at Buck is a high risk.
Without explanation, DEQ arbitrarily states that all three of the ash ponds at Buck are
low risk because of the volume of ash stored there.156
What DEQ fails to acknowledge is that there is far more ash stored at Buck than was
stored at Dan River. Yet the failure of the dam structures at Dan River caused devastating
consequences. DEQ cannot pretend that the ash stored at Buck is somehow a small enough
quantity to be a low risk in the event of dam failure.
4. Offsite drainage areas are at least intermediate risks at Buck.
DEQ acknowledged that the offsite drainage areas at Buck were an intermediate risk
factor.157 But once again, this determination had no effect on DEQ's decision to propose rating
Buck as low risk for dam safety based on future, speculative repairs.
5. DEQ cannot disregard all of the dam safety risks at Buck on the basis of
the speculative effects of dewatering and long -overdue repairs.
DEQ admitted that in their current state, all of the dams at Buck are either high or
intermediate risks.158 Yet DEQ proposed to downgrade the current risk of the dams at Buck
based on the hypothetical effects of future repairs. This is contrary to CAMA, which requires the
risk rating to be based on present conditions, not future promises that might or might not come to
pass.159
Skewing the risk rating for Buck based on uncertain future repairs is also contrary to
recent statements by DEQ's assistant secretary for the environment, Tom Reeder. On April 7,
2016, Mr. Reeder stated that if Duke Energy had not completed dam repairs, DEQ would not rate
the site low risk. To date, Duke Energy does not appear to have even obtained approval for some
of its proposed repairs, much less completed its repairs.
Duke Energy has known about the dam safety problems at Buck for years, and still has
not taken basic steps to fix the problems. It has been nearly two years since DEQ cited Duke
Energy for deficiencies in its dams at Buck in 2014. At that time, DEQ identified multiple
155 DEQ, Coal Combustion Residual Impoundment Risk Classifications at 98 (Jan. 2016).
156 DEQ, Coal Combustion Residual Impoundment Risk Classifications at 98-99 (Jan. 2016).
157 DEQ, Coal Combustion Residual Impoundment Risk Classifications at 99 (Jan. 2016).
158 DEQ, Coal Combustion Residual Impoundment Risk Classifications at 99 (Jan. 2016).
159 N.C. Gen. Stat. § 130A-309.213(a).
L;

structural failings in the dams surrounding the Buck coal ash basins, including pipes and other
structures that are broken, cracked, leaking, or "approaching the end of [their] safe performance
life."160 DEQ designated these problems as "serious."161 The cracked and leaking stormwater
pipes at Buck exhibit the same symptoms as those in the pipes at Dan River, which ultimately led
to the catastrophic coal ash spill there.
The 2014 notices of deficiency were not the first time that Duke Energy was alerted to
problems with its dams at Buck. As early as 2011, inspections of the pipes at Buck warned that
they were approaching the end of their safe performance life.162
Yet Duke Energy still has not completed these repairs, and at least one of Duke Energy's
repair plans has not yet been approved.
For one of the dams, DEQ had to admit that even the repairs Duke proposed would not
reduce the risk to "low." Instead, the ponds would also have to be dewatered, a process that can
itself cause structural instability.
As the former environmental safety director at Buck has testified, dewatering too quickly
"could potentially cause erosion and impacts to the dam structures. So it has to be done very
carefully."163 Yet in the past, Duke Energy does not appear to have approached dewatering at
Buck with caution: for example, at the same time that some Duke employees have noted that
lowering the water level by one foot per day "seems like a very accelerated rate, as I've generally
heard we want to stick to around 1 foot per week," 164 Duke was planning to lower the water level
at Buck by nearly a foot every other day.165
In addition, including speculation about the dam safety effects of dewatering is not an
appropriate analysis under the CAMA statute. CAMA's classifications determine the schedule
and closure methods available for each impoundment. Dewatering is part of the closure process,
not part of the risk evaluation process, which logically must come before a classification and
determination of a closure plan. Thus, trying to short-circuit the analysis set out in CAMA to
incorporate part of the closure process into the Department's risk classifications is inappropriate.
Earlier work within the limits of the dams has resulted in mistakes that caused a breach of
the dams at Buck. In 2012, contractors excavated a portion of the dam at Buck without a permit,
which caused a breach in the dam.166 In response, due to the "good relationship" between Duke
Energy and DEQ's Dam Safety division, DEQ's responded with "forgiveness of the unpermitted
work and willingness to expedite the review process."167 DEQ cannot assume that work on the
160 Attachments 21, 22, DEQ, Notice of Deficiency for Basin 1 to Basin 2 Dam (June 13, 2014); DEQ, Notice of
Deficiency for Main Dam (June 13, 2014).
161 id.
162 Attachment 23, Letter from Mel Browning & Clay Sams, MACTEC, to Alex Papp, Duke Energy (Jan. 5, 2011).
163 Deposition of Norbert Zalme at 85:1-3 (Dec. 14, 2015).
164 Attachment 24, Email from Sean DeNeale, Duke Energy, to Tim Russell et al., Duke Energy (Aug. 23, 2013).
165 Attachment 25, Email from Dean Beaver, Duke Energy, to Mike Bray et al., Duke Energy (Aug. 28, 2013).
166 Attachment 26, Email from David Brooks, Duke Energy, to Al Smith et al., Duke Energy (Jan. 24, 2012).
167 Attachment 27, Email from Tim Russell, Duke Energy, to Dave Waugh et al., Duke Energy (Jan. 25, 2012).
49

dams going forward will reduce risk, when work done improperly could actually increase the
risk at Buck.
DEQ must prioritize Buck as high or at least intermediate risk based on current
conditions, rather than banking on long -overdue repairs.
VIII. DEQ's risk determination process has fundamental flaws.
DEQ's approach to classifying groundwater risk is fundamentally flawed because it is
arbitrary, is not authorized by the CAMA statute, and it ignores the data gaps and uncertainty in
Duke's reports, as set forth below.
A. DEQ used arbitrary cutoffs.
DEQ has decided arbitrarily that ten North Carolinians' well water can be poisoned
without requiring Duke to excavate its coal ash to lined, dry storage. DEQ only requires
excavation —via an "Intermediate" risk classification —if 11 or more people's drinking water is
actually or potentially contaminated.168 There is no support for such an arbitrary cutoff.
Allowing even one North Carolinian's water to be poisoned is unacceptable. For DEQ to
knowingly allow the actual or potential contamination of any family's drinking water fails the
agency's most basic responsibility to the state. Allowing Duke Energy to leave coal ash in
contact with groundwater supplies under a cap -in -place scenario would be just such a failing.
This arbitrary approach also ignores the likelihood that a family served by contaminated
well water could have more children, or the house could be sold to a larger family, so that more
than 10 people would now be affected. Basing the key decision about lined storage of coal ash
on an arbitrary snapshot is short-sighted and indefensible.
More fundamentally, DEQ's approach ignores the importance of protecting groundwater
as a public resource. If groundwater is being contaminated beyond Duke Energy's property
boundary, an important public resource that belongs to all North Carolinians is being harmed. In
addition, future economic development and new housing in rural areas not served by municipal
water depend on clean drinking water supplies. Duke cannot be allowed to leave its coal ash in
contact with these groundwater supplies in perpetuity —it must be required to place the ash in
lined, dry storage.
For the same reasons, DEQ's claim that a "Low Risk" classification for groundwater is
appropriate if "alternate water is made available to all residents whose wells are being impacted
by coal ash impoundments" is unsupportable.169 This approach ignores the importance of
protecting the resource for future uses, and of protecting the Dan River and the natural
environment for all North Carolinians.
168 DEQ, Coal Combustion Residual Impoundment Risk Classifications at 15 (Jan. 29, 2016) (emphasis added).
169 Id. at 39.

It is also inconsistent with the General Assembly's approach under CAMA. CAMA
separately requires the provision of alternate water where a coal ash impoundment has
contaminated a drinking water well.170 That requirement applies irrespective of the
impoundment risk classification required by CAMA, and there is no basis for using the
separately required provision of alternate water to downgrade the risk rating for an
impoundment.
In addition, at Duke Energy's Sutton site in Wilmington, Duke was forced under public
pressure to agree to fund a water line to residents of the Flemington community, yet even after
that announcement, the General Assembly still rated the site High Priority and mandated
excavation to lined, dry storage, thereby removing the source of the ongoing groundwater
pollution. In a deposition this summer, DEQ Assistant Secretary Tom Reeder pointed out that
Duke Energy's groundwater pollution at Sutton had "nuked this whole drinking water source for
the Wilmington area." 171 DEQ's groundwater risk classifications cannot use the separately
required provision of alternate water to allow Duke to "nuke" public drinking water supplies and
avoid having to remove the source of the pollution.
B. DEQ's use of a "low -intermediate" classification is invalid.
If up to ten people are exposed to contaminated groundwater, DEQ has proposed an
invented rating of "Low/Intermediate Risk." 172 This is not a valid classification under CAMA.
The statute required DEQ to propose ratings for all of Duke Energy's impoundments by
December 31, 2015.173 There are only three options —Low, Intermediate, and High Risk,174 and
with good reason. After the Dan River spill and a federal criminal grand jury investigation into
Duke Energy and DEQ's handling of coal ash, the law is supposed to ensure that the inaction that
has characterized coal ash regulation in North Carolina for decades did not continue. The statute
required DEQ to make a clear recommendation at every site whether to require lined storage, and
allow the public to comment on a definite rating. Instead, DEQ has punted, avoiding that key
decision and incentivizing Duke Energy to keep delaying and obscuring the extent of its
contamination.
DEQ states, correctly, that Duke Energy's submissions have been deficient. The question
is whether Duke Energy should be allowed to benefit from these shortcomings. The answer
should be no. DEQ should take the approach that lined, dry storage is required until proven
otherwise, and place the burden on Duke Energy to demonstrate that the coal ash could be safely
stored without a liner. But instead, DEQ has proposed a non -classification that fails to answer
the key question for protection of groundwater: whether or not Duke will be required to store its
coal ash in a lined, dry, properly designed facility.
170 NCGS § 130A-309.211(c).
171 John Murawski, Top NC environmental official wanted to fine Duke Energy $50 million over coal ash, Charlotte
Observer (Oct. 8, 2015), http://www.charlotteobserver.com/news/business/article38272179.html#storylink=cpy.
172Id. (emphasis added).
17' N.C. Gen. Stat. § 130A-309.213(a).
174Id. at § 130A-309.213(b)
51

There is no legal basis for the "Low -Intermediate" classification. If there is not clear and
convincing evidence to demonstrate that cap -in -place would protect public resources, excavation
should be required.
C. DEQ's approach ignores significant data gaps and uncertainty.
DEQ has proposed groundwater risk classifications based on only one "key factor."
Unfortunately, DEQ chose to rely exclusively on self-serving claims from Duke Energy that are
not supported by its own studies. DEQ says its groundwater key factor is as follows: "Based on
the data provided in CSA Report and results of the initial groundwater modeling presented in
the CAP Reports, the number of down -gradient receptors (well users) 1,500 feet from the
compliance boundary that are potentially or currently known to be exposed to impacted
groundwater from source(s) or migration pathways related to the CCR impoundments."175 In
other words, for this factor DEQ looked only at what Duke chose to admit in its reports by
"provid[ing]" data or "present[ing]" modeling. This approach ignores the obvious and serious
deficiencies, misrepresentations, and gaps in Duke's reports, some of which are identified
elsewhere in DEQ's classifications but are ultimately ignored in the ratings for groundwater and
for the overall site classification.
This use of a single key factor that takes Duke's deficient studies at face value leads to
indefensible results at Buck.
For its "Groundwater Key Factor," DEQ states all three ash basins that "[b]ased on the
information received to date, there appears [sic] to be no downgradient receptors located 1,500
l
feet downgradient of the impoundment compliance boundary," 76 DEQ clarifies this remark in
its explanation of the Groundwater key factor: "[t]here are no reported supply wells within 1500
feet downgradient of the impoundment compliance boundary." 177 In other words, DEQ has
relied for its "key factor" on whether or not Duke Energy chose to admit it is contaminating
neighboring wells. Because Duke did not report that drinking wells were affected, DEQ gives
these impoundments a "Low Risk" rating. There is no support for this approach, given that DEQ
itself has identified significant data gaps left by Duke Energy.
D. Ratings based on "Key Factors" are illegal.
CAMA sets out an extensive list of factors that DEQ must consider in proposing its
classifications.178 CAMA requires DEQ to consider all of these factors, rather than ignoring
most of them in favor of a handful of supposed "key factors." It plainly states that DEQ "Shall. .
. at a minimum, consider all of the following" factors listed in the statute. 179 DEQ's "key
factor" approach violates this requirement.
175 DEQ, Coal Combustion Residual Impoundment Risk Classifications at 15 (Jan. 29, 2016) (emphasis added).
176 Narrative at 39 (emphasis added).
177 Id. at 41 (emphasis added).
17s N.C. Gen. Stat. § 130A-309.213(a).
179 Id.
52

DEQ's staff compiled detailed ratings that fully analyzed these factors, but DEQ
ultimately has put forward an approach that does not consider the required factors in any
identifiable way. Instead, DEQ has arbitrarily invented a single "key factor" for groundwater,
surface water, and dam safety, and ignored all the other factors. It has even moved these other
factors to an appendix at the back of its Narrative, indicating their marginalized status. DEQ
candidly admits that its discussion of other groundwater factors beyond the "key factor" is an
empty exercise: "The decision -making process allows for scoring of high, intermediate, or low
risk for all factors that relate to those criteria identified in CAMA, but is focused on assigning the
overall groundwater risk classification based on" a single "key factor."180 In other words, all
factors were assigned an individual rating, but only one factor determined the overall
groundwater risk classification.
The folly of this approach is evident from the example given above: for the "key factor"
that determined the groundwater risk rating, DEQ relied on Duke's statements in its reports that
it is not contaminating neighboring wells, while ignoring the uncertainty regarding that very
point, which DEQ acknowledged — to no effect — in one of the factors buried in the appendix.
The "key factor" approach has also distorted DEQ's surface water analysis. For example,
the statute lists as a required factor for consideration "[t]he proximity of surface waters to the
impoundment and whether any surface waters are contaminated or threatened by contamination
as a result of the impoundment," but this factor appears to have played no role in DEQ's
classification at Buck —despite the fact that numerous relevant factors merited High or
Intermediate Risk ratings at Buck.
E. DEQ's decision must be based on the risks present at the time DEQ makes its
determination, not based on future actions that might or might not occur,
and that might or might not help even if they do.
Instead of proposing to classify the risks at Buck based on the longstanding and ongoing
risks and hazards at Buck, DEQ is implicitly and in some cases explicitly closing its eyes to
present risks, and instead imagining what the risks might be in the future. For example, DEQ
proposes to downgrade the dam safety risk based on possible future repairs. In addition, Duke
Energy's reports focus on what might happen to the risks if the ash is capped in place, rather than
cleaned up. This futuristic risk assessment has no basis in the Coal Ash Management Act. DEQ
also proposes to classify a site as low risk if alternate water is provided. Speculative provision of
water for an indeterminate period of time does nothing to protect the valuable groundwater
resource at stake here, and does not provide a long-term solution. For all of these reasons,
DEQ's determination must be based on the risks present today, rather than on future promises by
Duke Energy.
F. It is inappropriate for DEQ to consider costs in any way in its decision.
The General Assembly did not include cost of closure and remediation in the list of
studies and information Duke Energy is required to submit to DEQ in preparation for
180 DEQ, Coal Combustion Residual Impoundment Risk Classifications at 13 (Jan. 29, 2016) (emphasis added).
53

classification.181 Nor is cost a factor the General Assembly identified for DEQ to consider as it
develops proposed classifications.182 CAMA does not permit DEQ to temper its analysis of the
options and timetable for closure and remediation of coal ash impoundments. Indeed, CAMA
specifically leaves any cost consideration until later in the process, at the closure plan stage: The
only permissible consideration of costs under CAMA is by the Coal Ash Management
Commission with respect to a coal ash impoundment closure plan — not the risk
classifications.183
Nonetheless, cost concerns permeated DEQ's prioritization analysis. The very first
paragraph of DEQ's Narrative is dedicated to cost concerns: "[These classifications] are of
critical importance because of the environmental impact and closure costs associated with each
classification. Impoundments classified as intermediate or high must be excavated at a potential
cost of up to $10 billion for all impoundments, while environmentally protective, less costly
options are available for low priority impoundments. Closure costs could be passed on to the
ratepayer. "184 DEQ's own press release announcing public hearings on the draft classifications
provided that "[t]he classification process is an important step in cleaning up coal ash to protect
the environment and ratepayers."185 Restated, DEQ apparently views its role in this process as
integral to protecting ratepayers by ensuring cleanup is not too costly. Concerns over cost
permeated DEQ's analysis in violation of CAMA.
Furthermore, the cost numbers quoted by DEQ are Duke's numbers, not an independent
evaluation. Santee Cooper is excavating about 10% of the amount that Duke would be required
to excavate for its entire fleet for $220 million. In fact, Duke itself has not claimed that the
excavation and removal of ash will cost $10 billion. Duke admits that $2 billion of the number is
the cost of going to dry storage in the future, and that excavation and removal will cost $6 to $8
billion. Duke's current activities will cost, according to Duke, $4 billion. So, the incremental
cost —even according to Duke —should be $2 to $4 billion. DEQ, even according to Duke's
numbers, is overstating the amount at issue tremendously. Moreover, compared to Santee
Cooper's real world experience, DEQ, by accepting Duke's numbers, is overstating the cost by
three to five times. 186 Further, both SCE&G and Santee Cooper in South Carolina have stated
that the excavations of all their coal ash will not require rate increases. An independent study of
Duke Energy's claims has shown the same thing.187
IX. Excavation and Placement in Lined Storage or Recyclint! Is Feasible at Buck.
Excavation is a proven option at Buck. Less than half a decade ago, Duke Energy
excavated 120,000 cubic yards from one of the Buck coal ash ponds and moved it to an on -site
location. Unfortunately, Duke Energy chose not to take the protective and relatively simple step
of lining this on -site location before placing the ash there. Duke Energy originally planned to
'81 See N.C. Gen. Stat. § 130A-309.209, 210.
182 See id. § 130A-309.213.
113Id. § 130A-309.214(d).
184 DEQ, Coal Combustion Residual Impoundment Risk Classifications at 2 (Jan. 29, 2016) (emphasis added).
'85 https://deq.nc.gov/press-release/deq-announces-14-public-meetings-draft-coal-ash-pond-closure-deadlines.
186 https://www.duke-energy.com/news/releases/201404220Lasp.
187 http://www.ieefa.org/wp-content/uploads/2014/06/IEEFA-Duke-Study-Summary-Final-6-10-141.pdf.
54

create a "double lined" landfill on site that would hold one -tenth of the coal ash at Buck, but did
not follow through with this plan.
Moreover, the Buck site has ready access to rail lines that were formerly used to bring
coal to the plant. Duke Energy representatives have stated that Duke can readily move 1 million
tons of coal ash per year by rail, meaning that even under Duke's own estimates (which may be
prone to bias), Duke Energy could clean up Buck using this method alone in five years.188 Duke
Energy has also indicated that it is even easier to move coal ash by rail at a retired coal plant,
such as Buck. Moreover, Duke Energy is already planning to excavate and give full protections
to all other legacy coal ash ponds in the state. Finally, if Duke Energy moves the ash out of the
groundwater and away from the river to a lined, dry storage option onsite, it could move the ash
even more quickly.
The demand for ash is expected to exceed supply in North Carolina in 2016 and 2017.189
Concrete manufacturers are even planning to import ash from Asia.190 And concrete
manufacturers have filed pleas with the utilities commission to encourage Duke Energy to give
up its ash for recycling into concrete.
X. The Pollutants Found at Buck Cause Serious Health Problems, and Pose a High
Risk.
High concentrations of numerous pollutants common in coal ash —including hexavalent
chromium, vanadium, iron, manganese, aluminum, antimony, arsenic, barium, boron, cobalt,
copper, and zinc —have all been found in people's drinking water wells and in the leaks
springing from the ponds at the Buck. These pollutants cause severe health effects, as described
below. These health problems are exacerbated when people are exposed to multiple pollutants.
Instead of requiring Duke Energy to clean up its coal ash to halt the contamination, DEQ has
instead eliminated standards that are designed to protect people's health. In deciding the risk
classifications for coal ash ponds, DEQ must recognize the true risk that the people exposed to
these coal ash contaminants face, rather than moving the goalposts for the benefit of Duke
Energy.
A. The pollutants detected at Buck cause grave health problems.
According to the ATSDR, some studies show that people exposed to high levels of
aluminum may develop Alzheimer's disease. People with kidney disease have trouble removing
aluminum from their system.
Arsenic is a known carcinogen that causes multiple forms of cancer in humans. It is also
a toxic pollutant, 40 C.F.R. § 401.15, and a priority pollutant, 40 C.F.R. Part 423 App'x A.
Arsenic is also associated with non -cancer health effects of the skin and the nervous system.
188 http://thestokesnews.com/news/4245/duke-explains-options-for-belews-creek
189 Duke Coal Ash Forum Presentation at 76 (Aug. 13, 2015).
190 Bruce Henderson, Concrete Makers Look to Import Coal ash, Charlotte Observer (Mar. 31, 2016),
http://www.charlotteobserver. com/news/business/article69284762.html.
55

Antimony is listed as a toxic pollutant, 40 C.F.R. § 401.15, and is associated with
reduced lifespan, decreased blood glucose, and altered cholesterol in rodents, and with vomiting
and cardiac and respiratory effects in humans.
Barium can cause gastrointestinal problems and muscular weakness. Ingesting large
amounts, dissolved in water, can change heart rhythm and can cause paralysis and possibly
death. Barium can also cause increased blood pressure.
Oral exposure to boron has led to developmental and reproductive toxicity in multiple
species. Specific effects include testicular degeneration, reduced sperm count, reduced birth
weight, and birth defects.
Chromium is a toxic pollutant, 40 C.F.R. § 401.15, and oral exposure to hexavalent
chromium, a human carcinogen, has been found to cause cancers of the stomach and mouth.
Exposure to the skin may cause dermatitis, sensitivity, and ulceration of the skin. It is well -
established in scientific studies that hexavalent chromium, commonly found in coal ash waste,
can cause cancer in humans.191 Exposed individuals are also vulnerable to other health
problems, from skin and eye irritation to kidney and liver damage.192 Although attention has
historically focused on the lung cancer risk of hexavalent chromium inhalation,193 evidence is
mounting that its consumption through drinking water is also carcinogenic. In response to
increasing scientific and public concern about the hexavalent chromium in groundwater,
California requested that the National Toxicology Program examine the substance's risks
further.194 The resulting 2-year study concluded that oral consumption of hexavalent chromium
can cause cancer in rodents, as demonstrated by an increase in tumors in locations rarely seen in
the animals.195 The evidence is not limited to animals: a study in Greece, for example, found
increased rates of liver cancer in residents exposed to hexavalent chromium in drinking water.196
IARC has determined that cobalt is possibly carcinogenic to humans. Short-term
exposure of rats to high levels of cobalt in the food or drinking water resulted in effects on the
blood, liver, kidneys, and heart. Longer -term exposure of rats, mice, and guinea pigs to lower
levels of cobalt in the food or drinking water results in effects on the same tissues (heart, liver,
kidneys, and blood) as well as the testes, and also caused effects on behavior. Sores were seen on
the skin of guinea pigs following skin contact with cobalt for 18 days.
191 National Toxicology Program, Hexavalent Chromium,
https://ntp.niehs.nih.gov/ntp/factsheets/ntphexavchrmfactr5.pdf, McNeill, Laurie et al., State of the Science of
Hexavalent Chromium in Drinking Water 1 (2012), Water Research Foundation, available at
http://www.waterrf org/resources/lists/publicprojectpapers/attachments/2/4404_projectpaper.pdf
192 National Toxicology Program, Hexavalent Chromium,
https://ntp.niehs.nih.gov/ntp/factsheets/ntphexavchrmfactr5.pdf
193 Id
194 Id
195 Stout, Matthew et al., Hexavalent Chromium Is Carcinogenic to F344/NRats and B6C3F1 Mice after Chronic
Oral Exposure, 117 Environmental Health Perspectives 716-22 (2009); McNeill et al., at 3.
196 Linos, Athena et al., Oral ingestion of hexavalent chromium through drinking water and cancer mortality in an
industrial area of Greece, 10 Environmental Health 50 (2011); McNeill et al, at 2.
M.

Copper is a toxic pollutant, 40 C.F.R. § 401.15, and according to EPA, people who
consume drinking water with high levels of copper can experience gastrointestinal distress, and
with long-term exposure may experience liver or kidney damage.
Iron can render water unusable by imparting a rusty color and a metallic taste and causing
sedimentation and staining; to prevent these effects the EPA has set a secondary drinking water
standard of 3 00 ug/L.
Manganese is known to be toxic to the nervous system. Manganese concentrations
greater than 50 ug/L render water unusable by discoloring the water, giving it a metallic taste,
and causing black staining. Exposure to high levels can affect the nervous system; very high
levels may impair brain development in children.
Zinc is a toxic pollutant, 40 C.F R. § 401.15, and according to ATSDR, ingesting high
levels of zinc may cause stomach cramps, nausea, and vomiting. Ingesting high levels of zinc for
several months may cause anemia, damage the pancreas, and decrease levels of high -density
lipoprotein (HDL) cholesterol.
According to the U.S. Agency for Toxic Substances and Disease Registry (ATSDR),
vanadium can cause nausea, diarrhea, and stomach cramps. And the International Agency for
Research on Cancer (IARC) has determined that vanadium is possibly carcinogenic to humans.
High concentrations of total dissolved solids can make drinking water unpalatable and
can cause scale buildup in pipes, valves, and filters, reducing performance and adding to system
maintenance costs.
B. These health problems are magnified and multiplied when people are
exposed to multiple pollutants.
Concurrent exposure to multiple contaminants may intensify existing effects of individual
contaminants, or may give rise to interactions and synergies that create new effects. Where
several coal ash contaminants share a common mechanism of toxicity or affect the same body
organ or system, exposure to several contaminants concurrently produces a greater chance of
increased risk to health.
A recent meta -study cited by the U.S. Environmental Protection Agency found that the
compounding effects of multiple -pollutant exposures may increase risk by a factor of four,
beyond the additive effects of the individual risk presented by each pollutant.197
197 Alan Boobis et al., Critical Analysis of Literature on Low -Dose Synergy for Use in Screening Chemical Mixtures
for Risk Assessment, 41 Crit. Rev. Toxicol. 369-83 (2001), available at
http://www.ncbi.nlm.nih.gov/pubmed/21309635 (cited by EPA, A Summary of Publications on Methods and Tools
for Assessing Cumulative Risk, Project Summary (Sept. 30, 2012),
http://cfpub.epa.gov/si/si_public_record_report.cfm?dirEntryld=246553&searchAll=hazardous&NoArchive=l &SIT
ype=PR&fed_org_id=111).
57

Of the wells tested at Buck, many showed high levels of numerous pollutants. In
addition, the people who lived in the shadow of the Buck smokestacks for decades were also
exposed to abundant toxic and pervasive air pollutants. The additional risk to individuals at
Buck through continued groundwater contamination may therefore be far more than the sum of
the risks of each pollutant they drink.
C. Many people at Buck are exposed to hexavalent chromium and vanadium at
levels that present serious health risks.
Hundreds of families across the state received letters telling them that their water is not
safe to drink, based on high concentrations of hexavalent chromium and vanadium. More than
70 families received these letters at Buck. The letters were based on the risk levels established
by the N.C. Department of Health and Human Services pursuant to the well -established safety
standards that are accepted in North Carolina and across the nation. These safety standards at set
a one -in -a -million risk threshold.
The letters informing people that their water was not safe to drink due to vanadium or
hexavalent chromium were later revoked, despite the fact that both the contamination levels and
the risks to these people had not changed.
Hexavalent chromium has been detected at Buck at levels over 300 times
higher than the health -based standard.
At least five families' wells near Buck have more than 20 ppb hexavalent chromium.
The highest known level detected at Buck is 22.3 ppb, 319 times more than the health -based
standard necessary to reduce people's risk to one -in -a -million. Instead of a one -in -a -million
cancer risk, these families live with a more than one -in -three -thousand risk ofgetting cancer
from drinking their water. Moreover, this one -in -three -thousand risk is based on the presence of
hexavalent chromium alone. If these families are exposed to other contaminants, as many of
them are, the combined effect of these pollutants can increase the risk up to four-fold.198 In other
words, families exposed to this level of hexavalent chromium plus other pollutants in their water
could have a cancer risk as high as one-in-750.
Yet this past month, DEQ and DHHS sent letters to these families telling them that it
was safe to drink their water. This disregard for the safety of residents living near Buck
suggests that DEQ is not fully grappling with the true risk that people face from coal ash.
Instead, DEQ turning a blind eye to the magnitude of the risk caused by storing coal ash in
unlined pits.
198 Alan Boobis et al., Critical Analysis of Literature on Low -Dose Synergy for Use in Screening Chemical Mixtures
for Risk Assessment, 41 Crit. Rev. Toxicol. 369-83 (2001), available at
http://www.ncbi.nlm.nih.gov/pubmed/21309635 (cited by EPA, A Summary of Publications on Methods and Tools
for Assessing Cumulative Risk, Project Summary (Sept. 30, 2012),
http://cfpub.epa.gov/si/si_public_record_report.cfm?dirEntryld=246553&searchAll=hazardous&NoArchive=l &SIT
ype=PR&fed_org_id= l 11).
6V

2. Levels of hexavalent chromium at Buck are vastly higher than levels in
municipal water supplies.
Contrary to DEQ's assertions, it is simply not true that the contamination in people's
wells around Bucks is the same as the contamination in municipal water supplies. At least five
people's wells near Buck have more than 20 ppb hexavalent chromium, and the average
hexavalent chromium level detected at Buck is 2.5 ppb. These levels are far higher than the
highest hexavalent chromium levels detected in the Salisbury municipal water supply, which has
a mean hexavalent chromium detection history of 0.073 ppb just over the 0.07 one -in -a -million
threshold.
Public Water Supply Hexavalent Chromium Concentrations
(screening level as required by NC's 15A 02L regulations is 0.07 ug/L; all values in ug/L)
f6
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Mean
0.067
0.073
0.066
0.056
0.061
0.034
0.057
0.048
0.043
0.044
0.034
Highest
0.12
0.13
0.13
0.099
0.075
0.05
0.11
0.089
0.08
0.06
0.048
D. It is inappropriate for DEQ to turn a blind eye to the health risks of
hexavalent chromium and vanadium, simply because the federal government
has been slow to act on these pollutants.
More than three million North Carolina citizens depend on private well water for their
drinking water more than in all but three other states.19 For decades, North Carolina has
recognized the importance of its groundwater with standards designed to protect that resource.
The state's groundwater rules emphasize that "the best usage of the groundwaters of the state is
as a source of drinking water" and that "groundwaters generally are a potable source of drinking
water without the necessity of significant treatment."200 As such, the rules "are intended to
maintain and preserve the quality of the groundwaters, prevent and abate pollution and
199 N.C. Department of Health and Human Services, Well Water & Health, Facts and Figures,
http://testyourwell.nc.gov/oee/wellwater/figures.html; U.N.C. Gillings School of Global Public Health,
Groundwater in North Carolina, http://sph.unc.edu/superfund-pages/ncwellwater/groundwater-in-north-carolina/.
200 15A N.C. Admin. Code 2L.0103(a).
M

contamination of the waters of the state, protect public health, and permit management of the
groundwaters for their best usage by the citizens of North Carolina."201
Given the importance of groundwater as a resource and the pervasive reliance on it in
North Carolina, DEQ has recognized that the state's groundwater standards "are, in most cases,
more health protective than the federal drinking water standards."202 In fact, EPA has yet to
finalize a federal drinking water standard for harmful pollutants like hexavalent chromium and
vanadium.203 And while federal drinking water standards "take into account a vast array of
inputs, including the cost and technology available," North Carolina's health -based standards
"are calculated to protect the groundwater resource and human health. ,204 North Carolina's
common-sense standards for groundwater protect both public and private drinking water —a
resource that is difficult to replace once it is contaminated.
North Carolina is in even more need of standards for hexavalent chromium and
vanadium, now that testing that has revealed high concentrations of contaminants such as
hexavalent chromium and vanadium around leaking coal ash ponds in North Carolina. Now,
more than ever, North Carolinians need the protections provided by the health -based standards
for these pollutants. All available evidence continues to show that hexavalent chromium and
vanadium pose health risks when they are present at levels above the current standards.
Other public health officials are beginning to take action. Responding to "emerging
scientific evidence" on the long-term risks of hexavalent chromium, in 2011 the U.S.
Environmental Protection Agency (EPA) issued guidance on hexavalent chromium monitoring
for water supplies nationwide.205 EPA is currently reviewing hexavalent chromium for drinking
water risks in anticipation of possibly regulating it under the Safe Drinking Water Act.206
California issued a stringent 0.02 parts per billion (ppb) public health goal for hexavalent
chromium in 2010, and established the nation's first MCL for hexavalent chromium in 2014.207
To date, however, no federal MCL exists for hexavalent chromium.208
North Carolina's recently -revoked screening level for hexavalent chromium is by no
means the most stringent standard in the region or the country. Tennessee, for example, recently
201 Id
202 DEQ, Well Water Testing, http://portal.ncdenr.org/web/guest/wellwatertesting.
20' 40 C.F.R. § 141.62; 15A N.C. Admin. Code 2L.0202(h); Appendix #1, IMACs,
http://portal.ncdenr.org/c/document_library/get_file?uuid=23 80a642-Of7e-42e2-8e59-
lc32087724af&groupld=38364.
204 DEQ, Well Water Testing.
205 EPA, EPA Issues Guidance for Enhanced Monitoring of Hexavalent Chromium in Drinking Water (Jan. 11,
2011)
http://yosemite.epa.gov/opa/admpress.nsf/a883 dc3da7094f97852572a00065d7d8/93 a75b03 l49d30bO852578150060
Of62!OpenDocument; Physicians for Social Responsibility, Earthjustice, and Environmental Integrity Project, EPA's
Blind Spot: Hexavalent Chromium in Coal Ash 2 (2011), available at
http: //earthj ustice. org/sites/default/files/CoalAshChromeReport.pdf
206 EPA, Toxicological Review of Hexavalent Chromium, External Review Draft (Sept. 2010), EPA/635/R-10/004A;
McNeill et al.
207 California Department of Public Health, First Drinking Water Standard for Hexavalent Chromium Now Final
(June 3, 2014), available at https://www.cdph.ca.gov/Pages/NR14-053.aspx.
208 40 C.F.R. § 141.62, 15A N.C. Admin. Code 2L.0202(h).

relied on a 0.035 ppb hexavalent chromium risk -based screening level calculated by EPA209 in
letters to homeowners using wells near coal ash cites a level twice as strong as North
Carolina's 0.07 ppb.210 Like North Carolina's health screening level, this risk -based screening
level represents EPA's best estimate of the hexavalent chromium concentration at which a
resident drinking tap water over a lifetime would have an incremental cancer risk of one in one
million.211 California's Public Health Goal for hexavalent chromium is more than three times as
stringent, at just 0.02 ppb.zlz North Carolina's health screening level is the least protective of the
three, and certainly should not be weakened.
Because this health screening level, like the levels used in California and Tennessee,
represents a purely health -based standard, comparison to the federal MCLs or analogous state
standards is inappropriate. The health screening level is an objective, widely -used, scientific
calculation of public health risk, specifically the hexavalent chromium concentration at which an
additional one in one million people consuming that water over a lifetime would develop cancer.
Importantly, it was not influenced by factors like the technological availability or economic cost
of treatment.
Federal MCLs, by contrast, takes into account the cost to the polluter and technologies.213
To compare the health screening level to a standard not based purely on health risk would
compare apples to oranges and undermine the integrity of the health screening level.
XI. Coal Ash at Buck Poses Additional Threats that DEO Did Not Consider.
The coal ash lagoons pose additional threats to fish, wildlife, and to the people who fish
and hunt wildlife that is exposed to pollutants in the coal ash lagoons. Video inspections by
DENR show fish swimming in the pipes that connect the coal ash lagoons to each other and to
the Yadkin River. The coal ash lagoons are partially bordered by Alcoa game lands, and DENR
has identified at least one animal trail extending from the ash lagoons. Duke also invites other
wildlife to live and feed in and around its coal ash lagoons, including osprey, which nest atop
platforms that extend out of the coal ash lagoons themselves.
XII. The Commenters
The Southern Environmental Law Center ("SELC") is a non-profit legal advocacy group
dedicated to protecting the environment of the South. SELC works with more than 100 partner
groups in six southeastern states. SELC has been actively involved in a variety of efforts to
protect groundwater, surface water, and communities in the Southeast from coal ash.
209 EPA, Risk -Based Screening Table - Generic Tables, http://www2.epa.gov/risk/risk-based-screening-table-
generic-tables (calculated for hexavalent chromium exposure through tap water).
210 E.g., Letter from Tisha Calabrese Benton & Patrick Flood, Tennessee Department of Environment &
Conservation, to Homeowners at Braham Well (Oct. 6, 2015).
211 EPA, Regional Screening Table User's Guide 5.14 (June 2015), http://www2.epa.gov/risk/regional-screening-
table-users-guide June-2015.
212 California Department of Public Health, First Drinking Water Standard for Hexavalent Chromium Now Final
(June 3, 2014), available at https://www.cdph.ca.gov/Pages/NR14-053.aspx.
213 Safe Drinking Water Act, 42 U.S.C. § 300g-1(b)(4)(B), (C), (D).
61

The Yadkin Riverkeeper's mission is to respect, protect, and improve the Yadkin -Pee
Dee River Basin through education, advocacy, and action. To carry out this mission, Yadkin
Riverkeeper provides programs and activities for its over 500 members, including river clean-ups
and initiatives to reduce stormwater runoff from construction sites. Yadkin Riverkeeper brings
legal action, when necessary, to enforce state and federal environmental laws on issues that
affect the Yadkin River Basin.
Waterkeeper Alliance, whose membership includes Yadkin Riverkeeper, is a global
movement of on -the -water advocates who patrol and protect over 100,000 miles of rivers,
streams, and coastlines in the United States and throughout the world, including the Yadkin
River. Waterkeeper Alliance brings legal action, when necessary, to assist and support its
member organizations' efforts to enforce state and federal environmental laws to protect rivers,
streams, and coastlines.
Sincerely,
Myra Blake
Staff Attorney
cc (via email):
Bruce Parris, DEQ Mooresville Regional Office
62

From: Perkins, Jay C <Jay.Perkins @duke-energy.corn>
Sent: Thursday, March 24, 2011 9:09 AM
To: Zalme, Nob J <[e-mail]>; Brown, David R
<David. Brown2 @duke -energy. corn>; Neill, Monte W <Monte.Neill@duke-
energy.com>; Judd, Mike <Mike. Juddgduke-energy. c om>; Herrick, Dayna J
<Dayna.Herrick�duke-energy.com>
Subject: RE: Drinking Water Sulfate
'Mil
From: Zalme, Nob J
Sent: Thursday, March 24, 2011 6:55 AM
To: Perkins, Jay C; Brown, David R; Neill, Monte W; Judd, Mike; Herrick, Dayna J
Subject: FW: Drinking Water Sulfate
Allen has an excellent point. The drinking water well is also downstream of the coal Pile!
�A,,b r Zahne
(5 Coordinator
'1��a�c Lirre�t,�y�_:93tt�'1.;'tect�n �i�a.t2t>�t
(,'eff ` 33 is 62-0221
From: Stowe, Allen
Sent: Thursday, March 24, 2011 6:51 AM
To: Zalme, Nob J
Subject: RE: Drinking Water Sulfate
Don't forget about the coal pile as well, which is why we tried to get them to abandon this well and install a new
one upgradient of the ash basin and coal pile...
Allen Stowe
FHS Water Management
Dube Energy Carolinas
704-382-4300 (Office)
704-516-554 (Cell)
Allen.St2At@ uke-ener�
From: Zalme, Nob J
Sent: Thursday, March 24, 2011 6:08 AM
To: Perkins, Jay C
Cc: Brown, David R; Neill, Monte W; Judd, Mike; Herrick, Dayna J; Stowe, Allen
Subject: RE: Drinking Water Sulfate
Jay,
Buck received results on the first sampling event of the new ash basin groundwater wells. One of the
groundwater wells downstream of the ash basins also has elevated sulfate. Note that Buck's drinking water well
is located downstream of the ash basins. I suppose it is possible for the ash basins to be contributing to the
elevated sulfate issue.
Duke-SEA-Meck-00037749

51'o mare
,fit-HS ('ooidinator
;auk.€ ;;rerv-13ax(S'tearra Stahon
€ y ic:e; (70= ,64 -2706
("eff 1.336,462-0221
From: Zalme, Nob J
Sent: Wednesday, March 23, 2011 6:58 AM
To: Perkins, Jay C
Cc: Brown, David R; Neill, Monte W
Subject: RE: Drinking Water Sulfate
Jay,
Buck's drinking water well has historically had elevated sulfate. In fact, sulfate was higher on the sampling event
three years ago than it was this year. NCDENR indicated that sulfate is a secondary standard and it is really not
an issue. Corrective action nor treatment is required. Were you able to verify lab data on the iron analysis? As
you know, we have resampled for iron at the well and normal sampling point.
M
r,W6 ZAttc
'043 Coordinator
Du1 eEnergy-CBucd ,,5teaiu Station
£;eff, :3.36,4 2-0221
From: Perkins, Jay C
Sent: Tuesday, March 22, 2011 4:20 PM
To: Zalme, Nob J
Subject: Drinking Water Sulfate
Nob, where did we say the sulfate in the drinking water at Buck was coming from. I want to include
this in our monthly highlights.
Thanks,
Jay Perkins
Duke Energy Analytical Laboratory
W-980-875-5348
C-704-796-6598
Duke-SEA-Meck-00037750

From:
Sent:
To:
Cc:
Subject:
Attachments:
I did... he agreed that:
William Miller <[e-mail]>
Wednesday, March 18, 2009 2:53 PM
Sullivan, Ed M
Schaeffer, Malcolm
RE: BUCK STEAM STATION
image001.jpg; Buck_Site_Water_Well.pdf
1) going deeper is not guarantee that the water quality would improve.
2) Going as far south as possible on Dukeville Rd and staying on the west side would offer the best
chance for minimizing impacts from the ash basin.
Malcolm said he would send brief note.
Thanks... Bill
William M. Miller, PE, PI_S
Senior Project Engineer
ltSWE
ENGINEERING INTEGRITY.
SWE, Inc.
44 Buck Shoals Road, Unit C3
Arden NC 28704;,';'
Ph: 828-687-9086
Fax:[phone]
[e-mail]
www.smeinc.com
This electronic message and its attachments are forwarded to you for convenience and "for information only." The
message may represent a summary with limitations, conditions and further explanations omitted in the interest of
brevity and time constraints. The contents of this electronic message and any attachments may be preliminary and
incomplete, subject to review and revision. If this electronic transmittal contains Findings, Conclusions or
Recommendations, S&ME, Inc. will submit a follow-up hard copy via mail or overnight delivery for your records, and this
hard copy will serve as the final record. In the event of conflict between electronic and hard copy documents, the hard
copy will govern. This electronic message and any attachments transmitted with it are the property of S&ME, Inc. and
may contain information that is confidential or otherwise protected from disclosure. The information this electronic
message contains is intended solely for the use of the one to whom it is addressed, and any other recipient should
delete this electronic message and destroy all copies. VIER 4, Rev 1-- 031207
From: Sullivan, Ed M [mailto:[e-mail]]
Sent: Wednesday, March 18, 2009 1:17 PM
To: William Miller
Subject: Fw: BUCK STEAM STATION
Duke-SEA-Meck-00220884

Did you talk to Malcolm yet?
From: Stowe, Allen
To: Wylie, Robert R
Cc: Sullivan, Ed M
Sent: Wed Mar 18 13:07:21 2009
Subject: Re: BUCK STEAM STATION
Robert,
No word yet. I emphasized to Ed yesterday that we needed Malcolm's input prior to tomorrow's meeting
Allen Stowe - sent using Blackberry
704-516-5548
From: Wylie, Robert R
To: Stowe, Allen
Cc: Sullivan, Ed M
Sent: Wed Mar 18 12:59:55 2009
Subject: BUCK STEAM STATION
Allen,
Have you heard if Malcolm has reviewed Buck Steam Station for another well? Our meeting is tomorrow a.m. and this
information will be good to have.
Thanks,
Robert Wylie
Water Management
Environmental, Health and Safety
Office Phone Number.............[phone]
Cell Phone Number................[phone]
Fax Number ..........................[phone]
Mail Code: EC13K
Duke-SEA-Meck-00220885

Memorandum Regarding LAMA Requirements
I. Introduction
The purpose of this document is (1) to establish Duke Energy's compliance with the groundwater
assessment and corrective action requirements of the North Carolina Coal Ash Management Act
("CAMA"), and (2) to identify information relevant to the Department's assessment and prioritization of
coal ash surface impoundments for closure under CAMA. As explained further below, Duke Energy has
submitted all groundwater information required by CAMA to date and will continue to submit information
required by the Department pursuant to CAMA authority. As a result, there is no basis for any finding by
the Department that Duke Energy has failed to comply with CAMA. Further, the information submitted by
Duke Energy, supplemented by other available, relevant information, is sufficient for the Department to
make an evidence -based assessment of the factors that CAMA requires for impoundment prioritization;
as a result, it would be legal error for the Department to prioritize the surface impoundments without full
consideration of, and findings of fact on, each of the factors.
II. Compliance with Groundwater Assessment and Corrective Action
CAMA's groundwater assessment and corrective action provisions are located at North Carolina
General Statutes § 130A-309.211. Duke Energy has complied with subsections (a) and (b) as follows:
A. Subsection (a) - Groundwater Assessment
Subsection (a) requires Duke Energy to, at each of its surface impoundments, do three things:
(1) submit a proposed Groundwater Assessment Plan for approval by the Department, (2) begin
implementing a Groundwater Assessment Plan approved by the Department, and (3) submit a
Groundwater Assessment Report describing all exceedances of groundwater quality standards
associated with the impoundment. Duke Energy has met each of these requirements.
As you are aware, Duke Energy submitted draft Groundwater Assessment Plans for all of its
surface impoundments in North Carolina on September 26, 2014. The Department provided comments
on November 5, 2014, and Duke Energy submitted revised Groundwater Assessment Plans on
December 30, 2014. The Department conditionally approved the Plans on various dates earlier this year,
NCDENRO194488

and Duke Energy began implementing each plan within 10 days of approval. Groundwater Assessment
Reports describing all exceedances of groundwater quality standards associated with the various surface
impoundments were submitted to the Department -in August and September. The Department's approval
of the plans reflected a determination that the {Mans met CAMA requirements. Duke Energy's
implementation of the plans, including the conditions of approval, under the Department's close oversight,
further supports a conclusion that the requirements of Subsection (a) were met.
According to the plain language of Subsection (a), Duke Energy's compliance with the
requirements does not depend on the substantive content of the Groundwater Assessment Reports.
Duke Energy was required to make plans to assess various groundwater factors, which it did. The
Department approved the plans, thereby determining that the Plans would assess those groundwater
factors. Duke Energy diligently implemented the Plans. There is no further requirement in Subsection
(a), or anywhere else in CAMA, that the results of the groundwater assessments definitively establish or
disprove the existence of any condition at a site. In fact, CAMA anticipates that groundwater
assessments performed under Subsection (a) may not supply all the information desired by the
Department —Subsection (b)(a) requires Duke Energy to include in a proposed Groundwater Corrective
Action Plan °[ajny other information related to groundwater assessment required by the Department."
Had the General Assembly anticipated that Groundwater Assessment Reports would be definitive
documents, there would have been no need to authorize the Department to request additional information
in the proposed Corrective Action Plans.
B. Subsection (b) - Corrective Action
Similarly, Subsection (b) requires Duke Energy to do two things: (1) submit a proposed
Groundwater Corrective Action Plan, and (2) begin implementing the Groundwater Corrective Action Plan
once it has been approved by the Department. The deadline for completion of the first requirement has
not yet passed. The Department and Duke Energy agreed that the corrective action plans would be
submitted in two parts, and Duke Energy has submitted the first part for all fourteen sites with surface
impoundments. The deadline for submission of the second part has not yet arrived.
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NCDENRO194489

The Corrective Action Plans contain each of the elements from Subsection (b)(1) that were to be
included in the first part submittals. The Corrective Action Plans were prepared by qualified professionals
and contain work performed to the industry standard. Additional information will be submitted in the part
two submittals. It is premature to evaluate Duke Energy's compliance with this requirement until the
submittals are complete.
III. Prioritization of Surface impoundments
Under CAMA, the Department is charged with developing proposed classifications of
surface impoundments according to the procedures in North Carolina General Statutes § 130A-309.213.
The prioritization must be based on "a site's risks to public health, safety, and welfare; the environment;
and natural resources." N.C. Gen. Stat. § 130A-309.213(a). In assessing the risks, the Department must
evaluate groundwater data submitted under § 130A-309.211, discharge information submitted under §
130A-309.212, and any other information deemed relevant. Further, the Department must consider all of
the following:
oo Any hazards to public health, safety, or welfare resulting from the impoundment.
oo The structural condition and hazard potential of the impoundment.
oo The proximity of surface waters to the impoundment and whether any surface waters are
contaminated or threatened by contamination as a result of the impoundment.
ao Information concerning the horizontal and vertical extent of soil and groundwater
contamination for all contaminants confirmed to be present in groundwater in exceedance
of groundwater quality standards and all significant factors affecting contaminant
transport.
0o The location and nature of all receptors and significant exposure pathways.
ao The geological and hydrogeological features influencing the movement and chemical and
physical character of the contaminants.
co The amount and characteristics of coal combustion residuals in the impoundment.
co Whether the impoundment is located within an area subject to a 100-year flood.
ao Any other factor the Department deems relevant to establishment of risk.
The Department must issue written declarations, including findings of fact, documenting a
proposed risk classification.
NCDENRO194490

This section requires the Department to make decisions based on the available evidence
regarding each of the listed factors.' It would not be consistent with this requirement for the Department
to make a classification decision based solely on one factor and disregard valid information about the
others. Further, the section anticipates that the Department will make decisions before complete
information about a site is available. For example, it does not require the Department to completely know
the vertical and horizontal extent of soil and groundwater contamination for each site; rather it requires
that the Department consider information concerning the vertical and horizontal extent. Similarly, it does
not require the Department to know all factors that might conceivably affect contaminant transport or all
conceivable exposure pathways; it requires the consideration only of significant factors affecting
contaminant transport and significant exposure pathways.
Additional support for this conclusion is found in the fact that this section defines an iterative
process by which evolving data, review, and commentary are used to classify surface impoundments as
low, intermediate, or high risk. This iterative process begins with a provisionally proposed classification by
the Department by December 31, 2015 and extends for a minimum (no maximum) of six months while
feedback and additional data are received and evaluated by the Department and the Coal Ash
Management Commission.
Taken as a whole, this section requires the Department to make evidence -based decisions using
the best available information in the record. Duke Energy has submitted substantial evidence into the
administrative record. Any classification should be based on this evidence, with the understanding that
additional information requests may be relevant to the degree of certainty in the classification but do not
undermine the validity of the classification.
IV. Conclusion
The Groundwater Assessment Plans, Groundwater Assessment Reports, and Groundwater
Corrective Action Plans submitted by Duke Energy to the Department meet the requirements of CAMA
and provide vast data, analysis, and findings. Chief among the findings is a determination by licensed
' Aside from CAMA, the North Carolina Administrative Procedure Act requires that agency decisions be
supported "by substantial evidence ... in view of the entire record as submitted." G.S. 150B-51(b)(5).
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NCDENRO194491

environmental geologists that none of the sites pose an imminent hazard to human health or the
environment.
Duke Energy is committed to meeting the Department's expectations by providing additional data,
fully leveraging the time provided by CAMA's iterative process to ensure final classifications reflect the
best science and engineering. Nonetheless, Duke Energy has compiled with all of CAMA's requirements
to date, and available information is sufficient for the Department to develop classifications as required by
CAMA.
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NCDENRO194492

THE PUBLIC SERVICE COMMISSION OF SOUTH CAROLINA
COLUMBIA, SOUTH CAROLINA
PROCEEDING #16-11513 FEBRUARY 10, 2016 10:37 A.M.
ALLOWABLE EX PARTE BRIEFING [ND-2016-5-E]
REQUESTED BY DUKE ENERGY CAROLINAS, LLC (DEC) AND DUKE ENERGY PROGRESS
(DEP) — COAL ASH DISPOSAL
TRANSCRIPT OF
ALLOWABLE EX PARTE BRIEFING
COMMISSION MEMBERS PRESENT: Nikiya M. Nikki' HALL,
Chairman; Swain E. WHITFIELD, Vice Chairman; and
COMMISSIONERS John E. Butch' HOWARD, Elliott F. ELAM, JR. ,
Comer H. `Randy' RANDALL, Elizabeth B. 'Lib' FLEMING, and
G. O'Neal HAMILTON,
ADVISOR TO COMMISSION: Joseph Melchers, General Counsel
STAFF PRESENT: F. David Butler, Senior Counsel; James Spearman,
Ph.D., Executive Assistant to the Commissioners; B. Randall Dong,
Esq . , Josh Mi nges , Esq . , and David W . Stark, III, Esq . , Legal Staff;
Tom Ellison and Lynn Ballentine, Advisory Staff; Jo Elizabeth M.
Wheat, CVR-CM/MIGNSC, Court Reporter; and Allison Minges and Deborah
Easterling, Hearing Room Assistants
APPEARANCES:
HEATHER SHIRLEY SMITH, ESQUIRE, along with MIKE RU H E
[Director, Environmental Policy and Affairs / Duke Energy
(SC) ] , presenter, representing DUKE ENERGY CAROLINAS, LLC, AND DUKE
ENERGY PROGRESS, LLC
JEFFREY M. NELSON, ESQUIRE, representing t h e SOUTH
CAROLINA OFFICE OF REGULATORY STAFF
PUBLIC SERVICE COMMISSION OF SOUTH CAROLINA
10 1 EXECUTIVE CENTER DRIVE
COLUMBIA, SC 29210
WWW.PSC.SC.GOV
POST OFFICE BOX 1 1 649
COLUMBIA, SC 2921 1

ALLOWABLE EX PARTS DEC and DEP / Coal Ash Disposal Update 2
BRIEFING
I N D E X
Dnr-C
PENING MATTERS ........................................... 3-6
PRESENTATION
MR. MIKE RUHE [DUKE ENERGYJ ........................... 6
Question(s)/Comment by Commissioner Hamilton ............... 19
Questions)/Comment by Commissioner Howard ................. 20
Question(s)/Comment by Vice Chairman Whitfield ............. 23
Question(s)/Comment by Commissioner Fleming ................ 28
Question(s)/Comment by Commissioner Elam ................... 33
Question(s)/Comment by Vice Chairman Whitfield ............. 34
REPORTER'S CERTIFICATE ..................................... 39
Please note the following inclusions/attachments to the record:
PowerPoint presentation (PDF)
For identification of additional referenced materials (if any) and
links for same, please see:
ORS correspondence filed as part of the ex parte briefing
process
2/10/16
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P R O C E E D I N G S
CHAIRMAN HALL: Thank you. Be seated. Good
morning, everyone. We will call this Allowable Ex
Parte Briefing to order, and ask Mr. Melchers to
read the docket, please.
MR. MELCHERS: Thank you, Madam Chairman.
Commissioners, we are here pursuant to a Notice of
Request for Allowable Ex Parte Briefing. The
requestors are Duke Energy Carolinas, LLC, and Duke
Energy Progress, LLC. The topic is: Coal Ash
Disposal. And we are here pursuant to that Notice
in the Commission's hearing room, February 10th, at
10:30 in the morning.
Madam Chair, if I could just make one
programming note.
Folks, we are having construction and
remodeling done to our downstairs, so if you need
to find a restroom, head up the stairs and then
just keep going straight down the hall upstairs.
Thanks.
CHAIRMAN HALL: All riqht. Thank vou, Mr.
Melchers.
And who appears representing Duke Energy
Carolinas?
MS. SMITH: Heather Shirley Smith, on behalf
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of Duke Energy Carolinas and Duke Energy Progress.
CHAIRMAN HALL: Okay. Thank you.
And for ORS?
MR. NELSON: Good morning, Madam Chair. I'm
Jeff Nelson. I represent the Office of Regulatory
Staff as Mr. Dukes Scott's representative.
CHAIRMAN HALL: Okay, Mr. Nelson. And do you
have any remarks you wanted to give?
MR. NELSON: I do.
CHAIRMAN HALL: Okay.
MR. NELSON: Thank you, Madam Chair.
Typically, as I've tried to do in these,
recently at least, I'd just like to do a little
intro regarding procedures and everything, for some
people maybe that haven't been here before.
For those of you who don't know me, I'm Jeff
Nelson, and I'm the Chief Counsel for the Office of
Regulatory Staff, and I am here as the designee for
the Executive Director of the Office of Regulatory
Staff, this morning. As the ORS representative,
it's my duty to certify the proceedings here this
morning within 72 hours of them being concluded to
the Chief Clerk of the Public Service Commission,
so we operate on a fairly tight timeframe under the
statutory framework that allows these allowable ex
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partes.
The requirements of the statute are, in part,
the allowable ex parte be confined to the subject
matter which has been noticed for this here today,
and the subject matter noticed in this matter is
"Coal Ash Disposal." So I, therefore, ask the
presenters, the Commission, and the Staff to please
keep the subject related just to coal ash disposal
this morning.
Additionally, the statute prohibits
participants, Commissioners, or Commission Staff,
from requesting or giving any commitment,
predetermination, or prediction regarding any
action by the Commission as to any ultimate or
penultimate issue which either is or is likely to
come before the Commission. We, therefore, ask the
participants, Commissioners, and Staff, also, if
possible, to keep from trying to refer to any
additional documents or materials that aren't
included in the presentation. When you do that,
myself and Heather both have to try and pull this
stuff together at the last minute, so we'd ask, if
at all possible, that you try and refrain from
referencing any documents like that.
As a final note, I'd like to point out to
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everybody here: Y'all should've gotten, when you
came in today, a form at the table out here. You
should have both signed in for the Public Service
Commission and received a form. Good legal advice
always is: Read the form. Read anything before you
sign it. So, I would ask you to please read that,
make sure you sign that form, and then turn it in
before you leave today.
That's all I have, Madam Chair. Thank you.
CHAIRMAN HALL: Okay. Thank you.
If there's nothing further, then Mr. Ruhe, if
you want to go ahead with your presentation.
MIKE RUHE [DUKE ENERGY]: Thank you. All
right.
CHAIRMAN HALL: Yeah, if you can hit that
button and pull it closer, please.
MIKE RUHE [DUKE ENERGY]: [Indicating.] Yeah.
I see the lights now. Okay.
CHAIRMAN HALL: Okay.
MIKE RUHE [DUKE ENERGY]: All right. Good
morning, Commissioners.
[Reference: Presentation Slide 1]
My name is Mike Ruhe. I'm the Environmental
Policy & Affairs Director for Duke Energy here in
South Carolina. Thank you for the opportunity to
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provide this update on Duke Energy's coal ash
management activities here in the State. It's been
exactly one year since I was last here before you.
Since then, much scientific and engineering
work has been done at both our W.S. Lee and
Robinson Plants. The results of that work have
been shared with our regulators, and we worked
closely with them and our local communities to
finalize these ash basin closure strategies.
[Reference: Presentation Slide 2]
As you may recall, following the Dan River ash
release in February of 2014, the company initiated
a thorough engineering evaluation of all of its ash
basins and related piping systems across our fleet.
We are committed to the safe and reliable
operations of those basins until they're ultimately
closed.
We've been developing a comprehensive, longer -
term ash basin closure strategy for all of our ash
basins. While closing these basins has always been
part of our — of the company's vision, we have
substantially accelerated that work. Because
conditions at each site are unique, we believe that
effective closure approaches should be based on
site -specific science and engineering, and we've
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ALLOWABLE EX PARTS DEC and DEP / Coal Ash Disposal Update
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engaged some of the best experts in the country to
help us develop those protective closure
strategies.
These strategies must protect the public and
they must protect groundwater. Further, we must be
able to implement them safely. The results of this
work has helped the company shape its overall ash
management closure strategies for both Lee and
Robinson, and I'm pleased to be able to share this
update with you today.
So let's first take a look at what we're doing
at W.S. Lee.
[Reference: Presentation Slide 3]
To review, the Lee Steam Station was built in
1951. Units 1 and 2 were officially retired on
November 6, 2014. Unit 3 was converted from coal -
firing to natural gas last year. And construction
of the new 750 megawatt natural-gas combined -cycle
is well underway.
Recall that the station has two active ash
basins, a primary and secondary basin, and these
basins no longer receive coal ash or coal -ash waste
since those units are retired, but they do still
receive processed wastewater from the plant.
There's also a closed inactive basin from the
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ALLOWABLE EX PARTS DEC and DEP / Coal Ash Disposal Update
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1950s, an ash structural fill, and a former borrow
area where ash was placed years ago that is
referred to as the ash fill area.
Collectively, the site contains about 3.6
million tons of ash.
[Reference: Presentation Slide 4]
All right. Here's an overview picture of the
site. You can see — I'll point out a couple of
things. Hopefully, I don't shut the machine off.
CHAIRMAN HALL: Just don't touch it.
MIKE RUHE [DUKE ENERGY]: Yes. Here is the
primary basin we're talking about [indicating], the
secondary basin [indicating]. The structural fill
[indicating] is right here. The plant proper
[indicating]. The coal pile that's long been gone
[indicating]. Here [indicating] is the inactive
basin, right here; you can see the footprint here.
And then the ash fill area is down here
[indicating], just in the lower right corner. And,
of course, there's the Saluda River [indicating].
[Reference: Presentation Slide 5]
On September 23, 2014, the company announced
that ash from the closed inactive basin and that
ash fill area would be excavated and disposed of in
a lined solution. Duke Energy entered into an
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ALLOWABLE EX PARTS DEC and DEP / Coal Ash Disposal Update
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agreement with DHEC on September 29th of that year
to do this work, and submitted an Ash Removal Plan
to the agency on December 18th. We believe it will
take about three years to complete the removal of
the ash from these two areas.
The company selected Waste Management,
Incorporated, to excavate and transport ash from
these two areas to a fully lined, solid -waste
landfill located in Homer, Georgia. This landfill
is also operated by Waste Management. Trucks
started hauling that ash from the site on May 15th
of last year, and so far, just over 260,000 tons
have been excavated and transported off -site. That
total represents about 19.2 percent of the total
ash from those two areas.
[Reference: Presentation Slide 6]
Okay. And here, we just have highlighted
those two areas a little bit more, so you can get a
better idea of what we're talking about, you know.
It just shows that other side of the road, where
the ash fill area is.
[Reference: Presentation Slide 7]
All right. Here is an aerial view where —
let's see, the ash fill area [indicating]. The
inactive basin [indicating]. And, of course, in
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ALLOWABLE EX PARTS DEC and DEP / Coal Ash Disposal Update
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the foreground here is where land was cleared for
the natural gas combined -cycle plant.
[Reference: Presentation Slide 8]
All right. Here's the inactive basin after
the trees were cleared and the topsoil removed, and
you can see here, of course, the dark material is
coal ash.
[Reference: Presentation Slide 9]
Here is a view, an overhead view, of how we're
loading trucks at that site, and you can see we've
got trucks that drive in, do the little loop here,
and then backhoes are excavating ash and loading it
into the trucks. Then they drive around to an
automated truck wash, here, to help reduce dust,
and then tarps are put over the truck to make sure
no ash or dust gets off when it goes on the road.
[Reference: Presentation Slide 10]
Then the trucks would proceed out, and then
they're weighed to make sure that they're in spec.
on the weight. And then they go off on the road
towards Georgia.
[Reference: Presentation Slide 11]
Of course, here's the route that we take,
which is primarily Interstate highway.
The company worked closely with Waste
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Management, South Carolina DOT, and local municipal
officials to determine the best route, or the best
combination of haul routes, that would present the
least impact to the local public.
Obtaining meaningful community input was
important to us, because we realized we'd be
putting a lot of trucks on local roads as they left
the station. So we met with community leaders,
developed targeted messages for those neighbors,
providing them updates about our plans. You know,
we sent over 5000 letters to them through the mail
and hosted community meetings where we had our
project managers and subject -matter experts
available to answer any of their questions. We
also support a website, so interested parties can
get the latest information about that project. You
know, the information that we were able to get was
invaluable to us, as we have to determine what the
best routes to go from out of the — from leaving
the station.
[Reference: Presentation Slide 12]
Okay, let's turn to discuss the other basins
at the site. Recall on December 18, 2014, Duke
Energy communicated to DHEC its closure strategy
for the remaining ash, for the primary and
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ALLOWABLE EX PARTS DEC and DEP / Coal Ash Disposal Update
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secondary basins and the structural fill.
Now, based upon the results of that site -
specific engineering work, the company decided, at
that time, to excavate the ash from those two
areas, as well, and to relocate them in a fully
lined landfill. That analysis also explored
options for disposing of this remaining ash at the
Lee site. Duke Energy submitted a Conceptual
Closure Plan for these areas on December 15, 2015,
and that plan also included a design for a
potential on -site, lined landfill.
Currently, we are looking to site that
landfill on the footprint of the existing secondary
basin. Landfill siting studies are currently
underway and we anticipate submitting a Landfill
Permit Application to DHEC in October of this year.
[Reference: Presentation Slide 13]
All right. Here is a drawing of what we had
in that proposed — in that Closure Plan. You can
see the outline of the primary basin, secondary
basin, and the structural fill. Now, our plans
would be to drain the water out of the secondary
basin, which is in the upper left-hand corner, and
then what little ash was in there — because that
secondary basin doesn't contain much ash — remove
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that ash, put it in the primary basin, and then we
would reconfigure that footprint to make it
suitable for a landfill, and then line it, and then
remove all the ash from the primary basin and that
structural fill into that secondary basin
footprint, and then cap it and close it.
[Reference: Presentation Slide 14]
So what are the advantages of the proposed
closure strategy? Well, first and foremost, it
eliminates the existing impoundments. Second, it
consolidates the ash in a fully lined and capped
location in close proximity to those existing ash
management units, minimizing ash handling, and it
also reduces community impacts. Third, groundwater
is protected. That landfill will be lined and
capped, leachate will be collected, and we will
continue to perform groundwater monitoring to
ensure that these controls function as designed.
And, finally, we are eliminating the use of public
roads for hauling ash once that landfill is
operational. This is very important for our plant
neighbors.
[Reference: Presentation Slide 15]
Now, let's take a look at the Robinson Plant.
The Robinson coal unit was built in 1960 and
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ALLOWABLE EX PARTE DEC and DEP / Coal Ash Disposal Update
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retired in September of 2012. The second Robinson
unit is a 710 megawatt nuclear unit that continues
to operate. The Robinson ash management facility
includes a single -celled ash basin and what we are
calling the 1960 fill area. That area's located
just to the west of Units 1 and 2. The entire site
contains about 4.2 million tons of ash.
[Reference: Presentation Slide 16]
And here's an aerial view of the site. Just
to reorient you, the plant proper is down here —
here's the plant proper, right down here
[indicating]. The ash basin is up here
[indicating] in this footprint. Here is Lake
Robinson and the dam [indicating]. And the 1960
fill area — and I'll have another drawing to kind
of highlight it — is in this area right here
[indicating]. This part right here [indicating] is
the footprint for the Darlington County CT site.
That 72-acre ash basin is comprised of a 49-
acre basin, itself, and then a 23-acre dry storage
area located just to the western part of that
basin. Ash thickness ranges anywhere between 11 to
53 feet. The surface of that ash basin is dry and
has been dry for several years.
[Reference: Presentation Slide 17]
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The 1960 fill area was created when the plant
started operating, and it received ash from Unit 1
until the current ash basin was constructed in the
mid-'70s. Duke Energy contracted with an outside
engineering firm in late 2013 to evaluate the
extent and volume of the ash stored in that area.
We've determined that this area covers
approximately 25 acres and holds an estimated
330,000 tons of ash.
Duke Energy entered into an agreement with
DHEC on July 17, 2015, to excavate the ash from
that area and relocate it to a proposed lined
landfill to be built on -site. Landfill siting
studies are currently underway for that landfill,
and we anticipate submitting a Class 3 Landfill
Permit Application to DHEC by April 1st.
The agreement we signed with DHEC requires us
to complete the excavation and removal of all ash
from this area within eight years.
[Reference: Presentation Slide 18]
Okay. And here's that extra drawing I was
showing you, zooming in on the plant a little bit.
It's a little bit faint, but you can get an idea of
where the boundary of that 1960 fill area is, right
underneath part of the transmission corridor there.
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[Reference: Presentation Slide 19[
So let's now take a look at the active basin
at Robinson. We conducted a number of geotechnical
studies in and around that basin and concluded,
again, that the best closure strategy would be to
excavate the ash from that area and relocate it to
a lined solution. That decision was communicated
to DHEC on April 30, 2015. A Conceptual Closure
Plan was submitted to the agency on November 13th,
and our plans are to dispose of this ash in the
same landfill that's being constructed for the 1960
ash -fill ash.
[Reference: Presentation Slide 20]
The location of the proposed landfill's on
Duke -Energy -owned land, on that adjacent Darlington
County combustion turbine site. You can see, the
square up there is the footprint of where we
propose to put the landfill.
[Reference: Presentation Slide 21]
The advantages of this proposed closure
strategy are very similar to those for W.S. Lee.
First, it eliminates the existing impoundment and
fill area. Second, it consolidates the ash on -site
in a fully lined, capped location that's in close
proximity to the existing ash management units.
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Third, groundwater is protected. Ash will be
removed and placed in an engineered landfill,
segregated from groundwater. Leachate, again, will
be collected, and we will perform groundwater
monitoring to ensure that these controls function
as designed. Finally, we'll be keeping ash trucks
off of public roads. We're looking into the
possibility of building either internal roads or
possibly a conveyor system to get ash from those
two areas to this new landfill.
[Reference: Presentation Slide 22]
As at W.S. Lee, we actively engaged the local
community and our plant neighbors to obtain
feedback about our site plans. We hosted community
meetings there, as well, making our project leaders
and subject -matter experts available to answer any
questions. At Robinson, we sent out almost 1000
letters to plant neighbors, providing them
information about the project. And like at Lee, we
have a public website that provides the most
current information about the project.
Our employees live in that community also, so,
you know, it's important to us to have all of our
plant neighbors be knowledgeable and comfortable
with the plans that we have at the site.
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[Reference: Presentation Slide 23]
So, in conclusion, Duke Energy is committed to
closing our ash basis. We will do this safely and
in a manner that protects the environment,
particularly groundwater. We will do it in a way
that minimizes the impacts to our communities, and
we will continue to work with our neighbors to keep
them informed on what we are doing. We will manage
these projects in a manner that controls cost.
And, finally, we will continue to work with DHEC to
ensure that we meet all of our — all required
regulatory standards.
Thank you, so much, for your time.
[Reference: Presentation Slide 24]
CHAIRMAN HALL: Thank you, Mr. Ruhe.
Commissioners, questions? Commissioner
Hamilton.
COMMISSIONER HAMILTON: Thank vou. Madam
Chair.
Happy to have you with us, today, sir, and we
certainly appreciate the update. At this present
time, are you on schedule with all DHEC
requirements and time limits, et cetera?
MIKE RUHE [DUKE ENERGY]: Yes, sir, we are.
COMMISSIONER HAMILTON: Have we experienced
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any fines in South Carolina, at this point?
MIKE RUHE [DUKE ENERGY]: We have not.
COMMISSIONER HAMILTON: Okay. So, as far as
DHEC is concerned, the project is totally on
schedule.
MIKE RUHE [DUKE ENERGY]: Yes, sir. We — the
project team meets with the technical folks over at
DHEC monthly, you know, to keep them updated and
because everything is really being fast -tracked,
you know, in their minds, so we're working very
closely with the agency to make sure all the
reviews are working on schedule to meet the
timeline.
COMMISSIONER HAMILTON: Thank you, very much.
Thank you, Madam Chair.
CHAIRMAN HALL: Thank you.
Commissioner Howard.
COMMISSIONER HOWARD: Good morning. Explain
to me what you mean by: still active as a
wastewater treatment system.
MIKE RUHE [DUKE ENERGY]: The plant has —
those ponds are considered NPDES — National
Pollutant Discharge System treatment systems, you
know, for wastewater, and are regulated by DHEC.
And so there are plant systems that still drain
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water — think floor sumps, that kind of thing, that
are still draining there. As part of the overall
new permit that we've got, that we're just now
getting from DHEC, you know, we will be closing all
that down, you know, when we close down the basins,
but we have to go over and have the new piping
systems all ready to go before we can shut down
that existing plant, because Unit 3 is still
operating as a natural gas plant.
COMMISSIONER HOWARD: Okay, thank you.
Commissioner Hamilton asked you about any fines in
South Carolina. What about fines about coal ash,
in general? How many fines have you procured or
are threatened with to have now for your coal ash
disposal?
MIKE RUHE [DUKE ENERGY]: There was the EPA
fine that was announced early last year for the
overall Dan River event. And then, in the press,
there was a North Carolina Department of
Environmental Quality fine for Dan River, also,
that was between $6-$7 million, you know, for that
event, too.
COMMISSIONER HOWARD: How much, total, were
they?
MIKE RUHE [DUKE ENERGY]: How much, total?
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COMMISSIONER HOWARD: Yeah, how many total
fines do you have?
MIKE RUHE [DUKE ENERGY]: Off the top of my
head, I do not know.
COMMISSIONER HOWARD: Well, how —
MIKE RUHE [DUKE ENERGY]: The EPA fine was, I
want to say, $100 million, you know, in that range.
COMMISSIONER HOWARD: How do you plan cost
recovery of these expenses?
MIKE RUHE [DUKE ENERGY]: I —
COMMISSIONER HOWARD: In other words, are you
planning to put them in rate base or not? That's
my question.
MIKE RUHE [DUKE ENERGY]: Closure of ash
basins, you know, since ash basins are part of the
NPDES treatment system, we've always viewed
eventual — we've always gone to eventual closure of
those basins. I'm not the person that's really in
a position to address rate questions. We'll have
someone else come back, you know, at that time,
when the time is right for that.
COMMISSIONER HOWARD: A hundred miles comes to
mind, but how long is the haul from this coal ash
at the disposal to the landfill in Homer, Georgia?
How long is that route?
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MIKE RUHE [DUKE ENERGY]: I believe it's 75
miles.
COMMISSIONER HOWARD: Thanks, very much.
CHAIRMAN HALL: Commissioner Whitfield.
VICE CHAIRMAN WHITFIELD: Thank you, Madam
Chair.
Thank you for this presentation. Appreciate
having you back here again, a year later, to update
us, and we appreciate you coming up to keep us
informed. And I've got just a couple of quick
questions. The Class 3 landfill that you said
you'll be submitting the permit application in
October of 2016, this year, when would that —
assuming you have the application in then, when
would that Class 3 landfill be operational at the
Lee facility?
MIKE RUHE [DUKE ENERGY]: It takes DHEC about
between three and five years to approve a landfill
and get it constructed, so that's why we've got
eight years to dispose of — well, we have eight
years to dispose of the ash from that one area.
VICE CHAIRMAN WHITFIELD: So three to five
years permitting, and another few years to —
MIKE RUHE [DUKE ENERGY]: And —
VICE CHAIRMAN WHITFIELD: — construct, so a
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total of roughly eight years, is —
MIKE RUHE [DUKE ENERGY]: That's correct.
VICE CHAIRMAN WHITFIELD: — what you're
looking at, before —
MIKE RUHE [DUKE ENERGY]: And that's been the
target that we've been working with DHEC, to try to
get it done in eight years.
VICE CHAIRMAN WHITFIELD: — before you would
have on -site —
MIKE RUHE [DUKE ENERGY]: Disposal capability.
VICE CHAIRMAN WHITFIELD: And that's just for
the active basins. The others, the inactive and
the ash fill pit, all that material is all what's
going to Homer, Georgia; is that correct?
MIKE RUHE [DUKE ENERGY]: At W.S. Lee, that's
correct.
VICE CHAIRMAN WHITFIELD: Okay, those two are
what's going to Homer, and the primary and
secondary — the active — are the ones that you
would be waiting to put in this new landfill on -
site.
MIKE RUHE [DUKE ENERGY]: That's correct.
VICE CHAIRMAN WHITFIELD: Okay. Now, how
about for the Robinson Plant? I see you're going
to have that application in here in about a month
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or so, in April. Is that on the same schedule,
again about eight years out?
MIKE RUHE [DUKE ENERGY]: Yes, sir.
VICE CHAIRMAN WHITFIELD: Okay. And,
obviously, it looks like, at Robinson, of course
you're dealing with a lot less tonnage of ash, but
you're going to be able to, as you said, do
something on -site, maybe even a conveyor belt, and
not actually have to put anything on the road, over
at the Robinson plant. Is that the way I'm hearing
it?
MIKE RUHE [DUKE ENERGY]: That's what we're
looking at. The decisions — the timeline decisions
were based upon, you know, working through the
investigation with DHEC. At W.S. Lee, there were
concerns about, you know, those ash storage areas.
The inactive landfill was very close to the river.
VICE CHAIRMAN WHITFIELD: Right.
MIKE RUHE [DUKE ENERGY]: And in discussions
with them, we did not feel that it was in a stable
situation for the long term, to wait until a
landfill was sited. So that's why that — that
determined the timeline there.
Over at Robinson, it's a different situation.
That 1960 fill area's not anywhere near the lake
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and it's a very stable ash placement. So they were
comfortable with the timeline of building a
landfill on -site.
VICE CHAIRMAN WHITFIELD: I see what you're
saying. The inactive basin is the one that's right
adjacent, like closest, to the Saluda River.
MIKE RUHE [DUKE ENERGY]: Yes, sir. It's
right close to the river and the dike is very steep
right there. And so, because of the age of that
basin, we were not as certain of the long-term
stability, you know, until that time. You know, it
was all heavily overgrown with trees, and our
engineering folks did not think it was a stable
configuration, long term, to wait that long.
VICE CHAIRMAN WHITFIELD: I noticed that the
tonnage you expect to move from Lee — I don't have
that page right now, but I think it was 1.4 million
tons — here it is — and you've moved not quite 20
percent, 19-point-something. And it looks like the
timeline you're on, you're somewhat on target. Are
you under a three-year contract with them to do
that? Or is it an annual thing you continue to
renew as the work gets done, as the ash gets
hauled? Or what obligation are you under, if you
could discuss that?
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MIKE RUHE [DUKE ENERGY]: Well, we signed a
consent agreement with DHEC, and that set up the
timeline to go over and have that ash moved. And
so we secured the trucking and everything else to
accommodate that. And so, you know, our plans are
to get it done within that three years.
VICE CHAIRMAN WHITFIELD: And, of course, it's
early, but it does look like you're somewhat on
target —
MIKE RUHE [DUKE ENERGY]: That's correct.
VICE CHAIRMAN WHITFIELD: — from your
percentages. Well, thank you, Mr. Ruhe. That's
all I have.
CHAIRMAN HALL: Thank you.
Commissioner Fleming.
COMMISSIONER FLEMING: Good morning, Mr. Ruhe.
Nice to have you here today.
MIKE RUHE [DUKE ENERGY]: Thank you.
COMMISSIONER FLEMING: Commissioner Howard
asked several of the questions that I wanted to
ask, so — but I did want to go a little farther
about how it will be paid for, the cleanup. And
you've talked about the tariff has been used in the
past, so the consumer would be the one responsible
for paying for the cleanup. But what about the
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fines?
MIKE RUHE [DUKE ENERGY]: With all the
cleanup, you know, that went with the Dan River —
you know, to be honest, I'm a technical person.
I've never really dealt with anything with the
fines or that, so I don't have an answer for that.
Heather, though, evidently does.
[Laughter]
MS. SMITH: Commissioner Fleming, we have
stated before, publicly, that we would not seek
recovery of those fines associated with the subject
matter from ratepayers. And we'd be happy to
provide a written statement to that effect,
articulating that position, for the Commission, in
conjunction with this ex parte presentation.
COMMISSIONER FLEMING: Okay. And do you
confirm, though, that you are planning to request
the cleanup recovery in tariffs?
MS. SMITH: We would request recovery for our
activities, our prudent activities, related to ash
disposal — not the fines, but those other
activities. And we've publicly stated that, and we
can include that language in anything we file with
the Commission, as well.
COMMISSIONER FLEMING: So the shareholders
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will assume the responsibility for any fines.
MS. SMITH: Yes.
COMMISSIONER FLEMING: Okay. I know you had a
limited timeframe, I believe in North Carolina, to
remove the ash.
MIKE RUHE [DUKE ENERGY]: [Nodding head.]
COMMISSIONER FLEMING: And as a result of
that, you said, as I recall, that that was a reason
not to do recycling or reprocess of that ash, that
there just wasn't enough time. Am I correct in
that?
MIKE RUHE [DUKE ENERGY]: In this
presentation, I didn't say anything —
COMMISSIONER FLEMING: No, no, no, no. In the
past.
MIKE RUHE [DUKE ENERGY]: The plants that we
have in North Carolina are different than the ones
we have in South Carolina. You know, our South
Carolina plants were older plants. They did not
have all of the pollution control agreement;
they're not continuing to operate. So, you know,
all our ash is sitting in ponds.
To make ash suitable for recycling, you know,
we would — there would have to be, in many cases,
carbon burnout, or this, that — different
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technologies done to make it suitable. And because
our volumes, in the grand scheme of things, are
very low at these two plants, economically it's not
feasible.
Now if you looked to the larger plants that
have scrubbers and continue to operate, there are
companies out there that will partner with
utilities to go over and make ash more amenable to
being recycled. But it's more difficult to do with
ash that — you know, it's not worth many recyclers'
time to set up an operation to do these types of
volumes.
COMMISSIONER FLEMING: So you would not be
doing recycling or —
MIKE RUHE [DUKE ENERGY]: We don't anticipate
doing any recycling of this ash.
COMMISSIONER FLEMING: — or reprocessing,
because of the cost factor.
MIKE RUHE [DUKE ENERGY]: Because of the cost,
that's right.
COMMISSIONER FLEMING: Okay. And I wanted to
also go back — could you talk some more about the
"active as a wastewater treatment" — and, I mean,
because as I understood what you said, there is
coal ash in that, as well, correct?
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MIKE RUHE [DUKE ENERGY]: Right.
COMMISSIONER FLEMING: And what are your plans
for those that are still active?
MIKE RUHE [DUKE ENERGY]: In South Carolina?
Or in North Carolina?
COMMISSIONER FLEMING: South Carolina.
MIKE RUHE [DUKE ENERGY]: Well, I mean, you
know, we still have active NPDES permits at both
Robinson and W.S. Lee. Both those ash basins are
still included in those permits. Part of the
Conceptual Closure Plans for those sites are a
requirement from DHEC to go over and close those
ash management units. That's why we submitted
them. And so we're going through closure right
now, and then that — and once they're closed, they
will be removed from the permit.
COMMISSIONER FLEMING: Okay. So there won't
be ash ponds —
MIKE RUHE [DUKE ENERGY]: There'll be no —
COMMISSIONER FLEMING: — once you've —
MIKE RUHE [DUKE ENERGY]: — ash ponds left.
COMMISSIONER FLEMING: — finished this, so
they'll —
MIKE RUHE [DUKE ENERGY]: That's correct.
COMMISSIONER FLEMING: — be totally —
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everything will be totally cleaned up.
MIKE RUHE [DUKE ENERGY]: They'll be totally
cleaned up. In fact, the last step will be, you
know, analysis of the ground that's left, and it
has to meet the criteria that DHEC sets for us, you
know, to say that "You're done."
COMMISSIONER FLEMING: I guess my confusion is
the fact that you can continue to use it — that
they continue to be active at the present time.
MIKE RUHE [DUKE ENERGY]: Well, I mean,
they're active until they're removed —
COMMISSIONER FLEMING: Uh-huh?
MIKE RUHE [DUKE ENERGY]: — you know, from the
permit. And since they're still on the permit,
we're still sampling them.
COMMISSIONER FLEMING: So there's been no
contamination, no —
MIKE RUHE [DUKE ENERGY]: No —
COMMISSIONER FLEMING: — release, as far as —
MIKE RUHE [DUKE ENERGY]: You know, as
processed water or rainwater or storm water goes
into the pond, we do monitor those, and they are
released like they were before, as long as they're
within the specifications of our permit. But
there's been no coal ash going to them for — you
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know, since those plants stopped operating.
COMMISSIONER FLEMING: Okay. And you're
saying that both Lake Robinson and the Saluda River
are — the measures that you're taking are
protecting both of those water sources.
MIKE RUHE [DUKE ENERGY]: Yes, ma'am.
COMMISSIONER FLEMING: Okay.
MIKE RUHE [DUKE ENERGY]: And groundwater, as
well.
COMMISSIONER FLEMING: Okay. Thank you.
CHAIRMAN HALL: Commissioner Elam.
COMMISSIONER ELAM: Good morning. Just one
question out of curiosity, I guess. On 17 and 18
of the presentation, you were talking about the
1960 fill area.
MIKE RUHE [DUKE ENERGY]: Right.
COMMISSIONER ELAM: And on the picture, you
had the fill area where the transmission corridor
from the plant went right through it.
MIKE RUHE [DUKE ENERGY]: [Nodding head.]
COMMISSIONER ELAM: When you're excavating
that, is that going to impact the operation of the
plant? Are you going to have to move the
transmission lines to keep the plant running, or...
MIKE RUHE [DUKE ENERGY]: We will have to
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coordinate that activity with plant operations.
And we've had discussions with the agency about
that.
34
COMMISSIONER ELAM: Okay. I just — it didn't
seem like you could dig around it.
[Laughter]
Okay, thank you.
CHAIRMAN HALL: Commissioner Whitfield.
VICE CHAIRMAN WHITFIELD: Thank you, Madam
Chairman.
Mr. Ruhe, I've just got one quick follow-up on
what we were talking about, about the ash that you
are removing from the Lee facility and hauling to
Homer, Georgia. Now that Ms. Smith has been real
clear on what would be paid for by the shareholders
and what would be paid for, or sought for payment,
by the ratepayers, since you're doing this work
kind of, as you would say, proactively, not as a
result of any fine or not a fine in effect, and as
we talked about the tonnage, you were on a
percentage of almost 20 percent right now being
hauled out of that facility, I guess what I was
getting at when I asked you was the contract under
a year, or three years — and if it's a contractual
matter and you can't say, just let me know, but my
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35
concern is, when you're dealing with a bulk item
like ash and as you start to remove it, naturally,
you're going to pick up dirt and other particles,
and that 1.4 million tons might end up being 1.7
million tons or, you know, more than what you're
estimating here, and if you find yourself a year or
so down the road slipping in that percentage and as
you get closer to finishing getting the remaining
amounts, cleaning up all of the ash, naturally,
that bulk item might be a little bigger than you
think it is. And what is your out, I guess, since
if you're going to potentially come seek recovery
for this one day, what are you doing to manage the
costs of this removal and transporting of this ash
into Georgia?
MIKE RUHE [DUKE ENERGY]: The volume of ash
that's in that basin is just an estimate. You
know, there weren't records really kept in those
days to say how much was in there. So we've done
geotechnical studies, probing, sticking probes in
the ground and then just doing the math to figure
out what an estimate of the tonnage would be. The
timeline and the closure — the clean closure —
requirements, you know, are outlined in the order
that we have from DHEC.
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VICE CHAIRMAN WHITFIELD: In the consent
36
order.
MIKE RUHE [DUKE ENERGY]: Yes, in the consent
order. So we're going to follow the requirements
of that.
VICE CHAIRMAN WHITFIELD: Well, I get —
MIKE RUHE [DUKE ENERGY]: Now, as far as the
details of how our contract is set up with Waste
Management, I do not know those details.
VICE CHAIRMAN WHITFIELD: Okay. Well, and I
get that you have to abide by the DHEC consent
order. I just wondered if there were any recourses
you have if you see yourself slipping in where you
need to be on the removal of that tonnage, or if
that tonnage — you said it was an estimated number,
1.4 million tons — if it ends up being more than
that, or for whatever reason — you know, I know
when you're dealing with a bulk item, it's hard to
get your arms around that sometimes. And I just
wondered if you had any — if Duke had any
management or oversight of that, to kind of manage
where you are. And I do see your percentages here
and you appear to be on target, but who knows if
you're going to stay with that or slip or where you
may be in the future, or what your recourse might
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37
be if you do.
MIKE RUHE [DUKE ENERGY]: We've got a
dedicated organization that is managing that
project and has folks at the site, you know, to
follow it. And I think right now we're probably
doing 100 trips a day, you know, going back and
forth.
VICE CHAIRMAN WHITFIELD: Right.
MIKE RUHE [DUKE ENERGY]: We believe that
there's enough time in that timeline to go over and
get it done within three years, you know, with the
give or take. There were even some delays in the
timeline just because of the heavy rains, both on
our end and those rains hit Homer, Georgia, as
well, and the landfills were closed for a week at a
time. So, you know, we're working aggressively to
go over and stay as close to that schedule as we
can.
VICE CHAIRMAN WHITFIELD: Well, thank you —
MIKE RUHE [DUKE ENERGY]: And we think we can
do it in the three years. We don't want to go back
before DHEC and ask for an extension.
VICE CHAIRMAN WHITFIELD: Well, I guess we'll
know more at your next update. Thank you.
Thank you, Madam Chair.
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CHAIRMAN HALL: Thank you.
Commissioners, any other questions?
[No response]
Okay. Thank you, so much, for your
presentation, Mr. Ruhe, and Ms. Smith, for assuring
us that the fines will be absorbed by the
shareholders. I think we breathe easier, hearing
that.
And if there's nothing else, then we are
adjourned.
[WHEREUPON, at 11:20 a.m., the
proceedings in the above -entitled matter
were adjourned.]
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ALLOWABLE EX PARTS DEC and DEP / Coal Ash Disposal Update 39
BRIEFING
C E R T I F I C A T E
I, Jo Elizabeth M. Wheat, CVR-CM-GNSC, do hereby
certify that the foregoing is, to the best of my skill and
ability, a true and correct transcript of all the proceedings
had in an Allowable Ex Parte Proceeding held before THE
PUBLIC SERVICE COMMISSION OF SOUTH CAROLINA in Columbia,
South Carolina, according to my verbatim record of same.
Given under my hand this 101" day of February,
2016.
Jo Elizabeth M. Wheat, CVR-CM/M-GNSC
Court Reporter
2/10/16
PUBLIC SERVICE COMMISSION OF SOUTH CAROLINA

A" *%, x n s r X-
526 South Church Street
Charlotte, NC 28202
September 11, 2013
hAr Anrdrt-w PitnPr
nlnrth ('nrnlinn riannrtmcnt of PmArnnmant and Kinfi Iral Pacnr brat
rli.rieinn nF lAhtnr Decn1 Irnee
✓IYIJIVI 1 VI V VG�GI 1 \GJVGI VGJ
A :9_ n .a .
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o IU Ld5l Uenier /Avenue, oune .SU I
Mooresville, NC 28 115
Subject: Duke Energy Carolinas, LLC
Buck Steam Station
Ash Basin Groundwater Assessment
Request for Assessment Suspension
Dear Mr. Pitncr•
Marling Address:
PO BOX 7006
Marl Code tC73K
Charlotte, NC28201-1006
704 382 4767
An 382 C, 40 f','
VI I May 3, LV I'D Uuk CnCr�y LUunC� bUUIIIILIGU cl i11Ui1UbCU VVUIII illdll LU conduct dll ash basin
udb111
groundwater assessment at Buck Steam Station in Salisbury, North Carolina. i he proposed work
plan sought to address groundwater exceedances detected at monitoring wells around the ash
basins. Duke has received no response from the North Carolina Department of Environmental and
Natural Resources (NCDENR) concerning these proposed work plans.
On Auaust 16, 2013, NCDENR filed a complaint alleging violations at several Duke coal-fired
stntinns inrlijdinn Rtirk Steam Statinn related to ash hasin seenane and nrnundwater mnnitnrinn
data that Shn A] cnmen rnnrinntratinnc ahewin nrnl IMIXA/Atenr ctnnHnrric Al len to then nennriinn rmmininint
anent associated o ltrmm� r111I1n rnnl Inete el ICnnnrllnr4 thn nrr%nr%enrl ncCeeemnnt 1A!/lrl! I Int11 thn
G11\ GJJ..�1Gw ..aw..111\ GI\\ I..yG. Jw JGJ1.. 11 1111e Llhe 1...1...I......J .J GJJ. JJ111. 11� .�. 11\ GI1.11 tlhe
ouLl.VIIIV- VI LIIG VUWLGIIullly ;,VI I ILJIQII IL is IeQIIGGu.
If you have any questions or concerns, please contact me at %U4-382-41161 or at
Sean. DeNeaieLduke-energy.com
Sincerely.
d
Sean I LJGIVGQIG, LI IyII1GGl 11
r-nivi _l n__vI
CIIVIrUnllentdl �CIVICGeS
Electronic cc: Mrs. Kim Hutchinson — Duke Energy Corporation
Mr. Dale Wooten — Buck Steam Station

GEO-HYDRO, INC
Consulting in Geology and Hydrogeology
1928 E. 141h Avenue
Denver, Colorado 80206
[phone]
EXPERT REPORT OF
MARK A. HUTSON, PG
Roxboro Steam Electric Plant
S emora, NC
Prepared for:
Southern Environmental Law Center
601 West Rosemary Street
Suite 220
Chapel Hill, NC 27516-2356
March 2016

GEO-HYDRO, INC
1. Summary of Opinions Formed
Based upon my review of the available information I have formed the following opinions on closure
of the coal ash basins at the Roxboro Steam Electric Plant (Roxboro).
1. Coal ash stored in the Roxboro ash basins is the source of contamination detected in
groundwater.
2. Capping coal ash located within the Roxboro ash basins will not protect groundwater quality
downgradient of the basins
Monitored Natural Attenuation (MNA) is not an acceptable groundwater remediation
strategy at Roxboro.
4. Capping coal ash located within the Roxboro ash basins will not be protective of surface
water quality.
5. Removal of the coal ash will remove the source and reduce the concentration and extent of
groundwater contaminants.
6. The coal combustion residual impoundment risk classification proposed by the North
Carolina Department of Environmental Quality (NCDEQ) improperly minimizes protection
of environmental quality.
The background and rationale behind each of these opinions are described in this report.

GEO-HYDRO, INC
2. Introduction
Duke Energy (Duke) reportedly stores approximately 33,390,000 tons of coal ash in various areas
around the Roxboro facility, including ash stored in two unlined ash basins (East and West), lined
and unlined landfills, and other ash filled areas'. An additional poorly identified and
uncharacterized Unnamed Eastern Extension impoundment was recently reported to NCDEQ. The
location and volume of additional coal ash contained in the Unnamed Eastern Extension
impoundment was not identified in any of the documents reviewed. Pollution caused by the coal ash
at this site is currently the subject of an enforcement action brought by the NCDEQ. Organizations
represented by the Southern Environmental Law Center are also parties to this litigation.
North Carolina General Assembly Session Law 2014-122, the Coal Ash Management Act (LAMA)
of 2014, required the owner of coal combustion waste surface impoundments to conduct
groundwater monitoring, assessment and remedial activities at coal ash basins across the state, as
necessary. The owner of the coal ash surface impoundments was required to submit a Groundwater
Assessment Plan (GAP) to NCDEQ by December 31, 2014. Comprehensive Site Assessment (CSA)
reports that reported the results of site characterization activities were required to be submitted
within 180 days of approval of the GAP. Information developed under the CSA provided the data to
be used to prepare Corrective Action Plans (CAP) that were to be submitted to NCDEQ within 90
days of submittal of the CSA. An agreement between Duke Energy and NCDEQ resulted in
breaking the CAP into Parts I and 2. As of this date only the CAP Part I has been produced for the
Roxboro site.
Further, CAMA specifies that any impoundments classified by NCDEQ as high -risk be closed no
later than December 31, 2019 by dewatering the waste and either, a) excavating the ash and
converting the impoundment to an industrial landfill, or b) excavating and transporting the waste off -
site for disposal in an appropriately licensed landfill. Intermediate -risk impoundments are required
to be closed similarly to high -risk impoundments, but under a relaxed closure deadline of December
31, 2024. Impoundments classified as low -risk by NCDEQ must be closed by December 31, 2029
either similarly to the high and intermediate -risk sites, or by dewatering to the extent practicable and
capping the waste in place.
In January 2016 the NCDEQ issued Draft Proposed Risk Classifications (NCDEQ, 2016) for 10 ash
impoundment sites, including Roxboro. NCDEQ assigned separate proposed risk classifications for
the West, East, and Unnamed Eastern Extension ash ponds. The East Ash Basin (EAB) was rated
low to intermediate risk and the West Ash Basin (WAB) was rated low risk, thus allowing for
closure of these impoundments by capping waste in place. The Unnamed Eastern Extension (UEE)
' Synterra, 2015a
2

GEO-HYDRO, INC
impoundment was rated intermediate risk pending further assessment. On behalf of the Southern
Environmental Law Center, I have reviewed the Groundwater Assessment Plan (SynTerra, 2014),
Comprehensive Site Assessment (SynTerra, 2015a), the Corrective Action Plan Part 1 (SynTerra,
2015b), the Draft Proposed Risk Classifications (NCDEQ, 2016), and three National Pollutant
Discharge Elimination System (NPDES) discharge monitoring reports (DMR's) for Roxboro (Duke
Energy, 2014).
This report details my opinions regarding: the source of groundwater and surface water pollution at
Roxboro, potential remedies for that pollution discussed in the Corrective Action Plan, and the
proposed risk classification for the Roxboro site.

GEO-HYDRO, INC
3. Qualifications
The opinions expressed in this document have been formulated based upon my formal education in
geology and over thirty-five years of experience on a wide range of environmental characterization
and remediation sites. My education includes B.S. and M.S. degrees in geology from Northern
Illinois University and the University of Illinois at Chicago, respectively. I am a registered
Professional Geologist (PG) in Kansas, Nebraska, Indiana, and Wisconsin, a Certified Professional
Geologist by the American Institute of Professional Geologists, and am currently serving as Past
President of the Colorado Ground Water Association.
My entire professional career has been focused on regulatory, site characterization, and remediation
issues related to waste handling and disposal practices and facilities. I have worked on contaminated
sites in over 35 states and the Caribbean. My site characterization and remediation experience
includes activities at sites located in a full range of geologic conditions, involving soil and
groundwater contamination in both unconsolidated and consolidated geologic media, and a wide
range of contaminants. I have served in various technical and managerial roles in conducting all
aspects of site characterization and remediation including definition of the nature and extent of
contamination, directing human health and ecological risk assessments, conducting feasibility
studies for selection of appropriate remedies to meet remediation goals, and implementing remedial
strategies. For the last ten years much of my consulting activity has been related to groundwater
contamination and permitting issues at coal ash storage and disposal sites.
2

GEO-HYDRO, INC
4. Site Background
The Roxboro plant is a coal-fired electricity -generating facility located near Semora, in Person County
North Carolina. Hyco Reservoir borders the Roxboro plant to the north and west. Coal ash generated
at the plant has been sluiced to the ash basins and hauled to landfill overlying the ash basins since
operations commenced in 1966. The EAB was constructed in 1966 by constructing an earthen dam
across two unnamed creeks located southeast of the power station (Figure 1). An unlined landfill was
constructed over the top of the sluiced ash in the EAB in the late 1980s and a lined landfill was
constructed over the unlined landfill in 20042.
The ground surface elevation below the EAB dam was reported to be between 390 and 400 feet mean
sea level (msl) 3. Groundwater elevations in EAB monitoring wells are reported to be between 464 and
469 ft ms14. The difference between the reported ash basin groundwater elevations and the natural
ground surface elevations underlying the EAB indicates that from 64 to 79 feet of saturated coal ash is
present within the EAB.
The WAB was constructed in 1973 by installing a dam across Sargents Creek, located south of the
power station. Coal combustion waste was historically sluiced into the WAB. A Flue Gas
Desulfurization (FGD) System, including a lined gypsum settling pond was constructed over a portion
of the WAB. The WAB currently remains in operation, receiving sluiced bottom ash from the power
station and surface waters discharged from the EAB and overlying lined landfill.
The ground surface elevation along the buried Sargents Creek was reported to be between 390 and 410
feet msl prior to construction of the WAB 5 Groundwater elevations in WAB monitoring wells are
reported to be between 448 and 463 ft ms16. The difference between the reported ash basin
groundwater elevations and the natural ground surface elevations underlying the basin indicates that
from 38 to 73 feet of saturated coal ash is present within the WAB.
The CSA describes three natural hydrogeologic units or zones of groundwater flow at the Roxboro
Plant. Coal ash is considered as its own hydrogeologic unit that is localized to the ash basins. The
zone closest to the surface is the shallow or surficial flow zone encompassing saturated conditions,
where present, in the saprolite and alluvium beneath the Site. A transition zone is encountered below
the shallow zone and is characterized primarily by partially weathered rock of variable thickness. The
bedrock flow zone occurs below the transition zone and is characterized by the storage and
2 SynTerra, 2015b, p. 1-2.
3 SynTerra, 2015b, Appendix E, p.3.
4 SynTerra, 2015a, Figure 6-5.
5 SynTerra, 2015b, Appendix E, p.4.
6 SynTerra, 2015a, Figure 6-5.
5

GEO-HYDRO, INC
transmission of groundwater in water -bearing fractures. Due to its limited occurrence and extent, the
shallow zone is considered part of the transition zone. Where present, groundwater exists under
unconfined conditions in each of the hydrogeologic units. The surficial/transition zone and bedrock
aquifers are interconnected.
On a regional scale groundwater appears to flow from highland areas in the south and southeast, to the
northwest toward Hyco Lake. On a local scale groundwater flow directions are poorly defined. Large
areas of the Bedrock Water Level Map included with both the CSA and CAP (Figure 2) show neither
groundwater elevation data nor contours. Due to the scarcity of head data the description of the
groundwater flow system included in the Groundwater Modeling Reports describes groundwater flow
in terms of inferred flows. The groundwater flow system beneath the eastern lobe of the EAB is
inferred to receive recharge from uplands to the south and east9, and discharge from the eastern lobe
by flowing toward the water intake canal, or northeast to a stream that drains the lake (now identified
as the unnamed eastern extension) that flows along the eastern side of the EAB and discharges into the
water intake canal10. Groundwater flow into the western lobe of the EAB is inferred to occur from the
west, south and east' 1. Groundwater discharges from the western lobe of the EAB are inferred to
occur to the north toward the plant. Further, the modeling report infers that groundwater beneath the
EAB flows toward discharge areas in wetlands and/or ponds located north of the EAB dam.
Groundwater flow into the WAB is inferred to flow into the basin from upland areas to the east.
Groundwater appears to discharge from the WAB to the north, west and south. Groundwater is
inferred to discharge from the WAB by flow to the north through and around the dam, through and
beneath the dam on the south end of the WAB, and to discharge into the canal located west of the
WAB.
Surface waters from the EAB, including groundwater that has discharged to surface water, are routed
to the west where it enters the northern end of the WAB. Sluice water used to transport bottom ash to
the WAB also discharges into the northern end of the WAB. Surface water from these sources, along
with precipitation and groundwater that discharges from the WAB, discharges through the filter dam at
the south end of the WAB and into the discharge canal. The discharge canal wraps around the west
side of the WAB, ultimately discharging into Hyco Lake. The CAP indicates12 that seeps and surface
7 SynTerra, 2015a, p.26.
8 SynTerra, 2015b, Appendix E
9 The discussion of groundwater flow included in Appendix E (p. 4) erroneously indicates that flow toward the EAB is from
uplands to the north and west. Examination of head distribution maps included with the modeling report make it clear that
this statement in the text is in error.
10 SynTerra, 2015b, Appendix E, Section 2.2.
11 The Groundwater Modeling Report actually says recharge is from the north rather than the south. It appears that this was
a mistake as the limited groundwater head data shows higher heads located south of the west lobe.
12 SynTerra, 2015b, Section 2.2.3.
M

GEO-HYDRO, INC
water drain into NPDES-permitted surface water bodies, but fails to recognize that the parameters
required for testing under the NPDES permit are not those that are elevated by coal ash impacts.
Data collected during the CSA show that groundwater is impacted by the ash basins with boron,
strontium, sulfate, total dissolved solids (TDS) and to a lesser extent, cobalt, iron, manganese, and
vanadium.13 The CSA also determined that Hyco Lake and the plants cooling water intake and
discharge canals are the primary receptors of impacted groundwater and seeps, and that groundwater
flow direction data and surface water data indicate that constituents of interest are migrating to the
reservoir14
Considering the various sources of water that is transferred from the WAB to Hyco Lake through the
discharge canal, it is very likely that the water contains high concentrations of ash -related constituents.
Unfortunately, no samples of discharge canal water were collected during the CSA. The CSA and
CAP each refer to surface water monitoring conducted under NPDES Permit NC0003425 as if that
monitoring augments the CSA surface water characterization. Review of three 2014 Discharge
Monitoring Reports 15 (DMRs) for the Roxboro site showed that NPDES surface water monitoring
requirements do not include the most common analytical parameters that are found in ash impacted
waters. This means that a major discharge of likely ash -impacted water from the Roxboro site into
Hyco Lake was not sampled as part of the CSA and is not being appropriately monitored under
NPDES requirements.
The groundwater flow and transport model of the site was constructed and used in the CAP to evaluate
groundwater flow and investigate three remedial scenarios. The scenarios investigated included the
No Action scenario, a Capping Ash in Place scenario, and a Complete Ash Removal scenario. The
model was used to predict contaminant distributions for the next 5, 15 and 30 years, under each
scenario.
The No Action scenario 16 relies on natural attenuation processes to reduce contaminant concentrations
over time. The ash basin remains in place without modification and "the assumption is made that
current recharge and contaminant loading rates from the ash to the underlying formations are held
constant". "The flow system is assumed to be at steady state with respect to the conditions in 2015."
"Concentrations in the ash were held constant at the measured concentrations." Using these
assumptions the model predicts that the boron plumes will continue to expand laterally and downward,
and increase in concentration over time. The predicted increases in plume size are predicted to be from
on the order of few hundred feet to very small. This result is likely due to constraints on plume size
13 SynTerra, 2015b, p. 3-8
14 SynTerra, 2015a, p.114
15 Duke Energy, 2014
16 The entire description of this scenario is presented in the CAP, Appendix E, Section 6.1.
7

GEO-HYDRO, INC
related to known hydrologic boundaries as were described above. Once a plume reaches a hydrologic
boundary the constituents migrating with groundwater are transferred to the surface water system and
the groundwater plume does not continue to grow in size though contaminants continue to migrate
with surface water.
The Capping Ash in Place scenario17 involves placing a low permeability liner over the ash basin to
prevent infiltration. The description of this scenario assumes that there is no recharge within the basin
and that contaminant concentrations in the ash were allowed to vary (even though concentrations were
fixed in the No Action scenario). Results of this model predict that zones of boron concentration
increase in size and concentration relative to 2015 conditions, but the magnitude of the increases are
less that those calculated under the No Action scenario. Concerns with the Capping Ash Basin
scenario include the assumption of no recharge within the basin and changing the way that
contaminant concentrations in the source material are handled. The hydrogeology of the Roxboro
impoundments (see description of groundwater flow above) includes recharge into the basins from
higher elevation areas to the south and east. Capping of the ash in the basin will not control influx of
groundwater from upland areas. Discharges of groundwater into the ash basins are likely significant as
groundwater discharges into the basin were sufficient to maintain streams prior to their being buried
under coal waste.
The concentration of contaminants in the ash were held constant in the No Action simulation but were
allowed to vary in the Capping Ash in Place scenario. This change in assumptions allowed the
concentration in the ash to decrease more rapidly in the Capping Ash in Place scenario than in the No
Action simulation. The rationale for changing the method of handling source concentrations between
simulations was not discussed. It is unclear if the noted reduction in plume size and concentration is a
result of cap installation, or if it is an artifact of the change in assumptions.
The Complete Ash Removal18 scenario represents complete removal of the ash by inactivating the
upper four model layers, adding drain cells to simulate drainages, and setting recharge within the ash
basin to ambient levels. The Complete Ash Removal scenario predicts the largest reduction in ash -
related contaminant concentrations of any of the tested scenarios.
17 The entire description of this scenario is presented in the CAP, Appendix E, Section 6.2
18 The entire description of this scenario is presented in the CAP, Appendix E, Section 6.3
N.

GEO-HYDRO, INC
5. Opinion 1: Coal Ash Stored in the Roxboro Ash Basins is the
Source of Contamination Detected in Groundwater
Coal ash is the source of contaminants detected in groundwater at concentrations above applicable
standards in the vicinity and downgradient of the ash basin. Data collected during the CSA show
that groundwater is impacted by the ash basins with boron, strontium, sulfate, TDS and to a lesser
extent, cobalt, iron, manganese, and vanadium.19 The lateral extent of groundwater impacts outside
of the ash basins is limited by the presence of water local discharge areas. The contaminated pore
water migrates out of the ash basins and either directly into surface water, or into groundwater that
subsequently discharges to surface water, and eventually into Hyco Lake. This interpretation is
consistent with the CSA which states that:
Hydrologic boundaries are present downgradient of the ash basins in the form of the
intake canal, the discharge canal and the cooling reservoir which discharges to Hyco
Lake. When the CCR constituents reach these hydrologic boundaries, they are
removed from the groundwater system, and they enter the surface water system. At
the Site, boron is the primary constituent that is migrating from the ash basins. 20
19 SynTerra, 2015b, p. 3-8
20 SynTerra 2015b, p.3-8
0

GEO-HYDRO, INC
6. Opinion 2: Capping Coal Ash Located Within the Roxboro Ash
Basin Will Not Protect Groundwater Quality Downgradient of the
Basins
The CAMA process proposed designation of the Roxboro Site as low -risk creates the possibility that
Duke could pursue closure of the Roxboro impoundment by capping the disposed ash in place.
Capping the waste within the footprint of the ash basin will not be protective of groundwater quality
downgradient of the basin.
Environmental contaminants contained in coal ash are leached into groundwater when precipitation
infiltrates through the waste or, when groundwater flows through waste that has been placed below
the water table. In the case of the Roxboro ash basins, both of these processes are currently acting to
create the contaminated ash porewater, groundwater, and surface water that discharge into local
surface waters and eventually into Hyco Lake. The cap -in -place remedy would likely reduce the
amount of water that enters the waste from precipitation. This remedy would however do nothing to
reduce the amount of groundwater that flows laterally into the basin from surrounding geologic
units, through the capped waste, into downgradient groundwater, and eventually into Hyco Lake.
The lined landfill that was constructed over a portion of the EAB should function as a cap over the
ash disposed in the unlined landfill and ash basin. The CSA21 indicates that construction of a lined
landfill has resulted in decreasing concentrations of iron, manganese and chromium in three
monitoring wells (GMW-06, GMW-10 and GMW-11). The available data set does not show a clear
pattern of decreasing contaminant concentrations related to construction of the lined landfill.
Review of the comprehensive analytical results from Roxboro22 shows that large decreases in
several parameters were observed in some monitoring wells during the first few sampling events and
prior to construction of the lined landfill. Figures 3 and 4 show graphs of boron, sulfate, selenium
and TDS concentrations measured in samples from wells in the immediate vicinity of the lined
landfill. Sulfate, TDS, and selenium23 concentrations in some wells were very high initially and
show rapid declines in concentration between the initial sampling event in 2002 and 2004 when the
lined landfill was constructed. This is an indication that decreased contaminant concentrations in
wells since their early sampling events appear to have been due to improper well development or
sampling techniques rather than improving water quality resulting from landfill construction.
Even if it is assumed that construction of the lined landfill has had a positive effect on groundwater
quality, the graphs show that concentrations of ash -related parameters in some monitoring wells has
21 SynTerra, 2015b, p.1-8
22 SynTerra, 2015a, Attachment 3
23 Note that boron was not included in the tested parameters until 2002, so the early concentrations of boron are
unknown.
10

GEO-HYDRO, INC
remained at or above water quality standards in wells GMW-06, GMW-08 and GMW-11 despite the
presence of the lined landfill. In fact, boron, sulfate, and TDS concentrations have been increasing
rapidly in monitoring well GMW-8 since 2013. Continued detections of elevated concentrations24
of ash -related contaminants at in groundwater around the lined landfill indicates that ash underlying
the lined landfill continues to release contaminants to groundwater, even though most infiltration
from above has presumably been eliminated by the landfill liner. This result is to be expected at any
location where ash remains submerged below the local water table. Continued generation and
downgradient migration of leachate will occur in the Roxboro Ash basins unless all of the ash in the
basin is dewatered and remains above the high water table, a scenario that is unlikely to occur at
Roxboro.
Groundwater modeling performed for the CAP provided no estimation of the amount of saturated
ash that would remain at Roxboro should the capping in place remediation scenario be implemented.
An estimate of the thickness of the remaining thickness of saturated ash can be obtained by
comparing the elevation of the natural ground surface beneath the basins to the groundwater
elevation in wells just outside of the basins 25. The ground surface elevation below the EAB dam
was reported to be between 390 and 400 feet ms126. Groundwater elevations in EAB monitoring
wells located just outside of the basin are reported to be between 462 and 513 ft ms127. The
difference between the lowest measured groundwater elevation in wells located just outside the ash
basin and the highest natural ground surface elevations underlying the EAB indicates that at least 62
feet of saturated coal should be expected to be present beneath the EAB were the cap in place
remediation scenario implemented.
The natural ground surface elevation beneath the WAB was reported to be between 390 and 410 feet
ms128. Groundwater elevations in WAB monitoring wells located just outside the ash basin are
reported to be between 452 and 456 ft ms129. The difference between the lowest measured
groundwater elevation in wells located just outside the ash basin and the highest natural ground
surface elevations underlying the EAB indicates that at least 42 feet of saturated coal should be
expected to be present beneath the EAB were the cap in place remediation scenario implemented.
The relative effects of the cap in place and removal of the ash scenarios on groundwater quality were
evaluated as part of the groundwater modeling exercise. The modeling report indicates that removal
24 above 2L standards
25 Estimates of the thickness of saturated ash that would likely remain were the capping ash in place scenario
implemented are provided since the groundwater modeling report did not provide an estimation. Further modeling, or
better model reporting, should be conducted to refine these estimates.
26 SynTerra, 2015b, Appendix E, p.3.
27 SynTerra, 2015a, Figure 6-5.
28 SynTerra, 2015b, Appendix E, p.4.
29 SynTerra, 2015a, Figure 6-5.
11

GEO-HYDRO, INC
of the ash reduces the concentration of boron in groundwater more than either the No Action or
Capping Ash in Place scenarios. This indicates that removal of the Roxboro coal ash is the most
effective option for improving groundwater quality and minimizing future discharges to Hyco Lake.
This is as would be expected considering that the cap in place scenario would leave a significant
thickness of saturated ash in place that would continue to leach ash constituents into the groundwater
far into the future.
12

GEO-HYDRO, INC
7. Opinion 3: Monitored Natural Attenuation Is Not An Acceptable
Groundwater Remediation Strategy at Roxboro
The CAp30 indicates that Duke may evaluate Monitored Natural attenuation as a potential
groundwater remedy for certain area of the Roxboro site. The CAP attempts to make it appear that
Monitored Natural Attenuation (MNA) is a viable remedial option for impacted groundwater
downgradient of the Roxboro ash basin. From a technical standpoint, MNA remedies typically
require:
• That there are no current receptors, including surface water or wetland discharges and water
supply wells.
• That there is sufficient lateral space between the contaminant source and groundwater
discharge areas to allow natural attenuation to reduce contaminant concentrations prior to
reaching a receptor.
• Evidence that the location of the leading edge of the contaminant plumes be stable (not be
expanding).
• That there is a natural reduction in contaminant concentrations along flow paths.
• That there is sufficient space between the contaminant source and groundwater discharge
areas to allow a monitoring system to be established, including sentry wells located ahead of
the leading edge of the contaminant plume.
None of these technical factors for considering MNA as an appropriate remedial strategy at the
Roxboro site are met. From a scientific standpoint there is no justification for considering MNA.
There are also legal requirements that must be met in North Carolina in order to utilize MNA as a
groundwater remedy, including:
• NCAC 02L .0106 (1)(1) requires a demonstration that all sources of contamination have been
removed or controlled. So far, Duke Energy has not proposed removal of the waste for
disposal in a secure location. Hydrogeologic conditions presented in this document shows
that some of the ash would remain saturated after capping. Saturated ash will continue to
leach metals into groundwater that will flow toward and eventually discharge into Hyco
Lake. As a practical matter, in the absence of removal all sources of contamination cannot be
controlled
• NCAC 02L .0106 (1)(2) requires a demonstration that the contaminant has the capacity to
degrade or attenuate under site -specific conditions. Many of the ash -related constituents in
groundwater at this site neither degrade nor attenuate. The Geochemical Site Conceptual
30 SynTerra, 2015b, p.5-1
13

GEO-HYDRO, INC
Model31 states that boron is an indicator of coal ash impacts to groundwater because it "is
essentially inert, has limited potential for sorption and lacks an affinity to form complexes
with other ions." The characteristics of the contaminant plumes alone are sufficient to render
the Roxboro site ineligible to use MNA as a remediation strategy.
31 SynTerra, 2015b, Section 3.3
14

GEO-HYDRO, INC
8. Opinion 4: Capping Coal Ash Located Within the Roxboro Ash
Basin Will Not Be Protective of Surface Water Quality
The most problematic issues at the Roxboro plant are related to the interaction of groundwater and
surface water bodies on and around the plant site. The CAP indicates in several locations that the
lateral extent of groundwater contamination is generally limited to areas beneath or immediately
downgradient of the ash basins. These statements would often be interpreted as indicating that
contamination has not spread far from the source and the problem should be readily remedied.
However, at the Roxboro site the ash basins are bounded by drainage features on around the
perimeter of the basins that act as groundwater discharge areas. Ash -impacted groundwater plumes
are not restricted to the immediate area of the basins by a lack of migration; their size is restricted
only because the contaminated groundwater discharges to surface water features. This is particularly
problematic since water quality in the channel that carries most of the discharge from this site has
not been characterized. No surface water samples were collected from the outflow channel even
though the combined drainage from the East and West Ash Basins are passed through this channel to
Hyco Reservoir. In addition, surface water monitoring conducted under NPDES Permit NC0003425
does not include the most common analytical parameters that are found in ash impacted waters. This
means that a major discharge of likely ash -impacted water from the Roxboro site into Hyco Lake
was not sampled as part of the CSA and is not being appropriately monitored under NPDES
requirements. The chemistry and volume of water that flows through canals and into Hyco Lake
under current and expected closure conditions must be evaluated to assure that the selected remedy
is protective of water quality in Hyco Lake.
A cap -in -place remedy would not be protective of surface water quality. While a cap would likely
reduce the amount of water that enters the waste from precipitation, this remedy would do nothing to
reduce the amount of groundwater that flows laterally into the basin from surrounding geologic
units, through the capped waste, into downgradient surface water drainages, and eventually into
Hyco Lake. Groundwater would continue to flow into the ash basins from adjacent upland areas.
Groundwater that flows through the ash will continue to leach metals from the ash and transport
those metals down -gradient before discharging into adjacent surface water features.
15

GEO-HYDRO, INC
9. Opinion 5: Removal of the Coal Ash Will Remove the Source and
Reduce the Concentration and Extent of Groundwater
Contaminants
Removal (excavation) of the coal ash from the Roxboro ash basin is the only remediation scenario
that will separate the coal ash source materials from groundwater and eliminate flow of
contaminated groundwater and surface water into Hyco Lake. Excavation of the ash will remove the
source of groundwater and surface water contaminants, and reduce the concentration and extent of
current contaminants. The groundwater flow and transport model of the site was used in the CAP to
evaluate groundwater flow and investigate three remedial scenarios. The scenarios investigated
included the Existing Conditions scenario, a Capping Ash in Place scenario, and a Removal of Ash
scenario. The model was used to predict contaminant distributions for the next 5, 15 and 30 years,
under each scenario. The model showed that the Removal of Ash scenario resulted in the largest
reduction in ash -related contaminant concentrations of any of the modeled scenarios.
16

GEO-HYDRO, INC
10. Opinion 6: The Coal Combustion Residual Impoundment Risk
Classification Proposed by NCDEQ Improperly Minimizes
Protection of Environmental Quality
A risk ranking process was specified in CAMA to determine the type of closure permitted at each
facility. The law specifically requires NCDEQ to classify each impoundment as either high -risk,
intermediate -risk, or low -risk, based on consideration, at a minimum, of all of the following criteria.
(1) Any hazards to public health, safety, or welfare resulting from the impoundment.
(2) The structural condition and hazard potential of the impoundment.
(3) The proximity of surface waters to the impoundment and whether any surface waters are
contaminated or threatened by contamination as a result of the impoundment.
(4) Information concerning the horizontal and vertical extent of soil and groundwater
contamination for all contaminants confirmed to be present in groundwater in exceedance of
groundwater quality standards and all significant factors affecting contaminant transport.
(5) The location and nature of all receptors and significant exposure pathways.
(6) The geological and hydrogeological features influencing the movement and chemical and
physical character of the contaminants.
(7) The amount and characteristics of coal combustion residuals in the impoundment.
(8) Whether the impoundment is located within an area subject to a 100-year flood.
(9) Any other factor the Department deems relevant to establishment of risk.
In order to evaluate each impoundment on the nine criteria the NCDEW established a risk
classification group32. The Risk Classification Group was broken into three sub -groups of people
based on areas of expertise (Groundwater, Surface Water, and Dam Safety) to develop a set of risk
factors to address each of the nine required criteria. Each subgroup reportedly placed a primary
emphasis on risk as it relates to the public from a groundwater, surface water, and dam safety
perspective and established one key factor that "plays a significant role in assigning an overall
classification" for that group. Other factors not identified as Key Factors were supposedly used to
"refine the risk classification and address the actual or potential risk to the environment and natural
resources."
The result of the risk classification methodology utilized by NCDEQ is that environmental and
ecologic risks posed by the Roxboro site were not fully considered by NCDEQ when establishing
the overall site risk and clean-up priorities. This resulted in the West, East, and Unnamed Eastern
Extension ash ponds being assigned Low, Low to Intermediate, and Intermediate risk ratings,
32 NDEQ, 2016, p. 13, Classification Methodology
17

GEO-HYDRO, INC
respectively, ratings that essentially ignore the known environmental impacts of the Roxboro ash
ponds. For example, Table 1 provides a listing of the groundwater risk classification factors and
associated ratings for each ash pond at Roxboro. Ten groundwater risk factors were established and
received ratings by NDEQ for each ash pond.
Table 1
Groundwater Risk Classifications
Groundwater Factors
East Ash Pond
West Ash Pond
Unnamed Eastern
Extension
Number of downgradient receptors within 1500 feet of
compliance boundary that are potentially or currently
Low Risk
Low Risk
Low Risk
known to be exposed to impacted water. (Key Factor)
Amount of stored CCR reported in an impoundment
High Risk
High Risk
High Risk
Depth of CCR with respect to the water table
High Risk
High Risk
High Risk
Exceedance of 2L or IMAC standards at or beyond the
High Risk
High Risk
High Risk
established CCR compliance boundary
Population served by water supply wells within 1,500 feet
Low /Intermediate
Low /Intermediate
Low /Intermediate
upgradient or side gradient of the compliance boundary
Risk
Risk
Risk
Population served by water supply wells within 1,500 feet
Low Risk
Low Risk
Low Risk
downgradient of the compliance boundary
Proximity of 2L or IMAC exceedances beyond the
High Risk
Intermediate Risk
High Risk
compliance boundary with respect to water supply wells
Groundwater emanating from the impoundment exceeds
High Risk
High Risk
High Risk
2L or IMAC and that discharges to a surface water body
Ingestion of contaminated soil or fugitive emissions
Low Risk
Low Risk
Low Risk
Data Gaps and Uncertainty
High Risk
High Risk
High Risk
The West Ash Pond received High or Intermediate ratings for 6 of the 10 groundwater risk
classification factors, one factor was rated as Low/Intermediate, and only 3 received ratings of Low
Risk. Only 30% of the rated groundwater risk classification factors were rated Low Risk, yet
NCDEQ gave the Roxboro West Pond an overall Low Risk rating for groundwater.
The East Ash Pond received 6 High Risk ratings, one factor was rated as Low/Intermediate, and only
3 received ratings of Low Risk. High risk rankings were assigned to 60% of the rated groundwater
risk classification factors, yet NCDEQ gave the Roxboro East Pond an overall Low to Intermediate
Risk rating for groundwater.

GEO-HYDRO, INC
The Unnamed Eastern Extension received High risk ratings for 6 of the 10 groundwater risk
classification factors, one factor was rated Low/Intermediate, and only 3 received ratings of Low
Risk. High risk rankings were assigned to 60% of the rated groundwater risk classification factors,
yet NCDEQ gave the Roxboro Unnamed Eastern Extension an overall Low Risk Rating for
groundwater.
Table 2 provides a listing of the surface water risk classification factors and associated ratings for
each of the Roxboro ash ponds. A total of eight surface water risk factors were rated by NCDEQ for
each pond. The West Pond received High or Intermediate ratings for 6 of the 8 surface water risk
classification factors and only 2 received ratings of Low Risk. Only 25% of the rated surface water
risk classification factors were rated Low Risk, yet NCDEQ gave the Roxboro West Pond an overall
Low Risk rating for surface water.
Table 2
Surface Water Risk Factors
Unnamed Eastern
Surface Water Factors
East Ash Pond
West Ash Pond
Extension
Landscape Position and Floodplain (Key Factor)
Low Risk
Low Risk
Low Risk
NPDES Wastewater and Ash Disposal Methods
Low/ Intermediate
High Risk
Intermediate / High
Risk
Risk
Impoundments Footprint Siting in Natural Drainage
High Risk
High Risk
High Risk
Way or Stream
Potential to Impact Surface Water Based on Total
High Risk
High Risk
Low Risk
Ash Amount at Facility
Potential to Impact Surface Water Based on Dilution
High Risk
High Risk
High Risk
Development Density of Single -Family Residences
Intermediate Risk
Intermediate Risk
Intermediate Risk
along Lake/Reservoir Shoreline
Classification of the Receiving Waters
Intermediate Risk
Intermediate Risk
Intermediate Risk
Proximity to Water Supply Intake
Low Risk
Low Risk
Low Risk
The East Pond received High or Intermediate ratings for 5 of the 8 surface water risk classification
factors, one factor was rated as Low/Intermediate, and only 2 received ratings of Low Risk. Only
25% of the rated groundwater risk classification factors were rated Low Risk, yet NCDEQ gave the
Roxboro East Pond an overall Low Risk rating for surface water.
The Unnamed East Extension Pond received High or Intermediate ratings for 5 of the 8 surface
water risk classification factors and only 3 received ratings of Low Risk. Only 37.5% of the rated
19

GEO-HYDRO, INC
surface water risk classification factors were rated Low Risk, yet NCDEQ gave the Unnamed
Eastern Extension pond an overall Low Risk rating for surface water.
The preceding analysis uses the risk ratings applied by NCDEQ with no evaluation or judgment
about whether they were or were not appropriately applied. The risk ratings given to the Roxboro
ash basins demonstrate that protection of environmental and natural resources is not being treated as
priority issues by the North Carolina agency entrusted with the responsibility to do just that. The
approach utilized by NCDEQ effectively ignores impacts to the natural environmental and natural
resources, and even ignores future human users of the groundwater and surface water resources. It
appears that in the view of NCDEQ the only way that a site can be rated as Intermediate or High
Risk is if a facility is located within a 100-year floodplain or if 11 or more people within 1,500 feet
of the compliance boundary are potentially or currently known to be exposed to ash -impacted
groundwater33. It is hard to imagine that exposed persons 1 through 10 would agree with this rating
scheme.
33 NCDEQ, 2016, page 15, Key Factors
20

GEO-HYDRO, INC
References
Duke Energy, 2014, Discharge Monitoring Reports for September, October, and November 2014.
National Pollutant Discharge Elimination System, Permit NC0003425.
NCDEQ, 2016, Coal Combustion Residual Impoundment Risk Classifications, January 2016.
SynTerra, 2014, Groundwater Assessment Work Plan for Roxboro Steam Electric Plant, Semora,
NC, September 2014.
SynTerra, 2015a, Comprehensive Site Assessment Report, Roxboro Steam Electric Plant, Semora,
NC, September 2015.
SynTerra , 2015b, Corrective Action Plan, Part 1, Roxboro Steam Electric Plant, Semora, NC,
December 2015.
United States Geological Survey, Olive Hill, N.C., 7.5 Minute Topographic Map, 1968, revised
1994.
21

GEO-HYDRO, INC
Figures

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Boron and Sulfate Concentrations
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Roxboro Steam Electric Plant

Applied Geochemistry 67 (2016) 177-185
Contents lists available at ScienceDirect
Applied Geochemistry
ELSEVIER journal homepage: www.elsevier.com/locate/apgeochem
Leaching potential and redox transformations of arsenic and selenium
in sediment microcosms with fly ash
Grace E. Schwartz a,1, Nelson Rivera a, Sung -Woo Lee a, James M. Harrington b,
James C. Hower `, Keith E. Levine b, Avner Vengosh d, Heileen Hsu -Kim a, *
a Duke University, Department of Civil & Environmental Engineering, 121 Hudson Hall, Durham, NC 27708, USA
b RTI International, Analytical Sciences, 3040 East Cornwallis Drive, Research Triangle Park, NC 27709, USA
University of Kentucky, Center for Applied Energy Research, 2540 Research Park Drive, Lexington, KY 40511, USA
a Duke University, Division of Earth and Ocean Sciences, Nicholas School of the Environment, Durham, NC 27708, USA
A R T I C L E I N F O
Article history:
Received 6 November 2015
Received in revised form
8 February 2016
Accepted 21 February 2016
Available online 23 February 2016
Keywords:
Coal combustion residuals
Water quality
Solid waste disposal
1. Introduction
A B S T R A C T
® CrossMark
The unintended release of coal ash to the environment is a concern due to the enrichment of contam-
inants such as arsenic (As) and selenium (Se) in this solid waste material. Current risk assessments of coal
ash disposal focus on pH as the primary driver of leaching from coal ash. However, redox speciation of As
and Se is a major factor for their mobilization potential and has received much less attention for risk
assessments, particularly in disposal scenarios where coal ash will likely be exposed to microbially-
driven redox gradients. The aim of this study was to demonstrate the differences of aerobic and
anaerobic conditions for the leaching of As and Se from coal ash. Batch sediment -ash slurry microcosms
were performed to mimic an ash spill scenario and were monitored for changes in As and Se speciation
and mobilization potential. The results showed that the dissolved As concentrations were up to 50 times
greater in the anaerobic microcosms relative to the aerobic microcosms during the two week incubation.
This trend was consistent with As redox speciation determined by X-ray absorption spectroscopy, which
indicated that 55% of the As in the solid phase at the end of the experiment was present as As(III) (a more
leachable form of arsenic relative to As(V)). In the aerobic microcosms, only 13% of the As was As(III) and
the rest was As(V). More than half of the Se was present as Se(IV) in the original fly ash and in the aerobic
microcosms, while in the anaerobic microcosms Se was gradually transformed to less soluble Se(0)
species. Likewise, dissolved Se concentrations were up to 25 times greater in the aerobic microcosms
relative to anaerobic conditions. While the overall observations of As and Se mobilization potential from
coal ash were consistent with expectations for aqueous and solid phase speciation of these elements, the
findings directly show the relevance of these processes for coal ash disposal. These results highlight the
need to select appropriate environmental parameters to include in risk assessments as well as provide
potential geochemical monitoring tools through the use of dissolved Se/As ratios to determine the redox
conditions of ash storage and spill sites.
Coal ash is the solid waste by-product of coal combustion and
includes bottom ash, fly ash, and sludge from flue gas desulfur-
ization units. Every year, over 60 Mt of coal ash are disposed in 300
landfills and 600 holding ponds across the United States (American
* Corresponding author.
E-mail address: [e-mail] (H. Hsu -Kim).
Current Affiliation: Smithsonian Environmental Research Center, 647 Contees
Wharf Road, Edgewater, Maryland, 21037 USA.
http://dx.doi.org/10.1016/j.apgeochem.2016.02.013
0883-2927/0 2016 Elsevier Ltd. All rights reserved.
© 2016 Elsevier Ltd. All rights reserved.
Coal Ash Association; US EPA, 2013d). Ash wastes are enriched in
many potentially toxic elements, and the presence of arsenic (As)
and selenium (Se) are a particular concern because of their rela-
tively high mobilization potential at neutral to alkaline pH values
that are typical of ash disposal impoundments (Izquierdo and
Querol, 2012; Meij, 1994). Moreover, these elements have the ten-
dency to bioaccumulate in the aquatic food web and impart eco-
toxicological effects (Izquierdo and Querol, 2012; Lemly, 2004;
Rowe, 2014; Sharma and Sohn, 2009; Thorneloe et al., 2010).
Coal ash impoundments are not always closely monitored,
particularly for effluent discharge to surface waters, seepage to

178
G.E. Schwartz et al. / Applied Geochemistry 67 (2016) 177-185
groundwater, and structural integrity. Consequently, impoundment
effluent discharge is a major source of As and Se contamination to
certain aquatic environments, with approximately 36,000 kg of As
and 102,000 kg of Se discharged annually to surface waters in the
United States (US EPA, 2013a). Ash impoundments have been cited
in 132 documented cases of groundwater and surface water
contamination (US EPA, 2007, 2013a). Moreover, impoundment
failures and direct release of ash have been reported by at least 41
different power plants in the last 15 years (US EPA, 2012a). These
impoundment failures include the 2008 ash spill at the Tennessee
Valley Authority (TVA) Kingston Fossil Plant. Arsenic and selenium
originating from the spilled ash were two contaminants of concern
at the site (Ruhl et at., 2009, 2010).
The mobility of As and Se in the environment is intimately
linked to redox speciation of these elements and the propensity of
individual species to associate with soil and sediment particles
through adsorption/desorption reactions and precipitation/disso-
lution reactions (Fernandez -Martinez and Charlet, 2009;
Masscheleyn et al., 1991). The As(V) oxyanion arsenate tends to
sorb more strongly to mineral phases such as iron oxides when
compared to the reduced As(III) arsenite form (Goldberg and
Johnston, 2001; Masscheleyn et al., 1991; Raven et al., 1998). If
sulfide is present in sufficient quantities, insoluble arsenic -sulfide
species (As2S3(s)) and soluble thioarsenicals may form (O'Day
et al., 2004; Wilkin et al., 2003). In contrast to As, the Se(VI) oxy-
anion selenate has little tendency to adsorb to solids or to precip-
itate out of solution compared to selenite Se(IV), which has greater
sorption affinity to metal oxyhydroxides, clays, and organic matter
(Fernandez -Martinez and Charlet, 2009). In anaerobic conditions,
selenium can persist as elemental selenium Se(0) or metal selenide
mineral phases that are sparingly soluble in water. Organo-Se
compounds such as selenocysteine and selenomethionine are a
reduced forms of Se that are biologically active (Lemly, 1993).
Arsenic associated with coal ash exists mainly as As(V) species
while Se is typically found as Se(IV) and elemental Se(0) species
(Chappell et al., 2014; Deonarine et al., 2015; Huggins et al., 2007;
Liu et al., 2013). The mobilization of As and Se from coal ash is
typically assessed using deionized water under aerobic conditions
and perhaps under a wide range of pH values (Bednar et al., 2010;
Izquierdo and Querol, 2012; Liu et al., 2013; Thorneloe et al., 2010).
Much less attention has been given to redox transformations that
can occur during ash disposal, even though these processes are
critical for As and Se mobilization, as stated above. Two studies
have attempted to address redox conditions by taking ash-
deionized water mixtures and purging a subset with nitrogen gas
(Bednar et al., 2010; Liu et al., 2013). The results of the work showed
no or minimal differences between the oxic and Nz-purged mix-
tures with respect to As and Se redox speciation and leaching po-
tential from the ash. These results were inconsistent with our
previous field studies at the TVA Kingston ash spill site and at
several North Carolina ash holding ponds, where the mobilization
of As and Se from coal ash appeared to change as a function of local
redox conditions (Ruhl et al., 2012, 2010, 2009). Comprehensive
measurements of As and Se speciation were not available from
these field sites to verify the mechanisms of leaching from the ash.
This study aimed to delineate the effects of redox gradients for
As and Se mobilization from coal ash using laboratory sediment
microcosms that more closely mimic the complexity of biogeo-
chemical redox processes in the environment. Another objective
was to improve our understanding of processes that were previ-
ously observed at coal ash spill sites and perhaps identify
geochemical tools for monitoring coal ash contaminants in redox
gradients. Batch sediment slurry microcosms were constructed
with aerobic and anaerobic conditions and were amended with fly
ash to simulate a coal ash spill into a benthic sediment -water
system. The microcosms were monitored for total dissolved con-
centrations of As and Se, speciation of these elements in the
aqueous and solid phases of the microcosms, and other water
chemistry variables relevant for As and Se leaching.
2. Materials and methods
2.1. Materials
All chemicals for reagents were purchased from Sigma Aldrich
(St. Louis, MO), unless otherwise stated. Trace metal grade acids
(Fisher Scientific, Pittsburgh, PA) were used for acid digestions and
pH adjustments of samples. All reagents and calibration standards
were prepared with >18 MQ-cm Milli-Q grade filtered water (EMD
Millipore).
The microcosms comprised of mixtures of sediment and water
from the Emory River (Tennessee, USA). Surface water and bottom
sediment samples for the microcosms were collected in April 2014
from mile marker 10 of the Emory River near Kingston
(35.9475941°,—84.53178889°), which is located several miles up-
stream of the TVA Kingston ash spill (Bartov et al., 2012; Deonarine
et al., 2013; Ruhl et al., 2009, 2010). The sediment was a mixture of
brown, organic fines and sand. Water samples were taken at 0.15 m
depth and were stored in acid -cleaned plastic jugs. Bulk sediment
was collected from the top layer of sediment (approximately 15 cm)
using a Ponar dredge (Wildco) and placed in screw top buckets. The
sediment and water samples were stored on ice for shipment to
Duke University and stored at 4 °C in the laboratory. These sedi-
ment and water samples were used within one month after
collection for the microcosm experiments. Prior to the construction
of the microcosms, the water was analyzed for trace element
concentration, pH, and conductivity.
The coal ash used for the microcosm experiments was collected
at the TVA John Sevier fossil plant in April 2011. The sample was a
composite of fly ash collected from electrostatic precipitator hop-
pers at each of the plant's four units. The composite fly ash sample
was characterized for major mineral oxide content (by X-ray fluo-
rescence) and for total As and Se concentrations (methods
described in Section 2.3).
2.2. Microcosm preparation and sampling
Sediment slurry microcosm experiments were conducted on
two separate occasions: the first under aerobic conditions, followed
by the second under anaerobic conditions. Each treatment type
(with and without ash; aerobic and anaerobic) was performed in
duplicate microcosms.
The microcosms were designed to mimic a stagnant, ash -
impacted environment. The sediment to surface water ratio in the
microcosms was chosen to provide an environment where suffi-
cient overlying water would be available for sampling and analyses
but microbial activity would not be limited. Each microcosm was
prepared in a 1-L acid -washed, glass jar and consisted of 240 g of
sediment (wet weight basis) and 600 mL of surface water. The
sediment was thoroughly homogenized by stirring before micro-
cosm construction. The river water was amended with a carbon
substrate for microbial activity, 0.5-mM pyruvate and 0.5-mM ac-
etate, immediately prior to microcosm construction.
The aerobic microcosms were continuously stirred and purged
with hydrated air using Teflon tubing and aquarium air stones
during the experiments. After an incubation period of three days,
56 g of coal ash was added to the microcosms designated for ash
amendment. This amount of coal ash corresponded to 40% (w/w) of
dry sediment, an amount that was observed at the TVA Kingston
ash spill site after dredging was completed (Deonarine et al., 2013).

G.E. Schwartz et al. / Applied Geochemistry 67 (2016) 177-185
179
A single replicate sediment -water microcosm containing
6 mg L-1 resazurin was also constructed to serve as an indicator of
redox conditions. This indicator microcosm was not used for the
ash experiments but was used only to infer aerobic conditions for
the other microcosms.
The anaerobic microcosm experiment was performed after the
completion of the aerobic experiment. These microcosms con-
tained the same amount of water and sediment (600 mL and 240 g,
respectively); however, they were constructed in 1-L glass pyrex
bottles with gas -tight caps and assembled inside an anaerobic
chamber (Coy Labs, Grass Lake, MI) containing an ambient atmo-
sphere of 90% Nzlgl, 5% COZIgy and 5% Hz(g). Surface water amended
with the carbon substrate (0.5-mM pyruvate and 0.5-mM acetate)
was purged with high purity NZ for at least 15 min immediately
prior to addition to the microcosms. A single replicate microcosm
with the resazurin redox indicator (6 mg L-1) and no ash was also
prepared for the anaerobic experiment. After assembly, the sealed
microcosms were stored in the laboratory under static conditions at
room temperature (22 °C). The microcosms were mixed end -over -
end once per day in addition to immediately prior to each sampling
time point. Anaerobic conditions (EH < —50 mV) were achieved in
approximately three days, as indicated by the resazurin indicator
microcosm turning from pink to a clear color. At this time, 56 g of
coal ash was added to the microcosms designated for the ash
amendments (performed in the anaerobic chamber).
At time points before (-72 h, -2 h) and after the ash amendment
(4, 24, 72,168, and 336 h), samples of the microcosm slurry were
collected (12-15 mL in most instances). A portion of the sample
was immediately filtered through a 0.2-µm nylon syringe filter
(VWR). This filtered fraction is herein referred as the "dissolved"
fraction. The solid phase of the slurry sample was collected by
centrifugation (3000 RPM for 15 min). For the aerobic microcosms,
the air bubblers and stir plates were turned off during the sampling.
For the anaerobic microcosms, the collection, filtration, and pres-
ervation of the sample were performed in the anaerobic chamber.
Samples for solid phase separation were capped in the anaerobic
chamber, centrifuged outside the chamber, and then returned
immediately to the anaerobic chamber for the remainder of the
sample preparation.
2.3. Sample preservation and chemical analyses
Filtered aqueous samples were split and analyzed for dissolved
As and Se concentrations, the speciation of dissolved As, pH, and
other relevant water quality variables. Samples for dissolved trace
element analysis (e.g., As, Se, and Fe) were immediately diluted in a
2% (v/v) HNO3/0.5% (v/v) HCl solution and analyzed by inductively
coupled plasma -mass spectrometry (ICP-MS, Agilent 7700). Sulfate
concentration was quantified by ion chromatography (Dionex). For
acid volatile sulfide (AVS), filtered water samples were preserved
with the addition of 10 mM ZnSO4 and 5 mM KOH (corresponding
to final concentrations in the sample) and stored at 4 °C until
analysis. AVS measurements were made using the method
described by Allen et al. (1993) and summarized in the Supporting
Information (SI).
Aliquots of the filtered sample were also analyzed for aqueous
phase As speciation (i.e., arsenate and arsenite) via ultra perfor-
mance liquid chromatography-ICP-MS (Waters ACQUITY UPLC)
coupled with a Thermo ELEMENT 2 sector field ICP-MS (Kim et al.,
2013; Milstein et al., 2003). These samples were preserved with
0.125-M EDTA, in accordance to Bednar et al. (2002). UPLC-ICP-MS
instrument parameters are shown in Table S2. Additional details of
aqueous sample preservation and analysis methods can be found in
the SI section.
Total Se and As concentrations in the original sediment and fly
ash samples were quantified by heated HNO3 acid digestion (85 °C
for 6 h) and analysis by ICP-MS. The same acid extraction procedure
was performed for a soil standard reference material (San Joaquin
Soil NIST SRM 2709) and a coal fly ash reference material (NIST SRM
1633c). The recovery of certified As concentration values were 84%
and 90% for the soil and fly ash references, respectively. Se re-
coveries were 84% and 105%, respectively. For the fly ash sample,
the major mineral oxide content was also characterized via X-ray
Fluorescence following the ASTM standard method for ash analysis.
Se and As speciation in the solid phase from the ash -amended
microcosms was determined using K-edge X-ray absorption near
edge structure (XANES) spectroscopy. The pellets obtained after
centrifugation were subsequently packed into sample holders as
wet pastes, covered with Kapton tape, and stored at 4 'C until
analysis. XANES analyses were also performed for the original
sediment and fly ash endmembers for the microcosms but were not
performed on the ash -free microcosms due to the relatively low
concentration of Se (<0.5 µg g 1) and arsenic (<2.5 µg g 1) and
limitations of synchrotron beamtime required for these
measurements.
XANES spectra were collected in fluorescence mode at Beamline
11-2 at the Stanford Synchrotron Radiation Lightsource (SSRL) in
Menlo Park, CA. Samples were held in a liquid NZ cryostat during
analysis, and XANES spectra were collected with the use of a Si(220)
(phi = 90°) monochromator and a 100-element solid state Ge de-
tector array. Successive scans were collected to ensure that no
changes in the sample occurred during data collection. Speciation
of As and Se in the samples was quantified by linear combination
fitting (LCF) of reference spectra to the sample spectra. For sele-
nium, the references included sodium selenate, sodium selenite,
selenite sorbed to aluminosilicate glass (Rivera et al., 2015), SO(S),
FeSe(s), and seleno-L-cystine. Arsenic references included As(V)-
and As(III)-oxides, arsenate adsorbed to aluminosilicate glass
(Rivera et al., 2015), arsenite adsorbed to ferrihydrite (Root et al.,
2007), orpiment (As2S3) and realgar (ASS). Additional details on
XANES sample preparation and analysis can be found in the SI
section.
3. Results and discussion
3.1. Characteristics of the ash, sediment, and water used for the
microcosms
Total As and Se concentrations in the ash were 44 µg g 1 dry
weight (dw) and 19 µg g 1 dw, respectively, while in the original
river sediment, total As and Se were 2.38 µg g 1 wet weight (ww)
and 0.27 µg g 1 ww, respectively. Characteristics of the surface
water included pH 7.5, 125.6 µS cm-1 conductivity, less than
4 µg L-1 As, and <0.4 µg L-1 Se. With these concentrations quan-
tified in the original materials, each sediment microcosm without
ash was estimated to contain 570 µg of As and 65 µg of Se. Micro-
cosms with sediment and ash each contained approximately
3040 µg total As and 1130 µg total Se, with 81% and 94% of the As
and Se originating from the fly ash. The fly ash sample comprised
primarily of silica-, aluminum-, and iron -oxides (56%, 28%, and
6.7%, respectively) (Table S1), characteristics that are typical for a
Class F fly ash.
3.2. Leaching potential of selenium in anaerobic and aerated
microcosms
Upon addition of the coal ash to both anaerobic and aerobic
microcosms, dissolved Se immediately increased to concentrations
that were 150-times greater than pre -amendment measurements
(Fig.1). The extent of dissolved Se release varied according to redox

180
G.E. Schwartz et al. / Applied Geochemistry 67 (2016) 177-185
(a) 120
J
rn
m
a�
0
0
co
100
80
60
40
20
my
Ash
-100 0 100 200 300 400
Hours after Coal Ash Amendment
(b) 120 Anaerobic
�1 100
6)
80 -D `Sediment -Only
0 Sediment + Ash
> 60
0
ij 40
20
0
-100 0 100 200 300 400
Hours after Coal Ash Amendment
Fig.1. Total dissolved selenium concentrations (<0.2 µm filtered fraction) in sediment -
ash microcosms: (a) Aerobic treatments; (b) Anaerobic treatments. Each data point
represents the average of duplicate microcosms. Error bars represent the range of
duplicates.
state, but in both cases, dissolved Se concentrations were greater in
microcosms with ash amendments than in the respective ash -free
control microcosms (<1.5 µg L-1 throughout the experiment).
Dissolved Se was generally greater in the aerobic microcosms
than in the anaerobic microcosms (with the exception of the first
time point at 4 h) (Fig.1). In the aerobic ash -amended microcosms,
total Se concentration reached a maximum of 53 µg L-1 at 24 h after
ash addition and decreased to 29 µg L-1 over the course of the two -
week experiment. While a decrease in soluble Se could indicate
reductive transformation of Se to less soluble, lower oxidation
states such as elemental selenium, other water chemistry variables
such as constant levels of dissolved sulfate (Fig. SI) and low levels
of dissolved iron (<0.02 mg L-1) (Fig. S2) throughout the experi-
ment indicated that aerobic conditions were maintained. The
decrease in dissolved Se could instead be a result of re -adsorption
of Se(IV) species onto coal ash and sediment particles, which has
been shown to occur in aerobic systems (Fan et al., 2002; Simmons
and Wallschlager, 2005). Measurements of dissolved Se speciation
were attempted, but the concentrations were below the limit of
quantification for our UPLC-ICP-MS system (<50 µg L-1).
In anaerobic ash -amended microcosms (Fig. 1b), there was an
immediate spike in total dissolved Se after the coal ash amend-
ment, but then Se concentration decreased from 94 µg L-1 at 4 h to
1.8 µg L-1 at 336 h. This decline in dissolved Se concentration was
more drastic than that observed in the aerobic microcosms
amended with ash.
The pH of the water could influence leaching of Se-oxyanions,
which tend to desorb in greater amounts from coal ash as pH in-
creases (Liu et al., 2013). In the ash -amended microcosms, the pH
was 7.3-7.5 in aerobic conditions and similar to pH values in the
anaerobic experiment (pH 7.1-7.4) (Fig. S3). These results indicated
that the differences between the aerobic and anaerobic microcosms
for dissolved Se could not be explained by pH.
The measured amount of dissolved Se was always less than 5% of
the total Se in the microcosm, and the bulk of the selenium
remained in the solid phase. Therefore, we examined the speciation
of solid phase Se as a means to determine the longer term leaching
potential of Se. In the original fly ash, approximately 65% (±0.4%) of
the Se was Se(IV) species, as indicated by LCF models of the Se K-
edge XANES spectra (Fig. 2, Table S3). A smaller proportion, 26%
(±0.4%) and 9% (±0.5%), was Se(0) and Se(VI), respectively. In all ash
and microcosm samples, the best fits were obtained with the use of
selenite sorbed to aluminosilicate rather than sodium selenite for
the Se(IV) reference. This suggests that the sorbed selenite material
was a better approximation of Se(IV) species in the coal ash -
sediment matrix than the sodium selenite standard.
In aerobic ash -amended microcosms, Se(IV) was the dominant
form of Se in the solid phase at all time points (Fig. 2, Table S3). This
result is consistent with the Se speciation of the original ash sam-
ple. The proportion of Se(0) also appeared to grow over the course
of the experiment (from 19 ± 0.6% at 24 h to 38 ± 0.5% at 336 h).
While abiotic reduction of Se is not expected in the aerated con-
ditions of the microcosms, selenite-reducing microorganisms are
capable of producing Se(0) in oxic conditions (Antonioli et al., 2007;
Hunter and Kuykendall, 2007; Hunter and Manter, 2009; Zheng
et al., 2014).
In the anaerobic microcosms amended with ash, Se speciation of
the solid phase was drastically different from the original fly ash
sample. LCF models of the XANES spectra showed that the majority
of selenium in the solids was Se(0) and FeSe and that the proportion
of Se(0)+FeSe increased from 68% at 4 h to 79% at 336 h (Fig. 2,
Table S3). The formation of FeSe was further supported by the
dissolved Fe data (Fig. S2). In the anaerobic experiment, dissolved
Fe concentrations immediately decreased to values below
1.5 mg L-1 after the ash amendment, even though dissolved Fe in
the ash -free anaerobic control was greater than 10 mg L-1 and
increasing with time. Sulfate reduction was also occurring in the
anaerobic microcosms (Fig. S1); thus, dissolved Fe was likely
precipitating out of solution as FeS and FeSe particles.
Collectively, the aqueous and solid phase Se speciation data
indicated that a portion of the Se in fly ash readily leached from the
ash under aerobic conditions. However, in anaerobic settings, the
results indicated that Se originating from the ash was transformed
to species of lower oxidation states, subsequently diminishing the
leaching potential of Se.
3.3. Arsenic dissolution and speciation in aerobic and anaerobic
microcosms
The leaching of As in the microcosms was also dictated by redox
potential, with much greater dissolved As concentrations observed
in anaerobic conditions than in aerobic conditions (Fig. 3). In the
aerobic microcosms (Fig. 3a), the addition of ash resulted in an
increase of total dissolved As concentration to a maximum value of
12 µg L-1 at 336 h (Fig. 3a). In the anaerobic experiment (Fig. 3b),
the total dissolved As concentration after the addition of ash was
greater: 157 µg L-1 was detected at 4 h and a maximum dissolved
As concentration of 498 µg L-1 was observed at 72 h (Fig. 3a). This
amount of dissolved As represented 9.8% of the total mass of As in
the microcosm container (570 µg As from the original sediment;
2460 µg As from the ash). After 72 h, total dissolved As concen-
trations declined slightly over the remainder of the anaerobic

G.E. Schwartz et al. / Applied Geochemistry 67 (2016) 177-185
181
(a) Sample - - - LCF (b)
Aerobic:336h
Aerobic:168h
Aerobic:24h
117
1
li
lilt
l t
Anaerobic:336h
"
Anaerobic:168h
w
Z
�'
I Anaerobic:24h
Q
X
.I
I
Sediment
E
��
Ash
o
Z
n
i
"
HA
Se(VI)
Se(IV)
Se(0)
FeSe
12650 12660 12670 12680
Energy (eV)
0% 20% 40% 60% 80% 100%
Percent Composition
® FeSe
Elemental Se
INSe(IV)
MSe(VI)
Fig. 2. Solid phase speciation of selenium: (a) Normalized Se K-edge XANES spectra for solids from the ash -amended microcosms and models of the data using linear combination
fitting (LCF) of reference spectra; (b) The relative proportions of iron selenide (FeSe), elemental Se(0), Se(IV) (as selenite sorbed to aluminosilicate), and Se(VI) (sodium selenate). The
total Se in the solid phase of the microcosm was estimated to be 3.8 µg g-1, of which 94% originated from the coal ash.
experiment.
The speciation of dissolved and solid phase As was largely
consistent with expectations for the tested redox condition. In the
aerobic ash -amended microcosms, more than 92% of the dissolved
As was in the oxidized form, As(V) (Fig. 4a). Similarly, As speciation
in the original fly ash and the sediment -ash mixture of the aerobic
microcosm was predominantly As(V) (85-89%, Fig. 5 and Table S3).
The best model fits for the As K-edge XANES spectra were obtained
with arsenate-sorbed to aluminosilicate glass as the As(V) refer-
ence material and with arsenite sorbed to ferrihydrite as the As(III)
reference material. We observed poorer fits with the use of As -
oxide compounds as the As(V) and As(III) references. This result
suggested that the sorbed standards were better mimics of As
species in the coal ash and ash -sediment matrices.
In the anaerobic experiment, the dissolved As after the addition
of ash was present mostly as arsenite (>86%) (Fig. 4b). As(V) was
consistently less than 15% of the dissolved As in the anaerobic
microcosms with ash. We note, however, that for the amount of
dissolved sulfide in the anaerobic microcosms with fly ash
(2-8 µM, Fig. S4), thioarsenite and thioarsenate species were
possible. Previous studies have shown that thio-arsenic species are
not preserved by the EDTA reagent and can be converted to arsenite
and arsenate prior to the analysis (Suess et al., 2011). While thio-
arsenicals were a possibility in the anaerobic microcosms, they
nevertheless were not expected to be dominant based on ther-
modynamic considerations (Wilkin et al., 2003).
In the solid phase of the ash -amended anaerobic microcosms,
As(III) was also the dominant form of As (55-73%) while As(V) was
less than 41% at all time points (Fig. 5, Table S3). This result indi-
cated relatively rapid transformation of As(V) from the fly ash to
As(III) species. The amount of As -sulfide solids in the anaerobic
experiment also increased from 2% at 24 h to 19% at 336 h. The
formation of relatively insoluble As -sulfide minerals such as orpi-
ment can result in a decrease of dissolved As (Burton et al., 2014;
O'Day et al., 2004). Thus, the production of As -sulfides species in
the anaerobic microcosm could explain the decrease of dissolved As
after the 72-h time point (Fig. 3b). Collectively the dissolved and
solid phase As species distribution in the anaerobic experiments
demonstrated reductive transformation of As from the ash material
and was consistent with expectations for As speciation in a strongly
reducing environment where sulfate reduction was occurring
(Smedley and Kinniburgh, 2002).
Unexpectedly, in the anaerobic ash -free microcosms, As(V) was
found to be the dominant form (70% and greater) of dissolved As
(Fig. 4c). With relatively low amounts of dissolved sulfide in the
ash -free microcosm (less than 0.1 µM at the end, Fig. S4), the dis-
solved As(V) was likely to primarily consist of arsenate rather than
thioarsenate. The total dissolved As and dissolved Fe concentra-
tions were also increasing with time in the anaerobic ash -free
microcosms. Thus, leaching of As was likely occurring through
reductive dissolution of iron oxides and release of As(V) sorbed to
these minerals. We note, however, that the reduction of Fe(III)-
oxides and As(V) occur in the same Eh range (0-100 mV) for
neutral pH conditions (Masscheleyn et al.,1991), and the reduction
potential of the anaerobic microcosms was likely to be less
than —50 mV, as indicated by the resazurin. Thus, it is unclear why
As(V) remained dominant in the anaerobic ash -free microcosms.
One potential explanation is that Fe(III) outcompeted As(V) as an
electron acceptor for microbial respiration. The kinetics for As(V)
reduction to As(III) are also known to be relatively slow, which may

182
G.E. Schwartz et al. / Applied Geochemistry 67 (2016) 177-185
(a) 16 Aerobic
J
6) 12 T
Q
8 I
> -a -Sediment Only
0
f Sediment + Ash
0 4
- - - - 0 a -
-100 0 100 200 300 400
Hours after Coal Ash Amendment
(b) 600 Anaerobic m❑ -Sediment Only
—W- Sediment+Ash
J
400
Q
Q)
N
O
n 200
0
-------❑
0 IT I
-100 0 100 200 300 400
Hours after Coal Ash Amendment
Fig. 3. Total dissolved arsenic concentrations (<0.2-µm filtered fraction) in sediment -
ash microcosms: (a) Aerobic treatments; (b) Anaerobic treatments. Data points and
error bars represent the average and range of duplicate microcosms.
have contributed to the presence of both species in the ash -free
microcosm (Masscheleyn et al., 1991; Smedley and Kinniburgh,
2002). Likewise, the ash -free microcosms were poised at moder-
ately reducing conditions while the ash -amended microcosms
were poised at lower redox potential (as indicated by reduction of
sulfate and production of sulfide in the presence of ash, Figs. SI and
S4). Lower Eh values in the ash amendments could lead to greater
conversion of As(V) to As(III) compared to the ash -free control.
In summary, the microcosm experiments demonstrated that the
leaching potential of As from coal ash was greater in anaerobic
conditions than aerobic conditions, due to redox transformations of
As. However, the large amount of sulfur from the ash could
contribute to secondary precipitation reactions of As -sulfides if the
ash was released or stored in sufficiently reducing conditions.
3.4. Implications for ash spill settings
The results of this study showed that in a system buffered at
neutral pH, redox potential had a major influence on the release of
Se and As from coal ash, with increased As release under anaerobic
conditions and increased Se release under aerobic conditions.
Furthermore, this study provided clues to the impact of coal ash on
the geochemistry of the benthic environment and subsequent im-
plications for As and Se speciation and solubility. For example, the
microcosm experiments showed that coal ash dramatically
increased dissolved sulfate concentrations. In anaerobic environ-
ments with active microbial populations, reduction of sulfate can
result in formation of sulfide and the sequestration of As(III) in
sulfide mineral phases.
The results also shed light on possible field -based tools to
(a) Aerobic: Ash -Amended Microcosms
12
10
Q
6
0
n 4
2
0
(b) 600
500
400
to
Q
300
0
w 200
100
0
(o) 80
-1 60
-o 40
0
Ch
0 20
0
. ... n, 'I 'I A o/
4 24 72 168 336
Hours after Coal Ash Amendment
Anaerobic: Ash -Amended Microcosms
124%
102%
10�% Ih
11 105%
105%
4 24 72 168 336
Hours after Coal Ash Amendment
Anaarnhir• Cariimant r)nly Mirror-c
As(V)
El As(III)
■ As(V)
El As(III)
As(V)
ElAs(III)
4 24 72 168 336
Hours after Coal Ash Amendment
Fig. 4. Dissolved arsenic as arsenate As(V) and arsenite As(Ill) in: (a) Aerobic ash -
amended treatment; (b) Anaerobic ash -amended treatment; (c) Anaerobic sediment
only (no ash) treatment. Bars represent the average of duplicate microcosms. The
percentages above each bar is the recovery of total dissolved As (quantified inde-
pendently by ICP-MS). Dissolved As concentrations in the ash -free aerobic microcosms
were below detection limits for speciation analysis (<12 µg L-1).
evaluate the processes controlling As and Se mobilization from coal
ash. The Se/As ratios in the aerobic and anaerobic experiments
showed opposite trends, depending on the redox state of the
experiment (Fig. 6). If the original Se/As ratio is known for a spilled
coal ash, one could delineate the conditions that control Se and As
mobilization based on the changes in their ratios relative to the
ratios in the original coal ash. This tool might provide an indirect
measurement of the redox state of the system and predictions for
future fluctuation in Se and As contents based on redox conditions.
The design of this study best mimics stagnant ash -impacted

G.E. Schwartz et al. / Applied Geochemistry 67 (2016) 177-185
183
a () b
Sample - - - LCF
Aerobic:336h
"
Aerobic:168h
Aerobic:24h
VVIA,,
Anaerobic:336h
W
Anaerobic:168h
z
Anaerobic: 24h
�
'll
N
E
`0
Sediment
z
"
"'
Ash
As(V)
1
As(111)
As -Sulfide
1XW
11840 11860 11880 11900 11920
Energy (eV)
0% 20% 40% 60% 80% 100%
Percent Composition
® As -Sulfide
ElAs(III)
a As(V)
Fig. 5. Solid phase speciation of arsenic: (a) Normalized As K-edge XANES spectra for solids from the ash -amended microcosms and models of the data using linear combination
fitting (LCF); (b) The relative proportions of As(V) (arsenate sorbed to aluminosilicate glass), As(Ill) (arsenite sorbed to ferrihydrite), and As -sulfide (as orpiment). Total As in the solid
phase of the microcosms was -10 µg g-1 and approximately 80% of the As originated from the coal ash.
10 aerobic
•
0 1
original ash
Q 0.1
A
0.01
anaerobic A
I�IZI)yl
0 100 200 300 400
Hours after ash addition
Fig. 6. Dissolved Se/As concentration ratios in the aerobic and anaerobic microcosms
amended with ash.
environments, and our results support observations from our pre-
vious field studies of coal ash impacted environments with limited
water exchange (Ruhl et al., 2009, 2010). For example at the TVA -
Kingston ash spill site, pore water extracted from buried
sediment -ash mixtures was found to have much higher total dis-
solved As concentration (mean = 324 µg L-1) than standing surface
water at the site (mean = 53.3 µg L-1) (Ruhl et al., 2010). Addi-
tionally, a study of North Carolina surface waters receiving coal ash
effluent revealed that both As and Se accumulated in lake bottom
sediments and were released into the water column during sea-
sonal thermal stratification and fluctuations of redox potential in
the water column (Ruhl et al., 2012). Our microcosm study repre-
sents only a 2 week snapshot of fly ash weathering, so some caution
is warranted in extrapolating the results to the long term fate of
contaminants at ash spill sites. Nevertheless, data from these ex-
periments strongly suggest that redox transformations of coal ash
contaminants should be considered when assessing remediation
options for ash -impacted environments, especially when balancing
the risks of natural attenuation and alternative measures such as
dredging.
Due to redox-induced adsorption/desorption reactions and
precipitation/dissolution reactions, As concentrations can be very
high in sediment pore water even though contaminant concen-
trations in overlying oxic surface waters may be well -below EPA
guidelines. These high concentrations could present a risk for bio-
magnification in the benthic aquatic food web. Furthermore, the
release of As from sediments into overlying surface waters during
thermal stratification events has implications for communities that
use the surface water for recreational use and as a drinking water
reservoir. The consequences of seasonal As release would be miti-
gated to some degree by dilution, but, nevertheless, the long-term
cycling of As in the environment should be taken into account
when communities consider plans for remediating coal ash
impacted sites (Ruhl et al., 2012).
In the case of Se, Se oxyanion species in the aerobic water col-
umn can be taken up by aquatic biota and converted to

184
G.E. Schwartz et al. / Applied Geochemistry 67 (2016) 177-185
organoselenium species, which are highly bioaccumulative (Fan
et al., 2002; Simmons and Wallschlager, 2005). Accumulation of
Se in sediments also presents a risk to benthic organisms that
ingest Se(0) and Se( -II) species and convert them to organo-
selenium species (Fan et al., 2002). Anaerobic sediments also act
as a source of selenium to the water column if the sediments are
disturbed in a way that results in the oxidation and remobilization
of reduced Se species (Belzile et al., 2000; Simmons and
Wallschlager, 2005). The constant risk of bioaccumulation, and
the latent risk of remobilization in Se -contaminated sediments
should be a major consideration for ash spill remediation.
3.5. Implications for coal ash management
This study's confirmation that redox potential is a key param-
eter in controlling As and Se mobilization during an ash spill brings
into question the applicability of the leaching tests currently used
to assess environmental risks. Coal ash management is guided by
the EPA's Toxicity Characteristic Leaching Protocol (US EPA,1992), a
leaching test performed under aerobic conditions at a single pH
value (pH = 4.9 or 2.4). Other EPA methods such as the Leaching
Environmental Assessment Framework evaluates contaminant
leaching over a wide range of pH values, but the tests still fail to
account for complexity in the real environment (US EPA, 2012b,
2012c, 2013b, 2013c). Likewise, previous experiments with N2-
purged water -ash mixtures did not result in changes to Se and As
speciation in coal ash (Bednar et al., 2010; Liu et al., 2013). The data
from our study suggests that the absence of oxygen, alone, is
insufficient for testing contaminant mobilization in anaerobic
conditions relevant for ash impoundments and ash spill sites.
Instead, microbially-driven redox transitions, which can be stimu-
lated by sulfate from the coal ash, are more environmentally rele-
vant and necessary for attaining sufficiently reducing conditions for
transformations of As, Se, and possibly other contaminants (e.g.,
mercury, chromium, etc.). Moreover, the impacts of the redox
transitions are likely to vary in degree according to the geochemical
properties of the coal ash, the sediment, as well as the composition
of the microbial community. All these considerations are needed in
the future improvements of standardized methods for coal ash risk
assessments.
Finally, these results are helpful for identifying suitable closure
methods for ash impoundments. The U.S. EPA now requires the
closure of ash ponds that show a risk of groundwater contamina-
tion or that are improperly sited (US EPA, 2014b). Likewise, recent
regulations in North Carolina require the closure of all the State's
ash impoundments by 2029; those designated as high -risk must be
closed by 2020 (US EPA, 2014a). One proposed closure method is
the "Cap in Place" approach, where the ash pond would be de -
watered and then covered with a porous or non -porous cap
(Duke Energy, 2015). One concern with this method is that the cap
could alter redox conditions in the impoundment, and this study
shows that such changes could enhance the release of soluble
arsenic into local groundwater. Thus, even if no previous ground-
water contamination issues have been reported, capping methods
that might induce anaerobic conditions should be avoided in the
closure of unlined impoundments. Overall, this research shows the
need to consider both coal ash characteristics and environmental
parameters when assessing the environmental risks of ash disposal.
Acknowledgments
We thank the Tennessee Valley Authority, Restoration Services,
and Environmental Services for their assistance with field sample
collection. We also thank Kaitlyn Porter for her assistance with ICP-
MS measurements. This work was supported by the National
Science Foundation (CBET-1235661). G. Schwartz was also partly
supported by a doctoral scholarship from the Environmental
Research and Education Foundation.
Appendix ASupplementary data
Supplementary data related to this article can be found at http://
dx.doi.org/10.1016/j.apgeochem.2016.02.013.
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From: Culbert, Erin B <Erin.Culbert a duke-energy.com>
Sent: Monday, January 28, 2013 7:35 AM
To: Zarzar, Issa <[e-mail]>; Mitchell, David F <David.Mitchell @r duke-
energy.com>; Herrin, Randy C <Randy.Herrin@duke -energy.com>; Stowe, Allen
<Allen.Stow@duke- energy. com>; Waugh, Dave <[e-mail]>
Cc: Hoffmann, Lisa M <Lis a. Hoffmann@ duke -energy. com>
Subject: RE: Ash basin FAQs
Thanks, Issa. Dave W., I'd like to hear your perspective this morning. Dave Mitchell and I have an interview with Bruce
Henderson this morning, so I'd like to collect our thoughts before 9:30 a.m.
Erin Culbert, APR
Corporate Communications
Duke Energy
704.382.5723 1 office
800.559.3853 1 24-hour media line
[e-mail]
From: Zarzar, Issa
Sent: Friday, January 25, 2013 6:54 PM
To: Culbert, Erin B; Mitchell, David F; Herrin, Randy C; Stowe, Allen; Waugh, Dave
Cc: Hoffmann, Lisa M
Subject: RE: Ash basin FAQs
My answers are in red. I would want Dave Waugh to comment on the ash pond closure strategy and what information
he feels comfortable releasing to the public.
From: Culbert, Erin B
Sent: Friday, January 25, 2013 12:43 PM
To: Mitchell, David F; Zarzar, Issa; Herrin, Randy C; Stowe, Allen
Cc: Hoffmann, Lisa M
Subject: Ash basin FAQs
All,
We have some media interviews coming up next week where we will be asked questions about decommissioning and
ash basin closure, particularly at Riverbend. Please review this to be sure what I have is correct and up-to-date. I need
any edits or concerns by 9 a.m. Monday.
What will happen to the units once they retire?
Once the units retire, attention and planning turns to its decommissioning. This is a comprehensive and
methodical process that takes several years and involves engineering analyses to determine the best site -
specific decisions. The long-term vision for retired units across our system is to return them to ground -level.
We will salvage what equipment we can repurpose at other sites, conduct any environmental abatement
needed, sell any scrap material we can, safely dismantle and remove the powerhouse, stack and any auxiliary
structures no longer needed and then restore the site. This approach is best suited to ensure continued safety,
security and environmental compliance at the site into the future, both for the company and the community.
Issa—would you expect demolition at these sites to begin about two to three years after retirement?
The simple answer is yes. Whoever, it depends on other factors such as Transmission (PD) switch
Duke-SEA-Meck-00001266

yard relay controls relocation from the plant control room to a remote new control room. This activity
could delay the process since it involves system outages.
What will happen to the ash basins once the plant retires?
We plan to close the ash basins (three at Buck, two at Riverbend) once they are no longer needed, in close
coordination with state regulators. This will be conducted through deliberate engineering and will comply with
all state and federal regulations. Our current strategy across the fleet involves a closure -in -place approach,
with dewatering, capping with a synthetic membrane, 18 inches of soil and a vegetated cover. This will prevent
rainwater from percolating and protect groundwater. This allows high environmental protection and is much
less expensive for customers than removing the ash and transporting it elsewhere. That approach is not
warranted and requires other considerations (truck traffic, landfill space, etc.)
[Do we have dollar estimates that we can release to the public for an average closure -in -place vs. clean
closure to illustrate the cost difference? Let's not use the term "clean closure" externally. It implies that other
methods are not.]
The Riverbend basin closure plan is being developed and has not been submitted to the state, but we would
expect it would follow the same strategy we're using across the fleet unless we learn new information during
our site characterization studies. The NPDES permit requires that plan be submitted to the state one year prior
to the closure of the impoundments.
Even once the ash basins are closed, Duke Energy is required to continue monitoring groundwater there for
many years and will continue to manage and steward the site.
Thanks,
Erin
Erin Culbert, APR
Corporate Communications
Duke Energy
704.382.5723 office
800.559.3853 24-hour media line
[e-mail]
Duke-SEA-Meck-00001267

GEO-HYDRO, INC
Consulting in Geology and Hydrogeology
1928 E. 141h Avenue
Denver, Colorado 80206
[phone]
EXPERT REPORT OF
MARK A. HUTSON, PG
Mayo Steam Electric Plant
Roxboro, NC
Prepared for:
Southern Environmental Law Center
601 West Rosemary Street
Suite 220
Chapel Hill, NC 27516-2356
February 2016

GEO-HYDRO, INC
1. Summary of Opinions Formed
Based upon my review of the available information I have formed the following opinions on closure
of the coal ash basin at the Mayo Steam Electric Plant (Mayo).
Coal ash stored in the Mayo ash basin is the source of contamination detected in surface
water and groundwater resources.
2. Capping the waste within the footprint of the Mayo ash basin will not be protective of
groundwater and surface water quality downgradient of the basin.
3. Monitored Natural Attenuation (MNA) is not a viable remedial option for impacted
groundwater and surface water downgradient of the Mayo ash basin.
4. Capping coal ash located within the Mayo ash basin will not be protective of surface water
quality in Crutchfield Branch.
Removal of the coal ash will reduce the concentration and extent of groundwater and surface
water contaminants.
6. The coal combustion residual impoundment risk classification proposed by North Carolina
Department of Environmental Quality (NCDEQ) improperly minimizes protection of
environmental quality.
The background and rationale behind each of these opinions are described in this report.

GEO-HYDRO, INC
2. Introduction
Duke Energy currently stores approximately 6,900,000 tons of coal ash in an unlined, water -filled
lagoon at the Mayo facility in Persons County NC. Pollution caused by the coal ash at this site is
currently the subject of an enforcement action brought by the NCDEQ. Organizations represented
by the Southern Environmental Law Center are also parties to this litigation.
North Carolina General Assembly Session Law 2014-122, the Coal Ash Management Act (CAMA)
of 2014, required the owner of coal combustion waste surface impoundments to conduct
groundwater monitoring, assessment and remedial activities at coal ash basins across the state, as
necessary. The owner of coal ash surface impoundments were required to submit a Groundwater
Assessment Plan (GAP) to NCDEQ by December 31, 2014. Comprehensive Site Assessment (CSA)
reports that reported the results of site characterization activities were required to be submitted
within 180 days of approval of the GAP. Information developed under the CSA provided the data to
be used to prepare Corrective Action Plans (CAP) that were to be submitted to NCDEQ within 90
days of submittal of the CSA. An agreement between Duke Energy and NCDEQ resulted in
breaking the CAP into Parts 1 and 2. As of this date only the CAP Part 1 has been produced for the
Mayo site.
Further, CAMA specifies that any impoundments classified by NCDEQ as high -risk be closed no
later than December 31, 2019 by dewatering the waste and either, a) excavating the ash and
converting the impoundment to an industrial landfill, or b) excavating and transporting the waste off -
site for disposal in an appropriately licensed landfill. Intermediate -risk impoundments are required
to be closed similarly to high -risk impoundments, but under a relaxed closure deadline of December
31, 2024. Impoundments classified as low -risk by NCDEQ must be closed by December 31, 2029
either similarly to the high and intermediate -risk sites, or by dewatering to the extent practicable and
capping the waste in place.
In January 2016 the NCDEQ issued Draft Proposed Risk Classifications (NCDEQ, 2016) for 10 ash
impoundment sites, including Mayo. The draft proposed risk classification assigned to Mayo is low
risk, thus allowing for closure of the impoundment by capping waste in place. On behalf of the
Southern Environmental Law Center, I have reviewed the Groundwater Assessment Plan (SynTerra,
2015a), Comprehensive Site Assessment (SynTerra, 2015b), the Corrective Action Plan Part 1
(SynTerra, 2015c), the Draft Proposed Risk Classifications (NCDEQ, 2016), and the National
Pollutant Discharge Elimination System (NPDES) permit for Mayo (North Carolina Department of
Environment and Natural Resources (NCDENR, 2009).
2

GEO-HYDRO, INC
This report details my opinions regarding: the source of groundwater and surface water pollution at
Mayo, potential remedies for that pollution discussed in the Corrective Action Plan, and the
proposed risk classification for the Mayo site.

GEO-HYDRO, INC
3. Qualifications
The opinions expressed in this document have been formulated based upon my formal education in
geology and over thirty-five years of experience on a wide range of environmental characterization
and remediation sites. My education includes B.S. and M.S. degrees in geology from Northern
Illinois University and the University of Illinois at Chicago, respectively. I am a registered
Professional Geologist (PG) in Kansas, Nebraska, Indiana, and Wisconsin, a Certified Professional
Geologist by the American Institute of Professional Geologists, and am currently serving as Past
President of the Colorado Ground Water Association.
My entire professional career has been focused on regulatory, site characterization, and remediation
issues related to waste handling and disposal practices and facilities. I have worked on contaminated
sites in over 35 states and the Caribbean. My site characterization and remediation experience
includes activities at sites located in a full range of geologic conditions, involving soil and
groundwater contamination in both unconsolidated and consolidated geologic media, and a wide
range of contaminants. I have served in various technical and managerial roles in conducting all
aspects of site characterization and remediation including definition of the nature and extent of
contamination, directing human health and ecological risk assessments, conducting feasibility
studies for selection of appropriate remedies to meet remediation goals, and implementing remedial
strategies. For the last ten years much of my consulting activity has been related to groundwater
contamination and permitting issues at coal ash storage and disposal sites.
2

GEO-HYDRO, INC
4. Site Background
The Mayo plant is a coal-fired electricity -generating facility located in north -central North Carolina in
the northeastern corner of Person County, North Carolina, north of the City of Roxboro. The northern
Plant property line extends to the North Carolina/Virginia state line. Mayo Lake borders the entire
eastern portion of this part of the Site. The Mayo Plant began coal-fired power production in 1983.
The 144 acre Mayo ash basin was formed by construction of a dam across the upper reaches of
Crutchfield Branch, a perennial' stream that once flowed in the valley immediately northwest of the
Mayo Steam Power Plant (Figure 1). The basin is impounded by an earthen dam approximately 2,300
feet long, with a dam height of 110 feet, and a crest height elevation of 479.8 feet above mean sea level
(msl). The ash basin contains approximately 6,900,000 tons of Coal Combustion Residuals2. Coal ash
and ash -impacted water have buried Crutchfield Branch behind the dam. The ash basin acts as an
elongated bowl -like feature with groundwater flowing to the basin from all sides, except from the
northeast, which is the discharge side from the basin. Groundwater flows north-northeast from the ash
basin into the small valley formed by Crutchfield Branch. Crutchfield Branch flows north off of Mayo
Plant property into Virginia3.
Constituents leached from ash into ash basin pore water at concentrations greater than North Carolina
Groundwater Quality Standards (2L) or Interim Maximum Allowable Concentrations (IMAC) include
antimony, arsenic, barium, boron, cobalt, iron, manganese, pH, thallium, total dissolved solids (TDS),
and vanadium 4. Ash -impacted water exits the impoundment by seeping through and around the dam
and discharging to the surface to reform the buried Crutchfield Branch, by migrating downgradient
from the impoundment as groundwater, and through NPDES discharge 0025 that discharges water
from the coal ash impoundment directly to Mayo Lake. Two engineered toe drains are located on the
downstream side of the dam and flow either directly into or eventually into Crutchfield Branch. Some
of the ash -contaminated impoundment water that infiltrates through the dam discharges to the surface
through the toe drains and other unplanned seeps below the dam to reform Crutchfield Branch.
The CSA determined that leaching from waste impounded within the ash basins impacts groundwater
in the vicinity of the ash basin 6. That document describes three hydrogeologic units or zones of
groundwater flow at the Mayo Plant. The zone closest to the surface is the shallow or surficial flow
1 The USGS Cluster Springs, VA -NC 7.5 minute topographic map shows Crutchfield Branch as a perennial stream across
most of the impounded area with intermittent reaches in the upper arms of the impoundment.
2 SynTerra, 2015a, p.6.
3 SynTerra, 2015 b, 1-7.
4 SynTerra, 2015a, p.129.
s NCDENR, 2009
6 SynTerra, 2015b,p. 1-7.
5

GEO-HYDRO, INC
zone encompassing saturated conditions, where present, in the residual soil, saprolite, or alluvium
beneath the Site. A transition zone is encountered below the surficial zone and the bedrock is
characterized primarily by partially weathered rock of variable thickness. The bedrock flow zone
occurs below the transition zone and is characterized by the storage and transmission of groundwater
in water -bearing fractures.
Available potentiometric data generally confirm that groundwater flow in the vicinity of the
impoundment is toward the north-northeast towards the reformed Crutchfield Branch. An exception to
this statement exists in the area of the Flue Gas Desulfurization (FGD) ponds located on the southeast
side of the impoundment where geology and groundwater flow direction are inadequately defined.
Site Layout and Water Level Mapss included with the CSA Report each show the FGD ponds located
inside the waste boundary, apparently indicating that the FGD ponds were constructed over disposed
ash. Review of the USGS topographic map (Figure 1) corroborates this interpretation. Contradicting
this information are cross-sections9 included with the CSA that each show the FGD ponds located
above soil/fill. The location of the waste boundary must be confirmed in order to determine the extent
of waste that must be remediated, either by excavation or capping.
The direction of groundwater flow is also poorly defined in the area of the FGD ponds. The CSA
report describes Mayo Lake as acting as a groundwater discharge area on the east side of the Plant.
Each of the C-C' cross -sections (see footnote) show the water table declining to the east between the
ash basin and wells CW-1/1D with flow toward the east beneath the area of the FGD ponds. The
Water Level Map shows the hydraulic gradient flowing toward the north from a high beneath the
electric plant toward the ash basin in this same location. An additional well cluster located between
the FGD ponds and discharge canal is needed to provide additional control on geology and
groundwater flow direction, velocity and chemistry in the area of the FGD ponds.
The groundwater flow and transport model of the site was constructed and used in the CAP to evaluate
groundwater flow and investigate three remedial scenarios. The scenarios investigated included the
No Action scenario, a Capping Ash in Place scenario, and a Complete Ash Removal scenario. The
model was used to predict contaminant distributions for the next 5, 15 and 30 years, under each
scenario.
The Existing Conditions scenario10 relies on natural attenuation processes to reduce contaminant
concentrations over time. The ash basin remains in place without modification and "the assumption is
made that current recharge and contaminant loading rates from the ash to the underlying formations are
7 Figure 2-1
8 Figure 6-9
9 C-C' Sections included presented in Figures 6-3, 6-6, 8-3, 11-lb, 11-2b. 11-3b, 11-4b, 11-5b, 11-6b, 11-7b, 11-8b, 11-9b,
and 11-10b
10 The entire description of this scenario is presented in the CAP, Appendix E, Section 6.1.
M

GEO-HYDRO, INC
held constant". "The flow system is assumed to be at steady state with respect to the conditions in
2015." "Concentrations in the ash were held constant at the measured concentrations." Using these
assumptions the model predicts that the boron and arsenic plumes will continue to expand and the
leading edge of the boron plume is predicted to move north of the compliance boundary over the next
30 years.
The Capping Ash Basin scenario' 1 involves placing a low permeability liner over the ash basin to
prevent infiltration. The description of this scenario assumes that there is no recharge within the basin,
that the dam was removed and that contaminant concentrations in the ash were allowed to vary
(concentrations were fixed in the Existing Conditions scenario). Other changes to the model included
modified boundary conditions to remove constant head conditions representing the impoundment and
the grid was modified to represent grading of the ash. Results of this modified model predict that the
leading edge of the boron plume would recede by 100 to 200 feet in the vicinity of the compliance
boundary. Arsenic concentrations are predicted to increase in the saprolite, but the increase is smaller
than that predicted under the Existing Conditions scenario.
Concerns with the Capping Ash Basin scenario include the assumption of no recharge within the basin
and changing the way that contaminant concentrations in the source material are handled. The
hydrogeologic setting of the impoundment12 describes groundwater discharges into the impoundment
form the east, west and south sides. Capping of the ash in the basin will not control discharging
groundwater. The discharges of groundwater into the ash are likely significant as groundwater
discharges into the basin were sufficient to support a perennial reach of Crutchfield Branch prior to
burying the stream with coal waste.
The concentration of contaminants in the ash were held constant in the Existing Conditions simulation
but were allowed to vary in the Capping Ash Basin scenario. This change in assumptions allowed the
concentration in the ash to decrease more rapidly in the Capping Ash Basin scenario than in the
Existing Conditions simulation. The rationale for changing the method of handling source
concentrations between simulations was not discussed. Comparison of the No Action scenario and
Capping Ash Basin scenario simulations show the leading edge of the boron plume receding by 100 to
200 feet by 2045. It is unclear if this reduction is a result of cap installation, or if it is an artifact of the
change in assumptions.
The Removal of Ash13 scenario represents complete removal of the ash by applying zero concentration
levels and regional recharge within the ash basin. Even if one ignores the defects with the first two
simulations, the Removal of Ash scenario predicts, by far, the largest reduction in ash -related
11 The entire description of this scenario is presented in the CAP, Appendix E, Section 6.2
12 SynTerra 2015b, p. 1-7 and 1-11.
13 The entire description of this scenario is presented in the CAP, Appendix E, Section 6.3
7

GEO-HYDRO, INC
contaminant concentrations. Figures 2, 3 and 4 show predicted 2045 boron concentrations within the
saprolite layer (Layer 5) for all three of the simulated options.
N.

GEO-HYDRO, INC
5. Opinion 1: Coal Ash Stored in the Mayo Ash Basin is the Source
of Contamination Detected in Surface Water and Groundwater
Coal ash is the source of contaminants detected in surface water and groundwater at concentrations
above applicable standards in the vicinity and downgradient of the ash basin. Data collected during
the CSA show that that ash basin pore water contains antimony, arsenic, barium, boron, cobalt, iron,
manganese, pH thallium, TDS and vanadium at concentrations greater than 2L or IMAC standards14
The contaminated pore water migrates into groundwater and is discharged into impoundment water,
each of which subsequently discharge to Crutchfield Branch. This interpretation is consistent with
the conclusions of the CSA which states that "The CSA found that leaching of CCR accumulated in
the ash basin is a source of COIs detected in groundwater and surface water downgradient of the
basin"ls
14 SynTerra 2015b, p. 1-7
15 Synterra 2015a, p.127, Constituent of Interest (COI)
0

GEO-HYDRO, INC
6. Opinion 2: Capping Coal Ash Located Within the Mayo Ash
Basin Will Not Protect Groundwater Quality Downgradient of the
Basin
Capping the waste within the footprint of the ash basin will not be protective of groundwater quality
downgradient of the basin. Further, the CAMA process proposed designation of the Mayo Site as
low -risk creates the possibility that Duke Energy (Duke) could pursue closure of the Mayo
impoundment by capping the disposed ash in place.
Environmental contaminants contained in coal ash are leached into groundwater when precipitation
infiltrates through the waste or, when groundwater flows through waste that has been placed below
the water table. In the case of the Mayo ash basin, both of these processes are currently acting to
create the contaminated ash porewater, groundwater, and surface water that discharge into
Crutchfield Branch and contaminate surface water downstream of the impoundment. The cap -in -
place remedy would likely reduce the amount of water that enters the waste from precipitation. This
remedy would however do nothing to reduce the amount of water that flows laterally into the basin
from surrounding geologic materials, through the capped waste, and eventually into Crutchfield
Branch.
The CAP and its included modeling results show that much of the coal ash in the Mayo ash basin
will remain submerged below the water table under a cap -in -place remedy. The thickness of
saturated waste that would remain saturated can be estimated by comparing the pre -impoundment
topographic map of the basin (Figure 1) with the calculated hydraulic head map for the cap in place
option (Figure 5). The topographic map of the buried valley shows that natural land surface below
the impoundment is located at approximately 400 feet above mean sea level (msl) near the center of
the basin. The calculated hydraulic head in the basin after ash is capped in place is predicted by the
model to be approximately 460 to 470 feet msl near the center of the basin. Therefore, the model of
the cap -in -place scenario predicts 60 to 70 feet of saturated ash would remain in portions of the
basin. The data presented in these figures is consistent with the known hydrogeology of the site.
Groundwater will continue to flow into the ash basin from adjacent areas and some infiltration
through the cap would continue to occur. Groundwater that flows through the ash will continue to
leach metals from the ash and transport those metals down -gradient before discharging into
Crutchfield Branch.
Further, the results of the groundwater modeling exercise undertaken as part of this program indicate
that removal of the Mayo coal ash is by far the most effective option for improving groundwater
quality and preventing future discharges to Crutchfield Branch. The modeling results indicate that
10

GEO-HYDRO, INC
removal of the ash significantly reduces the size and concentration of the boron plume in the
saprolite and transition zones, something that capping -in -place does not achieve.
11

GEO-HYDRO, INC
7. Opinion 3: Monitored Natural Attenuation Is Not An Acceptable
Groundwater Remediation Strategy at Mayo
The CAP 16 indicates that Duke may evaluate Monitored Natural attenuation as a potential
groundwater remedy for certain area of the Mayo site. The CAP attempts to make it appear that
Monitored Natural Attenuation (MNA) is a viable remedial option for impacted groundwater and
surface water downgradient of the Mayo ash basin. However, MNA is not a viable closure option
for this site for several reasons including the following North Carolina requirements for
implementing MNA:
1.0 NCAC 02L .0106 (1)(1) requires a demonstration that all sources of
contamination have been removed or controlled. So far, Duke Energy has not proposed
removal of the waste for disposal in a secure location. Modeling presented in this
document shows that most of the ash would remain saturated after capping. Saturated
ash will continue to leach metals into groundwater that will flow toward and eventually
discharge into Crutchfield Branch. As a practical matter, in the absence of removal all
sources of contamination cannot be controlled
2.0 NCAC 02L .0106 (1)(2) requires a demonstration that the contaminant has the
capacity to degrade or attenuate under site -specific conditions. Many of the ash -related
constituents in groundwater at this site neither degrade nor attenuate. The Geochemical
Site Conceptual Modell? states that boron best represents the extent of impact to
groundwater because it "does not sorb or precipitate within the ash or on aquifer
materials." Because of this, the Mayo site would not be eligible for MNA.
3.0 NCAC 02L .0106 (1)(6) requires a demonstration that groundwater discharge
will not possess contaminant concentrations that would result in violations of surface
water standards. Crutchfield Branch, which receives the contaminated groundwater
discharge at Mayo, currently exceeds surface water standards for several parameters.
Sampling has detected ash -related metals at concentrations above background and
relevant NCAC 2B and/or 2L standards, including boron, cobalt, copper, iron,
manganese, thallium, vanadium, and zinc 18. These surface water exceedances are likely
to continue since the majority of flow in Crutchfield Branch is associated with drainage
from the ash basin19 and the groundwater model shows that a substantial amount of ash
will continue to be saturated with groundwater that eventually flows to Crutchfield
Branch, even if the basin is capped.
16 SynTerra, 2015b, p.5-1
17 SynTerra, 2015b, Section 3.2
18 SynTerra, 2015b, Table 2-14
19 SynTerra, 2015b, Page 4-13, Section 4.4.1
12

GEO-HYDRO, INC
8. Opinion 4: Capping Coal Ash Located Within the Mayo Ash
Basin Will Not Be Protective of Surface Water Quality in
Crutchfield Branch
Prior to construction of the Mayo plant Crutchfield Branch was a free -flowing perennial stream that
occupied the valley through which it flowed. The coal ash basin was constructed by damming the
stream and used to segregate and store coal combustion wastes that were allowed to settle in the
basin. If coal ash located within the Mayo ash basin is capped in place, the surface water in
Crutchfield Branch will continue to be polluted and a significant portion of Crutchfield Branch will
remain buried by waste.
Crutchfield Branch, which receives the contaminated groundwater discharge at Mayo, currently
exceeds surface water standards for several parameters. Sampling has detected ash -related metals at
concentrations above background and relevant NCAC 2B and/or 2L standards, including boron,
cobalt, copper, iron, manganese, thallium, vanadium, and zinc 20. These surface water exceedances
will continue since the majority of flow in Crutchfield Branch is associated with drainage from the
ash basin 21 and the groundwater model shows that a substantial amount of ash will continue to be
saturated with groundwater that eventually flows to Crutchfield Branch, even if the basin is capped
(See Opinion #2). Coal ash must be separated from the groundwater and surface water flow
systems if further contamination of these resources is to be avoided
The surface water quality discussion in the CAP22 indicates that concentrations of ash -related
constituents in Crutchfield Branch decrease with distance downstream from the ash basin due to
"attenuation by dilution." This is problematic because, of course, there is so such process as
attenuation by dilution. Attenuation and dilution are two different processes. Attenuation occurs
when contaminants interact with the soil or sediments, and contaminants are removed from the
water. Dilution does not remove or treat any contaminants; instead, the concentration, but not the
amount, of a pollutant is reduced by diluting the polluted plume with water containing a lower
concentration of the contaminant. Thus, dilution and attenuation are distinctly different processes.
The made-up process referred to as "Attenuation by Dilution" appears to have been invented in an
effort to make discharges of contaminated groundwater and subsequent exceedances of surface water
quality standards appear acceptable.
North Carolina regulations covering corrective action plans based on natural processes (NCAC 02L
.0106 (1)(2)) require that a corrective action plan that proposes to utilize monitored natural
20 SynTerra, 2015b, Table 2-14
21 SynTerra, 2015b, Page 4-13, Section 4.4.1
22 SynTerra, 2015b, Section 4.4.2
13

GEO-HYDRO, INC
attenuation as a remedy demonstrate that the contaminant has the capacity to degrade or attenuate
under site -specific conditions. The Geochemical Site Conceptual Mode123 states that boron best
represents the extent of impact to groundwater because it "does not sorb or precipitate within the ash
or on aquifer materials." The properties of the contaminants at Mayo would therefore render the site
ineligible for remediation by MNA, even if attenuation by dilution were a real process. In addition,
capping the coal ash in the in place would leave a significant portion of Crutchfield Branch buried in
waste. Now that the Mayo waste handling system is no longer going to be used there is no
justification for leaving the existing stream covered in coal ash.
13 SynTerra, 2015b, Section 3.2
14

GEO-HYDRO, INC
9. Opinion 5: Removal of the Coal Ash Will Remove the Source and
Reduce the Concentration and Extent of Groundwater and
Surface Water Contaminants
Removal (excavation) of the coal ash from the Mayo ash basin will remove the source, and reduce
the concentration and extent of groundwater and surface water contaminants. The groundwater flow
and transport model of the site was used in the CAP to evaluate groundwater flow and investigate
three remedial scenarios. The scenarios investigated included the No Action scenario, a Capping
Ash in Place scenario, and a Complete Ash Removal scenario. The model was used to predict
contaminant distributions for the next 5, 15 and 30 years, under each scenario.
The extent of boron in groundwater for each scenario at the end of 30 years are shown in Figures 2,
3 and 4. The model shows that the Removal of Ash scenario results in, by far, the largest reduction
in ash -related contaminant concentrations.
15

GEO-HYDRO, INC
10. Opinion 6: The Coal Combustion Residual Impoundment Risk
Classification Proposed by NCDEQ Improperly Minimizes
Protection of Environmental Quality
A risk ranking process was specified in CAMA to determine the type of closure permitted at each
facility. The law specifically requires NCDEQ to classify each impoundment as either high -risk,
intermediate -risk, or low -risk, based on consideration, at a minimum, of all of the following criteria.
(1) Any hazards to public health, safety, or welfare resulting from the impoundment.
(2) The structural condition and hazard potential of the impoundment.
(3) The proximity of surface waters to the impoundment and whether any surface waters are
contaminated or threatened by contamination as a result of the impoundment.
(4) Information concerning the horizontal and vertical extent of soil and groundwater
contamination for all contaminants confirmed to be present in groundwater in exceedance of
groundwater quality standards and all significant factors affecting contaminant transport.
(5) The location and nature of all receptors and significant exposure pathways.
(6) The geological and hydrogeological features influencing the movement and chemical and
physical character of the contaminants.
(7) The amount and characteristics of coal combustion residuals in the impoundment.
(8) Whether the impoundment is located within an area subject to a 100-year flood.
(9) Any other factor the Department deems relevant to establishment of risk.
In order to evaluate each impoundment on the nine criteria the NCDEW established a risk
classification group24. The Risk Classification Group was broken into three sub -groups of people
based on areas of expertise (Groundwater, Surface Water, and Dam Safety) to develop a set of risk
factors to address each of the nine required criteria. Each subgroup reportedly placed a primary
emphasis on risk as it relates to the public from a groundwater, surface water, and dam safety
perspective and established one key factor that "plays a significant role in assigning an overall
classification" for that group. Other factors not identified as Key Factors were supposedly used to
"refine the risk classification and address the actual or potential risk to the environment and natural
resources."
The result of the risk classification methodology utilized by NCDEQ is that environmental and
ecologic risks posed by the Mayo site were not fully considered by NCDEQ when establishing the
overall site risk and clean-up priority. This resulted in an overall Low Risk rating, a rating that
essentially ignores the known environmental impacts of the Mayo Ash Basin. For example, Table
24 NDEQ, 2016, p. 13, Classification Methodology
16

GEO-HYDRO, INC
provides a listing of the groundwater risk classification factors and associated ratings for Mayo. Ten
groundwater risk factors were established and received ratings by NDEQ. Of the 10 rated factors, 6
received High or Intermediate Ratings, one factor was rated as Low/Intermediate, and only 3
received ratings of Low Risk. Only 30% of the rated groundwater risk classification factors were
rated Low Risk, yet NCDEQ gave Mayo an overall Low Risk Rating for Groundwater.
Table 1
Groundwater Risk Classification
Groundwater Factors
Mayo Rating
Number of downgradient receptors within 1500 feet of compliance boundary that
are potentially or currently known to be exposed to impacted water. (Key Factor)
Low Risk
Amount of stored CCR reported in an impoundment
Intermediate Risk
Depth of CCR with respect to the water table
High Risk
Exceedance of 2L or IMAC standards at or beyond the established CCR
compliance boundary
High Risk
Population served by water supply wells within 1,500 feet upgradient or side
gradient of the compliance boundary
Low /Intermediate Risk
Population served by water supply wells within 1,500 feet downgradient of the
compliance boundary
Low Risk
Proximity of 2L or IMAC exceedances beyond the compliance boundary with
respect to water supply wells
High Risk
Groundwater emanating from the impoundment exceeds 2L or IMAC and that
discharges to a surface water body
High Risk
Ingestion of contaminated soil or fugitive emissions
Low Risk
Data Gaps and Uncertainty
Intermediate Risk
Table 2 provides a listing of the surface water risk classification factors and associated ratings for
Mayo. A total of eight surface water risk factors were rated by NCDEQ. Of the 8 rated factors, 3
were High or Intermediate Risk, and additional 3 factors were rated as Low/Intermediate Risk, and
only 2 of 8 factors are rated Low Risk. Only 25% of the rated surface water risk classification
factors were rated Low Risk, yet NCDEQ gave Mayo an overall Low Risk Rating for Surface Water.
The preceding analysis uses the risk ratings applied by NCDEQ with no evaluation or judgment
about whether they were or were not appropriately applied. The risk ratings given to the Mayo ash
basin point out that protection of environmental and natural resources are not being treated as
priority issues by the North Carolina agency entrusted with the responsibility to do just that. The
approach utilized by NCDEQ effectively ignores impacts to the natural environmental and natural
resources, and even ignores future human users of the groundwater and surface water resources. It
appears that in the view of NCDEQ the only way that a site can be rated as Intermediate or High
Risk is if a facility is located within a 100-year floodplain or if 11 or more people within 1,500 feet
of the compliance boundary are potentially or currently known to be exposed to ash -impacted
17

GEO-HYDRO, INC
groundwater25. It is hard to imagine that exposed persons 1 through 10 would agree with this rating
scheme.
Table 2
Surface Water Risk Factors
Surface Water Factors
Mayo Rating
Landscape Position and Floodplain (Key Factor)
Low Risk
NPDES Wastewater and Ash Disposal Methods
Low/ Intermediate Risk
Impoundments Footprint Siting in Natural Drainage Way or
Stream
Low/ Intermediate Risk
Potential to Impact Surface Water Based on Total Ash Amount at
Facility
High Risk
Potential to Impact Surface Water Based on Dilution
High Risk
Development Density of Single -Family Residences along
Lake/Reservoir Shoreline
Low Risk
Classification of the Receiving Waters
Low/ Intermediate Risk
Proximity to Water Supply Intake
Intermediate Risk
15 NCDEQ, 2016, page 15, Key Factors

GEO-HYDRO, INC
References
NCDEQ, 2016, Coal Combustion Residual Impoundment Risk Classifications, January 2016.
NCDENR, 2009, Permit to Discharge Wastewater Under the National Pollutant Discharge
Elimination System, Permit NC0038377, October, 2009
SynTerra, 2014, Groundwater Assessment Work Plan for Mayo Steam Electric Plant, September
2014
SynTerra, 2015a, Comprehensive Site Assessment Report, Mayo Steam Electric Plant, Roxboro,
NC, September 2015.
SynTerra , 2015b, Corrective Action Plan, Part 1, Mayo Steam Electric Plant, Roxboro, NC,
December 2015.
United States Geological Survey, Cluster Springs VA. — N.C., 7.5 Minute Topographic Map, 1968,
photorevised 1987.
19

GEO-HYDRO, INC
Figures

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GEO-HYDRO INC Image taken from
� USGS Cluster Springs VA —NC
Ash Pond Topography
Consulting in Geology and Hydrogeology 1968
Mayo Steam Electric Plant
Photorevised 1987

Figure 32. Simulated October, 2045 boron concentrations (pg-I) in the model laver of the
saprolite (layer 5) for CAP I,
Images from Mayo CAP Part 1,
Appendix E
Figure 2
GEO-HYDRO, INC Predicted 2045 Layer 5
Consulting in Geology and Hydrogeology Boron Concentration
No Action Scenario
Mayo Steam Electric Plant

E=igurc 50. Simulated October, 2045 boron concentrations (jigFL.) in the mode) layer of the
saprolite (layer 5) ror CAP2.
Images from Mayo CAP Part 1,
Appendix E
Figure 3
GEO-HYDRO, INC Predicted 2045 Layer 5
Consulting in Geology and Hydrogeology Boron Concentrations
Capping Ash Basin Scenario
Mayo Steam Electric Plant

Figure 6 . Simulated October, 2045 Moron concentrations; (pg/L) in the model layer of the
:iproliw (layer 5) ruT CAPS.
Images from Mayo CAP Part 1,
Appendix E
Figure 4
GEO-HYDRO, INC Predicted 2045 Layer 5
Consulting in Geology and Hydrogeology Boron Concentration
Removal of Ash Scenario
Mayo Steam Electric Plant

Images from Mayo CAP Part 1,
Appendix E
GEO-HYDRO, INC
Consulting in Geology and Hydrogeology
f4�
Remove ash
Figure 5
Calculated Head Maps
Mayo Steam Electric Plant

SOUTHERN ENVIRONMENTAL
VIRON ENTAL A ENTER
Telephone [phone] WEST ROSEMARY STREET, SUITE 220 Facsimile 919-929-9421
CHAPEL HILL, NC 27516-2356
December 29, 2015
Mr. Donald R. van der Vaart, Secretary
North Carolina Department of Environmental Quality
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
K r Corrective Action Plan Part.L
Dear Mr. van der Vaart:
On behalf of the Roanoke River Basin Association, the Southern Environmental Law
Center submits the following first set of comments on Duke Energy's Corrective Action Plan
Part I for its Mayo Steam Station facility in Roxboro, N.C.
The Mayo Corrective Action Plan Part I (the "CAP") suffers from at least two
fundamental flaws. First, it demonstrates that much of the Mayo coal ash will remain submerged
in the groundwater if it is capped in place, yet does not discuss this fundamental problem in the
report or provide clear information on the extent of the problem. Second, the CAP improperly
relies on a nonexistent option for groundwater remediation, which in effect would adopt a "Flush
It to Virginia" approach by allowing the groundwater contamination to be flushed over the state
line into Virginia. Needless to say, this is not a recognized or valid option for groundwater
remediation. Our comments on these key issues and other specific problems with the CAP are
set out below.
The Coal Ash Will Remain Submerged In Groundwater If Capped In Place
The CAP and its modeling results show that much of the coal ash in the Mayo ash basin
will remain submerged in the groundwater under the Cap in Place scenario. Comparison of the
hydraulic head map for the Cap in Place option (Appendix E, Figure 17a) with the Closure in
Place Profile (Appendix E, Figure 16) reveals that much of the disposed ash would remain
saturated after capping. The data presented in these figures are consistent with the hydrogeology
of the site. A significant amount of groundwater will continue to flow into the ash basin from
adjacent areas, and some infiltration through the cap would also continue to occur. Groundwater
that flows through the ash will continue to leach metals from the ash and transport those metals
down -gradient before discharging into Crutchfield Branch, where they will be flushed across the
state line to Virginia.
Charlottesville ® Chapel Hill ® Atlanta ® Asheville ® Birmingham ® Charleston ® Nashville ® Richmond • Washington, DC
100% recycled paper

Conspicuously, Duke Energy has failed to provide any discussion of this fundamental
problem in the text of the CAP, and has omitted any figures illustrating the extent of the
groundwater saturation of the coal ash in the basin under the Cap in Place scenario.
The volume and thickness of ash that will remain saturated under the Cap In Place
closure option as well as the expected volume of contaminated groundwater that will continue to
discharge to Crutchfield Branch under this option must be clearly discussed in the CAP. DEQ
should not approve any closure plan that will result in significant amounts of coal ash remaining
submerged in groundwater and continuing to discharge pollutants beyond the compliance
boundary.
1 '# D I r
The CAP goes to great lengths to make it appear that monitored natural attenuation is a
viable remedial option for the Mayo ash basin. In the effort to justify monitored natural
attenuation, Duke Energy has gone so far as to invent a nonexistent form of purported
contaminant attenuation, which the CAP calls "attenuation by dilution." However, this proposal
- - is not attenuation at all. Instead, it amounts to flushing the contamination from the Mayo ash
basin downstream into Virginia. This is not an acceptable form of groundwater remediation.
There is no such thing as "attenuation by dilution." Attenuation and dilution are two
different processes. Attenuation occurs when contaminants interact with the soil or rock through
which the water is flowing and contaminants are removed from the groundwater. Dilution does
not remove or treat any contaminants; instead, the concentration, but not the amount, of a
pollutant is reduced by diluting the polluted plume with water containing a lower concentration
of the contaminant. Thus, dilution and attenuation are distinctly different processes. The CAP
document provides no support for attenuation to treat the groundwater contamination at Mayo or
the spread of the ash contaminated boron plume.
Instead, what the Duke Energy document proposes is to leave the coal ash pollution in the
groundwater, mix it with the waters of Crutchfield Branch, and send it downstream into Virginia.
Duke Energy's Mayo site does not qualify for valid natural attenuation under the North
Carolina groundwater rules, as discussed in more detail below, because the groundwater
pollution and pollution of North Carolina and Virginia waters will continue if the coal ash is left
in place. Perhaps recognizing this, Duke Energy and its consultants have invented a nonexistent
remediation option of letting the pollution flush out of the Mayo ash basin into Virginia. This
approach must be rejected.
Specific Comments
Page 2-, Section, 1.2, Provisional Background Groundwater Concentrations — The second
paragraph of this section indicates that historic data sets were evaluated to exclude results with
elevated sample turbidity above 10 NTUs but provides no indication that the data were evaluated
for the presence of outliers unrelated to turbidity, such as laboratory errors, sampling problems,
etc. The data set must also be tested for additional outliers that may not be related to,saple
2

turbidity, because including such outliers could artificially raise the purported background
concentration levels.
In addition, there is no discussion about how the 10 NTU level was selected. Please
justify selection of the 10 NTU criteria for modifying the data set.
Page 4-10, Section 4.3.2.1, Existing Conditions — This section of the document describes the
results of groundwater flow and contaminant transport modeling under existing conditions. The
model predicts that between the years 2015 and 2045, the boron plume would continue to expand
beyond the site boundary at Mayo Lake Road. Thus, Duke Energy's own model indicates that
reliance on natural attenuation to control the spread of groundwater contaminants would not be
effective.
Page 4-11, Section 4.3.2.2 Capping Ash Basin — The description of this scenario says that it
assumes the same conditions as the "Existing Conditions" scenario, with the exception of placing
an impermeable liner over the ash basin. However, that is not the case. The groundwater
modeling report (Appendix E) clearly states that assumptions on the concentrations of
contaminants in the ash (source material) were "relaxed" by being allowed to vary in the
"Capping Ash Basin" scenario but were held constant in the "Existing Conditions" simulation
(Appendix E at § 6.2). As Appendix E of the CAP states, "This change allows the concentration
in the ash and at shallow depths to decrease more rapidly [for Cap In Place] than in the No
Action scenario." Id. The report provides no rationale for changing this source concentration
variable between simulations, and RRBA is not aware of any justification for this approach. By
changing two parameters at once (adding the cap while simultaneously allowing the
concentrations of contaminants in the ash basin to decrease), the CAP makes it impossible to
meaningfully compare the Capping Ash Basin simulation with the Existing Conditions
simulation. Also, it may thereby overstate the supposed benefits of Capping in Place.
Page 4-11, Section 4.3.2.2 Capping Ash Basin — This section describes a scenario that includes
placement of an "impermeable liner" over the regraded ash basin as indicated on Figure 4-2.
The assumption of an impermeable cap was included in modeling of this option by assuming no
recharge within the ash basin (Appendix E, Section 6.2). However, the description of Option 2
provided in Figure 4-2 of the CAP report describes closure as capping of the graded ash only
with reclaimed soil from the dam and off -site borrow material. A soil cap constructed of
excavated dam soils and borrow material will not be impermeable. If the description in Figure 4-
2 is accurate, infiltration of precipitation through a soil cap must be realistically estimated and
the groundwater model must be revised to reflect more appropriate assumptions.
In addition, it is not clear whether the "no recharge" assumption described in Section 6.2
of Appendix E refers only to rainfall permeating through the cap or whether the model also
assumed no groundwater recharge from the sides of the basin valley. If the latter, this
assumption is incorrect and must be revised.
Page -11, Section .3.2.2 Capping Ash Basin — Comparison of the hydraulic head map for the
Cap in Place option (Appendix E, Figure 17a) with the Closure in Place Profile (Appendix E,
Figure 16) shows that much of the disposed ash will remain saturated after capping.

Groundwater will continue to flow into the ash basin from adjacent areas and some infiltration
through the cap will occur even if the basin is capped. Groundwater that flows through the ash
will continue to leach metals from the ash and transport those metals down -gradient, discharging
into Crutchfield Branch. However, no discussion of this issue is provided in the text. The
discussion in this section provides no indication of the thickness or volume of the accumulated
ash in the Ash Basin that will remain saturated. The CAP must clearly set out the volume and
thickness of ash remaining saturated after closure as well as the volume of contaminated
groundwater that will continue to discharge to Crutchfield Branch.
Page 4-11, Section 4.3.2.2, Capping Ash Basin — The CAP contains inconsistent descriptions of
how much of the ash basin dam would be removed under the Cap in Place scenario. The
preliminary concept for capping the ash basin referenced in this section (Figure 4-2) depicts
partial removal of the existing dam. The description provided in the text of this section simply
says that the dam would be removed, with no detail about how much of the dam structure would
be removed. Partial dam removal is also consistent with the closure in place profile provided in
Figure 16 of the groundwater modeling report (Appendix E). However, the description of the
capping in place scenario provided in the text of the groundwater modeling report describes
modeling based on removal of the entire dam, including removing low conductivity materials
from below grade. These inconsistent descriptions make it unclear how much of the ash basin
dam would be removed with the Cap in Place option. The details of what actions the Cap in
Place scenario would include needs to be consistent between the various documents, figures, and
modeling scenarios. Otherwise, the results of the modeling are invalid.
Page 4-11, Section 4.3.2.3, Removal of Ash — Despite the fact that groundwater modeling
results indicate that removal of the Mayo coal ash is by far the most effective option for
improving groundwater quality and preventing future discharges to Crutchfield Branch, the
entire discussion of this option consists of only one paragraph in the CAP report. Buried in an
Appendix, (Appendix E), is the conclusion of the groundwater modeling report that removing the
ash significantly reduces the size and concentration of the boron plume in the saprolite and
transition zones. Evaluation of remedial alternatives must not be pre -determined by Duke prior
to being fully evaluated and discussed in the CAP.
Page 4-14, Section 4.4.2, Surface Water Quality —The third full paragraph on this page
indicates that concentrations of ash -related constituents in Crutchfield Branch decrease with
distance downstream from the ash basin due to "attenuation by dilution." There is no such thing
as "attenuation by dilution." This is simply consultant -speak for allowing the Mayo coal ash
contamination to be flushed downstream into Virginia.
Dilution of a contaminant plume occurs when contaminated water is mixed with cleaner
water, thus diluting the plume but not removing any pollution. Attenuation occurs when
contaminants interact with the soil or rock through which the water is flowing and contaminants
are removed from the groundwater. Dilution of contaminants is not a form of attenuation; in
fact, it is a form of non -attenuation. The best description of the approach put forward by Duke
Energy and its consultant is Non -Attenuation by Dilution — something that North Carolina law
does not allow.
0

North Carolina regulations covering corrective action plans based on natural processes
[NCAC 02L .0106 (1)(2)] require that a corrective action plan that proposes to utilize monitored
natural attenuation as a remedy demonstrate that the contaminant has the capacity to degrade or
attenuate under site -specific conditions. Here, no data supporting attenuation as a mechanism
controlling the spread of the ash contaminant (boron) plume were provided. Thus, Duke Energy
has not made the required demonstration that the Mayo site is eligible for monitored natural
attenuation.
Page 5-1, Section 5.0, Corrective Action Plan Part 2 — Item 92 at the bottom of this page
indicates that monitored natural attenuation may be evaluated as a potential groundwater remedy
for certain areas of the site. However, monitored natural attenuation is not a viable closure
option for this site because:
• NCAC 02L .0106 (1)(1) requires a demonstration that all sources of contamination
and free product have been removed or controlled. So far, Duke Energy has not proposed
removal of the waste for disposal in a secure location. Controlling the waste will likely
require active operation of remedial systems for many decades if impacts to Crutchfield
Branch are to be controlled. Modeling presented in this document shows that most of the
ash would remain saturated after capping. Saturated ash will continue to leach metals
into groundwater that will flow toward and eventually discharge into Crutchfield Branch.
• NCAC 02L .0106 (1)(2) requires a demonstration that the contaminant has the
capacity to degrade or attenuate under site -specific conditions. Many of the ash -related
constituents in groundwater at this site neither degrade nor attenuate. The Geochemical
Site Conceptual Model (Section 3.2) states that boron best represents the extent of impact
to groundwater because it "does not sorb or precipitate within the ash or on aquifer
materials." Because of this, the boron contamination at Mayo would not be eligible for
monitored natural attenuation. As discussed above, and contrary to what is stated in this
report, "attenuation by dilution" does not exist.
• NCAC 02L .0106 (1)(6) requires a demonstration that groundwater discharge will
not possess contaminant concentrations that would result in violations of surface water
standards. Crutchfield Branch, which receives the contaminated groundwater discharge
at Mayo, currently exceeds surface water standards for several parameters. Sampling
has detected ash -related metals at concentrations above background and relevant NCAC
2B and/or 2L standards, including boron, cobalt, copper, iron, manganese, thallium,
vanadium, and zinc (see Table 2-14). These surface water exceedances are likely to
continue since the majority of flow in Crutchfield Branch is associated with drainage
from the ash basin (Page 4-13, Section 4.4.1) and the groundwater model shows that a
substantial amount of ash will continue to be saturated with groundwater that flows to
Crutchfield Branch, even if the basin is capped.
Appendix E, Section 4.8, Transport Model Sources and Sinks — The 4t' paragraph of this
section indicates that modeling results show that the outflow channel on the east side of the
Mayo ash basin gains groundwater. Groundwater that discharges into the outflow channel likely
transports coal ash pollution into the channel that is not reflected in discharge monitoring
conducted at NPDES Outfall 002. The contaminated groundwater is then channeled directly into
5

Mayo Lake. The magnitude and extent of groundwater contamination in the area of the outflow
channel must be determined.
Appendix E, Section 6.2, CAP2 — Capping Ash in Place — Comparison of the hydraulic head
map for the Cap in Place option (Figure 17a) with the Closure in Place Profile (Figure 16) shows
that much of the disposed ash is expected to remain saturated after capping. However, this report
discusses neither the thickness nor volume of ash that will remain saturated after the cap is
installed. The Corrective Action Plan and Groundwater Modeling Report (Appendix E) must
each identify and discuss the amount of ash that would remain saturated after closure by capping
and clearly set out the impacts to Crutchfield Branch as well as groundwater in the vicinity and
downgradient of the ash basin.
Appendix E, Section 6.2, CAP2 — Capping Ash in Place — This section clearly states that
assumptions on the concentration of contaminants in the ash (source material) were held constant
in the Existing Conditions simulation and allowed to vary in the Capping Ash Basin scenario.
This change allowed the concentration in the ash and at shallow depths to decrease more rapidly
than in the Existing Conditions simulation. No rationale is given for changing the method of
handling source concentrations between the two simulations.. While comparison of the Existing
Conditions and Capping Ash in Place simulations show the leading edge of the boron plum
receding by 100 to 200 feet by 2045, this change may be only a result of the change in
assumptions. In other words, by using different assumptions for the two simulations, the Duke
Energy report may have overstated the effect of the Cap In Place approach. DEQ cannot rely on
modeling results that are based on changes in multiple variables at once, because it is impossible
to determine whether the results are based on the addition of a cap or the changed assumption
about contaminant concentrations in the basin.
Cnnehminn
The Mayo CAP shows that the coal ash will remain submerged in the groundwater under
a cap -in -place scenario. That is an unacceptable result that will leave the source of the
groundwater pollution — the coal ash — in contact with groundwater, where it will continue to
leach out dangerous pollutants into public groundwater supplies. In addition, the CAP proposes
to simply flush the contaminated groundwater to Virginia. It attempts to avoid acknowledging
this unacceptable approach by giving it the invented name "attenuation by dilution" — a
regulatory and scientific contradiction in terms - but flushing pollution to a neighboring state is
not a valid form of remediation. As Duke Energy's own flawed report shows, there is no
evidence to support capping in place or attenuation of groundwater at the Mayo site.
Thank you for your consideration of these comments.
KSinSin erely,
1
Fran S. Holleman III
Nicholas S. Torrey

cc: Stanley (Jay) Zimmerman, Director, Division of Water Resources, Central Office
Rick Bolich, DEQ Raleigh Regional Office
Harry Sideris, Senior Vice President of Environmental, Health & Safety, Duke Energy
10

SOUTH CAROLINA ELECTRIC & GAS
R<>WE r FUR Livrnr<;
WAT E R E E STATION
SEMI-ANNUAL STATUS REPORT
JULY — DECEMBER 2015
January 2016

Semi -Annual Status Report
SCE&G Wateree Station
The purpose of this document is to present a status report for the six-month reporting
period of July 1, 2015 through December 31, 2015 in accordance with the August 17,
2012, Settlement Agreement and Release ("Agreement") between the Catawba
Riverkeeper Foundation, Inc. ("Riverkeeper") and South Carolina Electric & Gas
Company ("SCE&G")
2 ASH REMOVED
During the six-month reporting period of July 1, 2015 through December 31, 2015,
approximately 131,088 dry tons of ash were removed from Pond 1.
3 RESULTS OF GROUNDWATER SAMPLING
During the six-month reporting period of July 1, 2015 through December 31, 2015,
groundwater sampling for wells monitored pursuant to the Mixing Zone Consent
Agreement was performed, with the results presented in the following report:
Semi -Annual Water Quality Monitoring Report: October 2015 Monitoring,
SCE&G, Wateree Station, Eastover, South Carolina
The above report has been submitted to SCDHEC. A copy of the report is attached.
4 ACTIVITIES PERFORMED
During the six-month reporting period of July 1, 2015 through December 31, 2015, the
following activities were performed in furtherance of the Undertakings described in
Paragraph 1 of the Agreement:
A. Paragraph 1.2: SCE&G continued to remove ash from Pond 1 for sale, recycling
or placement in a Class 3 landfill. From January 1, 2012 to present (December
31, 2015), the cumulative net reduction of ash in Pond 1 is approximately
876,021 dry tons. SCE&G has achieved a net reduction of ash in Pond 1 of at
least 240,000 tons from January 1, 2012 to January 1, 2015 as required in
Paragraph 1.2 of the Agreement.
July — December, 2015 Page 1 of 2

Semi -Annual Status Report
SCE&G Wateree Station
B. Paragraph 1.5: On December 5, 2015, the emergency ash sluice pipe for Unit #1
was removed by being capped and abandoned in place. Plans are underway for
removal of the emergency sluice pipe for Unit #2 in the same manner, which will
prevent the deposit of any coal ash into the Ponds and satisfy all requirements of
Paragraph 1.5 of the Agreement.
C. Paragraph 1.7: The final permit to construct a new synthetically lined wastewater
pond to replace Pond 1 was issued by SCDHEC on October 16, 2015 (Permit
Number: 19945-IW). SCE&G issued a notice to proceed for the construction of
the new wastewater pond on November 9, 2015.
July — December, 2015 Page 2 of 2

Table 1
Historical Summary of Constituent Concentrations in Groundwater
Wateree Station
South Carolina Electric & Gas Company
Eastover, Richland County, South Carolina
Well ID
Event -T
Sample Date
Parameter
Arsenic
Cadmium
Chromium
Lead
Sulfate
MW-1
MZCL
50
5
100
50
2,000
ISM
4/17/01
<5
<1
<10
<5
2
2SO1
11/13/01
<5
<1
<10
<5
1.3
1S02
4/23/02
<5
<1
<10
<5
2.22
2SO2
10/23/02
<5
<1
<10
<5
3.88
1S03
4/15/03
<5
<1
<10
<5
0.86
2SO3
10/20/03
<5
<1
<10
<5
2.68
1SO4
3/9/04
<5
<1
<10
<5
1.1
2SO4
9/30/04
<5
<1
<10
<5
1.7
1S05
4/13/05
<5
<1
<10
6
3.05
2SO5
10/18/05
<5
<1
<10
5
5.01
1S06
3/15/06
5
<1
23
7
1.35
2SO6
10/16/06
<5
<1
<10
<5
1.2
1S07
4/30/07
<5
<1
<10
<5
0.69
2SO7
10/16/07
<5
<1
12
<5
8.9
1S08
4/16/08
<5
<1
<10
<5
1.4
2SO8
10/22/08
21.3
<1
80.3
67.5
0.56
2SO8 (Resample)
11/6/08
<5.0*
NS
NS
NS
NS
1S09
4/21/09
19
<1
93
40
11.36
1S09 (Resample)
5/7/09
24*
<1*
86.0*
34.0*
NS
2SO9
11/5/09
<5
<1
<10
<5
136.9
MW-IA
1510
4/20/10
<5
<1
<10
<5
0.75
2S10
10/19/10
<5
<1
<10
5.5
<0.50
1511
4/12/11
<5
<1
<5
<5
<0.50
2S11 2S11 (Resample)
11/1/11
9.3
<1
<5
<5
<0.50
2S11 (Resample)
11/22/11
<5*
NS
NS
NS
NS
1S12
5/15/12
<5
<1
<5
<5
<0.50
2S12
11/6/12
<5
<1
<5
<5
<0.50
1S13
5/13/13
<5
<1
<5
<5
<0.50
2S13
10/21/13
<5
<1
<5
<5
0.7
1S14
4/28/14
<5
<1
<5
<5
0.9
2S14
10/14/14
<5
<1
<5
<5
<0.5
1S15
4/14/15
<5
<1
<5
<5
<0.5
2S15
10/13/15
<5
<0.1
<0.5
1.6
<0.5
Page 1 of 9

Well ID
Event
Sample Date
Parameter
Arsenic
Cadmium
Chromium
Lead
Sulfate
MW-2
MZCL
50
5
100
50
2,000
1501
4/17/01
<5
<1
<10
<5
66.9
2SO1
11/13/01
<5
<1
<10
<5
57.7
1S02
4/23/02
<5
<1
<10
<5
52.6
2S02
10/23/02
<5
<1
<10
<5
60.3
1S03
4/15/03
<5
<1
<10
<5
52.4
2SO3
10/20/03
<5
<1
<10
<5
54.39
1SO4
3/9/04
<5
<1
<10
<5
52
2SO4
9/30/04
<5
<1
<10
<5
45.8
1S05
4/13/05
<5
<1
<10
<5
45.9
2SO5
10/18/05
<5
<1
<10
<5
44.6
1S06
3/15/06
<5
<1
<10
<5
39.56
2SO6
10/16/06
<5
<1
<10
<5
35.9
1S07
4/30/07
<5
<1
<10
<5
32.2
2SO7
10/16/07
<5
<1
<10
<5
34
1S08
4/16/08
<5
<1
<10
<5
38.3
2SO8
10/22/08
<5
<1
<10
8.4
33.7
1S09
4/21/09
<5
<1
<10
8.4
37.7
2SO9
11/5/09
<5
<1
<10
<5
31.4
1510
4/20/10
<5
<1
<10
<5
35.8
2S10
10/19/10
<5
<1
<10
<5
27.9
1511
4/12/11
<5
<1
<5
<5
33.6
2S11
11/1/11
<5
<1
<5
<5
34
1S12
5/15/12
<5
<1
<5
<5
34.6
2S12
11/6/12
5.1
<1
<5
<5
40.7
1S13
5/13/13
<5
<1
<5
<5
44.6
2S13
10/21/13
<5
<1
<5
<5
40.4
1S14
4/28/14
<5
<1
<5
<5
28.8
2S14
10/14/14
<5
<1
<5
<5
45.2
1S15
4/15/15
<5
<1
<5
<5
44.5
Page 2 of 9

Well ID
Event
Sample Date
Parameter
Arsenic
Cadmium
Chromium
Lead
Sulfate
2S15
10/13/15
2
<0.1
<0.5
<0.5
52.76
MW-3
MZCL
3,000
5
100
50
2,000
1501
4/17/01
165
<1
<10
<5
73.4
2SO1
11/13/01
231
<1
<10
<5
57.8
1S02
4/23/02
<1
<10
<5
64.1
2SO2
10/23/02
186
<1
<10
<5
57.2
1S03
4/15/03
284
<1
<10
<5
63.9
2SO3
10/20/03
193
<1
<10
<5
56.76
1SO4
3/9/04
432.7
<1
<10
<5
38.8
2SO4
9/30/04
198
<1
<10
22.4
44.8
1S05
4/13/05
377
<1
13
6
40.1
2SO5
10/18/05
201
<1
<10
<5
52.3
1SO6
3/15/06
305
<1
<10
<5
42.35
2SO6
10/16/06
209
<1
<10
<5
45.1
1S07
4/30/07
232
<1
<10
<5
43.8
2SO7
10/16/07
179
<1
<10
<5
38.1
1S08
4/16/08
402
<1
<10
<5
47.2
2SO8
10/22/08
189
<1
<10
<5
40.98
2SO8
11/6/08
208*
NS
NS
NS
NS
1S09
4/21/09
294
<1
<10
<5
35.8
1S09 (Resample)
5/7/09
143*
<1*
<10*
<5*
NS
2SO9
11/5/09
162
<1
<10
<5
29.6
1510
4/20/10
485
<1
<10
<5
36.6
2S10
10/19/10
144
<1
<10
<5
28.1
1511
4/12/11
176
1.3
<5
<5
63
2S11
11/1/11
202
<1
<5
<5
46.7
1S12
5/15/12
164
<1
<5
<5
58.8
2S12
11/6/12
162
<1
<5
<5
41.9
1S13
5/13/13
103
<1
<5
<5
70.5
2S13
10/21/13
153
<1
<5
<5
86.4
1S14
4/28/14
82.8
1.2
<5
<5
44.6
2S14
10/14/14
122
<1
<5
<5
59.1
1S15
4/15/15
52.5
<1
<5
<5
15.6
Page 3 of 9

Well ID
Event
Sample Date
Parameter
Arsenic
Cadmium
Chromium
Lead
Sulfate
2S15
10/12/15
2.9
<0.1
<0.5
<0.5
<0.5
MWA
MZCL
3,000
5
100
50
2,000
1501
4/17/01
8.1
<1
<10
<5
4.6
2SO1
11/13/01
<5
<1
<10
<5
4.4
1S02
4/23/02
8.8
<1
<10
<5
4.8
2SO2
10/23/02
<5
<1
<10
<5
4.1
1S03
4/15/03
12.3
<1
<10
<5
5.5
2SO3
10/20/03
<5
<1
<10
<5
2.91
1SO4
3/9/04
7.6
3.4
<10
<5
2.2
2SO4
9/30/04
7.9
2.2
<10
<5
12.6
1S05
4/13/05
<5
<1
<10
<5
3.39
2SO5
10/18/05
15.1
3.4
<10
<5
6.3
1SO6
3/15/06
<5
2.2
<10
<5
3.96
2SO6
10/16/06
<5
<1
<10
<5
4.3
1S07
4/30/07
<5
<1
<10
<5
<0.50
2SO7
10/16/07
<5
<1
<10
<5
<0.50
1S08
4/16/08
<5
1.1
<10
<5
<0.5
2SO8
10/22/08
<5
<1
<10
<5
<0.5
1S09
4/21/09
<5
<1
<10
<5
7.02
2SO9
11/5/09
<5
<1
<10
<5
<0.5
1510
4/20/10
<5
3.2
<10
<5
10.4
2S10
10/19/10
<5
<1
<10
<5
<0.5
1511
4/12/11
<5
<1
<5
<5
<0.5
2S11
11/1/11
<5
<1
<5
<5
3
1S12
5/15/12
<5
1.9
<5
<5
8.7
2S12
11/6/12
<5
1.5
<5
<5
<0.5
1S13
5/13/13
<5
1.5
<5
<5
1.05
2S13
10/21/13
<5
<1
<5
<5
0.9
1S14
4/28/14
<5
3.6
<5
<5
6.1
2S14
10/14/14
<5
3.7
<5
<5
0.96
1S15
4/15/15
<5
<1
<5
<5
1.4
Page 4 of 9

Well ID
Event
Sample Date
Parameter
Arsenic
Cadmium
Chromium
Lead
Sulfate
2S15
10/12/15
2
<0.1
0.5
<0.5
0.71
MW-5
MZCL
50
15
100
50
2,000
1501
4/17/01
<5
2.2
<10
<5
0.7
2SO1
11/13/01
<5
<1
<10
<5
34.6
1S02
4/23/02
5
4.2
18.5
8.5
1.93
2SO2
10/23/02
<5
<1
<10
<5
2.71
1S03
4/15/03
15.4
<1
<10
<5
<0.5
2SO3
10/20/03
<5
<1
<10
<5
<0.5
1SO4
3/9/04
8
3.1
<10
<5
<0.5
2SO4
9/30/04
7.3
5.8
<10
<5
4
1S05
4/13/05
10
<1
15
8
<0.5
2SO5
10/18/05
5.2
5.4
<10
<5
<0.5
1SO6
3/15/06
<5
5.5
<10
<5
<0.5
2SO6
10/16/06
<5
<1
<10
<5
<0.5
1S07
4/30/07
<5
<1
<10
<5
<0.50
2SO7
10/16/07
<5
1.14
<10
<5
<0.50
1S08
4/16/08
<5
1.9
<10
<5
<0.5
2SO8
10/22/08
<5
1.4
<10
6.6
<0.5
1S09
4/21/09
<5
<1
<10
<5
<0.5
2SO9
11/5/09
<5
<1
<10
<5
<0.5
1510
4/20/10
<5
3.4
<10
<5
<0.5
2S10
10/19/10
<5
<1
<10
<5
<0.5
1511
4/12/11
6.1
<1
<5
<5
<0.5
2S11
11/1/11
9.1
<1
<5
6.1
4
2S11 (Resample)
12/2/11
<5*
NS
NS
NS
NS
1S12
5/15/12
<5
3.4
<5
7
13.4
2S12
11/6/12
<5
2.9
<5
8.8
37.8
1S13
5/13/13
5.7
<1
9.5
7.2
<0.5
2S13
10/21/13
<5
1.1
<5
6.4
0.9
1S14
4/28/14
<5
3.5
5.7
<5
0.9
2S14
10/13/14
<5
<1
<5
6.2
<0.5
1S15
4/14/15
<5
2.9
<5
<5
<0.5
2S15
10/12/15
4.4
<0.1
<0.5
<0.5
<0.5
Page 5 of 9

Well ID
Event
Sample Date
Parameter
Arsenic
Cadmium
Chromium
Lead
Sulfate
MW-6
MZCL
50
5
100
50
2,000
2SO1
11/13/01
<5
<1
<10
<5
48.4
1S02
4/23/02
<5
<1
<10
<5
47.9
2SO2
10/23/02
<5
<1
<10
<5
39.5
1S03
4/15/03
<5
<1
<10
<5
32.4
2SO3
10/20/03
<5
<1
<10
<5
44.92
1SO4
3/9/04
<5
2.8
<10
<5
2.9
2SO4
9/30/04
<5
<1
<10
<5
32.1
1SO5
4/13/05
<5
<1
<10
<5
29.6
2SO5
10/18/05
<5
<1
<10
<5
35.9
1S06
3/15/06
<5
<1
<10
<5
34.22
2SO6
10/16/06
<5
<1
<10
<5
30.4
1S07
4/30/07
<5
<1
<10
<5
<0.50
2SO7
10/16/07
<5
<1
187
11.6
<0.50
1S08
4/16/08
6.4
<1
<10
<5
30
2SO8
10/22/08
<5
<1
29.6
<5
24.5
1S09
4/21/09
<5
<1
<10
<5
<0.5
2SO9
11/5/09
<5
<1
<10
<5
22.5
1510
4/20/10
<5
3.4
<10
<5
1.56
2S10
10/19/10
<5
3.7
<10
<5
5.33
1511
4/12/11
<5
1.2
<5
<5
29.9
2S11
11/1/11
<5
1.2
<5
<5
29.4
1S12
5/16/12
6.7
<1
7.3
<5
35
2S12
11/6/12
<5
<1
<5
<5
37.2
1S13
5/13/13
5
<1
<5
<5
31.2
2S13
10/21/13
<5
<1
<5
<5
34.8
1S14
4/28/14
<5
<1
<5
<5
26
2S14
10/13/14
<5
<1
<5
<5
26.2
1S15
4/14/15
<5
<1
<5
<5
30.8
Page 6 of 9

Well ID
Event
Sample Date
Parameter
Arsenic
Cadmium
Chromium
Lead
Sulfate
2S15
10/12/15
0.8
<0.1
<0.5
<0.5
29.52
MW-8
MZCL
50
15
100
50
2,000
1501
4/17/01
15.1
1
<10
<5
226.8
2SO1
11/13/01
<5
<1
<10
<5
91.6
1S02
4/23/02
7.8
<1
<10
5
158.5
2SO2
10/23/02
<5
<1
<10
<5
243
1S03
4/15/03
<5
4.4
<10
<5
441.3
2SO3
10/20/03
19.8
3.4
<10
<5
164.9
1SO4
3/9/04
<5
3.9
<10
<5
99.2
2SO4
9/30/04
<5
<1
<10
<5
247.1
1S05
4/13/05
<5
<1
<10
<5
290
2SO5
10/18/05
<5
<1
<10
<5
314
1SO6
3/15/06
<5
2.8
<10
<5
207.8
2SO6
10/16/06
<5
<1
<10
<5
170
1S07
4/30/07
6
<1
<10
<5
73
2SO7
10/16/07
<5
<1
<10
<5
13
1S08
4/16/08
<5
<1
<10
<5
15.1
2SO8
10/22/08
<5
<1
<10
<5
3.2
1S09
4/21/09
<5
<1
<10
<5
37.1
2SO9
11/5/09
<5
<1
<10
<5
37.8
1510
4/20/10
<5
3.1
<10
<5
12.08
2S10
10/19/10
<5
3.1
<10
<5
1.11
1511
4/12/11
<5
<1
6.5
<5
66.3
2S11
11/1/11
<10
2.2
<10
<10
115
1S12
5/16/12
<50
<10
<50
<50
195
2S12
11/6/12
10.7
2.8
<10
<10
198
1S13
5/13/13
<5
<1
5
10.6
129.9
2S13
10/21/13
<5
<1
<5
5.6
125
1S14
4/28/14
<5
2
<5
<5
119
2S14
10/13/14
<5
<1
<5
<5
77.4
1S15
4/14/15
<5
<1
<5
5
63.8
2S15
10/12/15
1.7
<0.1
2
0.62
49.4
Page 7 of 9

Well ID
Event
Sample Date
Parameter
Arsenic
Cadmium
Chromium
Lead
Sulfate
MW-9
MZCL
50
15
100
50
2,000
1501
4/17/01
<5
5.8
<10
<5
1,040
2SO1
11/13/01
<5
<1
<10
<5
1,182
1S02
4/23/02
<5
7.9
<10
5
1,044
2S02
10/23/02
<5
<1
<10
<5
1,603
1S03
4/15/03
7.7
8.8
<10
<5
775.6
2SO3
10/20/03
<5
<1
<10
<5
824.5
1SO4
3/9/04
<5
6.9
<10
<5
962
2SO4
9/30/04
<5
1
<10
<5
775.4
1S05
4/13/05
<5
<1
<10
<5
963
2SO5
10/18/05
<5
4.5
<10
<5
916
1S06
3/15/06
<5
<1
<10
<5
957
2SO6
10/16/06
<5
<1
<10
<5
861
1S07
4/30/07
<5
<1
<10
<5
241
2SO7
10/16/07
<5
<1
<10
<5
1,200
1S08
4/16/08
<5
2.4
<10
<5
9,330
2SO8
10/22/08
<5
2.4
<10
<5
1,247.30
1S09
4/21/09
<5
<1
<10
<5
432
2SO9
11/5/09
<5
<1
<10
<5
1,017
1510
4/20/10
<5
<1
<10
<5
992
2S10
10/19/10
<5
<1
<10
<5
1,045
1511
4/12/11
7.4
3.6
<5
8.8
900
2S11
11/1/11
9.6
<1
<5
10
992
2S11 (Resample)
12/2/11
<5*
<1*
NS
NS
NS
1S12
5/15/12
<5
2.2
<5
13.4
978
2S12
11/6/12
<5
8.2
<5
13.6
945
1S13
5/13/13
<5
2.2
<5
13.9
710
2S13
10/21/13
<5
3.4
<5
12
926
1S14
4/28/14
<5
<1
<5
9.1
425
2S14
10/13/14
<5
<1
<5
11.5
973
1S15
4/14/15
<5
<1
<5
11.1
761
2S15
10/13/15
3.9
0.5
0.6
<0.5
707.9
Page 8 of 9

Well ID
Event
Sample Date
Parameter
Arsenic
Cadmium
Chromium
Lead
Sulfate
MW-11
MZCL
3,000
5
100
50
2,000
1SO1
4/17/01
565
<1
<10
<5
59.2
2SO1
11/13/01
1,150
<1
<10
<5
60.3
1S02
4/23/02
1,143
<1
<10
<5
63.8
2S02
10/23/02
774
<1
<10
<5
68.2
1S03
4/15/03
322
<1
<10
<5
57.7
2SO3
10/20/03
1,345
<1
<10
<5
63.9
1SO4
3/9/04
337
<1
19.2
7.9
54.3
2SO4
9/30/04
563
<1
18.7
9.7
40.7
1S05
4/13/05
891
<1
73
39
53.9
2SO5
10/18/05
1,512
<1
31.4
13.7
54.2
1S06
3/15/06
5,100
<1
40
14
36.82
1S06 (Resample)
6/1/06
968*
NS
NS
NS
NS
2SO6
10/16/06
1,492
<1
<10
<5
68.2
1S07
4/30/07
4,051
<1
10
7
27.5
1S07 (Resample)
5/7/07
252*
NS
NS
NS
NS
2SO7
10/16/07
2,452
<1
<10
5.2
26.8
1S08
4/16/08
310
<1
<10
<5
35.4
2SO8
10/22/08
2,149
<1
13.2
8
32.04
2SO8 (Resample)
11/6/08
424*
NS
NS
NS
NS
1S09
4/21/09
567
<1
<10
<5
41.9
1S09 (Resample)
5/7/09
932*
<1*
<10*
<5*
NS
2SO9
11/5/09
576
<1
<10
<5
27.6
1S10
4/20/10
796
<1
31.7
10.9
60.8
2S10
10/19/10
696
<1
<10
<5
55.7
1S11
4/12/11
380
<1
8.7
<5
44.5
1S11 (Resample)
6/15/11
1,100*
<1*
<5*
<5*
102.4*
2S11
11/1/11
318
<1
<5
<5
107
1S12
5/15/12
690
<1
<5
<5
85.8
2S12
11/6/12
460
<1
<5
<5
43
1S13
5/13/13
94.5
<1
<5
<5
24.7
2S13
10/22/13
355
<1
<5
<5
42.4
1S14
4/28/14
97
<1
<5
<5
25.9
2S14
10/13/14
101
<1
<5
<5
22.2
1S15
4/14/15
93.8
<1
<5
<5
15.5
2S15
10/13/15
58.6
<0.1
1.8
0.61
19.35
MW-12
1S15
4/14/15
<5.0
<1.0
<5.0
<5.0
24.6
2S15
10/13/15
1.9
<0.1
0.5
<0.5
30.12
Notes:
1) All concentrations for total metals and are provided in micrograms per liter (µg/I).
2) Sulfate concentrations are provided in milligrams per liter (mg/L).
3) MZCL = Mixing Zone Contaminant Level.
4) MZCL for arsenic for wells MW-1A, MW-2, MW-5, MW-6, MW-8, and MW-9 is 50 ug/l.
5) MZCL for arsenic for wells MW-3, MW-4, and MW-11 is 3,000 ug/l.
6) MZCL for cadmium for wells MW-1, MW-2, MW-3, MW-4, MW-6, and MW-11 is 5.0 ug/I.
7) MZCL for cadmium for wells MW-5, MW-8, and MW-9 is 15.0 ug/I.
8) NS = Not analyzed.
9) Bold type indicates concentration above MZCL.
10) * = Results of resampling
Page 9 of 9

Vsantee cooper
CERTIFIED MAIL
January 11, 2016
Jeffrey P. deBessonet, Director
South Carolina Department of Health
and Environmental Control
Water Facilities Permitting Division
2600 Bull Street
Columbia, South Carolina 29201
RE: Grainger Generating Station
Ash Pond Closure: Ash Removal Report
Santee Cooper's annual closure plan states that Santee Cooper will provide status reports to DHEC
every six months regarding the amount of ash and underlying soil removed from Grainger Generating
Station.
Removal of ash for beneficial use began at Grainger on March 17, 2014. The following table provides
tons of ash and soil removed for 2015.
Year
Month
Ash (tons)
Soil (tons)
2015
January
28,720
0
2015
February
19,922
0
2015
March
1,051
0
2015
Aril
31,784
0
2015
May
22,211
0
2015
June
28,964
0
2015
July
30,106
0
2015
August
12,117
0
2015
September
32,767
0
2015
October
21,676
0
2015
November
33,917
0
2015
December
21,202
0
2015
Total YTD)
284,438
Sincerely,
TL
Thomas L. Kiers
Vice President
Environmental, Property and Water Systems Management
TLK: MrDM-cgb
cc. Frank Holleman
One R6er ood Dwe I MonCKS Corner,SC 29401-2901 1 [phone] 1 P.O. B.. 2946101 1 M=n Corner, SC 29461-6101

psantee cooper
FEDEX
January 14, 2015
Jeffrey P. deBessonet, Director
South Carolina Department of Health
and Environmental Control
Water Facilities Permitting Division
2600 Bull Street
Columbia, South Carolina 29201
RE: Grainger Generating Station
Ash Pond Closure: Ash Removal Report
Santee Cooper's annual closure plan states that Santee Cooper will provide status
reports to DHEC every six months regarding the amount of ash and underlying soil
removed from Grainger Generating Station.
Removal of ash for beneficial use began at Grainger on March 17, 2014. The following
table provides tons of ash and soil removed for 2014.
Year
Month
Ash tons
2014
January
0
0
2014
February
0
0
2014
March
4,700
0
2014
April
6,018
0
2014
May
11,906
0
2014
June
20,264
0
2014
July
14,886
0
2014
August
19,711
0
2014
September
25,862
0
2014
October
25,453
0
2014
November
23,022
0
2014
December
12,894
0
One Riverwood Drive I Moncks Corner, SC 29461-2901 1 [phone] 1 P.O. Box 2946101 I Moncks Corner; SC 29461-6101

Jeffrey P. deBessonet, Director
SCDHEC
January 14, 2015
Page 2
Sincerely,
%Z
Thomas L. Kiersp ,
Vice President
Environmental, Property and Water Systems Management
TLK:M
:Af Wgb
,t
cc: Frank Holleman

CERTIFIED MAIL
November 22, 2013
Mr. Chris Forrest
Groundwater Protection Section
SCDHEC Bureau of Water
2600 Bull Street
Columbia, South Carolina 29201
Mr. Keith Collinsworth, Manager
State Voluntary Cleanup Section
SCDHEC Bureau of Land and Waste Management
2600 Bull $treet
Columbia, South Carolina 29201
Dear Mr. Forrest and Mr. Collingsworth:
5cantee cooper
Re: South Carolina Public Service Authority
Santee Cooper Grainger Generating Station, Horry County
NPDES Permit# SC0001104; Site ID# 00367
NPDES Groundwater Semi-annual and Compliance Report for 2013
Enclosed are the results of the September 30-October 1, 2013, groundwater sampling event for
the NPDES Permit# SC0001104 groundwater monitoring and compliance wells located at the
Grainger Generating Station. Included with this report are the results from the surface water
sampling, staff gauge readings, a sample location map, a potentiometric map, and an arsenic
concentration map which delineates the distribution of arsenic at the site.
Lab results showed measurable concentrations of arsenic in six of the eighteen locations where
water samples were analyzed. Three were groundwater wells along the down gradient edge of
Ash Pond 1 and three were groundwater wells along the down gradient edge of Ash Pond 2.
While there is a good distribution of data points across the site, the locations with measurable
concentrations are segregated from each other by the close proximity of non -detectable results in
the river, the intake canal, and adjacent groundwater wells. All of these factors prevented the use
of isoconcentration lines.
If you have any questions or comments concerniirg this report, please contact Melanie Hill at
[phone] extension 4490.
Ore Rivenvood Drive I Moncks Corner, SC 29461-2901 1 [phone] 1 P.O. Box 2946101 I Moncks Corner, SC 29461-6101

Mr. Chris Forrest/Mr. Keith Collinsworth — SCDHEC
November 22, 2013
Page 2
PE
Environmental Management
Attachments
cc: Frank S. Holleman, III, Esq
Southern Environmental Law Center
601 W. Rosemary Street, Suite 220
Chapel Hill, North Carolina 27516

Grainger Generating Station
NPDES Groundwater Monitoring
Potentiometric Map
October 2013
Groundwater Contour Interval
23 Groundwater Elevation (feet)
Well ID TOC GW GW
Elevation Depth Elevation
(feet) (feet) (feet)
MW-1 13.32 10.78 2.54
MW-2 11.06 2.6 8.46
MW-3 6.72 4.98 1.74
MW-4 12.01 10.48 1.53
MW-5 9.09 5.39 3.7
MW-6 9.2 6.59 2.61
MW-12 14.9 11.31 3.59
MW-9 8.24 7.85 0.39
MW-10 8.92 5.65 3.27
MW-11 9.63 4.61 5.02
PZ-1 6.66 5.72 0.94
PZ-2 6.82 5.65 1.17
PZ-3 7.25 5.9 1.35
Water levels collected on October 1, 2013.
Staff Gauge ID
Date
Surface Water
Elevation
(Feet)
G-SW-ICP
Oct 2013
6.8
G-SW-Canal
Oct 2013
1.3
G-SW-HDD-1
Oct 2013
1.6
G-SW-AP2-1
Oct 2013
0
G-SW-AP2-2
Oct 2013
0
G-SW-HDD-2
Oct 2013
1.46
11/20/13:MDH

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'Osantee cooper
ANALYTICAL & BIOLOGICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AC54159 Location: GW Well GGSMW-1 Date: 09/30/2013
Loc. Code GGSMW-1 Time: 11:15
One Riverwood Drive
P.O. Box 2946101
Moncks Corner, SC 29461-2901
(843} 761-8000
Sample Collector: MDH
Analysis
Result QUAL
Units
Test Date
Analyst
Arsenic
<10
ug/L
10/31/2013
KLMUELLE
Arsenic - Dissolved
<10
ug/L
10/29/2013
KLMUELLE
Cadmium
<5
ug/L
10/31/2013
KLMUELLE
Chloride
4.54
mg/L
10/0212013
LCWILLIA
Spec. Cond.
557
us
09/30/2013
MDHILL
Chromium
<5
ug/L
10/31/2013
KLMUELLE
Copper
<10
ug/L
10/31/2013
KLMUELLE
Depth
10.78
Feet
09/30/2013
MDHILL
Elevation
2.54
Feet
10/04/2013
MDHILL
Iron
6103.6
ug/L
10/31/2013
KLMUELLE
Oxidation Reduction Potential
-57
my
09/30/2013
MDHILL
pH
6.49
SU
09/30/2013
MDHILL
Selenium
<10
ug/L
11/01/2013
KLMUELLE
Sulfate
214
mg/L
10/02/2013
LCW ILLIA
Total Dissolved Solids
397.5
mg/L
10/11/2013
AJBROWN
Temp
23.35
C
09/30/2013
MDHILL
Turbidity
11.2
NTU
09/30/2013
MDHILL
Zinc
<10
ug/L
10/31/2013
KLMUELLE
Method
EPA 200.7
EPA 200.7
EPA 200.7
EPA 300.0
EPA 200.7
EPA 200.7
EPA 200.7
SM2580
EPA 200.7
EPA 300.0
SM 2540C
EPA 200.7
Independent Laboratory Results: "GEL" -GEL Laboratories LLC -Lab ID # 10120; 'Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001
Qualifiers: U-Value below MDL;
is Estimated; M-Matrix Interference
Analysis Validated:

ANALYTICAL & BIOLOGICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AC54160 Location: GW Well GGSMW-2 Date: 09/30/2013
Loc. Code GGSMW-2 Time: 12:05
One Rivemood Drive
P.O. Box 2946101
Moncks Corner, SC 29461-2901
[phone]
Sample Collector: MDH
Analysis
Result QUAL
Units
Test Date
Analyst
Arsenic
<10
ug/L
10/31/2013
KLMUELLE
Arsenic - Dissolved
<10
ug/L
10/29/2013
KLMUELLE
Cadmium
<5
ug/L
10/31/2013
KLMUELLE
Chloride
20.3
mg/L
10/02/2013
LCWILLIA
Spec. Cond.
803
us
09/30/2013
MDHILL
Chromium
<5
ug/L
10/31/2013
KLMUELLE
Copper
<10
ug/L
10/31/2013
KLMUELLE
Depth
2.6
Feet
09/30/2013
MDHILL
Elevation
8.46
Feet
10/04/2013
MDHILL
Iron
6353.1
ug/L
10/31/2013
KLMUELLE
Oxidation Reduction Potential
-87
my
09/30/2013
MDHILL
pH
6.7
SU
09/30/2013
MDHILL
Selenium
<10
ug/L
11/01/2013
KLMUELLE
Sulfate
10.4
mg/L
10/02/2013
LCWILLIA
Total Dissolved Solids
505.0
mg/L
10/11/2013
AJBROWN
Temp
26.63
C
09/30/2013
MDHILL
Turbidity
7.5
NTU
09/30/2013
MDHILL
Zinc
<10
ug/L
10/31/2013
KLMUELLE
Method
EPA 200.7
EPA 200.7
EPA 200.7
EPA 300.0
EPA 200.7
EPA 200.7
EPA 200.7
SM2580
EPA 200.7
EPA 300.0
SM 2540C
EPA 200.7
Independent Laboratory Results: "GEL" -GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. -Lab ID# 98001
Qualifiers: U-Value below MDL; H-Holdin 'me Exceded)J-Value is Estimated; M-Matrix Interference
Z" e_�
Analysis Validated:

One Rivemood Drive
santee Moncksx orner, 1
cooper Moncks Corner, SC 29461-2901
[phone]
ANALYTICAL & BIOLOGICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AC54161 Location: GW Well GGSMW-3 Date: 10/01/2013 Sample Collector: MDH
Loc. Code GGSMW-3
Time: 13:40
Analysis
Result QUAL
Units
Test Date
Analyst
Arsenic
941.9
ug/L
10/31/2013
KLMUELLE
Arsenic - Dissolved
486.5
ug/L
10/29/2013
KLMUELLE
Cadmium
<5
ug/L
10/31/2013
KLMUELLE
Chloride
13.9
mg/L
10/02/2013
LCWILLIA
Spec. Cond.
1210
us
10/01/2013
MDHILL
Chromium
<5
ug/L
10/31/2013
KLMUELLE
Copper
<10
ug/L
10/31/2013
KLMUELLE
Depth
4.98
Feet
10/01/2013
MDHILL
Elevation
1.74
Feet
10/04/2013
MDHILL
Iron
25861.2
ug/L
10/31/2013
KLMUELLE
Oxidation Reduction Potential
-98
my
10/01/2013
MDHILL
pH
6.53
SU
10101/2013
MDHILL
Selenium
<10
ug/L
11/01/2013
KLMUELLE
Sulfate
<2.0
mg/L
10/02/2013
LCWILLIA
Total Dissolved Solids
747.5
mg/L
10/11/2013
AJBROWN
Temp
21.65
C
10/01/2013
MDHILL
Turbidity
0
NTU
10/01/2013
MDHILL
Zinc
<10
ug/L
10/31/2013
KLMUELLE
Method
EPA 200.7
EPA 200.7
EPA 200.7
EPA 300.0
EPA 200.7
EPA 200.7
EPA 200.7
SM2580
EPA 200.7
EPA 300.0
SM 2540C
EPA 200.7
Independent Laboratory Results: "GEL" - GEL Laboratories LLC - Lab ID # 10120; 'Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001
Qualifiers: U-Value below MDL;
is Estimated; M-Matrix Interference
Analysis Validated:

V.
race cooper
ANALYTICAL & BIOLOGICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AC54162 Location: GW Well GGSMW-4 Date: 10/01/2013
Loc. Code GGSMW-4
Time: 11:45
One Rivemood Drive
P.O. Box 2946101
Moncks Corner, SC 29461-2901
(84 3) 761-8000
Sample Collector: MDH
Analysis
Result QUAIL
Units
Test Date
Analyst
Arsenic
<10
ug/L
10/31/2013
KLMUELLE
Arsenic - Dissolved
<10
ug/L
10/29/2013
KLMUELLE
Cadmium
<5
ug/L
10/31/2013
KLMUELLE
Chloride
16.5
mg/L
10/02/2013
LCWILLIA
Spec. Cond.
365
us
10/01/2013
MDHILL
Chromium
<5
ug/L
10/31/2013
KLMUELLE
Copper
<10
ug/L
10/31/2013
KLMUELLE
Depth
10.48
Feet
10/01/2013
MDHILL
Elevation
1.53
Feet
10/04/2013
MDHILL
Iron
39443.2
ug/L
10/31/2013
KLMUELLE
Oxidation Reduction Potential
-5
my
10/01/2013
MDHILL
pH
5.59
SU
10/01/2013
MDHILL
Selenium
<10
ug/L
11/01/2013
KLMUELLE
Sulfate
<2.0
mg/L
10/02/2013
LCWILLIA
Total Dissolved Solids
280.0
mg/L
10/11/2013
AJBROWN
Temp
20.87
C
10/01/2013
MDHILL
Turbidity
0
NTU
10/01/2013
MDHILL
Zinc
<10
ug/L
10/31/2013
KLMUELLE
Method
EPA 200.7
EPA 200.7
EPA 200.7
EPA 300.0
EPA 200.7
EPA 200.7
EPA 200.7
SM2580
EPA 200.7
EPA 300.0
SM 2540C
EPA 200.7
Independent Laboratory Results: "GEL" -GEL Laboratories LLC -Lab ID # 10120; 'Test America" - TestAmerica Laboratories, Inc. -Lab ID# 98001
Qualifiers: U-Value below MDL;
is Estimated; M•Matrix Interference
Analysis Validated:

14pantee cooper
ANALYTICAL & BIOLOGICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AC54163 Location: GW Well GGSMW-5 Date: 09/30/2013
Loc. Code GGSMW-5 Time: 14:40
One Rivenmood Drive
P.O. Box 2946101
Moncks Coiner, SC 29461-2901
[phone]
Sample Collector: MDH
Analysis
Result QUAL
Units
Test Date
Analyst
Arsenic
14.5
ug/L
10/31/2013
KLMUELLE
Arsenic - Dissolved
18.2
ug/L
10/29/2013
KLMUELLE
Cadmium
<5
ug/L
10/31/2013
KLMUELLE
Chloride
15.4
mg/L
10102/2013
LCWILLIA
Spec. Cond.
539
us
09/30/2013
MDHILL
Chromium
<5
ug/L
10/31/2013
KLMUELLE
Copper
<10
ug/L
10/31/2013
KLMUELLE
Depth
5.39
Feet
09/30/2013
MDHILL
Elevation
3.7
Feet
10/04/2013
MDHILL
Iron
3665.6
ug/L
10/31/2013
KLMUELLE
Oxidation Reduction Potential
-88
my
09/30/2013
MDHILL
pH
5.92
SU
09/30/2013
MDHILL
Selenium
<10
ug/L
11/01/2013
KLMUELLE
Sulfate
216
mg/L
10/08/2013
LCWILLIA
Total Dissolved Solids
412.5
mg/L
10/11/2013
AJBROW N
Temp
21.4
C
09/30/2013
MDHILL
Turbidity
0
NTU
09/30/2013
MDHILL
Zinc
<10
ug/L
10/31/2013
KLMUELLE
Method
EPA 200.7
EPA 200.7
EPA 200.7
EPA 300.0
EPA 200.7
EPA 200.7
EPA 200.7
SM2580
EPA 200.7
EPA 300.0
SM 2540C
EPA 200.7
Independent Laboratory Results: 'GEL"- GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001
Qualifiers: LI-Value below MDL; H-HoldiggJimfSxceok; J-Value is Estimated; M-Matrix Interference
Analysis Validated:

ANALYTICAL & BIOLOGICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AC54164 Location: GW Well GGSMW-6 Date: 09/30/2013
Loc. Code GGSMW-6 Time: 12:50
One Rivermood Drive
P.O Box 2946101
Moncks Corner, SC 29461-2901
[phone]
Sample Collector: MDH
Analysis
Result QUAL
Units
Test Date
Analyst
Arsenic
<10
ug/L
10/31/2013
KLMUELLE
Arsenic - Dissolved
<10
ug/L
10/29/2013
KLMUELLE
Cadmium
<5
ug/L
10/31/2013
KLMUELLE
Chloride
49.3
mg/L
10/0212013
LCWILLIA
Spec. Cond.
870
us
09/30/2013
MDHILL
Chromium
<5
ug/L
10/31/2013
KLMUELLE
Copper
<10
ug/L
10/31/2013
KLMUELLE
Depth
6.59
Feet
09/30/2013
MDHILL
Elevation
2.61
Feet
10/04/2013
MDHILL
Iron
7412.8
ug/L
10/31/2013
KLMUELLE
Oxidation Reduction Potential
-62
my
09/30/2013
MDHILL
pH
6.35
SU
09/30/2013
MDHILL
Selenium
<10
ug/L
11/01/2013
KLMUELLE
Sulfate
0.93
mg/L
10/02/2013
LCWILLIA
Total Dissolved Solids
680.0
mg/L
10/11/2013
AJBROWN
Temp
23.17
C
09/30/2013
MDHILL
Turbidity
0
NTU
09/30/2013
MDHILL
Zinc
<10
ug/L
10/31/2013
KLMUELLE
Method
EPA 200.7
EPA 200.7
EPA 200.7
EPA 300.0
EPA 200.7
EPA 200.7
EPA 200.7
SM2580
EPA 200.7
EPA 300.0
SM 2540C
EPA 200.7
Independent Laboratory Results: "GEL"- GEL Laboratories LLC - Lab ID # 10120; 'Test America" - TestAmerica Laboratories, Inc. -Lab ID# 98001
Qualifiers: U-Value below MDL; H-Holding
Analysis Validated:
is Estimated; M•Matrix Interference

4qpantee cooper
ANALYTICAL & BIOLOGICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample# AC54165 Location: GW Well GGSMW-9 Date: 10/01/2013
Loc. Code GGSMW-9
Time: 12:30
One Rivemood Drive
P.O. Box 2946101
Moncks Corner, SC 29461-2901
f643) 761-8000
Sample Collector: MDH
Analysis
Result QUAL
Units
Test Date
Analyst
Arsenic
3371.6
ug/L
10/31/2013
KLMUELLE
Arsenic -Dissolved
1559.3
ug/L
10/31/2013
KLMUELLE
Cadmium
<5
ug/L
10/31/2013
KLMUELLE
Chloride
57.6
mg/L
10/02/2013
LCWILLIA
Spec. Cond.
783
us
10/01/2013
MDHILL
Chromium
<5
ug/L
10/31/2013
KLMUELLE
Copper
<10
ug/L
10131/2013
KLMUELLE
Depth
7.85
Feet
10/01/2013
MDHILL
Elevation
0.39
Feet
10/04/2013
MDHILL
Iron
22352.7
ug/L
10/31/2013
KLMUELLE
Oxidation Reduction Potential
-44
my
10/01/2013
MDHILL
pH
6.18
SU
10/01/2013
MDHILL
Selenium
<10
ug/L
11/01/2013
KLMUELLE
Sulfate
146
mg/L
10/02/2013
LCWILLIA
Total Dissolved Solids
517.5
mg/L
10/11/2013
AJBROWN
Temp
21.19
C
10/01/2013
MDHILL
Turbidity
114
NTU
10/01/2013
MDHILL
Zinc
<10
ug/L
10/31/2013
KLMUELLE
Method
EPA 200.7
EPA 200.7
EPA 200.7
EPA 300.0
EPA 200.7
EPA 200.7
EPA 200.7
S M2580
EPA 200.7
EPA 300.0
SM 2540C
EPA 200.7
Independent Laboratory Results: "GEL" -GEL Laboratories LLC - Lab ID # 10120; 'Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001
Qualifiers: U-Value below MDL; H-HoldingJime Excede�VJ-Value is Estimated; M•Matrix Interference
Analysis Validated:

One Rivevood Drive
sa tee cwoeC P.O. ks Corner, S
Moncks Corner, SC 29461-2901
(843) 761-BOOD
ANALYTICAL & BIOLOGICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AC54166 Location: GW Well GGSMW-10 Date: 10/01/2013 Sample Collector: MDH
Loc. Code GGSMW-10
Time: 10:55
Analysis
Result QUAL
Units
Test Date
Analyst
Arsenic
1097.9
ug/L
10/31/2013
KLMUELLE
Arsenic - Dissolved
361.2
ug/L
10/29/2013
KMUELLE
Cadmium
<5
ug/L
10/31/2013
KLMUELLE
Chloride
12.5
mg/L
10/02/2013
LCWILLIA
Spec. Cond.
1250
us
10/01/2013
MDHILL
Chromium
<5
ug/L
10/31/2013
KLMUELLE
Copper
<10
ug/L
10/31/2013
KLMUELLE
Depth
5.65
Feet
10/01/2013
MDHILL
Elevation
3.27
Feet
10/04/2013
MDHILL
Iron
32095.3
ug/L
10/31/2013
KLMUELLE
Oxidation Reduction Potential
-113
my
10/01/2013
MDHILL
pH
6.55
SU
10/01/2013
MDHILL
Selenium
<10
ug/L
11/01/2013
KLMUELLE
Sulfate
<2.0
mg/L
10/0212013
LCWILLIA
Total Dissolved Solids
675.0
mg/L
10/11/2013
AJBROWN
Temp
20.07
C
10/01/2013
MDHILL
Turbidity
0
NTU
10/01/2013
MDHILL
Zinc
<10
ug/L
10/31/2013
KLMUELLE
Method
EPA 200.7
EPA 200.7
EPA 200.7
EPA 300.0
EPA 200.7
EPA 200.7
EPA 200.7
SM2580
EPA 200.7
EPA 300.0
SM 2540C
EPA 200.7
Independent Laboratory Results: "GEL" - GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. -Lab ID# 98001
Qualifiers: U-Value below MDL; H-Holding TiMa-Excudud-J-Value is Estimated; M•Matrix Interference
Analysis Validated:

IV
santee cooper
ANALYTICAL & BIOLOGICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AC54167 Location: GW Well GGSMW-11 Date: 09/3012013
Loc. Code GGSMW-11
Time: 15:40
One Rivewood Drive
P.O. Box 2946101
Moncks Corner, SC 29461-2901
[phone]
Sample Collector: MDH
Analysis
Result QUAL
Units
Test Date
Analyst
Arsenic
450.0
ug/L
10/31/2013
KLMUELLE
Arsenic - Dissolved
121.6
ug/L
10/29/2013
KLMUELLE
Cadmium
<5
ug/L
10/31/2013
KLMUELLE
Chloride
14.0
mg/L
10/02/2013
LCWILLIA
Spec. Cond.
1150
us
09/30/2013
MDHILL
Chromium
<5
ug/L
10/31/2013
KLMUELLE
Copper
<10
ug/L
10/31/2013
KLMUELLE
Depth
4.61
Feet
09/30/2013
MDHILL
Elevation
5.02
Feet
10/04/2013
MDHILL
Iron
45491.5
ug/L
10/31/2013
KLMUELLE
Oxidation Reduction Potential
-97
my
09/30/2013
MDHILL
pH
6.43
SU
09/30/2013
MDHILL
Selenium
<10
ug/L
11/01/2013
KLMUELLE
Sulfate
<2.0
mg/L
10/02/2013
LCWILLIA
Total Dissolved Solids
730.0
mg/L
10/11/2013
AJBROWN
Temp
22.23
C
09/30/2013
MDHILL
Turbidity
0
NTU
09/30/2013
MDHILL
Zinc
<10
ug/L
10/31/2013
KLMUELLE
Method
EPA 200.7
EPA 200.7
EPA 200.7
EPA 300.0
EPA 200.7
EPA 200.7
EPA 200.7
SM2580
EPA 200.7
EPA 300.0
SM 2540C
EPA 200.7
Independent Laboratory Results: "GEL"- GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. -Lab ID# 98001
Qualifiers: U-Value below MDL;
Analysis Validated:
is Estimated; M-Matrix Interference

`Ip%ntee cooper
ANALYTICAL & BIOLOGICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AC54168 Location: GW Well GGSMW-12 Date: 09/30/2013
Loc. Code GGSMW-12 Time: 13:30
One Rivemood Drive
P.O. Box 2946101
Moncks Corner, SC 29461-2901
[phone]
Sample Collector: MDH
Analysis
Result QUAIL
Units
Test Date
Analyst
Arsenic
19.4
ug/L
10/31/2013
KLMUELLE
Arsenic - Dissolved
21.9
ug/L
10/29/2013
KLMUELLE
Cadmium
<5
ug/L
10/31/2013
KLMUELLE
Chloride
13.5
mg/L
10/02/2013
LCW ILLIA
Spec. Cond.
624
us
09/30/2013
MDHILL
Chromium
<5
ug/L
10/31/2013
KLMUELLE
Copper
<10
ug/L
10/31/2013
KLMUELLE
Depth
11.31
Feet
09/30/2013
MDHILL
Elevation
3.59
Feet
10/04/2013
MDHILL
Iron
12436.4
ug/L
10131/2013
KLMUELLE
Oxidation Reduction Potential
-57
my
09/30/2013
MDHILL
pH
5.74
SU
09/30/2013
MDHILL
Selenium
10.2
ug/L
11/01/2013
KLMUELLE
Sulfate
267
mg/L
10/08/2013
LCWILLIA
Total Dissolved Solids
485.0
mg/L
10/11/2013
AJBROWN
Temp
24.63
C
09/30/2013
MDHILL
Turbidity
0
NTU
09/30/2013
MDHILL
Zinc
<10
ug/L
10/31/2013
KLMUELLE
Method
EPA 200.7
EPA 200.7
EPA 200.7
EPA 300.0
EPA 200.7
EPA 200.7
EPA 200.7
SM2580
EPA 200.7
EPA 300.0
SM 2540C
EPA 200.7
Independent Laboratory Results: 'GEL"- GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. -Lab ID# 98001
Qualifiers: U-Value below MDL; XH-lHoIIdnime Exced &,; J-Value is Estimated; M-Matrix Interference
l
Analysis Validated:
Bria ynch - Results Supervisor, Central Lab

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ANALYTICAL & BIOLOGICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AC53946 Location: Lower Waccamaw River Date: 09/26/2013
Loc. Code WAC LOW
Time: 10:45
Analysis
Result QUAL
Units
Test Date
Air Temp
22
C
10/02/2013
Arsenic - MS
<2,5 J
ug/L
10/08/2013
Arsenic- Dissolved
<2.5 J
ug/L
10/08/2013
Collection Depth
2.2
m
10/02/2013
Field Conductivity
112
us
10/02/2013
Field pH
6.28
SU
10/02/2013
Flow
1330
cfs
10/03/2013
Gauge heigh
7.46
ft
10/03/2013
Oxidation Reduction Potential
138
my
10/02/2013
Weather
2
other
10/02/2013
Water Temp
23.23
C
10/02/2013
One Rivenvood Drive
P.O. Box 2946101
Moncks Corner, SC 29461-2901
[phone]
Sample Collector: CM/EG
Analyst
Method
EHGUERRY
TESTAMERICA
EPA 200.8
TESTAMERICA
EPA 200.8
EHGUERRY
EHGUERRY
EHGUERRY
CWMOORER
CWMOORER
EHGUERRY
SM2580
EHGUERRY
EHGUERRY
Independent Laboratory Results: "GEL" - GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001
Qualifiers: U-Value below MDL; H44olding Time xceded; J-Value is Estimated; M-Matrix Interference
Analysis Validated:

One Rivemood Drive
JGilee cooper Moncksxorner, 1
Gi 1, l� Moncks Corner, SC 29461-2901
[phone]
ANALYTICAL & BIOLOGICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AC53947 Location: GGS Cooling Pond Date: 09/26/2013 Sample Collector:'CM/EG
Loc. Code GGS CP Time: 11:09
Analysis Result QUAL Units Test Date Analyst Method
Air Temp 22 C 10/02/2013 EHGUERRY
Arsenic - MS <2.5 J ug/L 10/08/2013 TESTAMERICA EPA200.8
Arsenic - Dissolved <2.5 J ug/L 10/08/2013 TESTAMERICA EPA 200.8
Collection Depth 0.3 m 10/02/2013 EHGUERRY
Field Conductivity 87 us 10/0212013 EHGUERRY
Field pH 6.78 SU 10/02/2013 EHGUERRY
Flow Not Required cfs 10/07/2013 JMDAVIS
Gauge heigh Not Required ft 10/07/2013 JMDAVIS
Oxidation Reduction Potential 164.6 my 10/02/2013 EHGUERRY SM2580
Weather 2 other 10/0212013 EHGUERRY
Water Temp 22.74 C 10/02/2013 EHGUERRY
Independent Laboratory Results: "GEL" - GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001
Qualifiers: U-Value below MDL; H-Holding
is Estimated; M•Matrix Interference
Analysis Validated:

IV One Riverwood Drive
P.O. Box 2946101
Santee cooper (843) 7 Corner, SC 29461-2901
(643) 61-8000
ANALYTICAL & BIOLOGICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AC53948 Location: Ditch beside HWY 501 off Date: 09/26/2013 Sample Collector: CM/EG
Loc. Code 501_DITCH Waccamaw River Time: 11:27
Analysis Result QUAL Units Test Date Analyst Method
Air Temp 23 C 10/02/2013 EHGUERRY
Arsenic - MS <2.5 J ug/L 10/08/2013 TESTAMERICA EPA 200.8
Arsenic - Dissolved <2.5 J ug/L 10/0812013 TESTAMERICA EPA 200.8
Collection Depth 0.3 m 10/02/2013 EHGUERRY
Field Conductivity 113 us 10/02/2013 EHGUERRY
Field pH 6.35 SU 10/02/2013 EHGUERRY
Flow Not Required cfs 10/07/2013 JMDAVIS
Gauge heigh 2.4 ft 10/02/2013 EHGUERRY
Oxidation Reduction Potential 130.6 my 10/02/2013 EHGUERRY SM2580
Weather 2 other 10/02/2013 EHGUERRY
Water Temp 22.54 C 10/02/2013 EHGUERRY
Independent Laboratory Results: "GEL" - GEL Laboratories LLC - Lab ID # 10120; 'Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001
Qualifiers: U-Value below MDL; H-HDldin xce e ; aalue is Estimated; M-Matrix Interference
Analysis Validated:

�r One Riox 294 1 Drive
c n+ P.O. Box 2946101
Ja I Lee cwper Moncks Corner, SC 29461-2901
[phone]
ANALYTICAL & BIOLOGICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AC53949 Location: Waccamaw River Oxbow Date: 09/26/2013 Sample Collector: CM/EG
Loc. Code WAC_OX Time: 11:34
Analysis Result QUAL Units Test Date Analyst Method
Air Temp 23 C 10/0212013 EHGUERRY
Arsenic - MS <2.5 J ug/L 10/08/2013 TESTAMERICA EPA 200.8
Arsenic -Dissolved <2.5 U ug/L 10/08/2013 TESTAMERICA EPA200.8
Collection Depth 0.3 m 10/02/2013 EHGUERRY
Field Conductivity 113 us 10/02/2013 EHGUERRY
Field pH 6.32 SU 10/02/2013 EHGUERRY
Flow Not Required cfs 10107/2013 JMDAVIS
Gauge heigh Not Required ft 10/07/2013 JMDAVIS
Oxidation Reduction Potential 136.0 my 10/02/2013 EHGUERRY SM2580
Weather 2 other 10/02/2013 EHGUERRY
Water Temp 23.41 C 10/02/2013 EHGUERRY
Independent Laboratory Results: "GEL" - GEL Laboratories LLC - Lab ID # 10120; 'Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001
Qualifiers: U-Value below MDL; H-Hoi�grrime Exceded; J-V eis Estimated; M-Matrix Interference
Analysis Validated:

One Rivenvood Drive
�Sj pp��,,ppyy !� P.O. Box 2946101
V*santes Cooper Moncks Corner, SC 29461-2901
[phone]
ANALYTICAL & BIOLOGICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AC53950 Location: Waccamaw River Monitoring Date: 09/26/2013 Sample Collector: CM/EG
Loc. Code WRMW_5 Well Time: 11:44
Analysis Result QUAL Units Test Date Analyst Method
Air Temp 23 C 10/02/2013 EHGUERRY
Arsenic- MS <2.5 J ug/L 10/08/2013 TESTAMERICA EPA 200.8
Arsenic - Dissolved <2.5 J ug/L 10/08/2013 TESTAMERICA EPA 200.8
Collection Depth 0.3 m 10/02/2013 EHGUERRY
Field Conductivity 113 us 10/02/2013 EHGUERRY
Field pH 6.36 Su 10/02/2013 EHGUERRY
Flow 1410 cis 10/03/2013 CWMOORER
Gauge heigh 7.22 ft 10/03/2013 CWMOORER
Oxidation Reduction Potential 139.3 my 10/02/2013 EHGUERRY SM2580
Weather 2 other 10/02/2013 EHGUERRY
Water Temp 23.39 C 10/02/2013 EHGUERRY
Independent Laboratory Results: "GEL" - GEL Laboratories LLC - Lab ID # 10120; 'Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001
Qualifiers: U-Value below MDL; H-Holding T' xceded; J- alue is Estimated; M•Matrix Interference
Analysis Validated:�� \�

One Riverwood Drive
�� yy �}pyy� ry/� P.O. Box 2946101
sa tee cooper Moncks Corner, SC 29461-2901
[phone]
ANALYTICAL & BIOLOGICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AC53951 Location: Waccamaw River Monitoring Date: 09/26/2013 Sample Collector: CM/EG
Loc. Code WRMW Well 4R Time: 11:50
Analysis
Result QUAL
Units
Test Date
Analyst
Method
Air Temp
23
C
10/02/2013
EHGUERRY
Arsenic - MS
<2.5 J
ug/L
10/08/2013
TESTAMERICA
EPA 200.8
Arsenic - Dissolved
<2.5 U
ug/L
10/08/2013
TESTAMERICA
EPA 200.8
Collection Depth
0.3
m
10/02/2013
EHGUERRY
Field Conductivity
113
us
10102/2013
EHGUERRY
Field pH
6.28
SU
10/02/2013
EHGUERRY
Flow
1410
ofs
10/03/2013
CWMOORER
Gauge heigh
7.22
ft
10/03/2013
CWMOORER
Oxidation Reduction Potential
140.1
my
10/02/2013
EHGUERRY
SM2580
Weather
2
other
10/02/2013
EHGUERRY
Water Temp
23.36
C
10/02/2013
EHGUERRY
Independent Laboratory Results: "GEL"- GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001
Qualifiers: U-Value below MDL; H-Holding Ti�xceded; J- /e is Estimated; M•Matrix Interference
Analysis Validated:

santee cooper
Sample # AC53952 Location
Loc. Code WRMW_3R
ANALYTICAL & BIOLOGICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Waccamaw River Monitoring Date: 09/26/2013
Well
Time: 11:53
One Rivemood Drive
P.O. Box 2946101
Moncks Corner, SC 29461-2901
[phone]
Sample Collector: CM/EG
Analysis
Result QUAIL
Units
Test Date
Analyst
Method
Air Temp
23
C
10102/2013
EHGUERRY
Arsenic - MS
<2.5 J
ug/L
10/08/2013
TESTAMERICA
EPA200.8
Arsenic - Dissolved
<2.5 J
ug/L
10/08/2013
TESTAMERICA
EPA 200.8
Collection Depth
0.3
m
10/02/2013
EHGUERRY
Field Conductivity
114
us
10/02/2013
EHGUERRY
Field pH
6.32
SU
10/02/2013
EHGUERRY
Flow
1540
cfs
10/03/2013
CWMOORER
Gauge heigh
7.15
ft
10/03/2013
CWMOORER
Oxidation Reduction Potential
126.1
my
10/02/2013
EHGUERRY
SM2580
Weather
2
other
10/02/2013
EHGUERRY
Water Temp
23.51
C
10/02/2013
EHGUERRY
Independent Laboratory Results: "GEL" - GEL Laboratories LLC - Lab ID # 10120; 'Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001
Qualifiers: U-Value below MDL; H-Holding Time E ed; J-Value is stimated; M-Matrix Interference
Analysis Validated:

One Riverwood Drive
s,antLG Cooper Moncksx orner, 1
i-1 G Lhl 1 Moncks Corner, SG 29461-2901
[phone]
ANALYTICAL & BIOLOGICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AC53953 Location: Upper Waccamaw River Date: 09/26/2013 Sample Collector: CM/EG
Loc. Code WAC UP Time: 12:14
Analysis
Result QUAL
Units
Test Date
Analyst
Method
Air Temp
24
C
10/02/2013
EHGUERRY
Arsenic - MS
<2,5 i
ug/L
10/08/2013
TESTAMERICA
EPA200.8
Arsenic - Dissolved
<2,5 U
ug/L
10/08/2013
TESTAMERICA
EPA 200.8
Collection Depth
1.3
m
10/02/2013
EHGUERRY
Field Conductivity
116
us
10/02/2013
EHGUERRY
Field pH
6.26
SU
10/02/2013
EHGUERRY
Flow
1580
cfs
10/03/2013
CWMOORER
Gauge heigh
7.09
It
10/03/2013
CWMOORER
Oxidation Reduction Potential
126.4
my
10/02/2013
EHGUERRY
SM2580
Weather
2
other
10/02/2013
EHGUERRY
Water Temp
23.53
C
10102/2013
EHGUERRY
Independent Laboratory Results: "GEL"- GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc.- Lab ID# 98001
Qualifiers: U-Value below MDL; H-Holding Time Exgetl�--Value i stimated; M•Matrix Interference
Analysis Validated:

-qCantee Cooper'
CERTIFIED MAIL
March 1, 2016
SCDHEC
Bureau of Water/Water Pollution Control Division
Data and Records Management Section
2600 Bull Street
Columbia, South Carolina 29201
To whom it may concern:
Re: Santee Cooper Grainger Generating Station, Horry County
NPDES Permit# SC0001104
NPDES Groundwater Semi-annual Report for 2015-Addendum
When the site was sampled November 2-5, 2015, two of the wells, GGSMW-10 and GGSMW-3,
and the three piezometers at the site, PZ-1 through PZ-3, were inaccessible due to remaining
floodwaters from the 1000-year flood in early October 2015.
The two wells, both located on Ash Pond 1, were sampled on December 8, 2015, but, the three
piezometers, located near Ash Pond 2, were still under water. Attached are the laboratory results
and an updated arsenic concentration map.
The next groundwater sampling event is scheduled for April 4, 2016.
If you have any questions or comments concerning this project, please contact Melanie D.
Goings, P.G., at [phone] extension 4490.
Sincerely,
n W. Jack n, PE
Manager
CCP & Waste Management
Ok
SWJ:DBB:MDG: cgb
One Riverwood Drive I Moncks Corner, SC 29461-2901 1 [phone] 1 P.O. Box 2946101 I Moncks Corner, SC 29461-6101

Attachments
cc w/attachments:
Mr. Chris Forrest
Groundwater Protection Section
SCDHEC
Bureau of Water
2600 Bull Street
Columbia, South Carolina 29201
Mr. Gary Stewart
State Voluntary Cleanup Section
SCDHEC
Bureau of Land and Waste Management
2600 Bull Street
Columbia, SC 29201

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"santee cooper
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD37435 Location: GW Well GGSMW-3 Date: 12/08/2015
Loc. Code GGSMW-3 Time: 12:15
One Rivenvood Dnve
P.O. Box 2946101
Monks Comer, SC 29461-2901
(8431761-8000
Sample Collector: MDG
Analysis
Result DUAL
Units
Test Date
Analyst
Arsenic
198.4
ug/L
12/17/2015
KLMORAN
Arsenic -Dissolved
112.821
ug/L
12/17/2015
KLMORAN
Barium
85.2
ug/L
12/17/2015
KLMORAN
Cadmium
<5
ug/L
12/17/2015
KLMORAN
Chloride
6.61
mg/L
12/09/2015
LCWILLIA
Spec. Cord.
191
us
12/08/2015
MDGOINGS
Chromium
<5
ug/L
12/17/2015
KLMORAN
Copper
<10
ug/L
12/17/2015
KLMORAN
Depth
3.03
Feet
12/08/2015
MDGOINGS
Elevation
3.69
Feet
12/08/2015
MDGOINGS
Iron
3682.4
ug/L
12/17/2015
KLMORAN
Oxidation Reduction Potential
172
my
12/08/2015
MDGOINGS
Lead
<10
ug/L
12/17/2015
KLMORAN
pH
6.5
SU
12108/2015
MDGOINGS
Selenium
<10
ug/L
12/17/2015
KLMORAN
Sulfate
8.85
mg/L
12/09/2015
LCWILLIA
Total Dissolved Solids
240.0
mg/L
12/10/2015
AJBROWN
Temp
17.85
C
12/08/2015
MDGOINGS
Thallium
<1.0 U
ug/L
12/18/2015
TESTAMERICA
Total Suspended Solids
8.50
mg/L
12/10/2015
AJBROWN
Turbidity
9.1
NTU
12/08/2015
MDGOINGS
Zinc
61.8
ug/L
12/17/2015
KLMORAN
Independent Laboratory Results: "GEL' - GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001;
"DavisBrown"- Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
Analysis Validated: r
Debra K. Guerry - Supervisor, Analytical Services
Method
EPA 200.7
EPA200.7
EPA 200.7
EPA200.7
EPA 300.0
EPA200.7
EPA200.7
EPA 200.7
SM2580
EPA 200.7
EPA 200.7
EPA 300.0
SM 2540C
EPA 200.7 / 6010
SM 2540D
EPA 2003

santee cooper
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD37436 Location: GW Well GGSMW-10 Date: 12/08/2015
Loc. Code GGSMW-10 Time: 13:43
One Rivemood Drive
P.O. Box 2946101
Moncks Corner, SC 29461-2901
[phone]
Sample Collector:
Analysis
Result QUAL
Units
Test Date
Analyst
Arsenic
558.9
ug/L
12/17/2015
KLMORAN
Arsenic - Dissolved
188.010
ug/L
12/17/2015
KLMORAN
Barium
401.3
ug/L
12/17/2015
KLMORAN
Cadmium
<5
ug/L
12/17/2015
KLMORAN
Chloride
24.3
mg/L
12/09/2015
LCWILLIA
Spec, Cond.
1060
us
12/08/2015
MDGOINGS
Chromium
<5
ug/L
12/17/2015
KLMORAN
Copper
<10
ug/L
12/17/2015
KLMORAN
Depth
5
Feet
12/08/2015
MDGOINGS
Elevation
3.92
Feet
12/08/2015
MDGOINGS
Iron
61180.6
ug/L
12/17/2015
KLMORAN
Oxidation Reduction Potential
-17
my
12/08/2015
MDGOINGS
Lead
<10
ug/L
12/17/2015
KLMORAN
pH
6.09
SU
12/08/2015
MDGOINGS
Selenium
<10
ug/L
12/1712015
KLMORAN
Sulfate
87.1
mg/L
12/09/2015
LCWILLIA
Total Dissolved Solids
572.5
mg/L
12/10/2015
AJBROWN
Temp
18.1
C
12108/2015
MDGOINGS
Thallium
<1.0 U
ug/L
12/18/2015
TESTAMERICA
Total Suspended Solids
18.79
mg/L
12/10/2015
AJBROWN
Turbidity
43.4
NTU
12/08/2015
MDGOINGS
Zinc
20.2
ug/L
12/17/2015
KLMORAN
Independent Laboratory Results: "GEL" -GEL Laboratories LLC -Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. -Lab ID# 98001;
"DavisBrown"- Davis & Brown Lab ID # 21117;'Shealy'- Shealy,* Environmental Services, Inc.- Lab ID# 32010
Analysis Validated:
Debra K. Guerry - Supervisor, Analytical Services
MDG
Method
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 300.0
EPA 200.7
EPA 200.7
EPA 200.7
SM2580
EPA 200.7
EPA 200.7
EPA 300.0
SM 2540C
EPA 200.7 / 6010
SM 2540D
EPA 200.7

`psantee Cooper`
CERTIFIED MAIL
November 24, 2015
Mr. Chris Forrest
Groundwater Protection Section
SCDHEC
Bureau of Water
2600 Bull Street
Columbia, South Carolina 29201
Mr. Gary Stewart
State Voluntary Cleanup Section
SCDHEC
Bureau of Land and Waste Management
2600 Bull Street
Columbia, SC 29201
Dear Mr. Forrest:
Re: South Carolina Public Service Authority
Santee Cooper Grainger Generating Station, Horry County
NPDES Permit# SC0001104
NPDES Groundwater Semi-annual Report for 2015
Attached are results from the November 2-5, 2015 groundwater and surface water sampling
event. Separate maps showing sampling locations and arsenic concentrations are included.
Two of the wells, GGSMW-10 and GGSMW-3, both located on Ash Pond 1, and the three
piezometers, located near Ash Pond 2, were inaccessible due to remaining floodwaters from the
1000-year flood in early October 2015. Several photographs are attached. These sites will be
monitored as soon as the floodwaters retreat and the wells can be safely accessed. The results
will be reported as a separate transmittal.
Lab results showed measurable concentrations of arsenic in four of the sixteen locations where
water samples were analyzed. One was a groundwater well along the down gradient edge of Ash
Pond 1 and three were groundwater wells along the down gradient edge of Ash Pond 2.
An arsenic concentration map is provided to show the distribution of data points across the site.
Non -detectable results in the river, the intake canal, and most of the groundwater wells prevent
the use of isoconcentration lines. Ongoing ash removal activities, which began on March 17,
2014, will cause the groundwater geochemistry to fluctuate.
One Riverwood Drive I Monks Corner, SC 29461-2901 1 [phone] 1 P.O. Box 2946101 I Moncks Corner, SC 29461-6101

Mr. Chris Forrest— SCDHEC
November 24, 2015
Page 2
If you have any questions or comments concerning this project, please contact Melanie D.
Goings, P.G., at [phone] extension 4490.
Sincerely,
Susan W. Jackson, PE
Manager
CCP & Waste Management
SWJ: B:MDG: cgb
Attachments
cc w/attachments:
Frank S. Holleman, III, Esq
Southern Environmental Law Center
601 W. Rosemary Street, Suite 220
Chapel Hill, North Carolina 27516

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NPDES Groundwater Monitoring
Potentiometric Map
November 2015
Groundwater Contour Interval
23 Groundwater Elevation (feet)
Well ID TOC GW GW
Elevation Depth Elevation
(feet) (feet) (feet)
MW-1 13.32 9.51 3.81
M W-2 11.06 3.32 7.74
MW-3 6.72 NA
MW-4 12.01 12.01 0
MW-5 9.09 4.15 4.94
MW-6 8.19 4.75 3.44
MW-12 14.9 9.49 5.41
MW-9 8.24 2.95 5.29
MW-10 8.92 NA
MW-11 9.63 4.36 5.27
PZ-1 6.66 NA
PZ-2 6.82 NA
PZ-3 7.25 NA
Water levels collected on November 2, 2015.
However, due to the 1000-year flood, several wells
and piezometers were inaccessible (NA).
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"santee cooper
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34595 Location: GW Well GGSMW-1 Date: 11/02/2015
Loc. Code GGSMW-1
Time: 13:40
One Rivera ood Drive
P.O. Box 2946101
Monks Corner, SC 29461-2901
[phone]
Sample Collector:
Analysis
Result QUAL
Units
Test Date
Analyst
Arsenic
<10
ug/L
11/12/2015
KLMORAN
Arsenic -Dissolved
<10
ug/L
11/12/2015
KLMORAN
Barium
73.2
ug/L
11/12/2015
KLMORAN
Cadmium
<5
ug/L
11/12/2015
KLMORAN
Chloride
6.25
mg/L
11/04/2015
LCWILLIA
Spec. Cond.
168
us
11/02/2015
MDGOINGS
Chromium
<5
ug/L
11/1212015
KLMORAN
Copper
<10
ug/L
11112/2015
KLMORAN
Depth
9.51
Feet
11/02/2015
MDGOINGS
Elevation
3.81
Feet
11/02/2015
MDGOINGS
Iron
148873.0
ug/L
11/16/2015
KLMORAN
Oxidation Reduction Potential
2
my
11/02/2015
MDGOINGS
Lead
<10
ug/L
11/12/2015
KLMORAN
pH
5.93
Su
11/02/2015
MDGOINGS
Selenium
<10
ug/L
- 1111212015
KLMORAN
Sulfate
843
mg/L
11/04/2015
LCWILLIA
Total Dissolved Solids
1416
mg/L
11/11/2015
AJBROWN
Temp
22.53
C
11/02/2015
MDGOINGS
Thallium
<1.0 U
ug/L
11/13/2015
TESTAMERICA
Total Suspended Solids
16.35
mg/L
11/11/2015
AJBROWN
Turbidity
0
NTU
11/02/2015
MDGOINGS
Zinc
62.4
ug/L
11/12/2015
KLMORAN
Independent Laboratory Results: "GEL" - GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001;
"DavisBrown "- Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
Analysis Validated:
Debra K. Guerry - Supervisor, Analytical. Services
Method
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 300.0
EPA 200.7
EPA 200.7
EPA 200.7
SM2580
EPA 200.7
EPA 200.7
EPA 300.0
SM 2540C
EPA 200.7 / 6010
SM 2540D
EPA 200.7

SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34596 Location: GW Well GGSMW-2 Date: 11/02/2015
Loc. Code GGSMW-2 Time: 14:25
One Riverxood Drive
P.O. Box 2946101
MonChs Comer, SC 29461-2901
[phone]
Sample Collector:
Analysis
Result QUAL
Units
Test Date
Analyst
Arsenic
<10
ug/L
11/12/2015
KLMORAN
Arsenic -Dissolved
<10
ug/L
11/1212015
KLMORAN
Barium
59.9
ug/L
11/1212015
KLMORAN
Cadmium
<5
ug/L
11/12/2015
KLMORAN
Chloride
5.15
mg/L
11/04/2015
LCWILLIA
Spec. Cond.
339
us
11/02/2015
MDGOINGS
Chromium
<5
ug/L
11/12/2015
KLMORAN
Copper
<10
ug/L
11/12/2015
KLMORAN
Depth
3.32
Feet
11/02/2015
MDGOINGS
Elevation
7.74
Feet
11/02/2015
MDGOINGS
Iron
3601.4
ug/L
11/12/2015
KLMORAN
Oxidation Reduction Potential
-61
my
11102/2015
MDGOINGS
Lead.
<10
ug/L
11/12/2015
KLMORAN
pH
6.5
SU
11102/2015
MDGOINGS
Selenium
<10
ug/L
1111212015
KLMORAN
Sulfate
3.89
mg/L
1110412015
LCWILLIA
Total Dissolved Solids
206.0
mg/L
1111112015
AJBROWN
Temp
22.85
C
11/02/2015
MDGOINGS
Thallium
<1.0 U
ug/L
11/13/2015
TESTAMERICA
Total Suspended Solids
7.95
mg/L
11/11/2015
AJBROWN
Turbidity
16.7
NTU
11102/2015
MDGOINGS
Zinc
<10
ug/L
11/1212015
KLMORAN
Independent Laboratory Results: "GEL" - GEL Laboratories LLC - Lab ID # 10120, "Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001;
'DavisBrown"- Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
1 �7
Analysis Validated:
Debra K. Guerry - Supervisor, Analytical Services
Method
EPA 200.7
EPA200.7
EPA 200.7
EPA 200.7
EPA 300.0
EPA 200.7
EPA 200.7
EPA 200.7
SM2580
EPA 200.7
EPA 200.7
EPA 300.0
SM 2540C
EPA 200.7 / 6010
SM 2540D
EPA 200.7

One Rivenvoctl Drive
P.O. Box 2946101
santee cooper Moncks Comer, SC 29461-2901
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34598 Location: GW Well GGSMW-4 Date: 11/02/2015 Sample Collector:
Loc. Code GGSMW-4 Time: 15:52
Analysis
Result DUAL
Units
Test Date
Analyst
Arsenic
<10
ug/L
11/12/2015
KLMORAN
Arsenic - Dissolved
<10
ug/L
11/12/2015
KLMORAN
Barium
29.8
ug/L
11/12/2015
KLMORAN
Cadmium
<5
ug/L
11/12/2015
KLMORAN
Chloride
23.5
mg/L
11/04/2015
LCWILLIA
Spec. Cond.
288
us
11/02/2015
MDGOINGS
Chromium
<5
ug/L
11/1212015
KLMORAN
Copper
<10
ug/L
11/12/2015
KLMORAN
Depth
8.34
Feet
11/02/2015
MDGOINGS
Elevation
3.67
Feet
11/02/2015
MDGOINGS
Iron
21599.1
ug/L
11/12/2015
KLMORAN
Oxidation Reduction Potential
0
my
11/02/2015
MDGOINGS
Lead
<10
ug/L
11/12/2015
KLMORAN
pH
5.51
SU
11/02/2015
MDGOINGS
Selenium
10.5
ug/L
11/12/2015
KLMORAN
Sulfate
2.94
mg/L
11/04/2015
LCWILLIA
Total Dissolved Solids
228.0
mg/L
11/1112015
AJBROWN
Temp
19.7
C
11/02/2015
MDGOINGS
Thallium
<1.0 U
ug/L
11/1312015
TESTAMERICA
Total Suspended Solids
1.50
mg/L
11/11/2015
AJBROWN
Turbidity
0
NTU
11102/2015
MDGOINGS
Zinc
<10
ug/L
11112/2015
KLMORAN
Independent Laboratory Results; "GEL" -GEL Laboratories LLC -Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. -Lab ID# 98001;
"Davis Brown"- Davis & Brown Lab
�ID # 21117; 'Shealy"- Shealy Environmental Services, Inc. - Lab ID# 32010
Analysis Validated: �-
Debra K. Guerry - Supervisor, Analytical Services
Method
EPA 200.7
EPA200.7
EPA 200.7
EPA 200.7
EPA 300.0
EPA 200.7
EPA 200.7
EPA 200.7
SM2580
EPA 200.7
EPA 200.7
EPA 300.0
SM 2540C
EPA 200.7 / 6010
SM 2540D
EPA 200.7

One R,venvootl Dnve
/ ^ P.O. Box 2946101
Sal y'� ' lee cooper Monks Corner, SC 29461-2901
(843)761-B000
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34599 Location: GW Well GGSMW-5 Date: 11/03/2015 Sample Collector:
Loc. Code GGSMW-5 Time: 12:09
Analysis
Result QUAL
Units
Test Date
Analyst
Arsenic
11.9
ug/L
11112/2015
KLMORAN
Arsenic -Dissolved
14.4
ug/L
11/12/2015
KLMORAN
Barium
49.8
ug/L
11/12/2015
KLMORAN
Cadmium
<5
ug/L
11/12/2015
KLMORAN
Chloride
5.48
mg/L
11/06/2015
LCWILLIA
Spec. Cond.
354
us
11/03/2015
MDGOINGS
Chromium
<5
ug/L
1111212015
KLMORAN
Copper
<10
ug/L
11112/2015
KLMORAN
Depth
4.15
Feet
11/03/2015
MDGOINGS
Elevation
4.94
Feet
11/03/2015
MDGOINGS
Iron
4213.1
ug/L
11/12/2015
KLMORAN
Oxidation Reduction Potential
-112 -
my
11/03/2015
MDGOINGS
Lead
<10
ug/L
11/12/2015
KLMORAN
pH
5.66
SU
11103/2015
MDGOINGS
Selenium
<10
ug/L
11112/2015
KLMORAN
Sulfate
111
mg/L
11/06/2015
LCWILLIA
Total Dissolved Solids
263.0
mg/L
11/11/2015
AJBROWN
Temp
19.863
C
11/0312015
MDGOINGS
Thallium
<1.0 U
ug/L
11/13/2015
TESTAMERICA
Total Suspended Solids
<1.0
mg/L
11/1112015
AJBROWN
Turbidity
0
NTU
11/03/2015
MDGOINGS
Zinc
29.0
ug/L
11/12/2015
KLMORAN
Independent Laboratory Results: "GEL" -GEL Laboratories LLC -Lab ID # 10120;'Test America" - TestAmerica Laboratories, Inc - Lab ID# 98001;
"DavisBrown"- Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
;�.. �..LZ. ice-- •_% 'SCE .s,u(—�
Analysis Validated:
Debra K. Guerry - Supervisor, Analytical Services
Method
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 300.0
EPA 200.7
EPA 200.7
EPA 200.7
SM2580
EPA 200.7
EPA 200.7
EPA 300.0
SM 2540C
EPA 200.7 16010
SM 2540D
EPA 200.7

14 santee cooper
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34600 Location: GW Well GGSMW-6 Date: 11/02/2015
Loc. Code GGSMW-6
Time: 15:15
One Rivewood Drive
P.O. Box 2945101
Monks Corner, SC 29461-2901
Sample Collector:
Analysis
Result
QUAL Units
Test Date
Analyst
Arsenic
<10
ug/L
11/12/2015
KLMORAN
Arsenic -Dissolved
<10
ug/L
11/12/2015
KLMORAN
Barium
72.0
ug/L
11/12/2015
KLMORAN
Cadmium
<5
ug/L
11/12/2015
KLMORAN
Chloride
9.43
mg/L
11/04/2015
LCWILLIA
Spec. Cond.
928
us
11/02/2015
MDGOINGS
Chromium
<5
ug/L
11/12/2015
KLMORAN
Copper
<10
ug/L
11/12/2015
KLMORAN
Depth
4.75
Feet
11/02/2015
MDGOINGS
Elevation
3.44
Feet
11/02/2015
MDGOINGS
Iron
4521.7
ug/L
11/12/2015
KLMORAN
Oxidation Reduction Potential
-18
my
11/02/2015
MDGOINGS
Lead
<10
ug/L
11/12/2015
KLMORAN
pH
6.09
SU
1110212015
MDGOINGS
Selenium
11.2
ug/L
11/12/2015
KLMORAN
Sulfate
26.8
mg/L
11/04/2015
LCWILLIA
Total Dissolved Solids
651.0
mg/L
11/11/2015
AJBROWN
Temp
21.12
C
11/0212015
MDGOINGS
Thallium
<1.0
U ug/L
11/1312015
TESTAMERICA
Total Suspended Solids
3.95
mg/L
11/1112015
AJBROWN
Turbidity
0
NTU
11/02/2015
MDGOINGS
Zinc
<10
ug/L
11/1212015
KLMORAN
Independent Laboratory Results: "GEL" - GEL Laboratories LLC - Lab ID # 10120; "Test America' - TestAmerica Laboratories, Inc. - Lab ID# 98001;
"DavisBrown"- Davis & Brown Lab ID # 21117; "Shealy% Shealy Environmental Services, Inc.- Lab ID# 32010
Analysis Validated:
Debra K. Guerry - Supervisor, Analytical Services
Method
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 300.0
EPA 200.7
EPA 200.7
EPA 200.7
SM2580
EPA 200.7
EPA 200.7
EPA 300.0
SM 2540C
EPA 200.7 / 6010
SM 2540D
EPA 200.7

14pantee cooper
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34601 Location: GW Well GGSMW-9 Date: 11/02/2015
Loc. Code GGSMW-9 Time: 00:00
One R,ve.otl Drive
P.O. Box 2946101
Monks Comer, SC 29461-2901
Sample Collector:
Analysis
Result QUAL
Units
Test Date
Analyst
Arsenic
1241.3
ug/L
11/1212015
KLMORAN
Arsenic -Dissolved
1077.7
ug/L
11/12/2015
KLMORAN
Barium
49.3
ug/L
11112/2015
KLMORAN
Cadmium
<5
ug/L
11/12/2015
KLMORAN
Chloride
165
mg/L
11/06/2015
LCWILLIA
Spec. Cord.
1014
us
11/05/2015
MDGOINGS
Chromium
<5
ug/L
11/12/2015
KLMORAN
Copper
<10
ug/L
11112/2015
KLMORAN
Depth
2.95
Feet
11/05/2015
MDGOINGS
Elevation
5.29
Feet
11/05/2015
MDGOINGS
Iron
16768.3
ug/L
11/1212015
KLMORAN
Oxidation Reduction Potential
78
my
11/05/2015
MDGOINGS
Lead
<10
ug/L
1111212015
KLMORAN
pH
5A7
SU
11/05/2015
MDGOINGS
Selenium
<10
ug/L
11/1212015
KLMORAN
Sulfate
231
mg/L
11/0612015
LCWILLIA
Total Dissolved Solids
752.0
mg/L
11/11/2015
AJBROWN
Temp
20.91
C
11/05/2015
MDGOINGS
Thallium
<1.0 U
ug/L
11/13/2015
TESTAMERICA
Total Suspended Solids
4.10
mg/L
11/11/2015
AJBROWN
Turbidity
8.7
NTU
11/05/2015
MDGOINGS
Zinc
22.4
ug/L
11112/2015
KLMORAN
Independent Laboratory Results: "GEL" - GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001;
"DavisBrown"- Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
I jr
Analysis Validated:
Debra K. Guerry - Supervisor, Analytical Services
Method
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 300.0
EPA 200.7
EPA 200.7
EPA 200.7
SM2580
EPA 200.7
EPA 200.7
EPA 300.0
SM 2540C
EPA 200.7 / 6010
SM 2540D
EPA 200.7

One Riveiwood Drive
P.O. Box 2946101
Santee cooper Moncks Corner, SC 29461-2901
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34603 Location: GW Well GGSMW-11 Date: 11/03/2015 Sample Collector:
Loc. Code GGSMW-11 Time: 13:53
Analysis
Result QUAL
Units
Test Date
Analyst
Method
Arsenic
108.5
ug/L
11/12/2015
KLMORAN
EPA 200.7
Arsenic -Dissolved
43.3
ug/L
11/12/2015
KLMORAN
EPA 200.7
Barium
78.3
ug/L
11/12/2015
KLMORAN
EPA 200.7
Cadmium
<5
ug/L
11/12/2015
KLMORAN
EPA 200.7
Chloride
5.40
mg/L
11/04/2015
LCWILLIA
EPA 300.0
Si
545
us
11103/2015
MDGOINGS
Chromium
<5
ug/L
11/1212015
KLMORAN
EPA 200.7
Copper
<10
ug/L
11/12/2015
KLMORAN
EPA 200.7
Depth
4.36
Feet
11/03/2015
MDGOINGS
Elevation
5.27
Feet
11/03/2015
MDGOINGS
Iron
10171.5
ug/L
11/12/2015
KLMORAN
EPA 200.7
Oxidation Reduction Potential
-4
my
11/03/2015
MDGOINGS
SM2580
Lead
<10
ug/L
11/12/2015
KLMORAN
EPA200.7
1
6.24
Su
11/03/2015
MDGOINGS
Selenium
<10
ug/L
1111212015
KLMORAN
EPA 200.7
Sulfate
65.2
mg/L
11/04/2015
LCWILLIA
EPA 300.0
Total Dissolved Solids
347.0
mg/L
11/1112015
AJBROWN
SM 2540C
Temp
19.51
C
11/03/2015
MDGOINGS
Thallium
<1.0 U
ug/L
11/13/2015
TESTAMERICA
EPA 200.7/6010
Total Suspended Solids
16.08
mg/L
11/1112015
AJBROWN
SM 2540D
Turbidity
20
NTU
11103/2015
MDGOINGS
Zinc
44.1
ug/L
11/12/2015
KLMORAN
EPA 200.7
Independent Laboratory Results: "GEL" -GEL Laboratories LLC -Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. -Lab ID# 98001;
"DavisBrown"- Davis & Brown Lab ID # 21117; "Shealy°- Shealy Environmental Services, Inc- Lab ID# 32010
Analysis Validated: -
Debra K. Guerry - Supervisor, Analytical Services

14rantee cooper
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34604 Location: GW Well GGSMW-12 Date: 11/03/2015
Loc. Code GGSMW-12 Time: 11:19
One Rivewood Drive
P.O. Box 2946101
Monks Comer, SC 29461-2901
[phone]
Sample Collector:
Analysis
Result DUAL
Units
Test Date
Analyst
Arsenic
40.8
ug/L
11/12/2015
KLMORAN
Arsenic -Dissolved
46.5
ug/L
11/12/2015
KLMORAN
Barium
71.4
ug/L
11/1212015
KLMORAN
Cadmium
<5
ug/L
11/12/2015
KLMORAN
Chloride
5.73
mg/L
11/04/2015
LCWILLIA
Spec. Cond.
508
us
11/03/2015
MDGOINGS
Chromium
<5
ug/L
11/12/2015
KLMORAN
Copper
<10
ug/L
11/12/2015
KLMORAN
Depth
9,49
Feet
11/03/2015
MDGOINGS
Elevation
5.41
Feet
11/0312015
MDGOINGS
Iron
14070.7
ug/L
11/12/2015
KLMORAN
Oxidation Reduction Potential
-50
my
11/03/2015
MDGOINGS
Lead
<10
ug/L
11/1212015
KLMORAN
pH
5.89
SU
11/03/2015
MDGOINGS
Selenium
<10
ug/L
11112/2015
KLMORAN
Sulfate
138
mg/L
11/09/2015
LCWILLIA
Total Dissolved Solids
435.0
mg/L
11/11/2015
AJBROWN
Temp
21.32
C
11103/2015
MDGOINGS
Thallium
<1.0 U
ug/L
11113/2015
TESTAMERICA
Total Suspended Solids
<1.0
mg/L
11/11/2015
AJBROWN
Turbidity
0.3
NTU
11/0312015
MDGOINGS
Zinc
<10
ug/L
11112/2015
KLMORAN
Independent Laboratory Results: "GEL" - GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001;
"DavisBrown"- Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
Analysis Validated:
Debra K. Guerry - Supervisor, Analytical Services
Method
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 300.0
EPA 200.7
EPA 200.7
EPA 200.7
SM2580
EPA 200.7
EPA 200.7
EPA 300.0
SM 2540C
EPA 200.7 / 6010
SM 2540D
EPA 200.7

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One Rive vood Drive
P.O. Box 2946101
santee cooper Moneks Comer, SC 29461-2901
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34038 Location:
Loc. Code WAC_LOW
Lower Waccamaw River
Date: 10/26/2015
Time: 11:52
Sample Collector:
CM/EG
Analysis
Result QUAL
Units
Test Date
Analyst
Method
Air Temp
17
C
10/29/2015
CWMOORER
Arsenic
<3.0 u
ug/L
11/09/2015
TESTAMERICA
EPA 200.8
Arsenic - Dissolved
<3.0 u
ug/L
11/09/2015
TESTAMERICA
EPA 200.8
Collection Depth
2.25
m
10/29/2015
CWMOORER
Field Conductivity
59
us
10/29/2015
CWMOORER
Field pH
5.72
Su
10/29/2015
CWMOORER
Flow
4660
as
10/29/2015
CWMOORER
Gauge heigh
11.07
It
10/29/2015
CWMOORER
Oxidation Reduction Potential
205
my
10/29/2015
CWMOORER
SM2580
Weather
2
other
10/29/2015
CWMOORER
Water Temp
17.42
C
10/29/2015
CWMOORER
Independent Laboratory Results: "GEL" - GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001; "DavisBrown"-
Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
Analysis Validated: --�
Debra K. Guerry - Supervisor, Analytical Services

R,r,�} One Rivemood Dnve
Jca,1 1 Lee cooper Morcksx omen, t
I � l 1. cooper Moncks Cornea SC 29461-2901
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34039 Location: GGS Cooling Pond Date: 10/26/2015 Sample Collector: CM/EG
Loc. Code GGS_CP Time: 12:18
Analysis Result DUAL Units Test Date Analyst Method
Air Temp 17 C 10/29/2015 CWMOORER
Arsenic <3.0 U ug/L 11/09/2015 TESTAMERICA EPA 200.8
Arsenic - Dissolved <3.0 U ug/L 1110912015 TESTAMERICA EPA200.8
Collection Depth 0.3 m 10/29/2015 CWMOORER
Field Conductivity 58 us 10/29/2015 CWMOORER
Field pH 5.69 SU 10/29/2015 CWMOORER
Gauge heigh underwater ft 10/29/2015 CWMOORER
Oxidation Reduction Potential 201 my 10129/2015 CWMOORER SM2580
Weather 2 other 10/29/2015 CWMOORER
Water Temp 18.31 C 10/29/2015 CWMOORER
Independent Laboratory Results: "GEC' - GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001, "DavisBrowo"-
Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
Analysis Validated:
Debra K. Guerry - Supervisor, Analytical Services

One Rivenvood Drive
P.
B.
2946101
Santee cooper Mo ks Corner,S
Moncks Corner, SC 29461-2901
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34040 Location:
Loc. Code WAC_OX
Waccamaw River Oxbow
Date: 10/26/2015
Time: 12:42
Sample Collector:
CM/EG
Analysis
Result QUAL
Units
Test Date
Analyst
Method
Air Temp
17
C
10/29/2015
CWMOORER
Arsenic
<3.0 U
ug/L
11/09/2015
TESTAMERICA
EPA 200.8
Arsenic - Dissolved
<3.0 U
ug/L
11/09/2015
TESTAMERICA
EPA 200.8
Collection Depth
2.4
m
10/2912015
CWMOORER
Field Conductivity
59
us
10/2912015
CWMOORER
Field pH
5.45
SU
10/29/2015
CWMOORER
Oxidation Reduction Potential
219
my
10/29/2015
CWMOORER
SM2580
Weather
2
other
10/2912015
CWMOORER
Water Temp
17.46
C
10/29/2015
CWMOORER
Independent Laboratory Results: "GEL" - GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001; "DavisBrown"-
Davis & Brown Lab ID # 21117; "Shealy'-(rShealy Environmental Services, Inc: Lab ID# 32010
Analysis Validated: -
Debra K. Guerry - Supervisor, Analytical Services

One Riverxood Drive
n^ cooper
P.O. Box 2946101
14psai r� lt`G cooper Monks Corner, 5C 29461-2901
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34041 Location:
Ditch beside
HWY 501 off Date: 10/26/2015
Sample Collector:
CM/EG
Loc. Code 501 DITCH
_
Waccamaw
River
Time: 12:49
Analysis
Result
QUAL Units Test Date
Analyst
Method
Air Temp
17
C 10/29/2015
CWMOORER
Arsenic
<3.0
d ug/L 11/09/2015
TESTAMERICA
EPA 200.8
Arsenic -Dissolved
<3.0
J ug/L 11/09/2015
TESTAMERICA
EPA 200.8
Collection Depth
2.5
On 10/29/2015
CWMOORER
Field Conductivity
63
us 10/29/2015
CWMOORER
Field pH
5.79
Su 10/29/2015
CWMOORER
Gauge heigh
5.9
11 10/29/2015
CWMOORER
Oxidation Reduction Potential
186
my 10/29/2015
CWMOORER
SM2580
Weather
2
other 10/29/2015
CWMOORER
Water Temp
17.36
C 10/29/2015
CWMOORER
Independent Laboratory Results: "GEL" -GEL Laboratories LLC -Lab ID # 10120;"Test America"-TestAmerica Laboratories, Inc. -Lab ID# 98001; "DavisBrowB"-
Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
Analysis Validated:
Debra K. Guerry - Supervisor, Analytical Services

} One Rivenvood Drive
�antee cooper Moroks Corner,
1
JJC-1 lG IJVVt,Jiil Moncks Corner, SC 29461-2901
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34042 Location: Waccamaw River Monitoring Well Date: 10/26/2015 Sample Collector: CM/EG
Loc. Code WRMW_5 Time: 12:56
Analysis
Result DUAL
Units
Test Date
Analyst
Method
Air Temp
17
C
10/29/2015
CWMOORER
Arsenic
<3.0 U
ug/L
11/0912015
TESTAMERICA
EPA 200.8
Arsenic -Dissolved
<3.0 U
ug/L
11/09/2015
TESTAMERICA
EPA200.8
Collection Depth
1.7
,m
10/29/2015
CWMOORER
Field Conductivity
58
us
10/29/2015
CWMOORER
Field pH
5.48
SU
10/29/2015
CWMOORER
Flow
4750
cfs
10/29/2015
CWMOORER
Gauge heigh
11.05
It
10/29/2015
CWMOORER
Oxidation Reduction Potential
161
my
10/29/2015
CWMOORER
SM2580
Weather
2
other
10/2912015
CWMOORER
Water Temp
17.44
C
10129/2015
CWMOORER
Independent Laboratory Results: "GEL" -GEL Laboratories LLC -Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. -Lab ID# 98001;'DavisBrown"-
Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
Analysis Validated: i.
Debra K. Guerry - Supervisor, Analytical Services

One Rivenvood Drive
(i(1 cooper
P.O. Box 2946101
Santee COOper Monks Corner, SC 29461-2901
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34043 Location:
Loc. Code WRMW_4R
Waccamaw River Monitoring Well
Date: 10/26/2015
Time: 13:03
Sample Collector:
CM/EG
Analysis
Result DUAL
Units
Test Date
Analyst
Method
Air Temp
17
C
10/29/2015
CWMOORER
Arsenic
<3.0 U
ug/L
11/09/2015
TESTAMERICA
EPA 200.8
Arsenic -Dissolved
<3.0 U
ug/L
11/0912015
TESTAMERICA
EPA200.8
Collection Depth
1.7
m
10/29/2015
CWMOORER
Field Conductivity
59
us
10/29/2015
CWMOORER
Field pH
5.33
Su
10/29/2015
CWMOORER
Flow
4750
cfs
10/29/2015
CWMOORER
Gauge heigh
11.05
ft
10/29/2015
CWMOORER
Oxidation Reduction Potential
192
my
10/29/2015
CWMOORER
SM2580
Weather
2
other
10/29/2015
CWMOORER
Water Temp
17.45
C
10/29/2015
CWMOORER
Independent Laboratory Resufts: "GEL" - GEL Laboratories LLC - Lab ID # 10120, "Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001; "DavisBrown"-
Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
Analysis. Validated: !--
Debra K. Guerry - Supervisor, Analytical Services

One Rivenvood Drive
2946101
14pSanto cooper Mo ks Comer,S
�11I lCi cooper Moncks Corner, SC 29461-2901
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34044 Location:
Loc. Code WRMW_3R
Waccamaw River Monitoring Well
Date: 10/26/2015
Time: 13:07
Sample Collector:
CM/EG
Analysis
Result QUAL
Units
Test Date
Analyst
Method
Air Temp
17
C
10/29/2015
CWMOORER
Arsenic
<3.0 U
ug/L
11/09/2015
TESTAMERICA
EPA 200.8
Arsenic -Dissolved
<3.0 Ll
ug/L
11/09/2015
TESTAMERICA
EPA 200.8
Collection Depth
2.7
in
10/29/2015
CWMOORER
Field Conductivity
59
us
10/29/2015
CWMOORER
Field pH
5.31
SU
10/2912015
CWMOORER
Flow
4750
cfs
10/2912015
CWMOORER
Gauge heigh
11.05
It
10/29/2015
CWMOORER
Oxidation Reduction Potential
191
my
10/29/2015
CWMOORER
SM2580
Weather
2
other
10/29/2015
CWMOORER
Water Temp
17.45
C
10/29/2015
CWMOORER
Independent Laboratory Results: "GEL' - GEL Laboratories LLC - Lab ID # 10120;'Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001;'DavisBrown"-
Davis & Brown Lab ID # 21117; "Shealy"- Shealy Envvyirro�on"mentall, Services, Inc.- Lab ID# 32010
Analysis Validated:
Debra K. Guerry - Supervisor, Analytical Services

One Rive.... Dwe
Box 2946101
�antee cooper Mo ksCorner,S
Moncks Corner, SC 2946 L29m
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34045 Location:
Loc. Code WAC_UP
Upper Waccamaw River
Date: 10/2612015
Time: 13:21
Sample Collector:
CM/EG
Analysis
Result QUAL
Units
Test Date
Analyst
Method
Air Temp
17
C
10/29/2015
CWMOORER
Arsenic
<3.0 U
ug/L
1110912015
TESTAMERICA
EPA 200.8
Arsenic -Dissolved
<3.0 U
ug/L
11/09/2015
TESTAMERICA
EPA 200.8
Collection Depth
3.40
m
10/29/2015
CWMOORER
Field Conductivity
58
us
10/29/2015
CWMOORER
Field pH
5.29
SU
10/2912015
CWMOORER
Flow
4940
cis
10/29/2015
CWMOORER
Gauge heigh
11.06
ft
10/29/2015
CWMOORER
Oxidation Reduction Potential
213
my
10/29/2015
CWMOORER
SM2580
Weather
2
other
10129/2015
CWMOORER
Water Temp
17.47
C
10/29/2015
CWMOORER
Independent Laboratory Results: "GEL" - GEL Laboratories LLC -Lab ID # 10120, "Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001; "DavisBrown"-
Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
{jam
—�
Analysis Validated:
Debra K. Guerry - Supervisor, Analytical Services

From: Faulkner, Don <[e-mail]>
Sent: Wednesday, July 11, 2012 8:08 AM
To: Gates, Charlie <[e-mail]>
Bcc: c
Subject: Transitional units update
Cape Fear — No Safety, HPI, unit issues, or high risk work.
Unit 5 Status Online, Reduced to 130 NMW's due to elevated opacity, COA Submitted
Unit 6 Status Online, operating with throttle pressure lower to mitigate tube leaks, reduced
to 160 NMW,s, COA Submitted. Plans are to retire unit after evening peak Thursday to repair tube leak and be
back online Monday.
Lee & Riverbend — No Safety, HPI, unit issues, or high risk work.
All units in Reserve status, not issues EHS or other issues to report
Robinson Plant Status — No Safety, HPI, or high risk work.
Continue to work with ECC and Unit 2 (Nuclear) to manage Lake Temperatures for NPDES permit requirements.
Unit 1 Status Online, Reduced 5 MW's due to wet coal and operating with the XO heater
OOS.
Buck — No Safety, HPI, unit issues, or high risk work.
Unit 5 Status Off line on economy, unit may be required next Monday.
Unit 6 Status Off line on economy, unit may be required next Monday.
Environmental A fish kill was discovered yesterday afternoon along the bank of the creek that
feeds the "frog Pond" at Buck. Notification was made to Mooresville Office of NCDENR DWQ and to the NCWC
officer. DWQ did not indicate any further actions from us except that they requested. We monitor DO and PH
for a few days and to inform them if the fish kill increased. It is our SME's opinion that the Propylene Glycol spill
that occurred at the CC last week is the root cause of the kill. There were approximately 500 to 1000 dead small
sun fish along the bank. No enforcement action is anticipated based on the conversation with the personnel at
the Mooresville Office. (this was from the Combined Cycle site that occurred earlier in the week)
Dan River Status - No Safety, HPI, unit issues, or high risk work.
Decommissioning Meeting this week to review consultant's recommendations on
decommissioning
Duke-SEA-Meck-00343154

From: Mitchell, David F <David.Mitchell Dduke-energy.com>
Sent: Tuesday, April 5, 2011 10:34 AM
To: Herrick, Dayna J <Dayna.Herrickgduke-energy.com>
Subject: RE: Buck wastewater release
Thanks, let's make sure we don't tell the EM Director for the county and county manager that the cause of the
release was an operator on loan from Marshall Steam Station, who is inexperienced with Buck, made an
inadvertent, incorrect decision.
David Mitchell
Managing Director, Environmental
Ph: 704-382-6952
Cell: 704-773-6183
Fax: [phone]
................... ..................... ................... ...... ...............
From: Herrick, Dayna 3
Sent: Tuesday, April 05, 2011 9:59 AM
To: Mitchell, David F
Subject: Fw: Buck wastewater release
From: Zalme, Nob 3
Sent: Tuesday, April 05, 2011 07:09 AM
To: Stowe, Allen; Herrick, Dayna 3
Subject: FW: Buck wastewater release
fyi
Nob Za(nze
E9-IS Coordinator
IV uf�e Energy-Bucf�Steain Station
Office: [phone]
Ceff [phone]
From: Zalme, Nob 3
Sent: Tuesday, April 05, 2011 5:33 AM
To: Welch, Randy D; Culbert, Erin B
Cc: Townsend, Steve
Subject: RE: Buck wastewater release
Randy,
The amount of wastewater discharged through an unpermitted outfall is 8100 gallons. The cause of the release
was an operator on loan from Marshall Steam Station, who is inexperienced with Buck, made an inadvertent,
incorrect decision.
One of the powerhouse sump pumps has malfunctioned and parts have been ordered for repairs to be made.
The powerhouse sump discharges directly to the station yard sump, which discharges to the ash basin. In the
interim, a temporary pump was located at the sump with hoses routed to a storm drain outside of the
powerhouse, which drains to the station yard sump. This temporary operation allowed pooling of water
Duke-SEA-Meck-00585461

between the maintenance shop and warehouse.
An operator on loan from Marshall Steam Station evidently thought by routing the discharge to another drain, it
would eliminate pooling of water. He did not realize that the other drain flows through an oil trap tank, then to
the river. A Buck employee noticed the hose rerouted and switched it back to its original position, but not
before 30 minutes had elapsed. The Marshall employee was then provided guidance on the flow of the drainage
system.
An inexperienced operator should consult with his/her supervisor prior to making any changes in operation of
the plant.
I hope this helps. If you have any further questions, please let me know.
Nob
5Vb6 Zamme
LOS Coordinator
IDuf& Energy-Bucf�,Steaan Station
Office: [phone]
C'e!! [phone]
From: Welch, Randy D
Sent: Monday, April 04, 2011 5:13 PM
To: Culbert, Erin B
Cc: Townsend, Steve; Zalme, Nob 3
Subject: Re: Buck wastewater release
Erin,
Thanks for the information. I am very interested in the amount and cause. I would like to relay to the EM
Director for the county and county manager before this would be in the media if at all possible
Thanks
.................... ........ ...... ...... .. ..... .. ........ .....
From: Culbert, Erin B
Sent: Monday, April 04, 2011 04:43 PM
To: Media Relations
Cc: Stowe, Allen; Zalme, Nob 3; Welch, Randy D; Townsend, Steve
Subject: Buck wastewater release
We were notified today that the Buck Steam Station experienced a temporary wastewater release over the
weekend. We are still learning details about the volume released and other information. The wastewater did not
contain coal combustion byproducts or sanitary waste; it was water routed to the ash basin from the station
floor drains, which typically is process water from cooling motors, etc. As per state regulations, we will issue a
news release within 48 hours since the volume is more than 1,000 gallons. Initial estimates indicate we are
below the 15,000 gallon threshold for purchasing a legal ad for additional notification.
This would not have been visible to the public, but please refer media question to me should you receive any.
Thanks,
Duke-SEA-Meck-00585462

Erin
Erin Culbert, APR
Corporate Communications
Duke Energy
704.382.5723 office
704.200.4257 mobile
24-hour media line: 800.559,3853
[e-mail]
Duke-SEA-Meck-00585463

From: Newell, Jeff W <Jeff. Newell @duke -energy. com>
Sent: Wednesday, November 11, 2009 4:32 PM
To: David Weikle <[e-mail]>
Subject: FW: Buck Ash Qty. Graph
I just commented on deer loss. Bummer...
Nob did lower stop logs by 2 or 18 inches. T55 risk is low with next test in first week of Dec (but bug
flush today). This is to alleviate water from pond area where the north exit ramp from the pond collapsed
due to over saturation/seepage. This occurred on Tues and stopped trucks on a sunny day, which we can't
afford. This is why I wanted to mentioned challenges in my note because although we have caught volume
up, we still have major challenges.
From: David Weikle[mailto:[e-mail]]
Sent: Wednesday, November 11, 2009 4:18 PM
To: Newell, Jeff W
Subject: RE: Buck Ash Qty. Graph
Jeff, What's with the 5th comment?...Deer sank in pond. Is Nob actually going to lower the pond by two logs?
From: Newell, Jeff W [ma ilto:Jeff.Newel [e-mail]]
Sent: Wednesday, November 11, 2009 4:15 PM
To: Zalme, Nob J
Cc: Roberts, Greg; David Weikle; Keith Anthony
Subject: FW: Buck Ash Qty. Graph
See attached file. You are also aware of challenges:
RAIN recovery
• Sweaty ash and bridging in placement area.
• Bridging out of pond. Lowering of 2 stop logs should help. Thanks.
• Excavating ash from center strip of discharge channel.
• beer sank in pond.
See you soon. -Jeff
............................................................................................................................................................................................................................................
From: Mathis, Tony R
Sent: Tuesday, November 10, 2009 4:51 PM
To: Townsend, Steve; Whitehead, Robert J
Cc: Newell, Jeff W
Subject: FW: Buck Ash Qty. Graph
Reference latest excavation update. Good progress has been made over the past week to make up for the rain
delays, but unfortunately, the rains from Tropical Storm Ida may again force more delays in the excavation
work. We'll keep you posted.
From: Newell, Jeff W
Sent: Tuesday, November 10, 2009 12:39 PM
To: Mathis, Tony R
Cc: Ussery, Chris L; Horne, Jacob A EXHISfT
213
Duke-SEA-Meck-00324057

Subject: Fw: Buck Ash Qty. Graph
See attached file update for Buck Ash Project. 96,230 cy (nearly 50 percent complete) and 1.45 percent ahead of
production schedule... until the rains that are starting. Go, whoa, recover and go...! -Jeff
From: Jamie Lineberger <[e-mail]>
To: Newell, Jeff W
Sent: Mon Nov 09 18:47:17 2009
Subject: Buck Ash Qty. Graph
Jeff,
I have updated the qty. graph with today load count.
Duke-SEA-Meck-00324058

NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
NOTICE OF DEFICIENCY
June 13, 2014
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Duke Energy Corporation
Attention: Mr. Sean DeNeale, Engineer II
Environmental Services
Post Office Box 1006
Mail Code EC 13K
Charlotte, North Carolina 28201-1006
Duke Energy Corporation
Attention: Mr. John Elnitsky, Vice President
Project Management and Construction
Post Office Box 1007
Mail Code ST-28U
Charlotte, North Carolina 28201-1007
RE: Buck Steam Station Basin 1 to Basin 2 Dam
ROWAN-069 — High Hazard Potential
Yadkin — Pee Dee River Basin
Rowan County
Dear Mr. DeNeale and Mr. Elnitsky:
7011 1570 0000 0154 7432
7011 1570 0000 0154 7449
John E. Skvarla, III
Secretary
The "Dam Safety Law of I967," as amended, provides for the certification and inspection of dams in the
interest of public health, safety, and welfare, in order to reduce the risk of failure of such dams; to prevent
injuries to persons, damage to property; and to insure the maintenance of stream flows.
Our records indicate that you are the owner/and or responsible for the referenced dam, which is located off
Dukeville Road in Rowan County. On May 6, 2014, this Office received a digital copy of an internal
inspection of the spillway system for the referenced darn. This submittal was in response to an information
request issued by this Division on March 5, 2014, in which this Division requested that Duke Energy camera
inspect all facilities that have decant structures with corrugated metal,pipe (CMP) and concrete components.
The decant structure for this dam is comprised of a concrete riser with a concrete barrel.
A preliminary review of the camera inspection video of the decant structure and report has been performed
by personnel of the Land Quality Section for the referenced dam. The video documented a broken pipe
section at the 60.1 feet location, and additional cracks and infiltration stains.
Division of Energy, Mineral, and Land Resources
Land Quality Section - Mooresville Regional Office
610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115
Telephone: [phone] FAX: [phone] • Internet: http://portal.ncdenr,orglweb/Ir/land-quality
An Equal Opportunity I Affirmative Action Employer-- 50% Recycled 110% Post Consumer Paper

Duke Energy Corporation Buck Steam Station Basin I to Basin 2 Dam
June 13, 2014 ROWAN-069
Page 2 of 2
The condition of the decant structure appears serious enough to justify further engineering study in order to
determine appropriate remedial measures. Your dam is categorized as a "High Hazard" dam. In the event of
darn failure, significant environmental damage to the Yadkin River could occur due to release of coal ash
stored behind the dam.
In order to ensure the safety of this dam, you are directed to retain the services of a registered professional
engineer competent in the area of dam safety to review the internal video and provide a professional
assessment of the decant structure with regard to overall structural integrity and recommendations for repair.
Plans and specifications for repair based on the results of the study must be filed with the Division of Energy,
Mineral and Land Resources for approval pursuant to the North Carolina Administrative Code, Title 15A,
Subchapter 2D — Dam Safety (15A NCAC 2K). Please note any excavations in the dam or major repair work
to this dam must be approved by this Division before any work is done. Additionally, please note that this
dam may not be breached, meaning the dam may not be drained by cutting a notch in the dam, without prior
engineered breach plans being submitted to and approved by this Division.
Please submit a written response as quickly as possible, but no later than ten 10 days following
receipt of this Notice to advise us of your intended actions in this matter. This response must include a
schedule for repair plan development and implementation. If positive action is not taken within thirty
(30) days or before July 17, 2014, whichever term is longer, we shall present the case information for
appropriate enforcement action in accordance with North Carolina General Statute 143-215.36.
Enforcement action could include a civil penalty of up to $500.00 per day of violation, and/or issuance
of a Dam Safety Order requiring the repair or removal of this dam, and/or injunctive relief to gain
compliance.
Please notify this Office in writing if you wish to assert that you have no ownership or are otherwise not
responsible for maintenance or repairs to the subject dam. If you have an emergency situation during non -
office hours, you should notify 911 and the State Emergency Operations center at 1-[phone]. They
will notify the appropriate personnel in this office of the situation.
It is recommended that you or your engineer direct questions related to repair applications or the dam plan
review process to our dam safety staff at [phone]. All plans, specifications design data, and
calculations must be submitted to the State Dam Safety Engineer. If you have any questions regarding this
letter, please contact me at [phone]. Your cooperation and consideration in maintaining a safe dam is
appreciated.
Sincerely,
Zahid S. Khan, CPM, CPESC, CPSWQ
Regional Engineer
Land Quality Section
cc: Steven M. McEvoy, PE, State Dam Safety Engineer
cc: Water Quality Regional Operations Section

i
onmCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
NOTICE OF DEFICIENCY
June 13, 2014
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Duke Energy Corporation
Attention: Mr. Sean DeNeale, Engineer II
Environmental Services
Post Office Box 1006
Mail Code EC 13K
Charlotte, North Carolina 28201-1006
Duke Energy Corporation
Attention: Mr. John Elnitsky, Vice President
Project Management and Construction
Post Office Box 1007
Mail Code ST-28U
Charlotte, North Carolina 28201-1007
RE: Buck Steam Station Main Dam
ROWAN-047 — High Hazard Potential
Yadkin — Pee Dee River Basin
Rowan County
Dear Mr. DeNeale and Mr. Elnitsky:
7011 1570 0000 0154 7418
7011 1570 0000 0154 7425
John E. Skvarla, III
Secretary
The "Dam Safety Law of 1967," as amended, provides for the certification and inspection of dams
in the interest of public health, safety, and welfare, in order to reduce the risk of failure of such
dams; to prevent injuries to persons, damage to property; and to insure the maintenance of stream
flows.
Our records indicate that you are the owner/and or responsible for the referenced dam, which is
located off Dukeville Road in Rowan County. On May 6, 2014, this Office received a digital copy
of an internal inspection of the spillway system for the referenced dam. This submittal was in
Division of Energy, Mineral, and Land Resources
Land Quality Section - Mooresville Regional Office
610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115
Telephone: [phone] I FAX: [phone] • Internet: http://portal.ncdenr,org/web/Inland-quality
An Equal Opportunity 1 Affirmative Action Employer- 50% Recycled / 10% Post Consumer Paper

Duke Energy Corporation
June 13, 2014
Page 2 of 3
Buck Steam Station Main Dam
RO WAN-047
response to an information request issued by this Division on March 5, 2014, in which this Division
requested that Duke Energy camera inspect all facilities that have decant structures with corrugated
metal pipe (CMP) and concrete components. The decant structure for this dam is comprised of a
concrete riser with a CMP pipe barrel. The video was originally submitted to this Division on
December 10, 2013 with an engineered evaluation. The evaluation stated in part, "The 2013
condition of the pipe is similar to the previous condition in 2012. Thus, there is no change in the
conclusion that the pipe currently does not show signs of being in a critical condition for the
immediate future, but evidence that it is approaching the end of its safe performance life includes:
1) The age of the pipe; 2) the failing asphalt coating; 3) The rusted walls, and 4) The leaks (at two
locations) through walls between joints."
A preliminary review of the camera inspection video of the decant structure and report has been
performed by personnel of the Land Quality Section for the referenced dam. Comparison was made
between the submitted video and an internal inspection video of the discharge barrel submitted by
Duke Energy Corporation on January 27, 2011. The current video documented numerous
infiltration drippers and weeping locations. At approximate location 285.9, dripping has increased
to two locations, with increased flow in this area.
The condition of the decant structure appears serious enough to justify further engineering study in
order to determine appropriate remedial measures. Your dam is categorized as a "High Hazard"
dam. In the event of dam failure, significant environmental damage to the Yadkin River could
occur due to release of coal ash stored behind the dam.
In order to ensure the safety of this dam, you are directed to retain the services of a registered
professional engineer competent in the area of dam safety to review the internal video and provide a
professional assessment of the decant structure with regard to overall structural integrity and
recommendations for repair. Plans and specifications for repair based on the results of the study
must be filed with the Division of Energy, Mineral and Land Resources for approval pursuant to the
North Carolina Administrative Code, Title 15A, Subchapter 2D — Dam Safety (15A NCAC 2K).
Please note any excavations in the dam or major repair work to this dam must be approved by this
Division before any work is done. Additionally, please note that this dam may not be breached,
meaning the dam may not be drained by cutting a notch in the dam, without prior engineered breach
plans being submitted to and approved by this Division.
Please submit a written response as quickly as possible, but no Iater than ten 10 days
following receipt of this Notice to advise us of your intended actions in this matter. This
response must include a schedule for repair plan development and implementation. If
positive action is not taken within thirty (30) days or before July 17, 2014, whichever term is
longer, we shall present the case information for appropriate enforcement action in
accordance with North Carolina General Statute 143-215.36. Enforcement action could
include a civil penalty of up to S500.00 per day of violation, and/or issuance of a Dam Safety
Order requiring the repair or removal of this dam, and/or injunctive relief to gain
compliance.
Please notify this Office in writing if you wish to assert that you have no ownership or are otherwise
not responsible for maintenance or repairs to the subject dam. If you have an emergency situation

Duke Energy Corporation
June 13, 2014
Page 3 of 3
Buck Steam Station Main Dam
RO WAN-047
during non -office hours, you should notify 911 and the State Emergency Operations center at 1-
[phone]. They will notify the appropriate personnel in this office of the situation.
It is recommended that you or your engineer direct questions related to repair applications or the
dam plan review process to our dam safety staff at [phone]. All plans, specifications design
data, and calculations must be submitted to the State Dam Safety Engineer. If you have any
questions regarding this letter, please contact me at [phone]. Your cooperation and
consideration in maintaining a safe dam is appreciated.
Sincerely,
34JI-I P -S
9
4"
Zahid S. Khan, CPM, CPESC, CPSWQ
Regional Engineer
Land Quality Section
ec: Steven M. McEvoy, PE, State Dam Safety Engineer
cc: Water Quality Regional Operations Section

01,
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.......... ................... 'arld constructing a beffier tomorrow
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Duke-SEA-Meck-00232723

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Duke-SEA-Meck-00232724

36-inch CAVP P�pv-Buuk
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not a'Rnv<-,d. to tcs tho tha-, by ApHaEIS; or Wher means is not Immotical.
Duke-SEA-Meck-00232725

CVP Seg. isi Station Jfmwa-�"7 5, 24)., 1
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Page 4 of 4
ID u It E? -- S IE A - M e c It - 0 0 2 3 2 7 2 6

From: Russell, Tim <Tim.Russell2@duke- energy. com>
Sent: Friday, August 23, 2013 2:21 PM
To: DeNeale, Sean <[e-mail]>; Bray, Mike
<Mi ke.B ray@ duke- energy. com>
Cc: Beaver, Dean R <[e-mail]>; Neill, Monte W
<Monte.Neill@duke- energy. com>; Wooten, Dale <Dale.Wooten@duke-
energy.com>, Stowe, Allen <Al I en. Stowe@, duke- energy. com>
Subject: RE: Buck dewatering
1-foot per day is Duke's maximum rate to lower pool levels for stability purposes. TSS may dictate you lower the
level as a slower rate.
Tim Russell, P.E.
Geotechnical Leader
Central Engineering & Services
Duke Energy
[phone] - Office
[phone] - Mobile
From: DeNeale, Sean
Sent: Friday, August 23, 2013 2:18 PM
To: Russell, Tim; Bray, Mike
Cc: Beaver, Dean R; Neill, Monte W; Wooten, Dale; Stowe, Allen
Subject: RE: Buck dewatering
Mike, I'm not sure if you meant to say 1 foot per day...this seems like a very accelerated rate, as I've generally
heard we want to stick to around 1 foot per week.
Tim, what are your thoughts about the rate at which we can drop basin levels?
From: Bray, Mike
Sent: Friday, August 23, 2013 1:39 PM
To: Beaver, Dean R; Neill, Monte W
Cc: DeNeale, Sean; Wooten, Dale; Stowe, Allen
Subject: FW: Buck dewatering
Can we come up with a Plan dropping the #1 Ash Basin 1 foot per day. Talk to Opie, Shawn DeNeale and Allen
Stowe about doing this. We must get approval before we change anything. This was the way we did DR but a
couple of days we level in secondary pond was high so we waited.
Thanks Mike
From: Leap, Tom Y Jr
Sent: Friday, August 23, 2013 1:31 PM
To: Bray, Mike
Subject: FW: Buck dewatering
Duke-SEA-Meck-00286947

From: Ziegler, Ty [mailto:[e-mail]]
Sent: Friday, August 23, 2013 1:15 PM
To: Leap, Tom Y Jr
Cc: Taylor, Henry
Subject: Buck dewatering
Tom,
I asked Henry yesterday about the communication process for requesting a partial dewatering of the Buck New
Primary Ash Basin. Henry suggested that I start with you.
We'd like to lower the water surface elevation in the New Primary basin by approximately 5 ft to facilitate
geotechnical and environmental drilling. We need to start soon as my understanding is the general drawdown
protocol is a maximum of approximately 1 ft per week. At this time, our recommendation would be to not
increase the pond level — once lowered, but understand that will be a separate decision.
At this time, we are not requesting drawdown of the Old Primary or Secondary cells.
I also assume that we will need to notify/coordinate with Sean DeNeale (environmental) and Allen Stowe
(NPDES compliance).
Who at the station do we need to work with?
Thanks for any guidance.
Ty
TY ZIEGLER, P.E. HDR Engineering, Inc.
Environmental & Regulatory Manager, Hydropower Services
440 S Church Street, Suite 1000 1 Charlotte, NC 28202
704.248.3654 1 c: 704.516.2703
[e-mail] I hdrinc.com
Duke-SEA-Meck-00286948

From: Ziegler, Ty <[e-mail]>
Sent: Wednesday, August 28, 2013 9:04 AM
To: Wooten, Dale <[e-mail]>; Beaver, Dean R
<[e-mail]>; Bray, Mike <[e-mail]>;
Gardner, Maxie <Maxie.Gardner @ duke-energy.com>; Zalme, Nob J
<[e-mail]>; Brown, David R <David.Brown2@duke-
energy.com>; Stowe, Allen <[e-mail]>, Botkins, Henry A Jr
<Henry.Botkins@duke-energy. com>
Cc: Leap, Tom Y Jr <Tom.Leap@duke -energy.com>; Zarzar, Issa <Issa.Zarzar@duke-
energy.com>; Miller, Michael H <[e-mail]>; Neill, Monte W
<[e-mail]>; Cook, Mike M <[e-mail]>;
Russell, Tim <[e-mail]>; Stowe, Steve W <Steve.Stowe@duke-
energy.com>; Taylor, Henry <Henry. Taylor@duke-energy. com>; Miller, Bill
<Bill. Mill er@hdrinc. com>; Chrisman, Brian <[e-mail]>; Johnson,
Matthew <Matthew.Johns on @ hdrinc.com>
Subject: RE: Lowering Primary Ash Basin
All,
Thanks for the help in planning and coordinating the partial dewatering of the Primary Ash Basin at Buck. Removing
approximately 5 ft of water will greatly aid us in the geotechnical and environmental exploration (drilling).
HDR and our drilling sub -contractors (AE Drilling and SAEDACCO) are meeting Dean Beaver on site today to look at
access points and will begin the development of a drilling plan. Having the Primary Basin lowered by the end of
September should work well with the drilling schedule.
Henry previously scheduled a Buck Ash Basin Closure update meeting for today (mid -morning) and I know that many of
you were on the invite list. Dewatering activities would be a good agenda item.
Thanks again and talk to you soon.
Ty
TY ZIEGLER, P.E. HDR Engineering, Inc.
Environmental & Regulatory Manager, Hydropower Services
440 S Church Street, Suite 1000 1 Charlotte, INC 28202
704.248.3654 1 c: 704.516.2703
[e-mail] I hdrinc.com
From: Wooten, Dale [mailto:[e-mail]]
Sent: Wednesday, August 28, 2013 8:29 AM
To: Beaver, Dean R; Bray, Mike; Gardner, Maxie; Zalme, Nob J; Ziegler, Ty; Brown, David R; Stowe, Allen; Botkins, Henry
A Jr
Cc: Leap, Tom Y Jr; Zarzar, Issa; Miller, Michael H; Neill, Monte W; Cook, Mike M; Russell, Tim; Stowe, Steve W
Subject: RE: Lowering Primary Ash Basin
Allen,
You should have been copied on this note as well as Henry. Please advise if you have any problems with the below
schedule.
Thanks,
Duke-SEA-Meck-00217766

pale W OtP)r GSP
Certified Safety Professional ; Senior EHS Professional
Duke Energy; Buck CC / Buck Steam Station
1385 Dukeville Road, Salisbury, NC 28146
2: 704-630-3086 1 W: 704-202-2533 1 C: Dale.Wooten@_duke-energy.com
From: Beaver, Dean R
Sent: Wednesday, August 28, 2013 7:36 AM
To: Bray, Mike; Gardner, Maxie; Zalme, Nob J; '[e-mail]'; Wooten, Dale; Brown, David R
Cc: Leap, Tom Y Jr; Zarzar, Issa; Miller, Michael H; Neill, Monte W; Cook, Mike M; Russell, Tim; Stowe, Steve W
Subject: RE: Lowering Primary Ash Basin
Here is the plan for lowering the basin at Tower #1. We would like to remove the logs first thing each morning after the
pre -job brief. David Brown & Dale Wooten will monitor the water discharge at the other each tower and provide
guidance on Dewatering Plan. If needed we will modify this schedule to ensure the basins are settled between each
lowering. If there are any questions or concerns please let us know before this schedule is started.
Friday - 9/13/13 remove stop log to lower basin 9 Inches.
Weekend--9/14 and 9/15 settle out ash basin
Monday - 9/16/ 13 remove stop log to lower basin 9 Inches.
Tuesday — 9/17/13 settle out ash basin
Wednesday — 9/18/13 remove stop log to lower basin 9 Inches.
Thursday — 9/19/13 settle out ash basin
Friday — 9/20/13 remove stop log to lower basin 9 Inches.
Weekend 9/21 and 9/22 settle out ash basin
Monday 9/23/13 remove stop log to lower basin 9 Inches.
Tuesday 9/24/13 settle out ash basin
Wednesday 9/25/13 remove stop log to lower basin 9 Inches.
Thursday 9/26/13 settle out ash basin
Friday 9/27/13 remove stop log to lower basin 9 inches (Total drop of 5 feet 3 inches.)
Weekend 9/28 & 9/29 settle out ash basin.
..................................................................................................... ........................................................................................................................................... ...............
From: Bray, Mike
Sent: Tuesday, August 27, 2013 2:04 PM
To: Gardner, Maxie; Zalme, Nob J; '[e-mail]'; Wooten, Dale; Brown, David R
Cc: Leap, Tom Y Jr; Zarzar, Issa; Miller, Michael H; Beaver, Dean R; Neill, Monte W; Cook, Mike M; Russell, Tim; Stowe,
Steve W
Subject: RE: Lowering Primary Ash Basin
We will pull a log every other day. So Dean is changing schedule to match 9" every other day.
Thanks Mike
From: Gardner, Maxie
Sent: Tuesday, August 27, 2013 1:43 PM
To: Zalme, Nob J; Bray, Mike; '[e-mail]'; Wooten, Dale; Brown, David R
Cc: Leap, Tom Y Jr; Zarzar, Issa; Miller, Michael H; Beaver, Dean R; Neill, Monte W; Cook, Mike M; Russell, Tim; Stowe,
Steve W
Subject: Re: Lowering Primary Ash Basin
Afternoon Nob. Me trying to call you. Call me on my cell when you can...
From: Zalme, Nob J
Sent: Tuesday, August 27, 2013 09:13 AM
Duke-SEA-Meck-00217767

To: Bray, Mike; Ziegler, Ty <[e-mail]>; Wooten, Dale; Brown, David R; Gardner, Maxie
Cc: Leap, Tom Y Jr; Zarzar, Issa; Miller, Michael H; Beaver, Dean R; Neill, Monte W; Cook, Mike M; Russell, Tim; Stowe,
Steve W
Subject: RE: Lowering Primary Ash Basin
Fyi...I'm pretty sure the stop -logs in the discharge structures at cell 1 & cell 2 are 9" logs and cell 3 are 6" logs.
From: Bray, Mike
Sent: Monday, August 26, 2013 4:50 PM
To: Ziegler, Ty; Wooten, Dale; Brown, David R; Gardner, Maxie; Zalme, Nob J
Cc: Leap, Tom Y Jr; Zarzar, Issa; Miller, Michael H; Beaver, Dean R; Neill, Monte W; Cook, Mike M; Russell, Tim; Stowe,
Steve W
Subject: Lowering Primary Ash Basin
I have talked with Tim Russell and Alan Stowe and we are ok to start lowering the ash basin on 9/13/13. We plan on it
taking the ash pond down 1 foot and wait a day between removing stop logs. We will monitor water levels on all three
ash basins and look for any changes in the discharge. Dale Wooten and David Brown will be doing in process monitoring
during this process.
Here is the plan for lowering basin. We would like to remove the logs first think after pre job at the start of the morning
shift. If needed we will take whatever time needed to settle the basins between each lowering.
Friday - 9/13/13 remove stop logs to lower basin 1 foot.
Weekend--9/14 and 9/15 settle out ash basin
Monday - 9/16/ 13 remove stop logs to lower basin 1 foot
Tuesday — 9/17/13 settle out ash basin
Wednesday — 9/18/13 remove stop logs to lower basin
Thursday — 9/19/13 settle out ash basin
Friday — 9/20/13 remove stop logs to lower basin
Weekend 9/21 and 9/22 settle out ash basin
Monday 9/23/13 remove stop logs to lower basin
Tuesday and Wednesday 9/24 & 9/25 basin to settle at level needed.
After basin has been lowered, we will need to see plan telling us how and when you will be doing the drilling inside the
primary ash basin.
Thanks
hhannks p
i-INQE1, ('3Y
Manager Buck/Dan River
Plant Retirement and Demolition
Office [phone]
Cell [phone]
Mike. [e-mail]
Duke-SEA-Meck-00217768

From: Brooks, David M Jr <[e-mail]>
Sent: Tuesday, January 24, 2012 3:32 PM
To: Smith, Al <[e-mail]>, Botkins, Henry A Jr
<[e-mail]>; File, Brent P <Brent.File@duke-
energy.com>
Subject: FW: Buck CTCC - Ash Dike
Here is the latest on the Buck Ash dike breach. I have been tasked to work on the investigation. I talked to
Bobby Pratt about it today and the notification and contact with NCDENR is being handled by Tim Russell.
From: Brooks, David M Jr
Sent: Tuesday, January 24, 2012 11:43 AM
To: Herrick, Dayna J
Cc: Shuping, Todd; Zalme, Nob J
Subject: RE: Buck CTCC - Ash Dike
Dayna:
Tim Russell's note sums things up very well, but I contacted Bobby Pratt to answer your questions:
1. There was civil engineering performed on this job by Shaw, Bobby Pratt and others on the project but
they didn't know a NCDENR permit was required and that Tim or Alex had to review. When SM&E was
brought in again to do a slope stability analysis specific to the gate access they told Bobby that a
NCDENR permit was probably going to be required and that's when he brought in Tim Russell.
2. There was a stability analysis performed early in the project for some other site excavations near the
toe of the dam (prior to the TVA incident and the new rules for dams). No permits were required for
those excavations. They called SM&E back in to perform the slope stability and drainage analysis for the
gate access under the same assumptions.
Bobby Pratt, Shaw and SM&E are getting all of their documentation together at this time for Tim Russell or Alex
Papp to take to NCDENR to discuss this issue and get the dam permit. If you have any questions or need more
info, I recommend you talk to Bobby Pratt directly. I don't see me adding much value as a go between here. I
will make the appropriate entries to document the incident in eTrac as you directed.
Thanks,
DB
.............. ............._............ ..... ......... _................... ........ _ ..................
From: Herrick, Dayna J
Sent: Tuesday, January 24, 2012 9:57 AM
To: Brooks, David M Jr
Cc: Shuping, Todd
Subject: FW: Buck CTCC - Ash Dike
Tim's note below provides some insights into how we got to this place. Make sure you talk with Bobby Pratt
directly.
Duke-SEA-Meck-00376160

Dayna
............................................................................................. ...............................................................................................................................................
From: Russell, Tim
Sent: Tuesday, January 24, 2012 9:24 AM
To: Herrick, Dayna J
Subject: Re: Buck CTCC - Ash Dike
I think I've only scratched the surface as to why this issue did not go thru Program Engineering. First, when this
project began, NCUC was still the regulatory entity, and permits by DENR were not required. I gather Shaw was
still working under that presumption and engaged S&ME to evaluate their planned excavation into the dam to
facilitate the installation of the security gate.
During my discussion with Dave Waugh yesterday, Bobby Pratt (civil in Program Engineering, but not part of dam
safety) indicated that he and other project team members approved the gate location due to site limitations and
turn radius needed for trucks. Admittedly, Bobby said the excavation shown on Shaw's plans didn't seem to be
as steep as what is there now. In hindsight, he agrees he probably should have involved Alex and me given the
proposed excavation, but he didn't realize a permit was required and thought Shaw was operating in a manner
consistent with what had been done for previous project design phases (during NCUC tenure).
Hope this addresses your questions.
Tim Russell, PE
Senior Engineer
Program Engineering
Duke Energy
526 South Church Street
Charlotte, NC 28202
[phone]
[phone]
............................................................................................. ...............................................................................................................................................
From: Herrick, Dayna J
Sent: Tuesday, January 24, 2012 07:31 AM
To: Brooks, David M Jr
Cc: Russell, Tim; Shuping, Todd; Zalme, Nob J; Waugh, Dave
Subject: FW: Buck CTCC - Ash Dike
David,
Since the project team requested that you be their primary contact, please work with them to answer the
following questions:
1. Why was this work done without Program Engineering review and permit prior to the work?
2. Why was a stability analysis performed by a vendor without appropriate engagement by the Program
Engineering folks?
Make sure that this and whatever other information you can find goes into the database as "Other regulatory
non-compliance". Tim Russell or Alex Papp will be notifying DENR of the unpermitted activity and can be a
Duke-SEA-Meck-00376161

resource for your investigation. Give Nob a call and he can bring you up to speed on what he knows.
Day=
From: Zalme, Nob J
Sent: Monday, January 23, 2012 4:04 PM
To: Herrick, Dayna J
Subject: FW: Buck CTCC - Ash Dike
fyi
,T'o6 Zahne
EJfS Coordinator
Duke Energy-BuckSteam Station
Office: [phone]
Ce!C [phone]
From: Russell, Tim
Sent: Monday, January 23, 2012 9:17 AM
To: Zalme, Nob J
Subject: FW: Buck CTCC - Ash Dike
Tim Russell, P.E.
Senior Engineer
Program Engineering
Generation Engineering
Duke Energy
526 South Church Street
Charlotte, NC 28202
[phone] - Office
[phone] - Mobile
From: Russell, Tim
Sent: Monday, January 23, 2012 9:16 AM
To: Pratt, Bobby
Cc: Papp, Alex S
Subject: RE: Buck CTCC - Ash Dike
Bobby,
I presume the pipe and drainage issue is being addressed by Sells, so I'll address the issues involving dam safety.
In general, any ground disturbing work within the limits of the dam or alteration of associated appurtenances or
conduits (e.g. modification to the existing slope drain) require a permit from NCDENR Dam Safety. This also
includes any ground disturbing work beyond the toe of the dam that could affect drainage or stability
characteristics of the dam. Given the down -stream design grade of 2.5(H):1(V), it would appear that the
excavation completed for the gate could potentially affect the stability. I've attached the original design drawing
for this dam for reference. I understand Shaw had S&ME check the stability of this excavation, but this stability
calculation has not been provide to us for review. It should be noted that a minimum factor of safety of 1.5 is
the regulatory requirement for steady-state conditions. However, if the factor of safety after excavation is less
than the factor of safety prior to excavation, then Dam Safety would consider this excavation affects the stability
even if the resulting factor of safety met the minimum factor of safety requirement. Regardless, alteration of
Duke-SEA-Meck-00376162

the slope drain will require Dam Safety approval.
I've attached the procedure to repair/alter a dam per North Carolina 1967 Dam Safety Law. The permitting
process can take up to 60 days. The permit request application must include a construction schedule, design
drawings, material/product specifications, design data, and calculations prepared by a NC registered engineer
per section .0201 of NC GS 15A, Subchapter 2K. The design drawings need to include all_ modifications to the
dam, either temporary or permanent, and they typically include the following:
• Existing site plan to document current grades and site features;
• Proposed site plan to illustrate final planned grades and site features including any alterations to the
dam;
• Erosion and sediment control plan (this may not be needed as it could be considered part of the CTCC
construction); and
• Cross -sections and details.
I presume Shaw will prepare the application package. Dam Safety requires two copies of the application
package be submitted. We will review the package and submit it to Dam Safety under cover letter that
addresses other aspects of the submittal (i.e. emergency action plan, O&M manual, H & H analysis, etc.). This is
necessary so that we maintain the point of contact for Dam Safety.
Once the permit request submittal is approved by Dam Safety, they will issue a Certificate of Approval, at which
point, the work can proceed. Upon completion of the work, the registered engineer that prepared the submittal
package must review and approve the work and submit a certification letter along with two copies of as -built
drawings to Dam Safety. Dam Safety will then perform an inspection of the final conditions for approval.
I hope this summary helps.
Tim Russell, P.E.
Senior Engineer
Program Engineering
Generation Engineering
Duke Energy
526 South Church Street
Charlotte, NC 28202
[phone] - Office
[phone] - Mobile
From: Pratt, Bobby
Sent: Friday, January 20, 2012 3:18 PM
To: Russell, Tim
Subject: Buck CTCC - Ash Dike
Tim:
Attached are some pictures from the Buck CTCC project where the south gate is being installed. These pictures
are taken at the ditch between the entrance road and the extreme toe of the dike. To make room for the gate,
Shaw has cut into the slope and left a fairly steep cut face. They also installed the pad for the gate controls
across the ditch.
There are two main issues: the stability of the slopes and the proper function of the ditch.
Shaw has had surveys taken of the slopes and S&ME has performed stability analysis and all factors of safety are
Duke-SEA-Meck-00376163

above 1.5. However, the slopes will need to be laid back and properly protected.
For the ditch, Shaw installed a 12" pipe through the pad but it will not be sufficient for the anticipated flow.
Shaw is in the process of having Sells look at the drainage and determine the proper size pipe to handle the
flow. The new pipe will likely need to be routed around the concrete pad.
I'd like to discuss this with you Monday morning and get your thoughts.
Thanks,
Bobby
Duke-SEA-Meck-00376164

From: Herrick, Dayna J <[e-mail]>
Sent: Wednesday, January 25, 2012 12:31 PM
To: Mitchell, David F <David.Mitchell (duke-energy.com>
Subject: FW: Buck Station - New Dam — Additional Primary Basin (Rowan-068)
IVIA
q)ayna
............................................................................................. .................................................................................................................................................
From: Russell, Tim
Sent: Wednesday, January 25, 2012 11:17 AM
To: Waugh, Dave; Herrick, Dayna J; Zalme, Nob J; Pratt, Bobby
Cc: Townsend, Steve; Shuping, Todd; Niehaus, Robert A; Landseidel, Mark E; Brooks, David M Jr; Papp, Alex S
Subject: RE: Buck Station - New Dam — Additional Primary Basin (Rowan-068)
Folks,
Bobby Pratt and I had a telephone conversation with Andy Schneider, NCDENR's Assistant Dam Safety Engineer.
Andy indicated that he and Steve McEvoy (NCDENR's Dam Safety Engineer) would have preferred the gate
excavation adjacent to the additional primary basin dam to have been properly engineered and permitted prior
to executing the work. Since we were able to provide the S&ME engineering report that indicates acceptable
factors of safety against slope failure, Andy indicated there would not be any repercussions for the unpermitted
work. To alleviate some concern expressed by Andy about the relatively steep excavation slope, we indicated
large sized rip rap overlying a separation geotextile would be installed on the excavation slope face as soon as
possible as an interim measure to help protect against erosion and shallow sloughing. Additionally, Andy
indicated that any additional work would need to be addressed via engineered documents and submitted in a
permit request application to Dam Safety for approval. Andy recognized the urgency of this situation, and he
indicated an expedited two -week review turn -a -round time can be expected. This is the best possible outcome.
Their forgiveness of the unpermitted work and willingness to expedite the review process are a result of the
good relationship we've established with Dam Safety, and I hope to maintain that relationship going forward.
So, thanks in advance for everyone's participation in supporting me in that effort.
Going forward, I believe Bobby is working on arranging a meeting with Shaw, S&ME, and Sells to discuss the
tasks associated with this issue and Duke's expectations.
Tim Russell, P.E.
Senior Engineer
Program Engineering
Generation Engineering
Duke Energy
526 South Church Street
Charlotte, NC 28202
[phone] - Office
[phone] - Mobile
. _ .................. I ........ ...... ...... .. ..... .._ ...... .._ .....
From: Russell, Tim
Sent: Wednesday, January 25, 2012 8:02 AM
To: Waugh, Dave; Waugh, Dave; Zalme, Nob J; Pratt, Bobby
Cc: Townsend, Steve; Shuping, Todd; Niehaus, Robert A; Landseidel, Mark E; Brooks, David M Jr; Papp, Alex S
Subject: FW: Buck Station - New Dam — Additional Primary Basin (Rowan-068)
Duke-SEA-Meck-00585479

Folks,
Below is email correspondence I've exchanged with Dam Safety with regard to the gate excavation performed
by Shaw near the toe of the additional primary basin dam at Buck Station. I will provide an update subsequent
to the meeting with Dam Safety to summarize the results of the discussion. If there's anyone I've missed on this
email distribution, let me know so that I can include them on the summary email. Thanks.
Tim Russell, P.E.
Senior Engineer
Program Engineering
Generation Engineering
Duke Energy
526 South Church Street
Charlotte, NC 28202
[phone] - Office
[phone] - Mobile
From: Russell, Tim
Sent: Wednesday, January 25, 2012 7:50 AM
To: 'McEvoy, Steve'; Schneider, Andrew
Subject: RE: Buck Station - New Dam — Additional Primary Basin (Rowan-068)
Andy and Steve,
Attached is S&ME's stability analysis letter dated January 24, 2012 addressing the gate excavation at Buck
Station. In short, I've itemized the highlights in the list below:
• The existing embankment dam (New Dam of the Additional Primary Basin) was excavated near the toe
and appears to be inclined near 1(H):1(V) with a height of approximately 5 ft.
• A factor of safety for the downstream embankment (along the analysis section) was approximately 2
(2.06) for large (global) failure surfaces extending from near the dike crest to just beneath the gate
excavation area and exiting near the existing dike toe/roadway ditch.
• A factor of safety of approximately 1.7 (1.68) is obtained from an arc extending through the toe of the
gate excavation to near the inside corner of the first (lower) dike bench.
• By comparison, a similar profile section evaluated prior to the gate excavation exhibited a factors of
safety near 2 (2.07) for global stability and near 2.3 (2.28) for local stability of the south road excavation
slope.
• The factors of safety are considered acceptable for embankment stability for the static condition
evaluated, but the gate excavation sloped at near 1(H):1(V) will need to be addressed to prevent long
term erosion and sloughing issues.
Tim Russell, P.E.
Senior Engineer
Program Engineering
Generation Engineering
Duke Energy
526 South Church Street
Charlotte, NC 28202
[phone] - Office
[phone] - Mobile
From: McEvoy, Steve [mailto:[e-mail]]
Sent: Tuesday, January 24, 2012 4:37 PM
To: Schneider, Andrew
Cc: Russell, Tim
Subject: FW: Buck Station - New Dam — Additional Primary Basin (Rowan-068)
Duke-SEA-Meck-00585480

Andy:
Please review and advise me on this. We'll then schedule a meeting with Tim. Thanks
Steven M. McEvoy, PE
State Dam Safety Engineer
NC Land Quality Section
1612 Mail Service Center
Raleigh, NC 27699-1612
Office: [phone] ext. 711
[e-mail]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties.
From: Russell, Tim [mailto:[e-mail]]
Sent: Tuesday, January 24, 2012 2:46 PM
To: McEvoy, Steve
Cc: Schneider, Andrew
Subject: Buck Station - New Dam — Additional Primary Basin (Rowan-068)
Steve,
As you know, Shaw is constructing a new combined cycle gas power plant downstream of the additional primary
basin at Buck Station. Apparently, Shaw has excavated adjacent to the downstream side of the dam toe to
install a security gate and transformer pad. The current extent of the gate excavation does not extend to within
the footprint of the dam. However, it would appear that the excavation completed for the gate could
potentially affect the local stability of the toe. I have attached four PDF files for your reference. File BUK00-CV-
C-GR.PL-50-1.pdf depicts the location of the gate and the planned gate excavation contours. File BUKOC-CV-C-
GR.PL-04-2.pdf is a larger view of this area to better depict the gate location relative to the dam. File 3039-d-
02.pdf is the original design drawing of the dam. File IMG_3686.pdf is a picture of the excavation.
Shaw engaged S&ME to perform a stability analysis. The final stability report should be complete sometime this
week, but conversations with Larry Armstrong (S&ME's design engineer for the repair recently completed at
Allen) indicate the analyses are complete and the results indicate a global factor of safety of greater than 2 for
the critical slip surface under steady-state conditions. The local factor of safety for the toe is reportedly 1.7 for
the critical slip surface (again) for the steady-state condition. As such, there does not appear to be any stability
related issue.
Additional work is proposed and will likely include re-routing the ditch line around the transformer pad, altering
(turning) the 30-inch CMP to redirect surface water, and flattening the excavation slope. Currently, Shaw's
surveyor and civil designer are in the process of developing a topographic plan of the affected area and
calculating channel flows for sizing conduit. Once that is complete, I understand there will be a meeting
between Duke, Shaw & S&ME to discuss the path forward (see attached email). Before that meeting, I'd like to
talk with you and Andy about how the project should proceed and what you expect from a permitting
standpoint. Let me know when your schedule allows a good time to discuss this issue. Time is of the essence, so
thanks in advance for your immediate attention and assistance.
Tim Russell, P.E.
Duke-SEA-Meck-00585481

Senior Engineer
Program Engineering
Generation Engineering
Duke Energy
526 South Church Street
Charlotte, NC 28202
[phone] - Office
[phone] - Mobile
Duke-SEA-Meck-00585482

cleanenergy.org
Southern A111once for
Clean Energy
April 18, 2016
N.C. Division of Water Resources
Groundwater Protection Section
N.C. Department of Environmental Quality
Attn: Debra Watts
1636 Mail Service Center
Raleigh, NC 27699-1611
VIA E-MAIL
RE: Public Comments on DEQ's Draft Ratings for Duke Energy's Coal Ash
Impoundments
Dear Ms. Watts,
1.866.522.SACE
www.cleanenergy.org
P.O. Box 1842
Knoxville, TN 37901
865.637.6055
46 Orchard Street
Asheville, NC 28801
828.254.6776
250 Arizona Avenue, NE
Atlanta, GA 30307
404.373.5832
P.O. Box 310
Indian Rocks Beach, FL 33785
954.295.5714
P.O. Box 13672
Charleston, SC 29422
843.225.2371
Thank you for the public comment opportunity regarding DEQ's draft ratings for Duke Energy's coal
ash impoundments. I'm pleased that Duke is already required to move some of its coal ash to proper
storage. I'm writing to urge you to rank every coal ash impoundment in North Carolina as high or
intermediate priority. Duke Energy should be required to remove all of the coal ash at each of its 14
power plants sites to dry, lined storage away from our waterways and groundwater, and from our most
vulnerable communities such as low-income communities or communities of color
Duke's leaking coal ash impoundments across the state continue to threaten ground and surface water.
State health officials advised communities close to Duke's facilities not to drink their well water
because of harmful pollutants like vanadium and hexavalent chromium. No family should have to
question the safety of their water. Yet rating impoundments as low risk would allow Duke to cap coal
ash in place, with nothing to stop groundwater from mixing with the ash and carrying contamination to
surrounding communities and waterways.
DEQ's rating process offers the best opportunity to properly deal with Duke's coal ash pollution and
ensure the health and safety of NC communities. Please ensure Duke's coal ash is moved to lined, dry
storage, away from our rivers and waterways and our most vulnerable communities
Thank you for your consideration,
Adam Reaves
High Risk Energy Coordinator
Southern Alliance for Clean Energy (SACE)
[e-mail]
828.254.6776 ext. 35

North Carolina
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