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HomeMy WebLinkAboutNC0004979_Allen CAP Part 1_Appx C_Final_20151120This page intentionally left blank ELECTRIC CI"�21 I RESEARCH INSTITUTE Memorandum October 20, 2015 TO: Ed Sullivan and Tyler Hardin, Duke Energy FROM: Bruce Hensel, EPRI SUBJECT: ALLEN MODEL REVIEW Summary EPRI has reviewed the Allen model report and files provided by Duke Energy, HDR Engineering, Inc., and the University of North Carolina Charlotte. The review was performed by Tim Dale and John Ewing (Intera), with input by Chunmiao Zheng and myself. Based on this review, it is our opinion that, subject to the caveats below, this model is set-up and meets its flow and transport calibration objectives sufficiently to meet its final objective of predicting effects of corrective action alternatives on groundwater quality. The caveats associated with this opinion are: • Constant heads used to represent the Catawba River may provide an unmitigated source of water for simulation of any corrective action alternatives that potentially involve pumping near those boundaries. If corrective actions involve pumping, drain boundaries may be a more appropriate boundary condition selection than constant heads for this boundary. Specific Comments Model Report, Setup, and Calibration a) Is the objective/purpose of modeling clearly defined? Yes. The purpose of the study is clearly defined in Section 1 as three activities: 1) development of a calibrated steady-state flow model of current conditions; 2) development of a historical transient model of constituent transport that is calibrated to current conditions; and 3) predictive simulations of the different corrective action options. b) Is the site description adequate? Yes. The site description provided in Section 1.1 is sufficient for purposes of evaluating the model. c) Is the conceptual model well described with appropriate assumptions? Yes. The conceptual model section contains subsections discussing the regional and local geology and hydrogeology, the evolution of the ash basin system, the local groundwater flow system, local hydrologic and hydraulic boundaries, groundwater sources and sinks, water budget, modeled constituents of interest, and constituent transport. The CSA report is referenced as the source of the conceptual model and assumptions. The method used to estimate recharge is briefly discussed along with references. The rationale behind the choice of constituents to be modeled is discussed. Allen Model Review October 20, 2015 Page 2 The impact of the public and private water supply wells outside and inside the model domain along the assumed no -flow boundary to the west was not incorporated into the model. The cumulative impact of these wells on the potential for gradient reversal (to the west) in this area may or may not result in transport of constituents off site to the west. Personal communication with the model author indicated that these wells were not considered significant in the CSA and thus they were not included. A sensitivity analysis of the impact of these wells might be considered to document that they are not significant. d) Is the numerical model properly set up (steady state or transient; initial condition; boundary conditions; parameterization; etc)? i) Appropriateness of the simulator The use of MODFLOW-NWT and MT3DMS to simulate groundwater flow and contaminant transport, respectively, are both appropriate for the modeling objectives and represent an industry standard in choice of simulators. ii) Discretization: temporal and spatial (x y notably z) The spatial discretization for this model appears more than adequate to delineate differences in simulated heads and concentrations for all reasonable calibration and predictive purposes. For transport simulations, the Courant Number and the Grid Peclet Number can be used to determine whether discretization is numerically appropriate for a given model. In this model, transport time steps are automatically calculated by the simulator based on a specified Courant Number constraint of 1. This ensures that temporal discretization is appropriate for the spatial discretization of the model. The Grid Peclet Number (Pe_grid = Al/a) can be used to evaluate whether numerical dispersion dominates constituent transport based on spatial discretization and physical dispersion. Grid Peclet numbers preferably less than 2 and no more than 10 are generally recommended to minimize numerical dispersion. The lateral discretization (Ax = 20 feet, Ay = 20 feet) of the area comprising the ash pond and constituent sources, coupled with the longitudinal dispersivity of 80 feet in the Allen_Arsenic*.dsp and Allen_Boron*.dsp files results in Grid Peclet number of approximately 0.25 which is adequate. The transverse lateral dispersivity of 8 feet results in Grid Peclet numbers of approximately 2.5 which is within the acceptable range. The vertical discretization is more variable than the horizontal discretization with M1/M2 and fracture bedrock layers at approximately 30 to 40 feet, and the transition zone on the order of 10 feet or less. The vertical dispersivity of 0.8 feet results in Grid Peclet numbers of approximately 12.5 to 50, which is relatively high but given the predominately horizontal flow in the groundwater system, the amount of numerical dispersion in the vertical direction should have a small impact and is unlikely to influence model predictions in a meaningful way. Allen Model Review October 20, 2015 Page 3 iii) Hydrologic framework — hydraulic properties The hydrostratigraphy appears to be implemented correctly within the model domain. The hydraulic property values implemented in the model fall within their respective ranges as presented in the CSA report. iv) Boundary conditions The boundary conditions implemented in the model include aerially distributed recharge, drains, no -flow, and constant -heads. Aerially distributed recharge was noted as being a calibration parameter with a range based on a referenced mean annual range for the Piedmont range. Two zones of non -zero recharge were implemented in the model with both being at the low end of the referenced range. No -flow boundaries were assigned along the northern, western, and southern edges of the model domain. These were assigned at locations that were noted as a natural topographic divide and thus a presumed natural groundwater divide. This justification appears reasonable. The eastern boundary of the model is the Catawba River. The effects of the river on the flow field is incorporated through the use of constant -head boundary (CHB) conditions in model layers 5 through 8. The CHBs are used to assign a constant hydraulic head to a model cell and allows an unrestricted amount of water to move both into and out of the model depending on the hydraulic gradient. The use of the CHB should be carefully considered during the predictive simulations if any corrective actions are to include pumping near the assigned CHBs. v) Initial conditions in transient simulations The flow models are run in steady state, where initial conditions are not relevant apart from numerical convergence, which was achieved. The transient transport model assumes a zero concentration prior to the start of the ash pond usage with the ash pond acting as a constant concentration source thereafter. These initial conditions are reasonable. vi) Convergence criteria and mass balance errors The head tolerance in the NWT packages of 1 e-4 is more than adequate in ensuring head precision for the purposes of the model. The flow mass balance discrepancy in the MODFLOW Listing file of 0.00 percent is indicative of essentially no flow mass balance errors. The concentration mass balance discrepancy from MT3DMS is approximately 0.1 and 0.007 percent for the arsenic inactive and active basin simulations, respectively, and 0.02 and 0.008 percent for the boron inactive and active basin simulations, respectively. The maximum discrepancy value of 0.1 percent is adequate in ensuring minimal constituent mass balance errors and thus minimal impact on the contaminant transport model solutions. Allen Model Review October 20, 2015 Page 4 e) Is the calibration done properly and adequately? The flow model calibration head targets were based on the observed hydraulic heads from a single point in time of July 2015. The calibration results indicate a Mean Absoluter Error over the range in observed heads of 6.9 percent which is within the industry standard of 10 percent. Therefore the flow model adequately matches the observed values of July 2015. Concentration calibration was evaluated based on the model's ability to simulate high concentrations where high concentrations were observed and low concentrations where low concentrations were observed. • Calibrated arsenic concentrations were greater than 100 ug/L at eight of the 10 monitoring points with observed concentrations greater than 100 ug/L. Calibrated arsenic concentrations were less than 100 ug/L at four of the eight monitoring points with observed concentrations less than 100 ug/L. The simulated arsenic concentrations generally correlated to the observed magnitude of the arsenic concentrations over all of the observed depth intervals. • Calibrated boron concentrations were greater than 700 ug/L at 13 of 17 monitoring points with observed concentrations greater than 700 ug/L. Calibrated boron concentrations were less than 700 ug/L at 10 of 12 monitoring points with observed concentrations less than 700 ug/L. The simulated boron concentrations generally correlated to the observed magnitude of the boron concentrations over all of the observed depth intervals. i) Property/boundary condition correlation —parameter bounds The report denotes that the recharge to the ash basin systems and the hydraulic conductivity were both used as calibration targets in the early phases of the flow model calibration. For the final flow model calibration, the recharge was held constant at the low end of the recharge range and the hydraulic conductivity was varied. As the overall magnitude of the recharge is less uncertain than the hydraulic conductivity distribution across the site, setting the recharge to a constant value during the calibration process is a reasonable assumption. ii) Discretization of calibration parameters Hydraulic properties vary primarily by model layer which is used to differentiate between hydrologic units. Within a given layer, calibrated hydraulic properties are either uniform or based on zones of piece -wise constancy. iii) Appropriateness of target as a metric of simulation objectives (e.g., calibrating primarily to heads when transport is the primary purpose) The use of hydraulic heads and observed concentration values for calibration of the flow and transport models, respectively, are appropriate targets for the stated objectives. Allen Model Review October 20, 2015 Page 5 Is the sensitivity analysis conducted and if so, correctly? i) Sensitivity Analysis approach (look for parameters which maybe insensitive to flow but not to transport) A flow model sensitivity analysis was conducted whereby the horizontal and vertical hydraulic conductivity of the shallow and transition zone, and the recharge outside and inside the ash basin system were varied. The parameter values were varied about the calibrated values by ±20%. The results indicate which of the selected parameters the calibration results are most sensitive. For the transport models, a sensitivity analysis was conducted by increasing the Kd by a factor of 10 and increasing the porosity by 50%. No qualitative comparison was provided for the change in results but an overall discussion was provided. Model Files: a) Can the model be run with the input files provided by the developer? Yes. b) Do the model results match those presented in the report? i) Independent check of input data vs. conceptual model/report An independent check of the input data files shows that the conceptual model was implemented as noted in the report and the parameter values as noted in the report were input into the model. ii) Check of water balance vs. conceptual model A check of the water balance shows that approximately 87% of the inflows to the model is from recharge with 13% from the CHBs and is appropriate given the conceptual model. A check of the water balances for the outflows shows approximately 83% is attributed to the CHBs and the remaining 17% is attributed to the drains. While the expected amount of the outflow to the drains is not discussed, the magnitude of 17% seems high given the small areal outflow to the drains as compared to the river. However, this is not expected to appreciably affect the model's ability to meet its stated objective. iii) Independent check of model results vs. those reported The model results were independently checked and agree with those reported. Groundwater Flow and Transport Model Allen Steam Station Gaston County, NC Prepared for: HDR Engineering, Inc. Hydropower Services 440 S. Church St, Suite 1000 Charlotte, NC 28202 Investigators: William G. Langley, Ph.D., P.E. Dongwook Kim, Ph.D. UNC Charlotte / Lee College of Engineering Department of Civil and Environmental Engineering EPIC Building 3252 9201 University City Blvd. Charlotte, NC 28223 Revised November 17, 2015 TABLE OF CONTENTS 1 Introduction......................................................................................................................... 1 1.1 General Setting and Background................................................................................. 1 1.2 Study Objectives.......................................................................................................... 2 2 Conceptual Model............................................................................................................... 2 2.1 Geology and Hydrogeolo9y (HDR 2015)...................................................................... 3 2.2 Hydrostratigraphic Layer Development (HDR 2015).................................................... 3 2.3 Ash Basins and Ash Storage Areas............................................................................. 4 2.3.1 Ash Basin (HDR 2015).......................................................................................... 5 2.3.2 Ash Landfill........................................................................................................... 5 2.3.3 Structural Fills....................................................................................................... 6 2.3.4 Ash Storage.......................................................................................................... 6 2.4 Groundwater Flow System........................................................................................... 7 2.5 Hydrologic Boundaries................................................................................................. 7 2.6 Hydraulic Boundaries................................................................................................... 7 2.7 Sources and Sinks....................................................................................................... 8 2.8 Water Balance............................................................................................................. 8 2.9 Modeled Constituents of Interest (COI)........................................................................ 8 2.10 COI Transport.............................................................................................................. 9 3 Computer Model................................................................................................................. 9 3.1 Model Selection........................................................................................................... 9 3.2 Model Description........................................................................................................ 9 4 Groundwater Flow and Transport Model Construction.......................................................10 4.1 Model Hydrostratigraphy.............................................................................................10 4.2 GMS MODFLOW Version 10......................................................................................11 4.3 Model Domain and Grid..............................................................................................12 4.4 Hydraulic Parameters.................................................................................................13 4.5 Flow Model Boundary Conditions................................................................................13 4.6 Flow Model Sources and Sinks...................................................................................14 4.7 Flow Model Calibration Targets...................................................................................14 4.8 Transport Model Parameters......................................................................................14 4.9 Transport Model Boundary Conditions........................................................................15 4.10 Transport Model Sources and Sinks...........................................................................15 4.11 Transport Model Calibration Targets...........................................................................16 5 Model Calibration to Current Conditions.............................................................................16 5.1 Flow Model Residual Analysis.....................................................................................16 5.2 Transport Model Calibration........................................................................................17 5.3 Advective Travel Times...............................................................................................17 5.4 Flow and Transport Model Sensitivity Analysis...........................................................17 6 Simulation of Closure Scenarios........................................................................................18 6.1 Existing Conditions.....................................................................................................19 6.2 Cap-in-Place...............................................................................................................21 6.3 Excavation..................................................................................................................23 7 Summary and Conclusions................................................................................................25 7.1 Model Assumptions and Limitations............................................................................25 7.2 Model Predictions.......................................................................................................26 8 References........................................................................................................................27 111r_r34:110 Table 1. MODFLOW and MT3DMS Input Packages Utilized Table 2. Model Hydraulic Conductivity Table 3. Observed vs. Predicted Hydraulic Head (ft MSL) Table 4. Model Effective Porosity Table 5. Transport Model Calibration Results Table 6. Predicted Advective Travel Time Table 7. Flow and Transport Parameter Sensitivity Analysis FIGURES Figure 1. Conceptual Groundwater Flow Model/Model Domain Figure 2. Model Domain North -South Cross Section (A -A') through Inactive and Active Ash Basins Figure 3. Model Domain East-West Cross Section (B-B') through the Active Ash Basin Figure 4. Flow Model Boundary Conditions Figure 5. Model Recharge Areas and Contaminant Source Zones (Constant Concentration Cells) Figure 6. Observation Wells in Shallow Groundwater Zone Figure 7. Observation Wells in Deep Groundwater Zone Figure 8. Observation Wells in Bedrock Groundwater Zone Figure 9. Hydraulic Conductivity Zonation in S/M1 Model Layers (Model Layers 5-6) Figure 10. Hydraulic Conductivity Zonation in M2 Model Layer (Model Layer 7) Figure 11. Hydraulic Conductivity Zonation in TZ Model Layer (Model Layer 8) Figure 12. Hydraulic Conductivity Zonation in BR Model Layers (Model Layers 9 and10) Figure 13. Modeled Hydraulic Head (feet) vs. Observed Hydraulic Head (feet) Figure 14. Hydraulic Head (feet) in Shallow Groundwater Zone (Model Layer 6) Figure 15. Particle Tracking Results (see Table 6 for Advective Travel Times) Figure 16. Predicted Antimony (pg/L) in Monitoring Well AB-26D for Model Scenarios 1-3 Figure 17. Predicted Antimony (pg/L) in Monitoring Well AB-31D for Model Scenarios 1-3 Figure 18. Initial (2015) Antimony Concentrations (pg/L) in the Shallow Groundwater Zone Figure 19. Initial (2015) Antimony Concentrations (pg/L) in the Deep Groundwater Zone Figure 20. Initial (2015) Antimony Concentrations (pg/L) in the Bedrock Groundwater Zone Figure 21. "Existing Conditions" Scenario 1 - 2115 Predicted Antimony (pg/L) in the Shallow Groundwater Zone Figure 22. "Existing Conditions" Scenario 1 - 2115 Predicted Antimony (pg/L) in the Deep Groundwater Zone Figure 23. "Existing Conditions" Scenario 1 - 2115 Predicted Antimony (pg/L) in the Bedrock Groundwater Zone Figure 24. "Cap -in -Place" Scenario 2 - 2115 Predicted Antimony (pg/L) in the Shallow Groundwater Zone Figure 25. "Cap -in -Place" Scenario 2 - 2115 Predicted Antimony (pg/L) in the Deep Groundwater Zone Figure 26. "Cap -in -Place" Scenario 2 - 2115 Predicted Antimony (pg/L) in the Bedrock Groundwater Zone Figure 27. "Excavation" Scenario 3 - 2115 Predicted Antimony (pg/L) in the Shallow Groundwater Zone Figure 28. "Excavation" Scenario 3 - 2115 Predicted Antimony (pg/L) in the Deep Groundwater Zone Figure 29. "Excavation" Scenario 3 - 2115 Predicted Antimony (pg/L) in the Bedrock Groundwater Zone Figure 30. Predicted Arsenic (pg/L) in Monitoring Well AB-22S For Model Scenarios 1-3 Figure 31. Predicted Arsenic (pg/L) in Monitoring Well GWA-6S For Model Scenarios 1-3 Figure 32. Initial (2015) Arsenic Concentrations (pg/L) in the Shallow Groundwater Zone Figure 33. Initial (2015) Arsenic Concentrations (pg/L) in the Deep Groundwater Zone Figure 34. Initial (2015) Arsenic Concentrations (pg/L) in the Bedrock Groundwater Zone Figure 35. "Existing Conditions" Scenario 1 - 2115 Predicted Arsenic (pg/L) in the Shallow Groundwater Zone Figure 36. "Existing Conditions" Scenario 1 - 2115 Predicted Arsenic (pg/L) in the Deep Groundwater Zone Figure 37. "Existing Conditions" Scenario 1 - 2115 Predicted Arsenic (pg/L) in the Bedrock Groundwater Zone Figure 38. "Cap -in -Place" Scenario 2 - 2115 Predicted Arsenic (pg/L) in the Shallow Groundwater Zone Figure 39. "Cap -in -Place" Scenario 2 - 2115 Predicted Arsenic (pg/L) in the Deep Groundwater Zone Figure 40. "Cap -in -Place" Scenario 2 - 2115 Predicted Arsenic (pg/L) in the Bedrock Groundwater Zone Figure 41. "Excavation" Scenario 3 - 2115 Predicted Arsenic (pg/L) in the Shallow Groundwater Zone Figure 42. "Excavation" Scenario 3 - 2115 Predicted Arsenic (pg/L) in the Deep Groundwater Zone Figure 43. "Excavation" Scenario 3 - 2115 Predicted Arsenic (pg/L) in the Bedrock Groundwater Zone Figure 44. Predicted Barium (pg/L) in Monitoring Well AB-22S For Model Scenarios 1-3 Figure 45. Predicted Barium (pg/L) in Monitoring Well AB-26S For Model Scenarios 1-3 Figure 46. Initial (2015) Barium Concentrations (pg/L) in the Shallow Groundwater Zone Figure 47. Initial (2015) Barium Concentrations (pg/L) in the Deep Groundwater Zone IV Figure 48. Initial (2015) Barium Concentrations (pg/L) in the Bedrock Groundwater Zone Figure 49. "Existing Conditions" Scenario 1 - 2115 Predicted Barium (pg/L) in the Shallow Groundwater Zone Figure 50. "Existing Conditions" Scenario 1 - 2115 Predicted Barium (pg/L) in the Deep Groundwater Zone Figure 51. "Existing Conditions" Scenario 1 - 2115 Predicted Barium (pg/L) in the Bedrock Groundwater Zone Figure 52. "Cap -in -Place" Scenario 2 - 2115 Predicted Barium (pg/L) in the Shallow Groundwater Zone Figure 53. "Cap -in -Place" Scenario 2 - 2115 Predicted Barium (pg/L) in the Deep Groundwater Zone Figure 54. "Cap -in -Place" Scenario 2 - 2115 Predicted Barium (pg/L) in the Bedrock Groundwater Zone Figure 55. "Excavation" Scenario 3 - 2115 Predicted Barium (pg/L) in the Shallow Groundwater Zone Figure 56. "Excavation" Scenario 3 - 2115 Predicted Barium (pg/L) in the Deep Groundwater Zone Figure 57. "Excavation" Scenario 3 - 2115 Predicted Barium (pg/L) in the Bedrock Groundwater Zone Figure 58. Predicted Boron (pg/L) in Monitoring Well AB-22D For Model Scenarios 1-3 Figure 59. Predicted Boron (pg/L) in Monitoring Well AB-26S For Model Scenarios 1-3 Figure 60. Predicted Boron (pg/L) in Monitoring Well GWA-4S For Model Scenarios 1-3 Figure 61. Predicted Boron (pg/L) in Monitoring Well GWA-5BR For Model Scenarios 1-3 Figure 62. Initial (2015) Boron Concentrations (pg/L) in the Shallow Groundwater Zone Figure 63. Initial (2015) Boron Concentrations (pg/L) in the Deep Groundwater Zone Figure 64. Initial (2015) Boron Concentrations (pg/L) in the Bedrock Groundwater Zone Figure 65. "Existing Conditions" Scenario 1 - 2115 Predicted Boron (pg/L) in the Shallow Groundwater Zone Figure 66. "Existing Conditions" Scenario 1 - 2115 Predicted Boron (pg/L) in the Deep Groundwater Zone Figure 67. "Existing Conditions" Scenario 1 - 2115 Predicted Boron (pg/L) in the Bedrock Groundwater Zone Figure 68. "Cap -in -Place" Scenario 2 - 2115 Predicted Boron (pg/L) in the Shallow Groundwater Zone Figure 69. "Cap -in -Place" Scenario 2 - 2115 Predicted Boron (pg/L) in the Deep Groundwater Zone Figure 70. "Cap -in -Place" Scenario 2 - 2115 Predicted Boron (pg/L) in the Bedrock Groundwater Zone Figure 71. "Excavation" Scenario 3 - 2115 Predicted Boron (pg/L) in the Shallow Groundwater Zone Figure 72. "Excavation" Scenario 3 - 2115 Predicted Boron (pg/L) in the Deep Groundwater Zone Figure 73. "Excavation" Scenario 3 - 2115 Predicted Boron (pg/L) in the Bedrock Groundwater Zone Figure 74. Predicted Chromium (pg/L) in Monitoring Well AB-6R For Model Scenarios 1-3 Figure 75. Predicted Chromium (pg/L) in Monitoring Well AB-26D For Model Scenarios 1-3 Figure 76. Initial (2015) Chromium Concentrations (pg/L) in the Shallow Groundwater Zone Figure 77. Initial (2015) Chromium Concentrations (pg/L) in the Deep Groundwater Zone Figure 78. Initial (2015) Chromium Concentrations (pg/L) in the Bedrock Groundwater Zone Figure 79. "Existing Conditions" Scenario 1 - 2115 Predicted Chromium (pg/L) in the Shallow Groundwater Zone v Figure 80. "Existing Conditions" Scenario 1 - 2115 Predicted Chromium (pg/L) in the Deep Groundwater Zone Figure 81. "Existing Conditions" Scenario 1 - 2115 Predicted Chromium (pg/L) in the Bedrock Groundwater Zone Figure 82. "Cap -in -Place" Scenario 2 - 2115 Predicted Chromium (pg/L) in the Shallow Groundwater Zone Figure 83. "Cap -in -Place" Scenario 2 - 2115 Predicted Chromium (pg/L) in the Deep Groundwater Zone Figure 84. "Cap -in -Place" Scenario 2 - 2115 Predicted Chromium (pg/L) in the Bedrock Groundwater Zone Figure 85. "Excavation" Scenario 3 - 2115 Predicted Chromium (pg/L) in the Shallow Groundwater Zone Figure 86. "Excavation" Scenario 3 - 2115 Predicted Chromium (pg/L) in the Deep Groundwater Zone Figure 87. "Excavation" Scenario 3 - 2115 Predicted Chromium (pg/L) in the Bedrock Groundwater Zone Figure 88. Predicted Hexavalent Chromium (pg/L) in Monitoring Well AB-9D For Model Scenarios 1-3 Figure 89. Predicted Hexavalent Chromium (pg/L) in Monitoring Well AB-31 S For Model Scenarios 1-3 Figure 90. Predicted Hexavalent Chromium (pg/L) in Monitoring Well GWA-3D For Model Scenarios 1-3 Figure 91. Predicted Hexavalent Chromium (pg/L) in Monitoring Well AB-10D Model Scenarios 1-3 Figure 92. Initial (2015) Hexavalent Chromium Concentrations (pg/L) in the Shallow Groundwater Zone Figure 93. Initial (2015) Hexavalent Chromium Concentrations (pg/L) in the Deep Groundwater Zone Figure 94. Initial (2015) Hexavalent Chromium Concentrations (pg/L) in the Bedrock Groundwater Zone Figure 95. "Existing Conditions" Scenario 1 - 2115 Predicted Hexavalent Chromium (pg/L) in the Shallow Groundwater Zone Figure 96. "Existing Conditions" Scenario 1 - 2115 Predicted Hexavalent Chromium (pg/L) in the Deep Groundwater Zone Figure 97. "Existing Conditions" Scenario 1 - 2115 Predicted Hexavalent Chromium (pg/L) in the Bedrock Groundwater Zone Figure 98. "Cap -in -Place" Scenario 2 - 2115 Predicted Hexavalent Chromium (pg/L) in the Shallow Groundwater Zone Figure 99. "Cap -in -Place" Scenario 2 - 2115 Predicted Hexavalent Chromium (pg/L) in the Deep Groundwater Zone Figure 100. "Cap -in -Place" Scenario 2 - 2115 Predicted Hexavalent Chromium (pg/L) in the Bedrock Groundwater Zone Figure 101. "Excavation" Scenario 3 - 2115 Predicted Hexavalent Chromium (pg/L) in the Shallow Groundwater Zone Figure 102. "Excavation" Scenario 3 - 2115 Predicted Hexavalent Chromium (pg/L) in the Deep Groundwater Zone Figure 103. "Excavation" Scenario 3 - 2115 Predicted Hexavalent Chromium (pg/L) in the Bedrock Groundwater Zone Figure 104. Predicted Cobalt (pg/L) in Monitoring Well AB-10S For Model Scenarios 1-3 Figure 105. Predicted Cobalt (pg/L) in Monitoring Well AB-26S For Model Scenarios 1-3 Figure 106. Predicted Cobalt (pg/L) in Monitoring Well AB-32D For Model Scenarios 1-3 vi Figure 107. Predicted Cobalt (pg/L) in Monitoring Well GWA-5S For Model Scenarios 1-3 Figure 108. Initial (2015) Cobalt Concentrations (pg/L) in the Shallow Groundwater Zone Figure 109. Initial (2015) Cobalt Concentrations (pg/L) in the Deep Groundwater Zone Figure 110. Initial (2015) Cobalt Concentrations (pg/L) in the Bedrock Groundwater Zone Figure 111. "Existing Conditions" Scenario 1 - 2115 Predicted Cobalt (pg/L) in the Shallow Groundwater Zone Figure 112. "Existing Conditions" Scenario 1 - 2115 Predicted Cobalt (pg/L) in the Deep Groundwater Zone Figure 113. "Existing Conditions" Scenario 1 - 2115 Predicted Cobalt (pg/L) in the Bedrock Groundwater Zone Figure 114. "Cap -in -Place" Scenario 2 - 2115 Predicted Cobalt (pg/L) in the Shallow Groundwater Zone Figure 115. "Cap -in -Place" Scenario 2 - 2115 Predicted Cobalt (pg/L) in the Deep Groundwater Zone Figure 116. "Cap -in -Place" Scenario 2 - 2115 Predicted Cobalt (pg/L) in the Bedrock Groundwater Zone Figure 117. "Excavation" Scenario 3 - 2115 Predicted Cobalt (pg/L) in the Shallow Groundwater Zone Figure 118. "Excavation" Scenario 3 - 2115 Predicted Cobalt (pg/L) in the Deep Groundwater Zone Figure 119. "Excavation" Scenario 3 - 2115 Predicted Cobalt (pg/L) in the Bedrock Groundwater Zone Figure 120. Predicted Selenium (pg/L) in Monitoring Well GWA-6S For Model Scenarios 1-3 Figure 121. Predicted Selenium (pg/L) in Monitoring Well AB-22S For Model Scenarios 1-3 Figure 122. Initial (2015) Selenium Concentrations (pg/L) in The Shallow Groundwater Zone Figure 123. Initial (2015) Selenium Concentrations (pg/L) in the Deep Groundwater Zone Figure 124. Initial (2015) Selenium Concentrations (pg/L) in the Bedrock Groundwater Zone Figure 125. "Existing Conditions" Scenario 1 - 2115 Predicted Selenium (pg/L) in the Shallow Groundwater Zone Figure 126. "Existing Conditions" Scenario 1 - 2115 Predicted Selenium (pg/L) in the Deep Groundwater Zone Figure 127. "Existing Conditions" Scenario 1 - 2115 Predicted Selenium (pg/L) in the Bedrock Groundwater Zone Figure 128. "Cap -in -Place" Scenario 2 - 2115 Predicted Selenium (pg/L) in the Shallow Groundwater Zone Figure 129. "Cap -in -Place" Scenario 2 - 2115 Predicted Selenium (pg/L) in the Deep Groundwater Zone Figure 130. "Cap -in -Place" Scenario 2 - 2115 Predicted Selenium (pg/L) in the Bedrock Groundwater Zone Figure 131. "Excavation" Scenario 3 - 2115 Predicted Selenium (pg/L) in the Shallow Groundwater Zone Figure 132. "Excavation" Scenario 3 - 2115 Predicted Selenium (pg/L) in the Deep Groundwater Zone Figure 133. "Excavation" Scenario 3 - 2115 Predicted Selenium (pg/L) in the Bedrock Groundwater Zone Figure 134. Predicted Sulfate (pg/L) In Monitoring Well AB-33S For Model Scenarios 1-3 Figure 135. Predicted Sulfate (pg/L) In Monitoring Well GWA-6S For Model Scenarios 1-3 Figure 136. Initial (2015) Sulfate Concentrations (pg/L) in the Shallow Groundwater Zone Figure 137. Initial (2015) Sulfate Concentrations (pg/L) in the Deep Groundwater Zone Figure 138. Initial (2015) Sulfate Concentrations (pg/L) in the Bedrock Groundwater Zone vii Figure 139. "Existing Conditions" Scenario 1 - 2115 Predicted Sulfate (pg/L) in the Shallow Groundwater Zone Figure 140. "Existing Conditions" Scenario 1 - 2115 Predicted Sulfate (pg/L) in the Deep Groundwater Zone Figure 141. "Existing Conditions" Scenario 1 - 2115 Predicted Sulfate (pg/L) in the Bedrock Groundwater Zone Figure 142. "Cap -in -Place" Scenario 2 - 2115 Predicted Sulfate (pg/L) in the Shallow Groundwater Zone Figure 143. "Cap -in -Place" Scenario 2 - 2115 Predicted Sulfate (pg/L) in the Deep Groundwater Zone Figure 144. "Cap -in -Place" Scenario 2 - 2115 Predicted Sulfate (pg/L) in the Bedrock Groundwater Zone Figure 145. "Excavation" Scenario 3 - 2115 Predicted Sulfate (pg/L) in the Shallow Groundwater Zone Figure 146. "Excavation" Scenario 3 - 2115 Predicted Sulfate (pg/L) in the Deep Groundwater Zone Figure 147. "Excavation" Scenario 3 - 2115 Predicted Sulfate (pg/L) in the Bedrock Groundwater Zone Figure 148. Predicted Vanadium (pg/L) In Monitoring Well AB-6R For Model Scenarios 1-3 Figure 149. Predicted Vanadium (pg/L) In Monitoring Well AB-10D For Model Scenarios 1-3 Figure 150. Predicted Vanadium (pg/L) In Monitoring Well GWA-4S For Model Scenarios 1-3 Figure 151. Predicted Vanadium (pg/L) In Monitoring Well GWA-5BR For Model Scenarios 1-3 Figure 152. Initial (2015) Vanadium Concentrations (pg/L) in the Shallow Groundwater Zone Figure 153. Initial (2015) Vanadium Concentrations (pg/L) in the Deep Groundwater Zone Figure 154. Initial (2015) Vanadium Concentrations (pg/L) in the Bedrock Groundwater Zone Figure 155. "Existing Conditions" Scenario 1 - 2115 Predicted Vanadium (pg/L) in the Shallow Groundwater Zone Figure 156. "Existing Conditions" Scenario 1 - 2115 Predicted Vanadium (pg/L) in the Deep Groundwater Zone Figure 157. "Existing Conditions" Scenario 1 - 2115 Predicted Vanadium (pg/L) in the Bedrock Groundwater Zone Figure 158. "Cap -in -Place" Scenario 2 - 2115 Predicted Vanadium (pg/L) in the Shallow Groundwater Zone Figure 159. "Cap -in -Place" Scenario 2 - 2115 Predicted Vanadium (pg/L) in the Deep Groundwater Zone Figure 160. "Cap -in -Place" Scenario 2 - 2115 Predicted Vanadium (pg/L) in the Bedrock Groundwater Zone Figure 161. "Excavation" Scenario 3 - 2115 Predicted Vanadium (pg/L) in the Shallow Groundwater Zone Figure 162. "Excavation" Scenario 3 - 2115 Predicted Vanadium (pg/L) in the Deep Groundwater Zone Figure 163. "Excavation" Scenario 3 - 2115 Predicted Vanadium (pg/L) in the Bedrock Groundwater Zone viii INTRODUCTION The calibrated flow and transport model third -party peer review team was coordinated by the Electric Power Research Institute (EPRI) and included Dr. Chunmiao Zheng from the University of Alabama, James Rumbaugh from Environmental Simulations, Inc, and experienced modelers from Intera, Inc. The reviewers were provided with the conceptual site model, the Comprehensive Site Assessment (CSA), a draft model report, and digital model input and output files, allowing them to reconstruct the model for independent review. During the course of the review, the reviewers communicated with the modelers in order to better understand how the model was developed and calibrated. As a result of these communications, the model was modified and recalibrated, which allowed the reviewers to conclude that the model was constructed and calibrated sufficiently to achieve its primary objective of comparing the effects of closure alternatives on nearby groundwater quality. In addition, the reviewers identified limitations with the model, which are included in the discussion of model limitations later in this documentation. After EPRI acceptance of the Allen Groundwater model, the model was improved using measured aquifer test and water level results from monitor wells at the Allen site. In addition, a drainage feature was removed from the model near the northwest model boundary after further review of the CSA data. These changes did not change the model structure or boundaries and did not deviate from EPRI guidelines. 1.1 General Setting and Background Duke Energy owns and operates the Allen Steam Station (Allen), which is located on a 1,009 acre tract near the town of Belmont, in Gaston County, North Carolina. Allen began operation in 1957 as a coal-fired generating station and currently operates five coal-fired units. The coal ash residue from Allen's coal combustion process has historically been disposed in the ash basin system located to the south of the station and adjacent to the Catawba River (HDR Figures 2-1 through 2-41)(HDR 2015). The ash basin system at Allen consists of an active ash basin and an inactive ash basin. In general, the ash basin is located south of the power complex in historical drainage features formed from tributaries that flowed toward the Catawba River. There is one earthen embankment dam and one earthen dike impounding the active ash basin: the East Dam, located along the west bank of the Catawba River, and the North Dike, separating the active and inactive ash basins. The original ash basin at the Allen site (the inactive ash basin) began operation in 1957 and was formed by constructing an underlying portion of the earthen North Dike and the northern portion of the main East Dam where tributaries flowed toward the Catawba River. As the original ash basin capacity diminished over time, the active ash basin was formed in 1973 by constructing the southern portion of the East Dam and raising the North Dike. Ash has been sluiced to the active ash basin since 1973 (HDR 2015). 1 Please refer to the Comprehensive Site Assessment Report, ALSS Steam Station Ash Basin, August 2015 (HDR) for more information and referenced figures and tables (referred to herein as HDR tables and HDR figures). 1 Two unlined dry ash storage areas, two unlined structural fill units, and a double -lined dry ash landfill are located within the footprint of the inactive ash basin. The ash landfill was constructed in 2009. Construction of the structural fill units began in 2003 and was completed in 2009. The dry ash storage areas were constructed in 1996 (HDR 2015). Allen is a coal-fired electricity generating facility with a capacity of 1,155 megawatts (MW) along the Catawba River (specifically Lake Wylie). The five -unit station began commercial operation in 1957 with operation of coal-fired Units 1 and 2 (330 MW total). Unit 3 (275 MW) was placed into commercial operation in 1959, followed by Unit 4 (275 MW) in 1960, and Unit 5 (275 MW) in 1961. The Allen ash basin is situated between the Allen powerhouse to the north and topographic divides to the west (along South Point Road) and south (along Reese Wilson Road) (HDR Figure 2-2). Natural topography at the site generally slopes downward and eastward from that divide toward Lake Wylie. The topography at the site generally slopes from west to east, approximately 650 feet to 680 feet elevation near the west and southwest boundaries of the site to an approximate low elevation of 570 feet at the shoreline of Lake Wylie (an approximate distance of 0.8 miles). The air pollution control system for the coal-fired units at Allen includes a flue gas desulfurization (FGD) system that was placed into operation in 2009. Coal is delivered to the station by a railroad line. Other areas of the site are occupied by facilities supporting the production and transmission of power (two switchyards and associated transmission lines), the FGD wastewater treatment system, and the gypsum handling station (associated with the FGD system). A site features map is included as HDR Figure 2-4. Based on the CSA site investigation (HDR 2015), the groundwater system in the natural materials (alluvium, soil, soil/saprolite, and bedrock) at Allen is consistent with the Piedmont regolith-fractured rock system and is an unconfined, connected system of flow layers (HDR Figure 5-5). In general, groundwater within the shallow and deep layers (S and D wells) and bedrock layer (BR wells) flows from west and southwest to the east toward the Catawba River (Lake Wylie) and to the north toward Duke Energy property and the station discharge canal. 1.2 Study Objectives The purpose of this study is to predict the groundwater flow and constituent transport that will occur as a result of different possible closure actions at the site. The study consists of three main activities: development of a calibrated steady-state flow model of current conditions, development of a transport model for constituents identified as COls, and simulating transport for the following scenarios: Scenario 1) "Existing Conditions" scenario of existing site conditions, Scenario 2) "Cap in -Place" where impermeable cap(s) are placed over existing active/inactive ash basins and ash storage area, and Scenario 3) "Excavation" where ash is removed from the Allen ash basins and ash storage area. 2 CONCEPTUAL MODEL The site conceptual model for Allen is primarily based on the CSA Report (HDR 2015) for the Allen Steam Station. The CSA report contains extensive detail and data related to most aspects of the site conceptual model that are used in this report. P 2.1 Geology and Hydrogeology (HDR 2015) The Allen site is located within the Charlotte terrane, one of a number of tectonostratigraphic terranes that have been defined in the southern and central Appalachians and is in the western portion of the larger Carolina superterrane (HDR Figure 5-1). The Charlotte terrane is dominated by a complex sequence of plutonic rocks that intrude a suite of metaigneous rocks. A geologic map of the area around Allen is shown in CSA Figure 5-2 (HDR 2015). The fractured bedrock is overlain by a mantle of unconsolidated material known as regolith. The regolith includes residual soil and saprolite zones and, where present, alluvial deposits. Saprolite, the product of chemical weathering of the underlying bedrock, is typically composed of clay and coarser granular material and reflects the texture and structure of the rock from which it was formed. The weathering products of granitic rocks are quartz -rich and sandy textured. Rocks poor in quartz and rich in feldspar and ferro-magnesium minerals form a more clayey saprolite. The groundwater system in the Piedmont Province, in most cases, is comprised of two interconnected layers, or mediums: 1) residual soil/saprolite and weathered fractured rock (regolith) overlying 2) fractured crystalline bedrock (HDR 2015). The regolith layer is a thoroughly weathered and structureless residual soil that occurs near the ground surface with the degree of weathering decreasing with depth. The residual soil grades into saprolite, a coarser grained material that retains the structure of the parent bedrock. Beneath the saprolite, partially weathered/fractured bedrock occurs with depth until sound bedrock is encountered. This layer serves as the principal storage reservoir and provides an intergranular medium through which the recharge and discharge of water from the underlying fractured rock occurs. Within the fractured crystalline bedrock layer, the fractures control both the hydraulic conductivity and storage capacity of the rock mass. A transition zone (TZ) at the base of the regolith has been interpreted to be present in many areas of the Piedmont. It is described as consisting of partially weathered/fractured bedrock and lesser amounts of saprolite that grades into bedrock and is considered to be the most permeable part of the system (HDR 2015). 2.2 Hydrostratigraphic Layer Development (HDR 2015) Soil conditions encountered in the borings showed minimal variation across the site. Residual soil consists of clayey sand (SC), silty sand (SM), silty sand with gravel (SM), micaceous silty sand (SM), and gravel with silt and sand (GP). The following materials were encountered during the site exploration and are consistent with material descriptions from previous site exploration studies: Ash — Ash was encountered in borings advanced within the ash basin and ash storage areas, as well as through dikes. Ash was generally described as gray to dark gray, non -plastic, loose to medium dense, dry to wet, fine to coarse -grained. Fill — Fill material generally consisted of re -worked silts, clays, and sands that were borrowed from one area of the site and re -distributed to other areas. Fill was generally classified as silty sand, clay with sand, clay, and sandy clay on the boring logs. Fill was used in the construction of dikes, and as cover for ash storage area. Alluvium —Alluvium encountered in borings during the project was classified as clay and sand with clay. In some cases alluvium was logged beneath ash. 3 Residuum (Residual soils) — Residuum is the in -place weathered soil that consists primarily of silt with sand, clayey sand, sandy clay, clay with gravel, and clayey silts. Residuum varied in thickness and was relatively thin compared to the thickness of saprolite. Saprolite/Weathered Rock — Saprolite is soil developed by in -place weathering of rock that retains remnant bedrock structure. Saprolite consists primarily of medium dense to very dense silty sand, sandy silt, sand, sand with gravel, sand with clay, clay with sand, and clay. Sand particle size ranges from fine to coarse grained. Much of the saprolite is micaceous. Partially Weathered/Fractured Rock — Partially weathered (slight to moderate) and/or highly fractured rock encountered below auger refusal. Bedrock — Sound rock in boreholes, was generally slightly weathered to fresh and relatively unfractured. Based on the CSA, the groundwater system is consistent with the regolith-fractured bedrock system. To define the hydrostratigraphic units the following classification system was used and is based on Standard Penetration Testing (N) values, Recovery (REC), and Rock Quality Designation (RQD) collected during the drilling and logging of boreholes. The ash, fill, and alluvial layers are as encountered at the site. The natural system (except alluvium) includes the following layers: M1 — Soil/Saprolite: M2 — Saprolite/Weathered Rock: TZ — Transition Zone: BR — Bedrock: N <50 N>50 or REC<50% REC>50% and RQD<50% REC>85% and RQD>50%. Rock core runs that fell between the values for TZ and BR (REC<85% and RQD>50% or REC>85% and RQD<50%) were assigned a hydrostratigraphic layer based on a review of the borehole logs, rock core photographs, and geologic judgment. The same review was performed to determine the thickness of the TZ just in case it extended into the next core run, which when reviewed alone might have met the BR criterion, because of potential core loss or fractured/jointed rock with indications of water movement (iron/manganese staining). The above layers designations (M1, M2, TZ, and BR) are used on the geologic cross sections with transect locations shown on HDR Figure 8-2. The ash, fill and alluvial layers are represented by A, F, and S, respectively, on cross sections and in tables in the CSA. Ranges of hydrostratigraphic layer properties measured at Allen are provided in CSA Tables 11- 8 through 11-12 (HDR 2015). 2.3 Ash Basins and Ash Storage Areas Historical and current information about the Allen ash basin system assembled by HDR (2015) is relevant to developing the conceptual and numerical groundwater flow models. Refer to HDR Figures 2-2 and 2-4 for locations of ash basin system components described below. Coal ash residue from the coal combustion process has historically been disposed in the Allen ash basin. The area contained within the entire ash basin waste boundary, which is shown on HDR Figures 2-2 and 2-7, encompasses approximately 322 acres. The ash basin system is comprised of an inactive ash basin and an active ash basin. For convenience, the two ash 2 basins are sometimes jointly referred to as the "ash basin" in this report. In general, the ash basin is located in historical depressions formed from tributaries that flowed toward the Catawba River. The ash basin is operated as an integral part of the station's wastewater treatment system, which receives flows from the ash removal system, coal pile runoff, landfill leachate, FGD wastewater, the station yard drain sump, and site stormwater. There are two earthen dikes impounding the active ash basin: the East Dike, located along the west bank of the Catawba River; and the North Dike, separating the active and inactive ash basins. The original ash basin at the Allen site (the inactive ash basin) began operation in 1957 and was formed by constructing the earthen North Dike and the north portion of the East Dike where tributaries flowed toward Lake Wylie. As the original ash basin capacity diminished over time, the active ash basin was formed in 1973 by constructing the southern portion of the East Dike. Ash has been sluiced to the active ash basin since 1973. In addition to the ash basin, two unlined dry ash storage areas, two unlined structural fill units, and a lined dry ash landfill are located on top of the inactive ash basin. The ash landfill was constructed in 2009. Construction of the structural fill units began in 2003 and was completed in 2009. The dry ash storage areas were constructed in 1996. Additional information pertaining to each ash management unit is provided below. 2.3.1 Ash Basin (HDR 2015) The active ash basin, located on the southern portion of the property, is approximately 169 acres in area and contains an estimated 7,660,000 tons of ash. The inactive ash basin, located between the generating units and the active ash basin, is approximately 132 acres in area and contains approximately 3,920,000 tons of ash. The inactive ash basin was commissioned in 1957 and is located adjacent to and north of the active ash basin. Coal ash was sluiced to the inactive ash basin until the active ash basin was constructed in 1973. Fly ash precipitated from flue gas and bottom ash collected in the bottom of the boilers were sluiced to the ash basin using conveyance water withdrawn from the Catawba River. Since 2009, fly ash has been dry -handled and disposed in the on -site ash landfill, and bottom ash has continued to be sluiced to the active ash basin. During operations, the sluice lines discharge the water/ash slurry (and other permitted flows) into the Primary Ponds of the northern portion of the active ash basin. Primary Ponds 1, 2, and 3 were constructed in approximately 2004. Currently, Primary Ponds 2 and 3 are utilized for settling purposes. Other inflows to the ash basin include flows from coal pile runoff, landfill leachate, FGD wastewater, the station yard drain sump, and stormwater flows. Due to variability in station operations and weather, the inflows to the ash basin are highly variable. Effluent from the ash basin is discharged from the discharge tower to Lake Wylie via a 42-inch-diameter reinforced concrete pipe located in the southeastern portion of the ash basin (Outfall 002). The water surface elevation in the ash basin is controlled by the use of stop logs in the discharge tower. 2.3.2 Ash Landfill The ash landfill unit, referred to as the Retired Ash Basin (RAB) Ash Landfill (NCDENR Division of Waste Management (DWM) Solid Waste Section Permit No. 3612-INDUS), is located on the eastern portion of the Allen site, on top of the inactive ash basin. The landfill is bound to the north, east, and south by earthen dikes. The RAB Ash Landfill dam comprises the northern and 5 eastern boundaries of the landfill. The Catawba River is located immediately to the east and below the landfill. To the south of and adjacent to the RAB Ash Landfill is the existing active ash basin, and to the west is a structural fill area. The lined landfill is permitted to receive coal combustion residuals (CCR) including fly ash, bottom ash, boiler slag, mill rejects, and FGD waste generated by Duke Energy. In addition to these CCR materials, the landfill is permitted to receive nonhazardous sandblast material, limestone, coal, carbon, sulfur pellets, cation and anion resins, sediment from sumps, and cooling tower sludge. The RAB Ash Landfill is planned to contain two phases (Phase I and Phase II), and when fully constructed will cover a total of 47 acres. Phase I has been constructed and encompasses 25 acres on the southern half of the landfill footprint. The estimated gross capacity of Phase I is 2,082,500 cubic yards. Phase 11 has not yet been constructed and is planned to encompass 22 acres immediately north of the Phase I footprint. The estimated gross capacity of Phase 11 is 3,958,200 cubic yards. The entire landfill facility, including the waste footprint, associated perimeter berms, ditches, stormwater management systems and roads, is projected to encompass an area of approximately 62 acres, when complete. The approximate boundary of the RAB Ash Landfill is shown on HDR Figure 2-2. The Permit to Construct Phase I of the landfill was issued by NCDENR DWM in September 2008. Its initial Permit to Operate was issued by NCDENR DWM in December 2009, and the most recent Permit to Operate renewal was issued in December 2014. The landfill was constructed with a leachate collection and removal system and a three -component liner system consisting of a primary geomembrane, secondary geomembrane (with a leak detection system between them), and clay soil liner. Placement of waste material in the RAB Ash Landfill began in December 2009. Phase I contact stormwater and leachate are collected in the leachate collection pipe system and then pumped to the discharge location in the northeastern portion of the active ash basin. Since the landfill is situated over the inactive ash basin, the landfill was constructed with a double liner, leachate collection system (LCS) and leak detection system (LDS). NCDENR DWR determined that inclusion of the LCS, LDS, and leachate sampling is an acceptable alternative to groundwater monitoring for the landfill, which would be difficult to assess with the underlying inactive ash basin. 2.3.3 Structural Fills Two unlined Distribution of Residuals Solids (DORS) structural ash fills are located on top of the western portion of the inactive ash basin, adjacent to and west of the RAB Ash Landfill. These fills were constructed of ponded ash removed from the active ash basin per Duke Energy's DORS Permit issued by NCDENR DWQ. Placement of dry ash in the structural fills began in 2003 and was completed in 2009. During and following the completion of filling, the structural fill areas were graded to drain, and soil cover was placed on the top slopes and side slopes, and vegetation was established. The eastern structural fill covers approximately 17 acres and contains approximately 500,000 tons of ash. The western structural fill covers approximately 17 acres and contains approximately 328,000 tons of ash. 2.3.4 Ash Storage Two unlined ash storage areas are located on top of the western portion of the inactive ash basin, adjacent to and west of the two DORS structural fills. Similar to the two DORS structural fills, the ash storage areas were constructed in 1996 by excavating ash from the northern M. portion of the active ash basin in order to provide capacity for sluiced ash in the active ash basin and the future construction of Primary Ponds 1, 2, and 3. Following the completion of stockpiling, the ash storage areas were graded to drain, and a minimum of 18 and 24 inches of soil cover were placed on the top slopes and side slopes, respectively, and vegetation was established. Approximately 300,000 cubic yards of ash is stored in the ash storage areas, which encompass an area of approximately 15 to 20 acres of the western portion of the inactive ash basin. 2.4 Groundwater Flow System Groundwater recharged occurs from precipitation infiltration into the subsurface where the ground surface is permeable, including the dikes and ash of the ash basin system where exposed at the ground surface. After infiltrating the ground surface, water in the unsaturated zone percolates downward to the unconfined water table, except where ponded water conditions exist on portions of the Active Ash Basin. From the water table, groundwater moves downward and then laterally through unconsolidated material (residual soil/saprolite) into the TZ, then fractured bedrock. Mean annual recharge to shallow unconfined aquifers in the Piedmont ranges from 4.0 to 9.7 inches per year (Daniel 2001). Based on the site investigation, the groundwater system in the natural materials (alluvium, soil, soil/saprolite, and fractured bedrock) at Allen is consistent with the regolith-fractured rock system and is an unconfined, connected aquifer system without confining layers. The Allen groundwater system is divided into three layers referred to in this report as the shallow, deep (TZ), and bedrock flow layers to distinguish the flow layers within the connected aquifer system. In general, groundwater within the shallow flow layer, deep flow layer, and bedrock flow layer at the site flows from west and southwest to the east toward the Catawba River and to the northeast and north toward Duke Energy property and the station discharge canal (HDR Figures 6-5 through 6-7). Locally, groundwater is mounded beneath Primary Ponds 1 through 3 and depressed beneath the ash landfill and the southeastern Active Ash Basin. Steep hydraulic gradients are associated with the North and East Dikes. In accordance with the Piedmont Slope Aquifer System of LeGrand (2004), fractured density in bedrock decreases with depth, limiting deep groundwater flow (HDR Figure 5-5). 2.5 Hydrologic Boundaries The major discharge locations for the groundwater system at Allen, the Catawba River to the east and the Station Discharge Canal to the north (HDR Figure 2-4), act as a hydrologic boundaries for the site. A no -flow boundary is located between the Station Discharge Canal and the ash basin system at a presumptive, natural groundwater divide corresponding to a topographic divide. Thus, the Station Discharge Canal is not a component of the ash basin model to the south. 2.6 Hydraulic Boundaries The ash landfill situated over the RAB was constructed with a double liner, leachate collection system (LCS) and leak detection system (LDS) that act as a hydraulic boundary. Otherwise, the 7 groundwater flow system at Allen does not contain impermeable barriers or boundaries with the exception of bedrock at depth where fracture density, and fracture flow, is minimal. Natural groundwater divides exist along topographic divides, but are a result of local flow conditions as opposed to barriers. 2.7 Sources and Sinks Recharge, including to the ash basins, is the major source of water for the groundwater system. Most of this water discharges to the hydrologic boundary at the Catawba River. Recharge that infiltrates the Ash Landfill is intercepted by the liner system at depth and is diverted to the Active Ash Basin. Four public water supply wells and 219 private water supply wells have been identified within a 0.5-mile radius of the ash basin compliance boundary at Allen. Two existing water supply wells at the Allen site (CIF Well and pH Well) were sampled to supplement groundwater quality data in the vicinity of the Active Ash Basin. However, the CSA does not consider any effect that these wells may have on groundwater flow at the site, nor does it identify other sources or sinks. The CSA does not suggest that the Allen ash basin is within the capture zone or zone of influence of any extraction well or wells. Furthermore, it states that the groundwater flow direction across the site is away from the direction of the nearest public or private water supply wells (HDR 2015). 2.8 Water Balance Over an extended period of time, the rate of water inflow to the modeled area is equal to its rate of water outflow. That is, there is no net change in groundwater storage. Water enters the groundwater system through recharge and ultimately discharges to the Catawba River. 2.9 Modeled Constituents of Interest (COI) As defined in the CSA, constituents are those chemicals or compounds that were identified in the approved groundwater assessment plans for sampling and analysis (HDR 2015). The following criteria were used to determine if a COI required modeling: if the constituent exceeded regulatory groundwater standards (15A NCAC 02L.0202 groundwater standard or IMAC), and is traceable back to the source (i.e., existed in porewater) - the constituent was then deemed a COI for transport modeling. Per the CSA, the metals and trace metals detected in ash basin porewater are: antimony, arsenic, barium, boron, chromium, hexavalent chromium, cobalt, selenium, iron, manganese, sulfate, thallium, and vanadium. Exclusive of iron, manganese, and thallium, all of these COls were considered in the transport simulations. Iron and manganese are naturally occurring in the groundwater system and require more complex modeling than which is currently being performed. Thallium has only one estimated value above the exceedence threshold detected in groundwater, which does not yield a discerned plume to calibrate to. The simulated COls all occur at elevated levels in groundwater near the ash basins (HDR Figures 10-80 to 10-89, 10-93 to 10-95, 10-99 to 10-104, 10-114 to 10-119, and 10-126 to 10-128). Boron and sulfate are considered very mobile in groundwater as they do not readily precipitate or adsorb to soils. The other COls adsorb to commonly occurring soil types based upon the linear sorption coefficient ([KdD analysis performed by UNCC. P] 2.10 COI Transport COls entered the ash basin system in the dissolved phase and solid phase of the station's wastewater discharge. Some constituents are also present in native soils and groundwater beneath the basin. The accumulation and subsequent release of chemical constituents in the ash basin over time is complex. In the active and inactive ash basin, constituents may incur phase changes via dissolution, precipitation, chemical reactions and adsorption/desorption. Dissolved phase constituents may incur these phase changes as they are transported by advection and dispersion in groundwater flowing downgradient from the ash basins. In the fate and transport model, chemical constituents enter the basin in the dissolved phase by specifying a steady state concentration in the ash porewater. Phases changes (dissolution, precipitation, adsorption, and desorption) are collectively taken into account by specifying a linear sorption coefficient (distribution coefficient [KdD. The accumulation and subsequent release of chemical constituents in the ash basin over time is a complex process. In the conceptual fate and transport model, it was assumed that the entry of constituents into the ash basin is represented by a constant concentration in the saturated zone of the basin, which is continually flushed by recharge water infiltrating from above. At the ash storage area, leachable constituents enter the dissolved phase during transient infiltration events through the stored ash. Infiltration with constituents in solution moves downward through the stored ash and underlying, unsaturated soils and finally into groundwater at the water table. Dissolved phase constituents may incur phase changes also as they migrate through the stored ash and native soils to the water table. In the conceptual fate and transport model, it was assumed that the entry of constituents into groundwater beneath the ash storage area is represented by a constant concentration at the water table beneath the ash storage area, which is continually flushed by infiltrating recharge from above. 3 COMPUTER MODEL 3.1 Model Selection The computer code MODFLOW solves the system of equations that quantify the flow of groundwater in three dimensions (3D). MODFLOW can simulate steady-state and transient flow, as well as confined and water table conditions. Additional components of groundwater can be considered, including: pumping wells, recharge, evapotranspiration, rivers, streams, springs, and lakes. The information assembled in the conceptual site model is translated into its numerical equivalent from which a solution is generated by MODFLOW. 3.2 Model Description The specific MODFLOW package chosen for the study is NWT —a Newton formulation of MODFLOW-2005 that is specifically designed for improving the stability of solutions involving drying and re -wetting under water table conditions (Niswonger, et al. 2011). The numerical code selected for the transport model is MT3DMS (Zheng and Wang 1999). MT3DMS is multi - species 3-dimensional mass transport model that can simulate advection, dispersion/diffusion, and chemical reaction of COls in groundwater flow systems, and has a package that provides a link to the MODFLOW codes. The MODFLOW-NWT and MT3DMS input packages used to M create the groundwater flow and transport models, and a brief description of their use, are provided in Table 1. 4 GROUNDWATER FLOW AND TRANSPORT MODEL CONSTRUCTION The flow and transport model for the study was developed through a multi -step process. First, a 3D model of the site hydrostratigraphy was constructed based on historical site construction drawings and field data. Once the model domain was determined, a 3D steady-state groundwater model based on the hydrostratigraphy and the site conceptual model was produced. Flow parameters, assigned to the numerical grid, were adjusted during the steady- state flow model calibration process. Once the flow model was calibrated, a transient transport simulation for the selected COls was developed, and then calibrated by adjusting transport parameters and source zone concentrations to best match the observed (2015) concentrations in selected monitoring wells. Three terrain surface models for Allen were created using geographic information systems (GIS) software: 1) current existing surface, 2) pre -construction surface without ash and ash basin dikes, and 3) pre -construction surface with dikes but without ash. An interpolation tool in ArcGIS 10.3 software was used to generate the terrain surfaces as raster datasets with 20-foot cells. Each surface was created to cover the extent of the groundwater model domain. 4.1 Model Hydrostratigraphy The model hydrostratigraphy was developed using historical site construction drawings and borehole data to construct three-dimensional surfaces representing contacts between hydrostratigraphic units with properties provided in CSA Tables 11-8 through 11-12 (HDR 2015). 1) Existing Ground Surface Topographic and bathymetric elevation contours and spot elevations were produced from surveys conducted in 2014. Since these surveys did not cover the entire model extent, elevation data extracted as spot elevations from the North Carolina Floodplain Mapping Program's 2010 LiDAR elevation data were used for the areas surrounding the surveys. At Allen, simplified elevation contours were digitized along the river channels to depress the surface a small amount below water level. 2) Pre -construction Surface Elevation contours of the original ground surface were digitized in CAD from engineering drawings supplied by Duke Energy. These data were imported into GIS, and georeferenced. These contours were trimmed to the areas underlying ash basins, dams, dikes and ash storage areas. The source data used in the existing surface were then replaced by the original surface data where there was overlap. Elevation data from coal storage areas were removed. The pre - construction surface was then created using the combination of original surface elevations, 2014 survey elevations, and 2010 LiDAR elevations. 3) Pre -construction Surface with Dikes Surface models of the ash basin dams and dikes were constructed from crest elevations as determined from the 2014 survey and slopes given on the engineering drawings. Only the 10 sections of the dams and dikes facing the ash basins were modeled in this way. The 2014 survey data were used for dike/dam crests and outwardly facing surfaces. These surfaces were merged with the pre -construction surface. These GIS data sets were exported into formats readable by RockWorks and GMS MODFLOW. 4) 3-D Hydrostratigraphic Grids The natural materials in the CSA boreholes and existing boreholes were assigned a hydrostratigraphic layer using the above classification scheme and judgment and the borehole data entered into RockWorks 16TM for 3-D modeling. In the portions of the area to be modeled for which borehole data is not available, dummy boreholes were used to extend the model to the model boundaries. These boreholes were based on the hydrostratigraphic thickness of the existing boreholes and the elevation of the existing boreholes based on the assumption that the hydrostratigraphic layers are a subdued replica of the original topography of the site and geologic judgment. The grid of the pre -construction ground surface (described above) was used to constrain the modeling of the natural layers. For gridding the data on a 20 ft x 20 ft grid across the area to be modeled, a hybrid algorithm was used with inverse distance weighted two (2) and triangulation weighted one (1) and declustering, smoothing, and densifying subroutines. The declustering option is used to remove duplicate points and de -cluster clustered points. The option creates a temporary grid with a z-value assigned based on the closet data point to the midpoint of a voxel. The smoothing option averages the z-values in a grid based on a filter size. For this modeling, the z-value is assigned the average of itself and that of the eight nodes immediately surrounding it. One smoothing pass is made. The densify option adds additional points to the xyz input by fitting a Delaunay triangulation network to the data and adding the midpoint of each triangle to the xyz input points. The net result is that the subsequent gridding process uses more control points and tends to constrain algorithms that may become creative in areas of little control. Only one densification pass is made. The completed model grids were exported in spreadsheet format for use in the groundwater flow and transport model. 4.2 GMS MODFLOW Version 10 The conceptual model approach to construct a MODFLOW simulation in GMS MODFLOW consists of employing GIS tools in a Map module to develop a conceptual model of the site being modeled. The location of sources/sinks, layer parameters (such as hydraulic conductivity), and all other data necessary for the simulation can be defined at the conceptual model level. Once this model is complete, the grid is generated and the conceptual model is converted to the grid model and all of the cell -by -cell assignments are performed automatically. The following table presents the sequence of the steps used for the groundwater modeling. Steps 1 through 6 describe the creation of 3D MODFLOW model. 11 Step 1. Creating raster files for the model layer 3 surface layers (pre -construction, pre -construction with dike, and existing surface including dike and ash) using GIS and AutoCAD 2 subsurface layers transition TZ and bedrock BR by converting 3D scatter data Step 2. Creating the Raster Catalog to group the raster layers Assigning Horizons and materials for each layer Step 3. Creating horizon surfaces (i.e. TIN) from raster data Used exiting surface and bedrock rasters Step 4. Building Solids from the Raster Catalog and TINs Used raster data for the top and bottom elevations of the solids Step 5. Creating the conceptual model Building model boundary, specified head boundary Defining zones and assigning hydraulic conductivity and recharge rate Importing observation wells and surface flow data Step 6. Creating the MODFLOW 3D grid model Converting the solids to 3D grid model using boundary matching Mapping the conceptual model to 3D MODFLOW grid Step 7. Flow model calibration/Sensitivity Analysis Initializing the MODFLOW model Steady-state calibration with the trial -and error method Parameters: hydraulic conductivity and recharge rate Used observation well and surface flow data Step 8. Setting the transport model (MT3DMS) Species Stress periods Porosity and dispersion coefficient Distribution coefficient (Kd) from the lab experiments Recharge concentrations Step 9. Performing model simulations Model scenarios — 1) Existing Conditions, 2) Cap in -place, and 3) Excavation/removal of ash 4.3 Model Domain and Grid The model domain encompasses the Allen site, including a section of the Catawba River and all site features relevant to the assessment of groundwater associated with the ash basins. Figure 1 shows the conceptual groundwater flow model and model domain. The model domain extends beyond the ash management areas to hydrologic boundaries so groundwater flow and COI transport through the area is accurately simulated without introducing artificial boundary effects. The bounding rectangle around the model domain extends 9,000 feet north to south and 6,000 feet east to west and has a grid consisting of 306,802 active cells in ten layers. In plan view, the Allen model domain is bounded by the following hydrologic features of the site. • the western shore of the Catawba River (Lake Wylie) to the east; • the groundwater divide corresponding to the topographic divide to the north along Plant Allen Road; • the groundwater divide corresponding to the topographic divide to the east along NC 273/South Pointe Road; and 12 • the groundwater divide corresponding to the topographic divide to the south along Reese Wilson Road and Bell Post Road. The domain boundary was developed by manually digitizing the topographic divides using a base map containing 2-foot Lidar contours. The lower limit of the model domain coincides with an assumed maximum depth of water yielding fractures in bedrock. This was estimated to be 80 feet below the base of the transition zone across the site upper limit based on a review of boring logs contained in the CSA (HDR 2015). There are a total of 10 model layers divided among the identified hydrostratigraphic units to simulate flow with a vertical flow component. The units are represented by the model layers listed below: • Model layers 13 Ash Material • Model layers 2— - 4 Dike and Ash Storage Material • Model layer 5 and 6 M1 Saprolite and Alluvium where present • Model layer 7 M2 Saprolite • Model layer 8 TZ Transition Zone • Model layers 9 and 10 Fractured Bedrock In the groundwater flow model, fractured bedrock was simulated as an equivalent porous medium. The materials comprising each layer and typical layer thicknesses are shown in the north -south and east -west cross -sections through the ash basins in Figure 2 and Figure 3. 4.4 Hydraulic Parameters Horizontal and vertical hydraulic conductivities, which are specific for each hydrostratigraphic unit, are the primary determinants of groundwater flow for a given configuration of boundary conditions and sources and sinks, including recharge. Field measurements of these parameters from CSA Tables 11-8 through 11-12 (HDR 2015) provided guidance for their selection during the flow model calibration. Values assigned to the model are shown in Table 2. 4.5 Flow Model Boundary Conditions Boundary conditions for the Allen flow model are constant head. The outer boundary of the model domain was selected to coincide with physical hydrologic boundaries at rivers and drainage features, and no flow boundaries at groundwater divides corresponding to topographic divides (Section 2.5 and Figure 4). At the Catawba River, constant head boundaries representing the river stage elevation were applied to those layers above fractured bedrock (Layers 9 and 10) with bottom elevations below the water surface interpolated from photogrammetric surveys. It is noted that constant head boundary conditions may not be valid for groundwater extraction as a corrective action alternative. In this case, the constant head boundary assumption should be validated by a pump test or other means. 13 4.6 Flow Model Sources and Sinks Recharge is the only water source considered in the model. . The mean annual recharge in the Piedmont ranges from 4.0 to 9.7 inches per year (Daniel 2001). Recharge applied in the model is 5.0 inches per year outside the ash basin and 8.5 inches per year inside the ash basin, except where the RAB Ash Landfill is located where a rate of zero (0) inches per year was applied, as shown in Figure 5. The CSA does not consider any effect that extraction wells may have on groundwater flow at the site, nor does it identify other sources or sinks (see Section 2.7). 4.7 Flow Model Calibration Targets The steady-state flow model calibration targets are the 66 static water level measurements taken in observations made in July 2015. The observation wells included 32 wells screened in the ash, dikes, and shallow saprolite zones (S/M1/M2), 27 wells screened in the deep transition zone; and eight (7) wells screened in fractured bedrock. The observation wells in shallow (M1/M2), deep (TZ), and bedrock (BR) groundwater zones are shown in Figures 6, 7, and 8. Observations were assigned by layer as shown in Table 3. 4.8 Transport Model Parameters The calibrated, steady-state flow model was used to apply flow conditions for the transport model at the active ash basin and the inactive ash basin (HDR Figures 2-2 and 2-4) where the elevated concentrations of COls were detected during the June/July 2015 sampling event. Although their approximate dates of operation are known, the sluiced ash loading histories for these locations are not available. In order to calibrate the transport model to existing conditions, constant concentration source zones were applied at the ash (model layer 4) in the active and inactive ash basins starting from the date when the first ash basin was placed in service (i.e., 1957). The relevant input parameters are the constant boundary concentrations and the linear sorption coefficient (Kd) for sorptive constituents (including all Cols, except for boron and sulfate). Because a portion of the inactive ash basin was covered by the lined RAB Ash Landfill, the constant concentration in the inactive ash basin at that location was simulated as being covered and receives no recharge. This is discussed further in Section 4.10. The conceptual transport model specifies that Cols enter the model from the shallow saturated source zones in the ash basins. When the measured Kd values are applied in the numerical model to COls migrating from the source zones, some COls do not reach the downgradient observation wells where they were observed in June/July 2015 at the end of the simulation period. The most appropriate method to calibrate the transport model in this case is to lower the Kd values until an acceptable agreement between measured and modeled concentrations is achieved. Thus, an effective Kd value results that likely represents the combined result of intermittent activities over the service life of the ash basin. These may include pond dredging, dewatering for dike construction, and ash grading and placement. This approach is expected to produce conservative results, as sorbed constituent mass is released and transported downgradient. The Kd values for the Cols were applied as follows: 14 • Antimony: 0.1 ml/g • Barium: 0.7 ml/g • Boron: conservative (sorption not modeled) • Cobalt: 0.1 ml/g • Sulfate: conservative (sorption not modeled) • Vanadium: 0.5 ml/g • Chromium: 0.4 ml/g • Hexavalent Chromium: 0.5 ml/g • Selenium: 0.1 ml/g • Arsenic: 0.8 ml/g Preliminary results for sorption studies on soil samples obtained during the CSA at Allen indicate that the approximate minimum Kd for arsenic of native soils in or near the ash basins is 10 ml/gram in the transition zone and 200 ml/gram in the shallow zone (Langley and Oz 2015). Sorption was considered to be a calibration parameter as discussed above, and in Section 5.3. The bulk density used in the model is 2.65 grams/cubic centimeter for saprolite, TZ, and bedrock materials, and 2.12 grams/cubic centimeter for ash and dike materials. The velocity of COls in groundwater is directly related to the effective porosity of the porous medium. Effective porosity applied was estimated based on the values reported in the CSA (Table 11-9 and 11-12). All values applied to the model are shown in Table 4. Dispersivity is a physical property of the aquifer medium and is normally a fraction of the field scale problem (i.e., plume length), commonly 10% (Zheng and Bennett [20021). The dispersivity quantifies the degree to which mechanical dispersion of COls occurs. Dispersivity values of 80 ft, 8 ft, and 0.8 ft (longitudinal, transverse horizontal, transverse vertical) were applied in this model. In order to avoid artificial oscillation in the numerical solution to the advection dispersion equation, the grid Peclet number, or the ratio of grid spacing to longitudinal dispersivity, should be less than two (Zheng and Bennett [20021). Directly beneath the ash basin system, shallow groundwater flow is vertical downward. In this case, the grid Peclet number criteria will not be met due to the relatively small value for vertical dispersivity and the relatively large grid spacing, or thickness of the model layers at depth. The effect of numerical oscillation on modeled concentration and mass transport is indeterminate. However, any effect is considered to be limited as vertical groundwater flow transitions to horizontal over a short distance beneath the ash basin system. 4.9 Transport Model Boundary Conditions The transport model boundary conditions have zero concentration where water leaves the model. Initial concentrations, and concentrations in infiltrating recharge water, are zero. No background concentration is specified. The inactive and active ash basins are represented by constant concentration boundary conditions. 4.10 Transport Model Sources and Sinks The active and inactive ash basins are the sources for COls in the model. During the transport model calibration and the existing conditions scenario, the sources were modeled as constant concentration cells in the saturated portions of the ash (model layer 4) of the ash basin (Figure 15 5). Their magnitudes are based on COI measurements in the shallow zone from the June/July 2015 sampling event and are further refined during model calibration, as described in Section 5.3. The source zone for the inactive ash basin is covered in part by the lined RAB Ash Landfill. Recharge to this area beneath the landfill was set to zero to represent the effects of the overlying landfill liner system. The transport model sinks correspond to the constant head boundaries of the flow model. Water and COI mass are removed as they enter cells comprising these boundaries. 4.11 Transport Model Calibration Targets The calibration targets are the measured COI concentrations for the June/July 2015 sampling event as shown in CSA Tables 7-6 and 10-8 (HDR 2015). Specific calibration targets for the transport model calibration are discussed in Section 5.3. 5 MODEL CALIBRATION TO CURRENT CONDITIONS 5.1 Flow Model Residual Analysis The flow model was calibrated to the water level observations obtained during June 2015 in the shallow, deep, and bedrock wells (Table 3). The water table elevation in the ash basin cells and selected depressions across the site were also considered as calibration targets. The observation data from this single point in time were used as a flow model calibration data set. The locations of the observation wells are provided in Figures 6, 7, and 8. The initial trial -and - error calibration assumed homogeneous conditions in each model layer. Recharge was also fixed at reasonable values early in the calibration process, and then refinements were made by adjusting hydraulic conductivity zones, as shown in Figures 9, 10,11, and 12. The basis for delineating the zones in this way was to obtain the best local calibration using conductivity values within the range of measurements from monitor well testing as documented during the CSA (HDR 2015). The calibrated flow model parameters are provided in Table 2. Modeled and observed water levels (post -calibration) are compared in Table 3 and Figure 13. The calibrated flow model is assumed to represent long term, steady-state flow conditions for the site and the ash basin system under long-term, average conditions. This assumption should be verified as additional data are collected from the existing and any additional monitoring wells. The square root of the average square error (also referred to as the root mean squared error, or RMS error) of the modeled versus observed water levels for wells gauged in June 2015 is also provided in Table 3. The model calibration goal is an RMS error less than 10% of the change in head across the model domain. The ratio of the average RMS error to total measured head change is the normalized root mean square error (NRMSE). The NRMSE of the calibrated model is 9.5%. Contours of hydraulic heads in the calibrated flow model are shown for the shallow groundwater zone (model layer 6) in Figure 14. Groundwater flow transitions from vertical to primarily horizontal flow directly beneath the ash basins due to the absence of a dike or fill layer beneath the ash and above the shallow zone. Groundwater within the shallow, deep, and bedrock zones 16 flows from the west and southwest to the east and discharges to the Catawba River. Locally the water table gradient is reduced beneath Primary Ponds 1 through 3, and increased beneath the RAB Ash Landfill and the southeastern portion of the active ash basin. Steep hydraulic gradients are associated with the North, East and RAB Dikes. 5.2 Transport Model Calibration For the transport model calibration, the calibration parameters consisted of the constant source concentrations, porosity and the linear sorption coefficient (Kd) for each COI. These parameters were adjusted to minimize residual concentrations in target wells. The model assumed an initial concentration of 0 within the groundwater system for all Cols at the beginning of operations approximately 58 years ago. A source term matching the pore water concentrations for each COI was applied within the inactive ash basin, active ash basin and the ash storage areas at the start of the calibration period. The source concentrations were adjusted to match measured values in the downgradient monitoring wells that had exceedances of the 2L Standard for each COI in June 2015. Calibration results comparing measured versus predicted model concentrations are provided in Table 5 for the modeled COls. Table 5 also shows the calibration source concentrations in the inactive ash basin, active ash basin and the ash storage areas. The locations of the monitoring wells are provided in Figures 6, 7, and 8. These calibration parameters were used in the transport model to simulate the initial (2015) concentrations in the shallow, deep and bedrock groundwater flow zones of each COI for each closure simulation. COI 5.3 Advective Travel Times Particle tracking was performed during model calibration to determine if advective travel times are reasonable. Particles were placed at wells located near the Catawba River and also near the western model boundary. The particle tracks are shown in Figure 15 and predicted advective travel times are provided in Table 6. 5.4 Flow and Transport Model Sensitivity Analysis Sensitivity model runs were performed to evaluate the parameters with the greatest influence on the modeled hydraulic heads and COI concentrations when key transport parameters are varied. Sensitivity of the flow model was considered by varying selected parameters by 20% above and below their respective calibration values and calculating the NRMSE for comparison with the calibration value as shown in Table 7. In addition to the flow model sensitivity analysis, the calibrated transport model parameters, including effective porosity and sorption coefficient (Kd), were varied by 20% above and below their respective calibration values to determine the affect on COI transport. The average modeled concentration change relative to the calibrated concentration of arsenic and boron at monitoring wells, used during transport model calibration, were calculated to show the transport model sensitivity. Based on this approach, the flow model was most sensitive to increased and decreased horizontal hydraulic conductivity of the shallow aquifer, followed by decreased recharge outside the ash basins, and then decreased recharge within the ash basins. The model was less sensitive to changing vertical hydraulic conductivity in the shallow and transition zones (S/M 1 /M2/TZ), as groundwater flow is dominantly horizontal in these hydrostratigraphic layers. 17 Arsenic concentrations were most sensitive to increased recharge in areas outside the ash basins, followed by Kd and then horizontal hydraulic conductivity of the shallow hydrostratigraphic layers (S/M1/M2). The concentrations of arsenic were the least sensitive to changing vertical hydraulic conductivity in the transition zone (TZ) (Table 7). The Kd relates the adsorbed COI concentration to the concentration of the COI dissolved in water. Non -reactive, or conservative COIs, which at this site include boron and sulfate, are assumed to have a Kd of zero and therefore move at advective flow rates (average linear groundwater velocity). The movement of reactive COIs, such as arsenic and chromium is retarded by sorption. A decrease of Kd increases the rate of COI transport resulting in increased concentrations at downgradient monitoring wells by the end of the calibration period (58 years). An increase of Kd decreases the rate of COI transport resulting in decreased concentrations in downgradient monitoring wells by the end of the calibration period (58 years) (Table 7). Boron concentrations were most sensitive to both increased and decreased horizontal hydraulic conductivity of the shallow hydrostratigraphic layers (S/M1/M2) and increased and decreased recharge inside the ash basins. The concentrations of boron were the least sensitive to changing vertical hydraulic conductivity in the transition zone (TZ) (Table 7). Effective porosity of a porous medium is the porosity that is available for continuous fluid flow through the material. The effective porosity primarily affects the velocity at which fluid can move through a material where a smaller value increases fluid velocity and a greater value decreases fluid velocity. Boron and arsenic concentrations are relatively unaffected by increasing or decreasing the effective porosity in the transport model sensitivity runs. Longitudinal dispersivity is an empirical factor quantifying how much contaminants stray away from a path parallel to the primary direction of groundwater flow, or how much of the contaminant moves faster than or slower than the average groundwater velocity. Increasing dispersivity results in increased COI concentrations at the leading edge of the plume as dissolved COI mass is spread more easily throughout the aquifer when a relatively high dispersivity value is applied. 6 SIMULATION OF CLOSURE SCENARIOS The groundwater model, calibrated for flow and constituent fate and transport under existing conditions, was applied to evaluate four ash basin closure scenarios at Allen: 1) the Existing Conditions scenario; the 2) ash basin Cap -in -Place scenario; and the 3) Excavation scenario (ash removal), which comprises a combination of excavation, partial excavation, and capping over some of the ash basin. Being predictive, these simulations produce flow and transport results for conditions that are beyond the range of those considered during the calibration. Thus, the model should be recalibrated and verified over time as new data becomes available in order to improve its accuracy and reduce its uncertainty. The model domain developed for existing conditions was applied without modification for the Existing Conditions and Cap -in -Place scenarios. For the Excavation scenario, the basins were removed. The flow parameters for this model were identical to the Existing Conditions scenario, except for the removal of ash related layers, and the same recharge being applied to the ash basin as the remainder of the site. Similarly for the Hybrid Cap, excavated areas have ash related layers removed and recharge adjusted. in 6.1 Existing Conditions The Existing Conditions scenario consists of modeling each constituent using the calibrated models for flow and transport under the existing conditions across the site for 250 years into the future. This length of time is sufficient in allowing near -steady-state concentrations to be reached across the site and at the compliance boundary. Concentrations can only increase initially for this scenario with source concentrations being held at their constant value the entire simulated time period. Thereafter, the concentrations and mass flux of dissolved constituents at the compliance boundary remain constant. This scenario represents the worst case in terms of groundwater concentrations on and offsite, and COls discharging to the Catawba River. The time to achieve a steady-state concentration plume depends on the source zone location relative to the compliance boundary and its loading history. Source zones close to the compliance boundary will cause steady-state conditions to be reached relatively faster. The time to steady-state concentration is also dependent on the sorptive characteristics of each COI. Sorptive COls will be transient for a longer time period as their peak breakthrough concentration travels at a rate that is less than the groundwater pore velocity. Lower effective porosity will result in shorter times to achieve steady-state for sorptive and non-sorptive COls. Concentration contours and concentration breakthrough curves are all referenced to a time zero that represents the time the closure action was implemented, which for the purposes of modeling is assumed to be 2016. The scenario models COI concentrations forward from the end of the 58 year simulation and represents 2015 as the initial concentrations. Figures 16 and 17 show predicted antimony concentrations versus time at representative monitoring wells under all three model scenarios. The concentration versus time curves show that under the Existing Conditions scenario, antimony concentrations increase at downgradient wells over the modeled time period of 250 years after 2015. Antimony concentrations remain elevated above the Interim Maximum Allowable Concentration (IMAC) for antimony, which is 1 pg/l, at all wells under the Existing Conditions scenario at the compliance boundary. Figures 18 through 20 show the shallow, deep and fractured bedrock zones in 2015 and Figures 21 through 23 show them in 2115, or in 100 years. Antimony exits the model with groundwater discharging at the Catawba River to the east of the site in all zones in 2015 and 2115. In 2115, the shallow groundwater zone has the highest concentrations. Figures 30 and 31 show predicted arsenic concentrations versus time at representative downgradient monitoring wells under all three scenarios. The concentration versus time curves show that under the Existing Conditions scenario, arsenic concentrations in monitoring well AB- 22S increase over time, but remain below the 2L Standard of 10 pg/I and nearly reach steady- state conditions near the end of the modeling period. Monitoring well GWA-6S arsenic levels continue increasing through the model period with concentrations above the 2L Standard. Figures 32 though 34 and Figures 35 through 37 show the shallow, deep and fractured bedrock zones in 2015 and 2115, respectively. Under existing conditions, arsenic is above the 2L Standard at the compliance boundary downgradient of the inactive ash landfill in all model layers and below the 2L Standard downgradient of the active ash basin. Figures 44 and 45 shows predicted barium concentrations versus time at representative downgradient monitoring wells under all three scenarios. The concentration versus time curves show that under the Existing Conditions scenario, barium concentrations remain below the 2L 19 Standard, which is 700 pg/I, in monitoring well AB-22S and AB-26S and approach steady-state conditions near the end of the modeling period. Figures 46 through 48 and Figures 49 through 51 show the shallow, deep and fractured bedrock zones in 2015 and 2115, respectively. Barium is not above the 2L Standard at the compliance boundary in 2015, but is predicted to approach the 2L Standard in 2115 within the shallow zone at the compliance boundary downgradient of the retired ash landfill. Figures 58 through 61 show predicted boron concentrations versus time at representative downgradient monitoring wells under all three scenarios. The concentration versus time curves show that under the Existing Conditions scenario, boron concentrations remain elevated above the 2L Standard, which is 700 pg/l, and concentrations reach steady state for the entire modeling period in wells AB-22D, AB-26S, GWA-4S and GWA-5BR. Figures 62 through 64 and Figures 65 through 67 show the shallow, deep and fractured bedrock zones in 2015 and 2115, respectively. Barium is above the 2L Standard at the compliance boundary in 2015, and is predicted to remain above 2L Standard in 2115 downgradient of the retired ash landfill and the active ash basin. Figures 74 and 75 show predicted chromium concentrations versus time at representative downgradient monitoring wells under all three scenarios. The concentration versus time curves show that under the Existing Conditions scenario, chromium concentrations remain elevated above the 2L Standard, which is 10 pg/l, for the entire modeling period in monitoring well AB-6R and exceeds the 2L Standard at monitoring well AB-26D by 2125. Figures 76 through 78 and Figures 79 through 81 show the shallow, deep and fractured bedrock zones in 2015 and 2115, respectively. Chromium is above the 2L Standard at the compliance boundary in 2015, and is predicted to remain above 2L Standard in 2115 downgradient of the retired ash landfill and the active ash basin. Figures 88 through 91 show predicted hexavalent chromium concentrations versus time at downgradient monitoring wells under all three model scenarios. The concentration versus time curves show that under the Existing Conditions scenario, hexavalent chromium concentrations remain elevated above the North Carolina Department of Health and Human Services (DHHS) health screening level (HSL), which is 0.07 pg/l, and increase over time. Figures 92 through 94 and Figures 95 through 97 show the predicted hexavalent chromium concentrations in the shallow, deep and fractured bedrock zones in 2015 and 2115, respectively. Hexavalent chromium is above the DHHS HSL at the compliance boundary in 2015, and is predicted to remain above DHHS HSL in 2115 downgradient of the retired ash landfill and the active ash basin. Figures 104 through 107 show predicted cobalt concentrations versus time at downgradient monitoring wells under all three model scenarios. The concentration versus time curves show that under the Existing Conditions scenario, cobalt concentrations remain elevated above the IMAC, which is 1 pg/I, and increase over time. Figures 108 through 110 and Figures 111 through 113 show the predicted cobalt concentrations in the shallow, deep and fractured bedrock zones in 2015 and 2115, respectively. Cobalt is above the IMAC at the compliance boundary in 2015, and is predicted to remain above the IMAC in 2115 downgradient of the retired ash landfill and the active ash basin. Figures 120 and 121 shows predicted selenium concentrations versus time at monitoring wells GWA-6S and AB-22S, respectively, under all three model scenarios. Monitor Well GWA-6S is 20 downgradient of the inactive ash basin and shows elevated selenium above the 21 Standard of 20 ug/L. AB-22S is downgradient of the active ash basin and is not above the 2L Standard. Figures 122 through 124 and Figures 125 through 127 show the predicted selenium concentrations in the shallow, deep and fractured bedrock zones in 2015 and 2115, respectively. Selenium is above the 2L Standard at the compliance boundary in 2015 downgradient of the retired ash landfill in the shallow and deep groundwater zones, and is predicted to remain above the 2L Standard in 2115 downgradient of the retired ash landfill. Figures 134 and 135 show predicted sulfate concentrations versus time at downgradient monitoring wells under all three model scenarios. In well AB-33S sulfate concentrations exceed the 2L Standard of 250,000 pg/I about 10 years after initial use of the inactive ash basin. Concentration of sulfate in well GWA-6S does not exceed the 2L Standard. Figures 136 through 138 and Figures 139 through 141 show the predicted sulfate concentrations in the shallow, deep and fractured bedrock zones in 2015 and 2115, respectively. Sulfate is above the 2L Standard at the compliance boundary in 2015 downgradient of the retired ash landfill in the shallow and deep groundwater zones, and is predicted to remain above the 2L Standard in 2115 downgradient of the retired ash landfill. Figures 148 through 151 show predicted vanadium concentrations versus time at representative monitoring wells under all three model scenarios. The concentration versus time curves show that under the Existing Conditions scenario, vanadium concentrations increase over the course of the model time period. Concentrations generally continue to increase over time without reaching a steady-state. Vanadium concentrations at all monitoring wells exceed the IMAC, which is 0.3 pg/I. Figures 152 through 154 and Figures 155 through 157 show the predicted vanadium concentrations in the shallow, deep and fractured bedrock zones in 2015 and 2115, respectively. Vanadium is above the IMAC at the compliance boundary in 2015 downgradient of the retired ash landfill and the active ash basin in all groundwater zones, and is predicted to remain above the IMAC in 2115 downgradient at the compliance boundary. 6.2 Cap -in -Place The Cap -in -Place scenario simulates the effects of covering the ash basins at the beginning of the predictive simulation with an impermeable cap. In the model, recharge and source zone concentrations at the ash basins are set to zero. Groundwater flow is affected by this scenario as the water table is lowered and groundwater velocities may be reduced beneath the capped areas. Near the center of the inactive ash basin, the water table is lowered by approximately 26 ft relative to the level simulated under the Existing Conditions scenario. In the active ash basins, the difference in water level is approximately 36 ft. In the model, non-sorptive COls will move downgradient at the pore velocity of groundwater and will be displaced by the passage of a single pore water volume, while sorptive COI's migration in groundwater is retarded because of sorption with soils/rocks. The model uses the predicted concentration from the 2015 calibration as the initial concentration at the start of the model scenario. Figures 16 and 17 show predicted antimony concentrations versus time at representative monitoring wells under all three model scenarios. The concentration versus time curves show that under the Cap -in -Place scenario, antimony concentrations decrease and remain above the IMAC throughout the modeling period. Figures 24 through 26 show the predicted antimony concentrations under this scenario in the shallow, deep and fractured bedrock zones, 21 respectively, at 100 years post closure implementation. Antimony remains above the IMAC at the compliance boundary at the Catawba River downgradient of the active and inactive ash basins. Figures 30 and 31 show predicted arsenic concentrations versus time at representative downgradient monitoring wells under all three scenarios. The concentration versus time curves show that under the Cap -in -Place scenario, arsenic concentrations begin to decrease upon implementation, but remain above the 2L Standard through the modeling period at monitoring well AB-22S. For monitoring well GWA-6S, this area of the model goes dry due to lack of recharge. Figures 38 through 40 show the shallow, deep and fractured bedrock zones in 2115, or 100 years post closure implementation. Arsenic remains above the 2L Standard at the compliance boundary at the Catawba River downgradient of the inactive ash basin. Figures 44 and 45 shows predicted barium concentrations versus time at representative downgradient monitoring wells under all three scenarios. The concentration versus time curve shows that under the Cap -in -Place scenario, barium concentrations decrease upon implementation and decrease slowly throughout the modeling period and remain below the 2L Standard in the downgradient monitoring wells throughout the 250 year modeling period. Figures 52 through 54 show the shallow, deep and fractured bedrock zones in 2115, or 100 years post closure implementation. Barium remains below the 2L Standard at the compliance boundary at the Catawba River downgradient of the inactive ash basin and active ash basin. Figures 58 through 61 show predicted boron concentrations versus time at representative downgradient monitoring wells under all three scenarios. The concentration versus time curves show that under the Cap -in -Place scenario, boron concentrations in all wells decrease sharply immediately after implementation. Figures 68 through 70 show the shallow, deep and fractured bedrock zones in 2115, or 100 years post closure implementation. Boron is below the 2L Standard at the compliance boundary at the Catawba River downgradient of the inactive ash basin and active ash basin. Figures 74 and 75 show predicted chromium concentrations versus time at representative downgradient monitoring wells under all three scenarios. The concentration versus time curve at AB-26D shows that under the Cap -in -Place scenario, chromium concentrations increase upon implementation, but remain below the 2L Standard throughout the modeling period. At well AB-6R, chromium concentrations decrease, but remain above the 2L Standard until 2225, or 210 years after closure implementation. Figures 82 through 84 show the shallow, deep and fractured bedrock zones in 2115, 100 years after closure implementation. Chromium is above the 2L Standard at the compliance boundary at the Catawba River downgradient of the inactive ash basin and active ash basin in the shallow, deep, and bedrock zones. Figures 88 through 91 show predicted hexavalent chromium concentrations versus time at downgradient monitoring wells under all three model scenarios. The concentration versus time curves show that under the Cap -in -Place scenario, hexavalent chromium concentrations increase after implementation and continue to increase (AB-91D) or remain steady (AB-31S & GWA-31D) during the model period. Figures 98 through 100 show the shallow, deep and fractured bedrock zones under this scenario in 2115, 100 years after closure implementation. Hexavalent chromium remains above the DHHS HSL at the compliance boundary at the Catawba River. 18JOIJ Figures 104 through 107 show predicted cobalt concentrations versus time at downgradient monitoring wells under all three model scenarios. The concentration versus time curves show that under the Cap -in -Place scenario, cobalt concentrations show an overall decrease over time, but remain above the IMAC. Figures 114 through 116 show the shallow, deep and fractured bedrock zones under this scenario in 2115, 100 years after closure implementation. Under the Cap -in -Place scenario, cobalt remains above the IMAC at the compliance boundary at the Catawba River. Figures 120 and 121 shows predicted selenium concentrations versus time at monitoring wells GWA-6S and AB-22S, respectively, under all three model scenarios. The concentration versus time curves show that under the Cap -in -Place scenario, selenium concentrations decrease below the 2L Standard following closure implementation. Figures 128 through 130 show the shallow, deep and fractured bedrock zones under this scenario in 2115. Selenium is associated with the inactive ash storage basin and is highest in the shallow layer. Under the Cap -in -Place scenario, selenium remains above the 2L Standard at the compliance boundary at the Catawba River in the deep and bedrock zones, but is above the 2L Standard within the shallow zone. Figures 134 and 135 show predicted sulfate concentrations versus time at downgradient monitoring wells under all three model scenarios. The concentration versus time curves show that under the Cap -in -Place scenario, the monitor wells downgradient of the active ash basin go dry due to reduced recharge to the groundwater system. Figures 142 through 144 show the shallow, deep and fractured bedrock zones under this scenario in 2115, 100 years after closure implementation. Sulfate concentrations under the Cap -in -Place scenario fall below the 2L Standard at the compliance boundary at the Catawba River downgradient of the inactive ash basin and active ash basin. Figures 148 through 151 show predicted vanadium concentrations versus time at representative monitoring wells under all three model scenarios. The concentration versus time curves show that under the Cap -in -Place scenario, vanadium concentrations increase over time and then remain fairly constant. Figures 158 through 160 show the shallow, deep and fractured bedrock zones under this scenario in 2115, 100 years after closure implementation. Vanadium concentrations under the Cap -in -Place scenario remain above the IMAC at the compliance boundary at the Catawba River downgradient of the inactive ash basin and active ash basin. 6.3 Excavation In the Excavation scenario, all ash from the ash basins and ash storage areas is removed and transported offsite. In the model, the constant concentration sources and all ash above and below the water table are removed. Unlike the Cap -in -Place scenario, this scenario assumes recharge rates become equal to rates surrounding the ash basins, except for the RAB Ash Landfill where the recharge rate remains zero (0) inches per year in all scenarios (see Figure 5). Starting from the time that excavation is complete, COls already present in the groundwater continue to migrate downgradient as clean water infiltrates from ground surface and recharges the aquifer at the water table. The COls are flushed from the saturated zone beneath the source areas. COI migration is retarded relative to the pore water velocity as sorptive COls adsorb to the soil/rock surfaces. The model uses the predicted concentration from the 2015 calibration as the initial concentration. 23 Figures 16 and 17 show predicted antimony concentrations versus time at representative monitoring wells under all three model scenarios. The concentration versus time curves show that under the Excavation scenario, antimony concentrations decrease and fall below the IMAC toward the end of the modeling period. Figures 27 through 29 show the predicted antimony concentrations under this scenario in the shallow, deep and fractured bedrock zones, respectively, at 100 years post closure implementation. Antimony remains above the IMAC at the compliance boundary at the Catawba River. Figures 30 and 31 show predicted arsenic concentrations versus time at representative downgradient monitoring wells under all three scenarios. The concentration versus time curves show that under the Excavation scenario, arsenic concentrations decrease upon implementation and fall below the 2L Standard at monitoring well GWA-6S near the end of the simulation. Figures 41 through 43 show the shallow, deep and fractured bedrock zones in 2115 or 100 years post closure implementation. Arsenic remains above the 2L Standard at the compliance boundary at the Catawba River. Figures 44 and 45 shows predicted barium concentrations versus time at representative downgradient monitoring wells under all three scenarios. The concentration versus time curve shows that under the Excavation scenario, barium concentrations decrease upon implementation and decrease slowly throughout the modeling period and remain below the 2L Standard in the downgradient monitoring wells throughout the modeling period. Figures 55 through 57 show the shallow, deep and fractured bedrock zones in 2115, or 100 years post closure implementation. Barium remains below the 2L Standard at the compliance boundary at the Catawba River downgradient of the inactive ash basin and active ash basin. Figures 58 through 61 show predicted boron concentrations versus time at representative downgradient monitoring wells under all three scenarios. The concentration versus time curves show that under the Excavation scenario, boron concentrations in all wells decrease sharply immediately after implementation. Figures 71 through 73 show the shallow, deep and fractured bedrock zones in 2115, or 100 years post closure implementation. Boron is below the 2L Standard at the compliance boundary at the Catawba River downgradient of the inactive ash basin and active ash basin. Figures 74 and 75 show predicted chromium concentrations versus time at representative downgradient monitoring wells under all three scenarios. The concentration versus time curve at AB-26D shows that under the Excavation scenario, chromium concentrations increase upon implementation, but remain below the 2L Standard throughout the modeling period. At well AB- 6R, chromium concentrations decrease, but remain above the 2L Standard until 2075, or 60 years post implementation. Figures 85 through 87 show the shallow, deep and fractured bedrock zones in 2115, 100 years after closure implementation. Chromium is below the 2L Standard at the compliance boundary at the Catawba River downgradient of the inactive ash basin and active ash basin in the deep and bedrock groundwater zones and above the 2L Standard in the shallow groundwater zone. Figures 88 through 91 show predicted hexavalent chromium concentrations versus time at downgradient monitoring wells under all three model scenarios. The concentration versus time curves show that under the Excavation scenario hexavalent chromium concentrations increases after implementation and slowly decreases during the model period. Figures 101 through 103 show the shallow, deep and fractured bedrock zones under this scenario in 2115, 100 years 24 after closure implementation. Hexavalent chromium remains above the DHHS HSL at the compliance boundary at the Catawba River. Figures 104 through 107 show predicted cobalt concentrations versus time at downgradient monitoring wells under all three model scenarios. The concentration versus time curves show that under the Excavation scenario, cobalt concentrations show an overall decrease over time and fall below the IMAC in three out of four monitoring wells. Figures 117 through 119 show the shallow, deep and fractured bedrock zones under this scenario in 2115, 100 years after closure implementation. Cobalt remains above the IMAC at the compliance boundary at the Catawba River. Figures 120 and 121 shows predicted selenium concentrations versus time at monitoring wells GWA-6S and AB-22S, respectively, under all three model scenarios. The concentration versus time curves show that under the Excavation scenario, selenium concentrations decrease below the 2L Standard following closure implementation. Figures 131 through 133 show the shallow, deep and fractured bedrock zones under this scenario in 2115. Under the Excavation scenario, selenium is below the 2L Standard at the compliance boundary at the Catawba River in all groundwater zones. Figures 134 and 135 show predicted sulfate concentrations versus time at downgradient monitoring wells under all three model scenarios. The concentration versus time curves show that under the Excavation scenario, sulfate concentrations decrease to zero shortly after implementation. Figures 145 through 147 show the shallow, deep and fractured bedrock zones under this scenario in 2115, 100 years after closure implementation. Sulfate concentrations under the Excavation scenario fall below the 2L Standard at the compliance boundary at the Catawba River downgradient of the inactive ash basin and active ash basin. Figures 148 through 151 show predicted vanadium concentrations versus time at representative monitoring wells under all three model scenarios. The concentration versus time curves show that under the Excavation scenario, vanadium concentrations increase over time and begin to decrease towards the end of the model scenario. Figures 161 through 163 show the shallow, deep and fractured bedrock zones under this scenario in 2115, 100 years after closure implementation. Vanadium concentrations under the Excavation scenario remain above the IMAC at the compliance boundary at the Catawba River downgradient of the inactive ash basin and active ash basin. 7 SUMMARY AND CONCLUSIONS 7.1 Model Assumptions and Limitations The model assumptions include the following: • The steady-state flow model was calibrated to hydraulic heads measured at observation wells in June 2015 and considered the ash basin water level. The model is not calibrated to transient water levels over time, recharge, or river flow. A steady-state calibration does not consider groundwater storage and does not calibrate the groundwater flux into adjacent surface water bodies. • MODFLOW simulates flow through porous media and groundwater flow in the bedrock groundwater zone is via fractures in the bedrock. A single domain MODFLOW modeling 25 approach for simulating flow in the primary porous groundwater zones and bedrock was used for contaminant transport at the Allen site. • The model was calibrated by adjusting the constant source concentrations at the ash basins and ash storage area to reasonably match 2015 COI concentrations in groundwater. • For the purposes of numerical modeling and comparing closure scenarios, it is assumed that the selected closure scenario will be completed in 2016. • Predictive simulations were performed and steady-state flow conditions were assumed from the time that the ash basins and ash storage area were placed in service through the current time until the end of the predictive simulations (2265). • COI source zone concentrations at the inactive and active ash basins and ash storage area were applied uniformly within each source area and assumed to be constant with respect to time for transport model calibration. • The uncertainty in model parameters and predictions has not been quantified; therefore, the error in the model predictions is not known. It is assumed the model results are suitable for a relative comparison of closure scenario options. • Model results along certain boundaries are impacted by the cell saturation level resulting in some numerical spikes in the calculations that do not represent concentrations in surrounding cells. These numerical spikes are localized calculations and do not impact the overall model results. • Since the Catawba River is modeled as a constant head boundary in the numerical model, it will not be possible to assess the effects of pumping wells or other groundwater sinks that are near the river. • The model does not account for varying geochemical conditions such as pH and redox potential that could affect COI mobility and change modeling results. As identified by HDR, site -specific geochemistry and geochemical modeling will be considered in CAP 2. 7.2 Model Predictions The model predictions are summarized as follows: • The model predicts that all of the closure scenarios will reduce concentrations of antimony. The model predicted the Excavation scenario to be the most effective at reducing antimony concentrations. Under all scenarios, the model predicts concentrations of antimony will exceed the IMAC at the compliance boundary. Concentrations of antimony are greater in shallow portions of the groundwater system than the deep and bedrock groundwater system. • The model predicts that all of the closure scenarios will reduce concentrations of arsenic. The model predicted the Cap -In -Place scenario to be the most effective at reducing arsenic concentrations. Under all scenarios, the model predicts concentrations of arsenic will exceed the 2L Standard at the compliance boundary. Concentrations of arsenic are greater in shallow portions of the groundwater system than the deep and bedrock groundwater system. W • The model predicts that barium is below the 2L Standard at the compliance boundary and that the closure scenarios will further reduce concentrations of barium in all groundwater zones. • The model predicts rapid reduction of boron under the ash basin closure scenarios. The Excavation scenario reduces boron concentrations quicker than the Cap -in -Place option with reduction of boron concentrations below the 2L Standard across the entire model domain by 2115. • The model predicts that all of the closure scenarios will reduce concentrations of chromium. The model predicted the Excavation scenario to be the most effective at reducing chromium concentrations. Under all scenarios, the model predicts concentrations of chromium will exceed the 2L Standard at the compliance boundary in all groundwater zone. Concentrations of chromium are greater in shallow portions of the groundwater system than the deep and bedrock groundwater system. • The model predicts that all of the closure scenarios will reduce concentrations of hexavalent chromium. The model predicted the Excavation scenario to be the most effective at reducing hexavalent chromium concentrations. Under all scenarios, the model predicts concentrations of hexavalent chromium will exceed the DHHS HSL at the compliance boundary in all groundwater zones. Concentrations of hexavalent chromium are greater in shallow portions of the groundwater system than the deep and bedrock groundwater system. • The model predicts that both closure scenarios reduce selenium concentrations below the 2L Standard at the compliance boundary in a short period of time. The Excavation scenario was predicted by the model to be most effective at reducing selenium concentrations. • The model predicts that all of the closure scenarios will reduce concentrations of cobalt. The model predicted the Excavation scenario to be the most effective at reducing cobalt concentrations. Under all scenarios, the model predicts concentrations of cobalt will exceed the IMAC at the compliance boundary in all groundwater zones. Concentrations of cobalt are greater in deeper portions of the groundwater system than the shallow system over time as the plume moves downward. • The model predicts that the closure scenarios will slightly reduce concentrations of vanadium and that the IMAC will be exceeded at the compliance boundary in all groundwater zones. The Excavation scenario is predicted by the model to be most effective at reducing vanadium concentrations. Vanadium concentrations are greater in shallow portions of the groundwater system than in the deep or bedrock zones. • Among the COls, sulfate, and boron are similar in that both are considered conservative; that is, neither has a strong affinity to attenuate nor adsorb to soil/rock surfaces. As a result, the model predicts similar behavior for both of these COls, and other COls with low sorption coefficients (Kd)—rapid and nearly complete reduction predicted under all closure scenarios, with the Excavation scenario proving the most effective. MA 8 REFERENCES Daniel, C.C., III, 2001, Estimating ground -water recharge in the North Carolina Piedmont for land use planning [abs.], in 2001 Abstracts with Programs, 50th Annual Meeting, Southeastern Section, April 5-6, 2001: Raleigh, N.C., The Geological Society of America, v. 33, no. 2, p. A-80. Haven, W.T. Introduction to the North Carolina Groundwater Recharge Map -Groundwater Circular Number 19, North Carolina Department of Environment and Natural Resources Division of Water Quality, Groundwater Section. HDR. Comprehensive Site Assessment Report, ALSS Steam Station Ash Basin, August 2015. Langley, W.G. and Oz, S. Soil Sorption Evaluation for ALSS Steam Station, UNC-Charlotte, in preparation. LeGrand, H. E. 2004. A Master Conceptual Model for Hydrogeological Site Characterization in the Piedmont and Mountain Region of North Carolina, A Guidance Manual, North Carolina Department of Environment and Natural Resources Division of Water Quality, Groundwater Section. Niswonger, R.G., Panday, S., and Ibaraki, M. 2011. MODFLOW-NWT, A Newton formulation for MODFLOW-2005: U.S. Geological Survey Techniques and Methods 6-A37, 44 p. Zheng, C. and Bennett, G. 2002. Applied Contaminant Transport Modeling, Second Edition, Wiley Interscience. Zheng, C. and Wang, P. 1999. MT3DMS, A modular three-dimensional multi -species transport model for simulation of advection, dispersion and chemical reactions of contaminants in groundwater systems, Documentation and Users Guide, U.S. Army Engineer Research and Development Center Contract Report SERDP-99-1, Vicksburg, MS, 202 p. W Table 1. MODFLOW and MT3DMS Input Packages Utilized MODFLOW Input Package Description Name (NAM) Contains the names of the input and output files used in the model simulation and controls the active model program Basic (BAS) Specifies input packages used, model discretization, number of model stress periods, initial heads and active cells Contains finite -difference grid information, including the number Discretization (DIS) and spacing of rows and columns, number of layers in the grid, top and bottom model layer elevations and number of stress periods Specified Head and Specifies a head and/or a concentration that remains constant Concentration (CHD) throughout the simulation Drain (DRN) Acts as a "drain" to remove water from the groundwater system. Simulates drainage areas within the model Recharge (RCH) Simulates areal distribution of recharge to the groundwater system Newton Solver (NWT) Contains input values and the Newton and matrix solver options Upstream Weighting (UPW) Replaces the LPF and/or BCF packages and contains the input required for internal flow calculations Flow Transfer Link File (LMT) Used by MTDMS to obtain the location, type, and flow rates of all sources and sinks simulated in the flow model MT3DMS Input Package Description Flow Transfer Link File (FTL) Reads the LMT file produced by MODFLOW Basic Transport Package (BTN) Reads the MODFLOW data used for transport simulations and contains transport options and parameters Advection (ADV) Reads and solves the selected advection term Dispersion (DSP) Reads and solves the dispersion using the explicit finite - difference formulation Source and Sink Mixing (SSM) Reads and solves the concentration change due to sink/source mixing using the explicit finite -difference formulation Chemical Reaction (RCT) Reads and solves the concentration change due to chemical reactions using the explicit finite -difference formulation Generalized Conjugate Gradient Solves the matrix equations resulting from the implicit solution of (GCG) Solver the transport equation Table 2. Model Hydraulic Conductivity Model Layer Hydrogeologic Unit Measured , Value Range Calibrated Model Value Horizontal Hydraulic Conductivity (feet/day) Horizontal Hydraulic Conductivity (feet/day) Vertical Hydraulic Conductivity (feet/day) 1 - 4 Ash 0.652-19.843 2 0.37 2-4 Dike 0.0074 —0.179 0.004 — 0.008 0.004 — 0.007 5-6 M1-Saprolite 0.210-12.760 S-1 0.70 0.020 S-7 3.98 0.398 S-13 2.33 0.233 S-14 2.07 0.100 S-16 2.70 0.270 S-22 1.00 0.020 S-25 1.50 0.020 7 M2-Saprolite 0.082-3.40 S-5 3.13 0.313 S-7 3.98 0.398 S-10 0.27 0.027 S-12 0.15 0.015 S-13 2.33 0.233 S-14 2.07 0.100 S-16 2.70 0.270 8 TZ 0.156-9.921 S-14 2.07 0.100 S-19 2.80 0.100 S-21 5.00 0.100 9 - 10 BR 0.0145-0.116 S-20 0.01 0.001 S-23 0.1 0.001 S-24 0.001 0.001 'Range = geometric mean +/- one standard deviation (see HDR Tables 11-10) Table 3. Observed vs. Predicted Hydraulic Head (ft MSL) Well Name Model Layer Observed Hydraulic Head (feet) Modeled Hydraulic Head (feet) Sq. Error AB-21 S 2 635.6 634.2 2.0 AB-21 SL 2 635.9 634.2 2.9 AB-24S 2 636.8 627.4 88.4 AB-24SL 2 637.1 627.5 93.7 AB-25S 2 639.9 619.8 403.7 AB-25SL 2 637.0 619.9 294.3 AB-27S 2 638.8 616.7 488.7 AB-28S 2 641.0 625.3 247.3 AB-29S 2 611.1 607.0 16.4 AB-29SL 2 611.4 607.1 18.3 AB-30S 3 617.9 617.1 0.5 AB-39S 3 619.7 617.1 6.6 AB-20S 6 636.9 636.7 0.1 AB-22S 6 595.0 595.7 0.5 AB-23S 6 636.3 629.3 49.0 AB-26S 6 582.1 591.8 96.0 AB-32S 6 582.7 577.2 30.6 AB-33S 6 600.4 598.8 2.7 AB-34S 6 612.7 615.2 6.5 AB-35S 6 619.8 622.5 7.3 AB-36S 6 620.2 628.6 70.7 AB-37S 6 621.1 630.7 91.4 AB-38S 6 624.7 625.0 0.1 GWA-14S 6 627.7 631.6 15.8 GWA-15S 6 625.8 631.6 33.3 GWA-1 S 6 615.2 607.5 60.2 GWA-2S 6 570.5 579.1 73.9 GWA-3S 6 571.5 582.5 121.1 GWA-4S 6 571.7 573.6 3.7 GWA-5S 6 567.2 570.4 10.3 GWA-6S 6 597.3 601.9 21.5 GWA-9S 6 635.7 636.9 1.4 AB-20D 8 636.4 636.6 0.0 AB-21 D 8 635.7 631.8 15.5 AB-22D 8 599.0 593.7 28.7 AB-24D 8 634.7 625.4 85.3 AB-26D 8 583.6 589.7 36.6 Table 3. Observed vs. Predicted Hydraulic Head (ft MSL) (cont.) Well Name Model Layer Observed Hydraulic Head (feet) Modeled Hydraulic Head (feet) Sq. Error AB-27D 8 617.2 606.4 116.6 AB-28D 8 629.3 618.1 125.0 AB-29D 8 612.7 605.9 46.4 AB-30D 8 619.5 617.3 4.8 AB-31 D 8 578.9 578.6 0.1 AB-31 S 8 577.9 578.6 0.5 AB-32D 8 577.0 576.1 0.7 AB-33D 8 594.0 598.2 18.3 AB-34D 8 611.7 615.5 13.9 AB-35D 8 620.5 622.6 4.4 AB-36D 8 620.9 628.6 58.5 AB-37D 8 622.7 630.7 64.0 AB-38D 8 624.3 625.0 0.5 AB-39D 8 619.7 615.7 16.4 GWA-14D 8 626.0 631.5 30.0 GWA-15D 8 625.9 631.5 32.0 GWA-1 D 8 614.7 605.4 87.1 GWA-21D 8 573.3 578.4 26.0 GWA-31D 8 573.8 579.8 35.4 GWA-41D 8 570.8 572.0 1.3 GWA-51D 8 571.2 568.7 6.5 GWA-61D 8 586.7 602.1 236.5 GWA-91D 8 636.7 636.7 0.0 AB-21 BR 10 635.7 631.8 15.3 AB-35BR 10 620.6 622.6 3.9 GWA-1 BR 10 614.3 608.4 34.0 GWA-3BR 10 573.7 579.8 36.8 GWA-5BR 10 562.4 571.1 75.9 GWA-6BR 10 588.6 595.3 45.8 Max 641.0 Sum s.e 3661.7 Min 562.4 No. of wells 66 Max -Min 78.6 Sgrt(Avg s.e.) 7.45 NRMSE 0.095 Table 4. Model Effective Porosity Model Layer Hydrogeologic Unit Effective Porosity 1-3 Ash and Dike Materials 0.14 4 Dike Materials 0.10 5-6 M1 — Saprolite and Alluvium 0.12 7 M2 — Saprolite 0.20 8 Transition Zone 0.01 9 — 10 Bedrock 0.005 Table 5. Transport Model Calibration Results COI Monitoring Well Measured Concentration (pg/L) Predicted Concentration (pg/L) Inactive Ash Basin Constant Concentration = 15 pg/L Ash Storage / Landfill Constant Concentration = 25 pg/L Ash Ponds Constant Concentration = 10 pg/L Active Ash Basin Constant Concentration = 15 pg/L Sorption coefficient [Kd] = 0.1 mL/g Antimony AB-24D 1.30 0.80 AB-26D 2.70 3.29 AB-31 D 6.00 5.95 GWA-14D 1.60 0.00 AB-23BRU 1.10 0.53 Inactive Ash Basin Constant Concentration = 700 pg/L Ash Storage / Landfill Constant Concentration = 700 pg/L Ash Ponds Constant Concentration = 10 pg/L Active Ash Basin Constant Concentration = 10 pg/L Sorption coefficient [Kd] = 0.8 mL/g Arsenic AB-36S 369.00 359.22 GWA-6S 193.00 54.10 AB-22S 0.19 4.37 AB-26S 0.16 1.39 AB-20D 1.70 0.02 AB-21 D 1.20 0.01 Inactive Ash Basin Constant Concentration = 1000 pg/L Ash Storage / Landfill Constant Concentration = 1800 pg/L Ash Ponds Constant Concentration = 600 pg/L Active Ash Basin Constant Concentration = 200 pg/L Barium Sorption coefficient [Kd] = 0.7 mUg AB-22S 64.00 93.92 AB-26S 100.00 104.26 AB-36S 990.00 977.62 Inactive Ash Basin Constant Concentration = 2600 pg/L Ash Storage / Landfill Constant Concentration = 1800 pg/L Ash Ponds Constant Concentration = 600 pg/L Active Ash Basin Constant Concentration = 1800 pg/L Boron Sorption coefficient [Kd] = No Sorption AB-31 S 1,800 1,564 GWA-4S 1,700 1,332 AB-26S 900 1,346 GWA-6S 1,400 448 Table 5. Transport Model Calibration Results (cont.) COI Monitoring Well Measured Concentration (Ng/L) Predicted Concentration (Ng/L) AB-22D 1,400 1,411 Boron (cont.) AB-27D 1,500 1,076 GWA-5BR 750 910 Inactive Ash Basin Constant Concentration = 30 pg/L Ash Storage / Landfill Constant Concentration = 20 pg/L Ash Ponds Constant Concentration = 32 pg/L Active Ash Basin Constant Concentration = 32 pg/L Sorption coefficient [Kd] = 0.4 mL/g AB-6R 15.9 16.8 Chromium AB-5 12.5 0.0 AB-21 D 13.9 0.7 AB-24D 13.3 0.8 AB-26D 29.8 1.7 AB-35D 24.7 0.8 GWA-14D 24.5 0.0 AB-21 BR 18.9 0.0 AB-23BRU 65.6 0.1 Inactive Ash Basin Constant Concentration = 33 pg/L Ash Storage / Landfill Constant Concentration = 45 pg/L Ash Ponds Constant Concentration = 36 pg/L Active Ash Basin Constant Concentration = 36 pg/L Sorption coefficient [Kd] = 0.5 mL/g AB-12S 0.47 0.00 AB-13S 0.43 0.00 AB-31 S 0.16 1.01 AB-4S 0.36 0.05 Hexavalent AB-1 OD 3.00 2.97 Chromium AB-11 D 2.60 0.03 AB-12D 0.10 0.00 AB-14D 0.87 0.00 AB-20D 1.70 0.45 AB-21 D 20.00 0.38 AB-24D 19.00 0.69 AB-29D 0.82 0.91 AB-31 D 1.40 0.80 AB-33D 0.07 1.00 AB-35D 6.10 0.79 Table 5. Transport Model Calibration Results (cont.) COI Monitoring Well Measured Concentration (pg/L) Predicted Concentration (pg/L) AB-36D 0.73 0.56 AB-37D 0.34 0.36 AB-91D 0.64 0.38 GWA-31D 0.92 0.76 Hexavalent GWA-91D 0.64 0.12 Chromium (cont.) AB-1 R 4.00 0.00 AB-21 BR 20.00 0.01 AB-25BRU 0.83 0.31 AB-35BR 2.90 0.06 AB-25BR 4.70 0.00 Inactive Ash Basin Constant Concentration = 38 pg/L Ash Storage / Landfill Constant Concentration = 45 pg/L Ash Ponds Constant Concentration = 38 pg/L Active Ash Basin Constant Concentration = 38 pg/L Sorption coefficient [Kd] = 0.1 mL/g AB-10S 1.60 24.11 AB-13S 1.10 1.68 AB-22S 8.60 30.42 AB-32S 14.30 29.58 AB-34S 40.00 14.36 AB-9S 6.80 19.31 GWA-1 S 11.40 8.46 GWA-2S 2.40 5.90 GWA-4S 5.50 19.48 Cobalt GWA-5S 29.70 29.34 GWA-9S 8.50 6.64 AB-26S 5.90 14.27 AB-33S 12.30 12.62 GWA-14S 8.30 0.00 GWA-3S 16.20 13.16 GWA-6S 4160.00 5.75 AB-14D 10.10 0.03 AB-26D 9.90 13.26 AB-30D 1.40 1.49 AB-32D 2.00 18.50 AB-35D 1.70 3.50 AB-38D 5.00 0.57 GWA-91D 1.90 3.87 Table 5. Transport Model Calibration Results (cont.) COI Monitoring Well Measured Concentration (Ng/L) Predicted Concentration (Ng/L) Inactive Ash Basin Constant Concentration = 100 pg/L Ash Storage / Landfill Constant Concentration = 10 pg/L Ash Ponds Constant Concentration = 10 pg/L Selenium Active Ash Basin Constant Concentration = 10 pg/L Sorption coefficient [Kd] = 0.1 mL/g AB-22S 0.50 8.11 GWA-6S 73.50 22.07 AB-21 BR 1.10 0.63 Inactive Ash Basin Constant Concentration = 530,000 pg/L Ash Storage / Landfill Constant Concentration = 10 pg/L Ash Ponds Constant Concentration = 10 pg/L Active Ash Basin Constant Concentration = 200,000 pg/L Western Fingers Constant Concentration = 200,000 pg/L Sulfate Sorption coefficient [Kd] = No Sorption AB-33S 337,000 340,763 GWA-6S 1,830,000 82,503 AB-22S 55,300 61,285 AB-26S 68,400 67,455 GWA-9S 12,300 13,844 Inactive Ash Basin Constant Concentration = 90 pg/L Ash Storage / Landfill Constant Concentration = 120 pg/L Ash Ponds Constant Concentration = 90 pg/L Active Ash Basin Constant Concentration = 90 pg/L Sorption coefficient [Kd] = 0.5 mL/g AB-10S 0.37 25.40 AB-12S 0.37 0.00 AB-13S 1.10 0.00 AB-22S 1.20 47.89 Vanadium AB-26S 2.10 26.01 AB-32S 0.81 54.45 AB-36S 0.39 18.47 AB-5 2.30 0.00 GWA-1 S 0.39 6.65 GWA-2S 1.30 0.02 GWA-4S 1.20 15.03 GWA-9S 0.97 4.26 AB-31 S 1.10 3.71 Table 5. Transport Model Calibration Results (cont.) COI Monitoring Well Measured Concentration (Ng/L) Predicted Concentration (Ng/L) AB-4S 0.60 0.13 AB-6R 4.40 15.64 GWA-15S 3.10 0.01 AB-1 OD 5.30 7.45 AB-11 D 1.80 0.09 AB-12D 3.90 0.00 AB-14D 0.96 0.00 AB-20D 36.90 1.14 AB-21 D 14.00 0.97 AB-22 D 3.30 12.04 AB-24D 16.80 1.73 AB-26D 93.20 3.20 AB-27D 6.30 5.91 AB-28D 13.20 0.60 AB-29D 16.30 2.86 AB-21D 6.10 0.22 AB-30D 13.60 0.29 AB-31 D 13.90 2.92 Vanadium (cont.) AB-32D 9.50 13.34 AB-33D 7.60 3.66 AB-34D 16.30 0.60 AB-35D 21.10 1.62 AB-36D 16.80 1.12 AB-37D 8.60 0.72 AB-38D 3.00 0.85 AB-39D 6.30 3.84 AB-91D 7.20 1.37 GWA-14D 7.60 0.00 GWA-15D 17.80 0.00 GWA-1 D 14.30 3.28 GWA-21D 11.80 0.27 GWA-31D 18.70 1.93 GWA-41D 4.10 2.34 GWA-51D 22.50 14.71 GWA-5S 0.99 14.71 GWA-91D 13.00 0.30 AB-1 R 21.50 0.00 Table 5. Transport Model Calibration Results (cont.) COI Monitoring Well Measured Concentration (lag/L) Predicted Concentration (lag/L) AB-21 BR 17.70 0.02 AB-23BRU 29.90 0.09 AB-25BRU 18.10 0.78 AB-35BR 16.10 0.12 Vanadium (cont.) GWA-1 BR 2.60 0.78 GWA-3BR 17.90 0.61 GWA-5BR 10.10 3.61 GWA-6BR 4.60 1.04 AB-25BR 27.20 0.00 Table 6. Predicted Advective Travel Time Groundwater Zone Monitoring Well Advective Travel Time to Model Boundary (years) Shallow AB-22S 5.2 AB-26S 3.0 AB-31 S 2.1 AB-32S 2.4 AB-6R 12.9 AB-9S 1.6 GWA-2S 4.7 GWA-6S 6.2 GWA-9S 232 GWA-15S 66.5 Deep AB-9D (21) AB-11 D 2.0 AB-22D (41) AB-26D (38) AB-31 D (37) AB-32D (43) GWA-2D (38) GWA-9D 5.0 GWA-15D 3.4 Bedrock GWA-1 BR 1.3 GWA-5BR (29) GWA-6BR 13.1 'Computed travel time over 3-D flow path using flow and transport terms from the groundwater flow and transport model. 2Travel time is displayed in days in parentheses if travel times are less than one year. Table 7. Flow and Transport Parameter Sensitivity Analysis Calibrated Calibrated +20% Calibrated -20% Average Average Concentration Concentration Hydraulic Hydraulic Change in Hydraulic Change in Parameter Head Head % Calibration Head % Calibration NRMSE NRMSE Change Monitor Wells NRMSE Change Monitor Wells N N (ug/L) N (ug/L) Arsenic Boron Arsenic Boron Horizontal K 9.4 12.5 3.1 2.9 -160.3 11.5 2.1 2.6 105.6 in S/M1/M2 Horizontal K 9.4 9.9 0.5 0.4 -34.1 9.3 -0.1 -0.8 20.9 in TZ Vertical K in 9.4 9.5 0.1 -0.4 -1.7 9.4 0.0 0.4 7.1 S/M 1 /M2 Vertical K in 9.4 9.4 0.0 0.0 -0.8 9.4 0.0 0.0 0.1 TZ Recharge in the Ash 9.4 9.5 0.1 1.2 111.8 11.0 1.6 -0.4 -136.5 Basin Recharge in 9.4 10.7 1.3 12.8 37.1 11.1 1.7 -7.3 -62.0 Other Areas Kd -7.6 - 7.4 - Effective Porosity in -0.5 -20.3 0.4 17.5 S/M1/M2 �Y Groundwater i Discharge Figure 1. Conceptual Groundwater Flow Model/Model Domain a n Figure 2. Model Domain North -South Cross Section (A -A') through Inactive and Active Ash Basins i B _t Bt B By Figure 3. Model Domain East-West Cross Section (B-B') through the Active Ash Basin Figure 4. Flow Model Boundary Conditions Figure 5. Model Recharge Areas and Contaminant Source Zones (Constant Concentration Cells) Figure 6. Observation Wells in Shallow Groundwater Zone Figure 7. Observation Wells in Deep Groundwater Zone Figure 8. Observation Wells in Bedrock Groundwater Zone Figure 9. Hydraulic Conductivity Zonation in S/M1 Model Layers (Model Layers 5-6) Figure 10. Hydraulic Conductivity Zonation in M2 Model Layer (Model Layer 7) Figure 11. Hydraulic Conductivity Zonation in TZ Model Layer (Model Layer 8) Figure 12. Hydraulic Conductivity Zonation in BR Model Layers (Model Layers 9 and10) b4U.( 632.( 624. 616.( 0) 608.( > 600.( a� 0 592.( 584.( 576.( 568.( ................... ................... ................... ................... ...... .............. ................... ................... .... ................ 560. 560.0 568.0 576.0 584.0 592.0 600.0 608.0 616.0 624.0 632.0 640.0 Observed Value Figure 13. Modeled Hydraulic Head (feet) vs. Observed Hydraulic Head (feet) ° ° Layer L Layer 3 Layer 6 Layer 8 Layer 10 6 �► II f� / / ^ ! 1t 1 LEGEND DUKE ENERGY i PROPERTY BOUNDARY ASH BASIN WASTE ` BOUNDARY i n 3 LANDfILIJASFi STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN Ad v v Active Ash Basin; r _ I � 1 - --f— f- f -,( — W- _jf N A 0 500 1,000 Feet Figure 14. Hydraulic Head (feet) in Shallow Groundwater Zone (Model Layer 6) GWA-6 AB-32 GWA-5 AB-31 GWA-15 u AB-5 w— EGENDLAKE WYLE \ _ DUKE ENERGY (CATAWBA RIVER PROPERTY BOUNDARY - ASH BASIN WASTE BOUNDARY -- LANDFILLIASH STORAGE _ 41— F'. AREABOUNDARY ASH BASIN COMPLIANCE hN _ BOUNDARY „ ASH BASIN COMPLIANCE I/•�jiV BOUNDARY COINCIDENT WITH DUKE ENERGY 0 500 1,i100 PROPERTY BOUNDARY MODEL DOMAIN4d Feet 9 Figure 15. Particle Tracking Results (see Table 6 for Advective Travel Times) 8 7 6 5 a, O 4 E 4— C— < 3 2 1 0 Predicted Antimony at AB-26D Existing Condition Cap -in -Place Excavation IMAC/2L Standard LO LO LO LO tin LD ua in (n LO ur (n LO ua V) ua (D 03 O N It (D 03 0 N Kt (D 00 0 Oil �t (D (3) 0 a 0 C� rD ry C%I N cu r r C%I CV N CV R! K K K N N N CAI CAI N Figure 16. Predicted Antimony (Ng/L) in Monitoring Well AB-26D for Model Scenarios 1-3 10 s 4 N Predicted Antimony at AB-31 D :.0 00 O CV CO cc O N -3 CO CO 0 N It w fJ7 CA © Q C, 0 CD CV N CV N r +— N N N N CJ N N N N N CJ N CA N Figure 17. Predicted Antimony (Ng/L) in Monitoring Well AB-31D for Model Scenarios 1-3 LEGEND z 5 7 10 15 18 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT MATH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N 0 5�00 Feet Figure 18. Initial (2015) Antimony Concentrations (Ng/L) in the Shallow Groundwater Zone 4 I� LANDFILLIASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WTH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1,000 Feet Figure 19. Initial (2015) Antimony Concentrations (pg/L) in the Deep Groundwater Zone is DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY L4NDFILLIASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT NTH DUKE ENERGY PROPERTY BOUNDARY MODELDOMAIN �nrin t:;_ N A 0 500 1,000 Feet Figure 20. Initial (2015) Antimony Concentrations (pg/L) in the Bedrock Groundwater Zone r- r 1 4 ACTIVE ASH BASIN rl 1 LEGEND �" 1 ' m 10 IN 15 5 18 0 DUKE ENERGY _ _ a PROPERTY BOUNDARY E N ASH BASIN WASTE m BOUNDARY e LANDFILLIASH STORAGE u AREABOUNDARY N _ ASH BASIN COMPLIANCE x - SCUNDARY 0 ASH BASIN COMPLIANCE w BOUNDARY COINCIDENT _ _ N4TH DUKE ENERGY 0 500 1,000 f PROPERTY BOUNDARY MODEL DOMAIN Feet Figure 21. "Existing Conditions" Scenario 1 - 2115 Predicted Antimony (pg/L) in the Shallow Groundwater Zone �1 FI I I 1 I I 1 1 1 I 1 1 J A 500 1,000 0 �eet Figure 22. "Existing Conditions" Scenario 1 - 2115 Predicted Antimony (pg/L) in the Deep Groundwater Zone Figure 23. "Existing Conditions" Scenario 1 - 2115 Predicted Antimony (pg/L) in the Bedrock Groundwater Zone LEGEND 1 'r 6 10 15 18 _ DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREABOUNDARY _ ASH BASIN COMPLIANCE 80UNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT VATH DUKE ENERGY PROPERTYBOUNDARY MODEL DOMAIN w� - N A 0 500 1,000 Feet Figure 24. "Cap -in -Place" Scenario 2 - 2115 Predicted Antimony (pg/L) in the Shallow Groundwater Zone Figure 25. "Cap -in -Place" Scenario 2 - 2115 Predicted Antimony (pg/L) in the Deep Groundwater Zone ti i00 1,000 0 eet Figure 26. "Cap -in -Place" Scenario 2 - 2115 Predicted Antimony (pg/L) in the Bedrock Groundwater Zone LEGEND 2 5 6 40 15 18 ` DUKE ENERGY 4 PROPERTY BOUNDARY I ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT NTH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN —1 - I 1 I I 1 N A 0 500 1,000 Feet Figure 27. "Excavation" Scenario 3 - 2115 Predicted Antimony (Ng/L) in the Shallow Groundwater Zone �e1 �1 rr r TP a I I I I � I h r I x r� LEGEND � t ' 1 7 tU tj a _ l DUKE ENERGY I _ a PROPERTY BOUNDARY E N ASH BASIN WASTE m BOUNDARY LANDFILL/ASH STORAGE a AREA BOUNDARY ASH BASIN COMPLIANCE N x BOUNDARY 0 ASH BASIN COMPLIANCE BOUWITH DARYUKE ECOINCIDENT yy „�• PRO DUKE ENERGY 0 500 1,600 PROPERTY BOUNDARY ?� MODEL DOMAIN Feet i Figure 28. "Excavation" Scenario 3 - 2115 Predicted Antimony (Ng/L) in the Deep Groundwater Zone Figure 29. "Excavation" Scenario 3 - 2115 Predicted Antimony (Ng/L) in the Bedrock Groundwater Zone Predicted Arsenic at AB-22S Existing Condition 10 cap -in -Place - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - — Excavation m 11 (D m C7 N ]' (0 CC) 0 N Et (D co 0 N I:t (0 Cf3 CF7 n C7 0 0 C] N N N N r r N N CV N N N N N N N CV N N N Figure 30. Predicted Arsenic (pg/L) in Monitoring Well AB-22S For Model Scenarios 1-3 140 120 100 80 60 L 40 NA 0 Predicted Arsenic at GWA-6S Existing Condition Cap -in -Place Excavation - IMAC/2L Standard ED m La N � L.O CO a N it (O CO O N 'Kt Liz Cfl Cfl C] C] C7 O C7 N N N N r N N N N N N N N N N C'J CW N N Figure 31. Predicted Arsenic (Ng/L) in Monitoring Well GWA-6S For Model Scenarios 1-3 LEGEND 10 SQ 100 200 ass DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1,000 Feet Figure 32. Initial (2015) Arsenic Concentrations (fag/L) in the Shallow Groundwater Zone Figure 33. Initial (2015) Arsenic Concentrations (Ng/L) in the Deep Groundwater Zone 1, �V a �f f11 iZ� n LEGEND � 1 5 10 50 100 200 - 399 ❑UKE ENERGY a PROPERTY BOUNDARY ASH BASIN WASTE m x BOUNDARY y S LANDF3LLlASH STORAGE 'u AREABOUNDARY g ASH BASIN COMPLIANCE i 0 BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT d WITH DUKE ENERGY a PROPERTY BOUNDARY MODEL DOMAIN g N A 0 500 1,000 Feet Figure 34. Initial (2015) Arsenic Concentrations (fag/L) in the Bedrock Groundwater Zone Figure 35. "Existing Conditions" Scenario 1 - 2115 Predicted Arsenic (pg/L) in the Shallow Groundwater Zone LEGEND 1 5 10 50 100 200 = 399 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFfiLL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1,000 Feet Figure 36. "Existing Conditions" Scenario 1 - 2115 Predicted Arsenic (pg/L) in the Deep Groundwater Zone Figure 37. "Existing Conditions" Scenario 1 - 2115 Predicted Arsenic (pg/L) in the Bedrock Groundwater Zone Figure 38. "Cap -in -Place" Scenario 2 - 2115 Predicted Arsenic (pg/L) in the Shallow Groundwater Zone LEGEND 1 5 10 50 100 200 399 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY I L J MODEL DOMAIN a I I I I I I I I 1 1 r' 1 N A 0 500 1,000 Feet Figure 39. "Cap -in -Place" Scenario 2 - 2115 Predicted Arsenic (pg/L) in the Deep Groundwater Zone Figure 40. "Cap -in -Place" Scenario 2 - 2115 Predicted Arsenic (pg/L) in the Bedrock Groundwater Zone F— LEGEND 1 5 10 50 100 200 399 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFfiLL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1.000 Feet Figure 41. "Excavation" Scenario 3 - 2115 Predicted Arsenic (Ng/L) in the Shallow Groundwater Zone I LEGEND 1 5 10 50 100 200 399 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILIJASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY I L J MODEL DOMAIN a N A 0 500 1,000 Feet Figure 42. "Excavation" Scenario 3 - 2115 Predicted Arsenic (pg/L) in the Deep Groundwater Zone LEGEND 5 10 50 100 200 - 399 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1,000 monsoons Feet Figure 43. "Excavation" Scenario 3 - 2115 Predicted Arsenic (pg/L) in the Bedrock Groundwater Zone F11 .M 500 Z33 E 400 i Cz 300 m 200 100 0 Predicted Barium at AB-22S Existing Condition Cap -in -Place - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Excavation IMAC/21- Standard - - un u> u3 to LO L u7 ua LO LO LO LO in V) LO u7 (D CO Q CQ d` Cp 00 O N S.fl m 0 N �t CD rn rn ca o C� o o Cv N N C\j r r C!! CV CV CV CU CU CL CU N CV CU N CV C41 Figure 44. Predicted Barium (pg/L) in Monitoring Well AB-22S For Model Scenarios 1-3 F11 o 500 E 400 CO 300 200 100 C Predicted Barium at AB-26S in uD u7 to LO LO LO LO w M w V) V) M in [D CC} Q CU d' (0 CO O Cm [D CO C) N [D C3) Ci7 n C7 C] C7 n N N N N r r N N N N N N N N CV N N N N N Figure 45. Predicted Barium (pg/L) in Monitoring Well AB-26S For Model Scenarios 1-3 �-7— LEGEND 1 10 50 100 350 700 9I = 903 0 ❑UKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE m BOUNDARY S LANdF3LLlASH STORAGE u AREA BOUNDARY g w ASH BASIN COMPLIANCE i BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT d WITH DUKE ENERGY a PROPERTY BOUNDARY MODEL DOMAIN g N A 0 500 1,000 Feet Figure 46. Initial (2015) Barium Concentrations (fag/L) in the Shallow Groundwater Zone Figure 47. Initial (2015) Barium Concentrations (pg/L) in the Deep Groundwater Zone 0 LEGEND � 1 10 50 100 350 700 - 903 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN i 4. N A 0 500 1,000 Feet Figure 48. Initial (2015) Barium Concentrations (pg/L) in the Bedrock Groundwater Zone LEGEND � 1 10 50 100 350 700 903 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE .� BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY = MODEL DOMAIN I u I I 1 N A 0 500 1.000 Feet Figure 49. "Existing Conditions" Scenario 1 - 2115 Predicted Barium (fag/L) in the Shallow Groundwater Zone LEGEND �t 10 50 100 350 700 903 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN I f I I I 1 I f 1 Il N A 0 500 1.000 Feet Figure 50. "Existing Conditions" Scenario 1 - 2115 Predicted Barium (pg/L) in the Deep Groundwater Zone LEGEND 10 50 100 350 700 903 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY CO4NCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN I I I I I r N A 0 500 1.000 Feet Figure 51. "Existing Conditions" Scenario 1 - 2115 Predicted Barium (pg/L) in the Bedrock Groundwater Zone Figure 52. "Cap -in -Place" Scenario 2 - 2115 Predicted Barium (pg/L) in the Shallow Groundwater Zone 1 �\ 1\ ICI LEGEND 10 50 100 350 700 903 — — DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY CO4NCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1.000 Feet Figure 53. "Cap -in -Place" Scenario 2 - 2115 Predicted Barium (fag/L) in the Deep Groundwater Zone LEGEND r"M 1 10 50 100 350 700 903 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE , _ BOUNDARY CO4NCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY _ MODEL DOMAIN I I I I I I I I I 1 1 1 r� I 1 N A 0 500 1,000 Feet Figure 54. "Cap -in -Place" Scenario 2 - 2115 Predicted Barium (pg/L) in the Bedrock Groundwater Zone LEGEND �t 10 50 100 350 700 903 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN 1 4 J A I I I I I J N A 0 500 1.000 Feet Figure 55. "Excavation" Scenario 3 - 2115 Predicted Barium (fag/L) in the Shallow Groundwater Zone LEGEND 10 50 100 350 700 903 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY CO4NCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN .000 Feet Figure 56. "Excavation" Scenario 3 - 2115 Predicted Barium (pg/L) in the Deep Groundwater Zone LEGEND 1 10 50 100 350 700 _ 903 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1,000 Feet Figure 57. "Excavation" Scenario 3 - 2115 Predicted Barium (pg/L) in the Bedrock Groundwater Zone 1600 1400 1200 •—• 1000 800 Q i N • 1 !, 400 I!m 0 Predicted Boron at AB-22D Existing Condition Cap -in -Place Excavation — — — — — — — — — — — — — — — — — — — — — — — — — — — — — IMAC/2L Standard CD CO C7 N � CD 09 0 Cm St tD m C7 N It (D CA CA C� O C7 C7 C7 CQ N N N r N N N N N CU N N CV N N CU N N Figure 58. Predicted Boron (Ng/L) in Monitoring Well AB-22D For Model Scenarios 1-3 IIEDIV, 1200 1000 C— 800 O �Me, 400 WE u Predicted Baran at AB-26S to LO LO LO LI7 Liz LO LO Ln LO LO CS} w Lit Ln LC3 w CO C7 Cq � CD CO 0 N Ct CD m 0 N tt CD t77 [3] C3 C3 C3 C3 C3 CV N N N r N N N N CV C%I N N N N N N CU N Figure 59. Predicted Boron (Ng/L) in Monitoring Well AB-26S For Model Scenarios 1-3 1400 1200 1000 800 O O m 600 400 200 0 Predicted Baron at C WA-45 Existing condition Cap -in -Place Excavation — — — — — — — — — — — — — — — — — — — — — — — — — — — — IMACI2L Standard — -� u) ur Ln LO in U') uO ua U') uO uO to err w m u) QD m C] N � (R m O N �t tD m CD N et to 0) 0) n C] C] O O N N N N r r N N N iV CV N N N N N N CV N N Figure 60. Predicted Boron (Ng/L) in Monitoring Well GWA-4S For Model Scenarios 1-3 1000 m C 600 D L /© W f II 200 0 Predicted Boron at GWA-5BR u7 Un sn 1.0 to LO u') �n Un LO en LO u7 u7 Un u� to 00 0 N -f t9 00 C4 N CD CO 0 N It (D to G) O O O O O (V N Cat (V r r N N N N CJ N N N N C I N N [\t N Figure 61. Predicted Boron (Ng/L) in Monitoring Well GWA-5BR For Model Scenarios 1-3 LEGEND 50 100 300 500 700 1,200 - 1,921 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT +MTH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN ,000 Figure 62. Initial (2015) Boron Concentrations (pg/L) in the Shallow Groundwater Zone Figure 63. Initial (2015) Boron Concentrations (pg/L) in the Deep Groundwater Zone R 01 z a a 0 LEGEND s 50 100 300 u 500 P s 700 �z 1,200 9I = 1,921 0 DUKEENERGY a PROPERTY BOUNDARY ASH BASIN WASTE m BOUNDARY x w S LANDFILVASH STORAGE 'u AREA BOUNDARY g ASH BASIN COMPLIANCE i BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT d ` WITH DUKE ENERGY a PROPERTY BOUNDARY .x. MODEL DOMAIN r N A 0 500 1,000 Feet Figure 64. Initial (2015) Boron Concentrations (Ng/L) in the Bedrock Groundwater Zone LEGEND 50 100 300 500 700 1,200 1,921 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN *1 fi N A 0 500 1,000 Feet Figure 65. "Existing Conditions" Scenario 1 - 2115 Predicted Boron (pg/L) in the Shallow Groundwater Zone LEGEND 50 100 300 500 700 1,200 1,921 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY © MODEL DOMAIN l _t N A 0 500 1,000 Feet Figure 66. "Existing Conditions" Scenario 1 - 2115 Predicted Boron (pg/L) in the Deep Groundwater Zone LEGEND 50 100 300 500 700 1,200 1,921 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY © MODEL DOMAIN N A 0 500 1,000 Feet Figure 67. "Existing Conditions" Scenario 1 - 2115 Predicted Boron (fag/L) in the Bedrock Groundwater Zone r� rr rr fr LEGEND 50 100 300 500 700 1,200 1,921 ❑UKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY CO4NCIDENT .� WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1,000 Feet Figure 68. "Cap -in -Place" Scenario 2 - 2115 Predicted Boron (pg/L) in the Shallow Groundwater Zone r` rr rr fr LEGEND 50 100 300 500 700 1,200 1,921 ❑UKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY CO4NCIDENT .� WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1,000 Feet Figure 69. "Cap -in -Place" Scenario 2 - 2115 Predicted Boron (pg/L) in the Deep Groundwater Zone r` rr rr fr LEGEND 50 100 300 500 700 1,200 1,921 ❑UKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY CO4NCIDENT .� WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1,000 Feet Figure 70. "Cap -in -Place" Scenario 2 - 2115 Predicted Boron (pg/L) in the Bedrock Groundwater Zone LEGEND 50 100 000 500 700 1,200 1,921 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFiLLlASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE , _ BOUNDARY CO4NCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY _ I L J MODEL DOMAIN iL 1 N A 0 500 1,000 Feet Figure 71. "Excavation" Scenario 3 - 2115 Predicted Boron (Ng/L) in the Shallow Groundwater Zone r� rr rr fr LEGEND 50 100 300 500 700 1,200 1,921 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY CO4NCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY I L J MODEL DOMAIN iL N A 0 500 1,000 Feet Figure 72. "Excavation" Scenario 3 - 2115 Predicted Boron (pg/L) in the Deep Groundwater Zone LEGEND 50 100 300 500 700 1,200 1,921 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL%SH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT 1MTH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1.000 monsoons Feet Figure 73. "Excavation" Scenario 3 - 2115 Predicted Boron (pg/L) in the Bedrock Groundwater Zone 20 0] 15 ZI E E O 10 L7 5 U Predicted Chromium at AB-f R u-) M Un uO cn in uO M u7 to w u7 M Ln ua uO CD 00 (D N 'IT 0 CO O N 'd' cD CO C) N d' (D (7S Cfl O 0 0 Q 0 N N N N r r N N N N N N N N N N N N N N Figure 74. Predicted Chromium (Ng/L) in Monitoring Well AB-6R For Model Scenarios 1-3 16 14 12 4 :a 81 Predicted Chromium at AB-26D (O M C] N d' (D CO C7 N (D CO C) N tt w 65 C] C7 C7 0 C7 N N N N r r CV N N N CV N N N N N N N N N Figure 75. Predicted Chromium (pg/L) in Monitoring Well AB-26D For Model Scenarios 1-3 w i r I ILI 1 n I - I 4' LEGEND 1 2 5 10 15 11L 20 ® 27 DUKEENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1,000 Feet Figure 76. Initial (2015) Chromium Concentrations (pg/L) in the Shallow Groundwater Zone f ' I I I I I 1 1 , LEGEND 1 2 5 10 15 20 27 DUKEENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREA BOUNDARY AI ASH BASIN COMPLIANCE I `� BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY 0 500 1,000 MODEL DOMAIN Feet Figure 77. Initial (2015) Chromium Concentrations (pg/L) in the Deep Groundwater Zone LEGEND 1 2 5 10 15 20 27 DUKEENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN �k 1 a I I I I N A 0 500 1,000 Feet Figure 78. Initial (2015) Chromium Concentrations (pg/L) in the Bedrock Groundwater Zone Figure 79. "Existing Conditions" Scenario 1 - 2115 Predicted Chromium (Ng/L) in the Shallow Groundwater Zone i i LEGEND 2 5 10 15 20 27 _ DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILUASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN ti f t r � i , V6 N k 0 500 1,000 Feet Figure 80. "Existing Conditions" Scenario 1 - 2115 Predicted Chromium (Ng/L) in the Deep Groundwater Zone LEGEND 2 S 10 15 20 27 DUKEENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1,000 Feet Figure 81. "Existing Conditions" Scenario 1 - 2115 Predicted Chromium (Ng/L) in the Bedrock Groundwater Zone Pp-MEWIL-9 —i LEGEND 2 S 10 15 20 Mb 27 DUKEENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN ri N A 0 500 1,000 Feet Figure 82. "Cap -in -Place" Scenario 2 - 2115 Predicted Chromium (fag/L) in the Shallow Groundwater Zone 7LEGEN' D 2 S 10 15 20 Mb 27 DUKEENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN r I I I I I I 1 N A 0 500 1,000 Feet Figure 83. "Cap -in -Place" Scenario 2 - 2115 Predicted Chromium (pg/L) in the Deep Groundwater Zone i / LEGEND 2 S 10 15 20 27 _ DUKEENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1,000 Feet Figure 84. "Cap -in -Place" Scenario 2 - 2115 Predicted Chromium (Ng/L) in the Bedrock Groundwater Zone I I I I 1 LEGEND S 1 t� 10 J 15 20 27 _ DUKEENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE AN BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY 0 500 1,000 MODEL DOMAIN Feet Figure 85. "Excavation" Scenario 3 - 2115 Predicted Chromium (Ng/L) in the Shallow Groundwater Zone I 'rr r► 1-71 �_11 rI 1 �r I I I I I I - F tt. 9 w - 0 a r LEGEND r w 2 tv� S 10 A+ a 15 a' a 20 I 27 0 DUKEENERGY PROPERTY BOUNDARY ten' ASH BASIN WASTE m BOUNDARY x s LANDFILL/ASH STORAGE AREA BOUNDARY w ASH BASIN COMPLIANCE AN BOUNDARY a ASH BASIN COMPLIANCE w BOUNDARY COINCIDENT p WITH DUKE ENERGY 0 500 1,000 PROPERTY BOUNDARY a MODEL DOMAIN Feet Figure 86. "Excavation" Scenario 3 - 2115 Predicted Chromium (pg/L) in the Deep Groundwater Zone LEGEND 2 S 10 15 20 Mb 27 DUKEENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN 1 I I I I I I 1 N A 0 500 1,000 Feet Figure 87. "Excavation" Scenario 3 - 2115 Predicted Chromium (Ng/L) in the Bedrock Groundwater Zone Wa a Predicted Hexawalent Chromium at AB-9D Existing Condition Cap-ln-Place Excavation DHHS HSL M N V. � CO a N Itace C) N ED CF1 CA C7 C7 C] C] C7 N N N N r r N N N N N N N N N N N N N N Figure 88. Predicted Hexavalent Chromium (Ng/L) in Monitoring Well AB-91D For Model Scenarios 1-3 12 0) 10 E P 0 C) g 4- 4] 7 4 (z X CU rJ Predicted Hexa►ralent Chromium at AB-31'S Existing Condition Cap-ln-Place Excavation QHHS HSL La W) LO In to Usa u> u} Ley to ua Vr ua Cfl M C] N d- (D CO O N d' CP CO Ci N (D CA Cn C7 C] C] CQ C7 N N N N w-- r N N N N N N N N N N N CV N N Figure 89. Predicted Hexavalent Chromium (pg/L) in Monitoring Well AB-31S For Model Scenarios 1-3 16 14 12 E 10 0 Z g U 6 [[S 0] X 4 _. 81 Predicted Hexavalent Chromium at GWA-3D LO LO (n ua w LO LO (n on (n era u) u) V) u> (0 M ® i11 I:t (0 CO O N It (D CO O N (D CT� Ol C7 C] C7 O C] N N N N r r Cq N N N N N N N N N N N N N Figure 90. Predicted Hexavalent Chromium (Ng/L) in Monitoring Well GWA-31D For Model Scenarios 1-3 20 0) F 15 F 0 C) 10 a� x 9 Predicted Hexa►ralent Chromium at AB-10D fD M C7 N CD CO O N KD CO C3 N �t (D CS7 0) C7 C7 0 C? C3 N N N N r r CV N N N N N N N N N N N N N Figure 91. Predicted Hexavalent Chromium (Ng/L) in Monitoring Well AB-10D Model Scenarios 1-3 LEGEND - 0.07 5 10 15 ® 20 30 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILIJASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1,000 Feet Figure 92. Initial (2015) Hexavalent Chromium Concentrations (pg/L) in the Shallow Groundwater Zone I I R I I I e I I 1 LEGEND � �I 0.07 a t" s � 10 15 20 30 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFfiLL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE N BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY CO4NCIDENT WITH DUKE ENERGY - 0 500 1.000 PROPERTY BOUNDARY MODEL DOMAIN Feet Figure 93. Initial (2015) Hexavalent Chromium Concentrations (fag/L) in the Deep Groundwater Zone Figure 94. Initial (2015) Hexavalent Chromium Concentrations (pg/L) in the Bedrock Groundwater Zone Figure 95. "Existing Conditions" Scenario 1 - 2115 Predicted Hexavalent Chromium (pg/L) in the Shallow Groundwater Zone LEGEND �I 0.07 5 10 15 20 30 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFfiLL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY CO4NCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY I L� MODEL DOMAIN a 'M N A 0 500 1,000 Feet Figure 96. "Existing Conditions" Scenario 1 - 2115 Predicted Hexavalent Chromium (pg/L) in the Deep Groundwater Zone LEGEND 0.07 s 10 15 20 30 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFfiLL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY CO4NCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN pq . .y N A 0 500 1.000 Feet Figure 97. "Existing Conditions" Scenario 1 - 2115 Predicted Hexavalent Chromium (fag/L) in the Bedrock Groundwater Zone Figure 98. "Cap -in -Place" Scenario 2 - 2115 Predicted Hexavalent Chromium (pg/L) in the Shallow Groundwater Zone LEGEND 0.07 s 10 15 20 30 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFfiLL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY CO4NCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN I I I f I I I N A 0 500 1.000 Feet Figure 99. "Cap -in -Place" Scenario 2 - 2115 Predicted Hexavalent Chromium (pg/L) in the Deep Groundwater Zone i \1 �i !t rI �—tl F i LEGEND 0.07 s 10 15 20 30 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFfiLL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY CO4NCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1.000 Feet Figure 100. "Cap -in -Place" Scenario 2 - 2115 Predicted Hexavalent Chromium (pg/L) in the Bedrock Groundwater Zone Figure 101. "Excavation" Scenario 3 - 2115 Predicted Hexavalent Chromium (pg/L) in the Shallow Groundwater Zone LEGEND �I 0.07 s 10 15 20 30 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFfiLL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY CO4NCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN L 1 I ! I Q I I I 1 N A 0 500 1.000 Feet Figure 102. "Excavation" Scenario 3 - 2115 Predicted Hexavalent Chromium (pg/L) in the Deep Groundwater Zone LEGENI - 0.07 N1� 1 5 u 10 8 15 i 20 _ 30 DUKE ENERC PROPERTYE ASH BASIN V BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY = MODEL DOMAIN 1'r � r r -- u r► A 1Zn r--,-� N A 0 500 1,000 Feet Figure 103. "Excavation" Scenario 3 - 2115 Predicted Hexavalent Chromium (pg/L) in the Bedrock Groundwater Zone 30 25 p� 20 03 -0 15 O U 10 5 0 Predicted Cobalt at AB-1 OS u7 un u) U-) +.ra an Ln u-) U") (n 4n m Asa s.e) u7 u) (D CO CD N co CO O N d CO I70 G) N EI' (D m G7 O O O O O N N N N r +-- N N N N N N CV N N N CJ N N N Figure 104. Predicted Cobalt (pg/L) in Monitoring Well AB-1 OS For Model Scenarios 1-3 30 25 z 0) 15 10 5 0 Predicted Cobalt at AB-26D w CO C) N �t cD CO O CV -t CO CO G) N IS CD QS 9) i7 O O a O N N CV CV r .-- N N N N N N N N N N N N N N Figure 105. Predicted Cobalt (pg/L) in Monitoring Well AB-26S For Model Scenarios 1-3 25 20 5 0 Predicted Cobalt at AB-32D u7 to LO Un Un s n Ln Sri u-) Un u r Urn sn Vi ua w (D CO CD CV It CD CO O) CL It CO 00 C) N V (D QS G) (D O CD 0 C7 C+J N Cm N r +-- N N N N N N CA R1 N N C i NN N Figure 106. Predicted Cobalt (pg/L) in Monitoring Well AB-32D For Model Scenarios 1-3 35 30 0) =L 20 _-I.— Cz © 15 WA 10 5 Lei Predicted Cobalt at GWA-5S LO U"� U-) U-) U') in m ua u7 m u7 Ln to Un �n uO CD C6 f7 N �t cD CO O N d' cD CO C N � CD m G) O O O O O N N N C\! r - N N RI N N N N N N N CJ N N Ctd Figure 107. Predicted Cobalt (Ng/L) in Monitoring Well GWA-5S For Model Scenarios 1-3 R LEGEND 1 2 5 10 15 25 _ 36 _ DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN r N A 0 500 1,000 Feet Figure 108. Initial (2015) Cobalt Concentrations (fag/L) in the Shallow Groundwater Zone 9 Figure 109. Initial (2015) Cobalt Concentrations (pg/L) in the Deep Groundwater Zone ,1 1, �I a l� LEGEND 15 25 - 36 _ DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY = MODEL DOMAIN �1 I I I I I I I I 7 1 I I r� l\ i E" l� N / a 0 500 1,000 Feet Figure 110. Initial (2015) Cobalt Concentrations (pg/L) in the Bedrock Groundwater Zone LEGEND 2 5 10 15 25 36 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY = MODEL DOMAIN 1,000 Feet Figure 111. "Existing Conditions" Scenario 1 - 2115 Predicted Cobalt (pg/L) in the Shallow Groundwater Zone Figure 112. "Existing Conditions" Scenario 1 - 2115 Predicted Cobalt (pg/L) in the Deep Groundwater Zone Figure 113. "Existing Conditions" Scenario 1 - 2115 Predicted Cobalt (pg/L) in the Bedrock Groundwater Zone Figure 114. "Cap -in -Place" Scenario 2 - 2115 Predicted Cobalt (pg/L) in the Shallow Groundwater Zone Figure 115. "Cap -in -Place" Scenario 2 - 2115 Predicted Cobalt (pg/L) in the Deep Groundwater Zone Figure 116. "Cap -in -Place" Scenario 2 - 2115 Predicted Cobalt (pg/L) in the Bedrock Groundwater Zone Figure 117. "Excavation" Scenario 3 - 2115 Predicted Cobalt (pg/L) in the Shallow Groundwater Zone Figure 118. "Excavation" Scenario 3 - 2115 Predicted Cobalt (pg/L) in the Deep Groundwater Zone LEGEND 1 2 5 10 15 25 L 36 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL%SH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT 1MTH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1.000 monsoons Feet Figure 119. "Excavation" Scenario 3 - 2115 Predicted Cobalt (pg/L) in the Bedrock Groundwater Zone QI 20 15 10 5 Predicted Selenium at G'WA-6S Existing Condition Cap -in -Place Excavation IMRC/2L standard — u> oO U') to in Ln w uO LO 07 w U) V) u) Ln ua to M o Cu t sD CO _o N � (D co a I* w N CS? 0) C] C7 0 C7 C] CV N N N r r CV N N N N N N N N N C'J CV N N Figure 120. Predicted Selenium (pg/L) in Monitoring Well GWA-6S For Model Scenarios 1-3 20 A 9 Predicted Selenium at AS-22S U� uD U) LO in LO Ut'r LO LO Un U') V) LO in LO u) to M C7 N d to CO C7 N 'cl- tD CO C) N t (D Cf3 v) C] C] C] C� C] N N N N r r N N N N N N N CV N N N CU N N Figure 121. Predicted Selenium (Ng/L) in Monitoring Well AB-22S For Model Scenarios 1-3 1, k` �I 1% n N' 0-0 LEGEND 1 5 10 20 30 40 60 g _ _ DUKEENERGY 'a PROPERTY BOUNDARY ASH BASIN WASTE m BOUNDARY x w S LANdFILLlASH STORAGE 'u AREABOUNDARY g ASH BASIN COMPLIANCE i BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT d WITH DUKE ENERGY a PROPERTY BOUNDARY MODEL DOMAIN g N A 0 500 1,000 Feet Figure 122. Initial (2015) Selenium Concentrations (Ng/L) in The Shallow Groundwater Zone Figure 123. Initial (2015) Selenium Concentrations (Ng/L) in the Deep Groundwater Zone ,1 1, a l� 1--zn p �I E R QI LEGEND s 5 w 10 u a� 20 P g 30 w 40 _ 60 g _ _ ❑UKE ENERGY 'a PROPERTY BOUNDARY ASH BASIN WASTE m BOUNDARY x w S LANdFILLlASH STORAGE 'u AREABOUNDARY g ASH BASIN COMPLIANCE i BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT d WITH DUKE ENERGY a PROPERTY BOUNDARY i MODEL DOMAIN i ,000 7 Figure 124. Initial (2015) Selenium Concentrations (pg/L) in the Bedrock Groundwater Zone Figure 125. "Existing Conditions" Scenario 1 - 2115 Predicted Selenium (pg/L) in the Shallow Groundwater Zone LEGEND 1 5 10 20 30 40 ® 60 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY C04NCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN 1 i I I h I I 1 t" N A 0 500 1.000 Feet Figure 126. "Existing Conditions" Scenario 1 - 2115 Predicted Selenium (pg/L) in the Deep Groundwater Zone LEGEND 1 5 10 20 30 40 ® 60 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY C04NCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN 0 N A 0 500 1.000 Feet Figure 127. "Existing Conditions" Scenario 1 - 2115 Predicted Selenium (pg/L) in the Bedrock Groundwater Zone LEGEND 1 5 10 20 30 40 60 ❑UKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY CO4NCIDENT .� WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN r�r !r 1 N A 0 500 1,000 Feet Figure 128. "Cap -in -Place" Scenario 2 - 2115 Predicted Selenium (pg/L) in the Shallow Groundwater Zone LEGEND 5 10 20 30 ® 40 60 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WSATH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN l I I I I I I I I I I 1 1 1 I 1 N A 0 500 1,000 Feet Figure 129. "Cap -in -Place" Scenario 2 - 2115 Predicted Selenium (pg/L) in the Deep Groundwater Zone I �1\ �I u� ff 7y` ^! J LEGEND n 5 10 20 S 30 40 60 0 DUKE ENERGY a PROPERTY BOUNDARY ASH BASIN WASTE m BOUNDARY s m s LANDFiLLlASH STORAGE 'u AREABOUNDARY �i w ASH BASIN COMPLIANCE x BOUNDARY 0 h ASH BASIN COMPLIANCE _ BOUNDARY CO4NCIDENT d _ WITH DUKE ENERGY a. PROPERTY BOUNDARY MODEL DOMAIN I I I I r N k 0 500 1,000 Feel Figure 130. "Cap -in -Place" Scenario 2 - 2115 Predicted Selenium (pg/L) in the Bedrock Groundwater Zone 11 it 11 1 r� LEGEND 1 5 10 20 30 40 60 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY I= MODEL DOMAIN N A 0 500 1,000 Feet Figure 131. "Excavation" Scenario 3 - 2115 Predicted Selenium (pg/L) in the Shallow Groundwater Zone LEGEND 1 5 10 20 30 40 60 ❑UKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY CO4NCIDENT .� WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1,000 Feet Figure 132. "Excavation" Scenario 3 - 2115 Predicted Selenium (pg/L) in the Deep Groundwater Zone �I !d h d r � J LEGEND 5 10 20 30 40 _ 60 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREA BOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1.000 monsoons Feet Figure 133. "Excavation" Scenario 3 - 2115 Predicted Selenium (pg/L) in the Bedrock Groundwater Zone 350000 300000 250000 200000 Cz 150000 U) i111111111111h111113 0 Predicted Sulfate at AB-33S Existing Condition Cap -in -Place Excavation IMAC/2L Standard — — CO CD C? N It (D CO C? N CA CO O N d• (D C s33 0 CD C3 CC] N N N N r N N N N N CV N cl3 N N N. CV CQ N Figure 134. Predicted Sulfate (Ng/L) In Monitoring Well AB-33S For Model Scenarios 1-3 250000 200000 - 150000 U) i00000 50000 C Predicted Sulfate at GWA-6S LO to LO LO Ura era LO LO LO LO w 4.0 (n Un LO LO w w 0 N t (D CO O CU t (D CO 4 N (D 0) CA 0 0 C3 C3 C3 r N N N N r r N N N N N N N N N N N N CAl N Figure 135. Predicted Sulfate (pg/L) In Monitoring Well GWA-6S For Model Scenarios 1-3 I� dd r�l! a �d m LEGEND 1,000 5,000 20,000 75,000 150,000 250,000 - 390,590 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1,000 Feel Figure 136. Initial (2015) Sulfate Concentrations (pg/L) in the Shallow Groundwater Zone Figure 137. Initial (2015) Sulfate Concentrations (pg/L) in the Deep Groundwater Zone LEGEND 1,000 5,000 20,000 75,000 150,000 250,000 _ 390,590 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT +MTH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N k 0 500 1,000 monsoons Feet Figure 138. Initial (2015) Sulfate Concentrations (Ng/L) in the Bedrock Groundwater Zone LEGEND 1,000 5,000 20,000 75,000 150,000 250,000 390,590 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY = MODEL DOMAIN N A 0 500 1,000 Feet Figure 139. "Existing Conditions" Scenario 1 - 2115 Predicted Sulfate (fag/L) in the Shallow Groundwater Zone LEGEND 1,000 5,000 20,000 75,000 150,000 250,000 390,590 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY = MODEL DOMAIN N A 0 500 1,000 Feet Figure 140. "Existing Conditions" Scenario 1 - 2115 Predicted Sulfate (pg/L) in the Deep Groundwater Zone LEGEND 1,000 5,000 20,000 75,000 150,000 250,000 390,590 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY = MODEL DOMAIN N A 0 500 1,000 Feet Figure 141. "Existing Conditions" Scenario 1 - 2115 Predicted Sulfate (pg/L) in the Bedrock Groundwater Zone Figure 142. "Cap -in -Place" Scenario 2 - 2115 Predicted Sulfate (pg/L) in the Shallow Groundwater Zone Figure 143. "Cap -in -Place" Scenario 2 - 2115 Predicted Sulfate (pg/L) in the Deep Groundwater Zone Figure 144. "Cap -in -Place" Scenario 2 - 2115 Predicted Sulfate (pg/L) in the Bedrock Groundwater Zone Figure 145. "Excavation" Scenario 3 - 2115 Predicted Sulfate (pg/L) in the Shallow Groundwater Zone Figure 146. "Excavation" Scenario 3 - 2115 Predicted Sulfate (pg/L) in the Deep Groundwater Zone Figure 147. "Excavation" Scenario 3 - 2115 Predicted Sulfate (pg/L) in the Bedrock Groundwater Zone Ac 40 E 30 CO (Z 20 IN Predicted Vanadium at AB-6R cn Ln LO en ua Ln Ln Ln LD Ln ua V) u) Vn u) M O N � (D CD 4 t J � CO CD C7 N �t cn CAS CD C7 C7 C7 0 0 N N CU CV r r- N N N N N N Ctl CR1 Rt 713 N N CV CV Figure 148. Predicted Vanadium (pg/L) In Monitoring Well AB-6R For Model Scenarios 1-3 50 40 0) 1 E30 C ciS 2© 10 0 Predicted Vanadium at AB-10D Existing Condition Cap -in -Place Excavation IMAC12L Standard — — CD M Q N d' (D CO Ca N d- (D CO C) N (D Cf} i37 C] C7 C7 C] C3 04 N N N r r N N N N N N N N N N N N N N Figure 149. Predicted Vanadium (pg/L) In Monitoring Well AB-1 OD For Model Scenarios 1-3 A 40 E _D 30 ([S c[S > 20 10 A Predicted Vanadium at GWA-45 LO LO LO LO cn to sn LO U') in rn ua u) u) LO u) CD M C7 N I:t (D CO O N CD ao C? CL �t (D i7'i O] C7 C] C] C] C7 N N N N r r C\j N N N N N N N N N N Cm N N Figure 150. Predicted Vanadium (fag/L) In Monitoring Well GWA-4S For Model Scenarios 1-3 50 40 i~33 30 E D_ 0 M (Z 20 10 01 Predicted Vanadium at GWA-5BR Existing Condition LO LO LO LO LO sn LO U) LO Ln ;n LO LO u) u) LO (4 M C7 N <! to CO C3 N Q- M CO C7 N �t (D Cf; 07 C] C] C7 C] C] CV N N N r r C�1 N N N N CV CV N N N N N N N Figure 151. Predicted Vanadium (pg/L) In Monitoring Well GWA-5BR For Model Scenarios 1-3 LEGEND 0.30 2 5 15 30 50 77 _ DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN ra , N 0 500 1,000 Feet Figure 152. Initial (2015) Vanadium Concentrations (Ng/L) in the Shallow Groundwater Zone LEGEND 0.30 2 5 15 30 50 77 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILLIASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN ,000 Figure 153. Initial (2015) Vanadium Concentrations (pg/L) in the Deep Groundwater Zone Figure 154. Initial (2015) Vanadium Concentrations (Ng/L) in the Bedrock Groundwater Zone Figure 155. "Existing Conditions" Scenario 1 - 2115 Predicted Vanadium (pg/L) in the Shallow Groundwater Zone f I I I I 1 I I I LEGEND 0.30 2 5 15 � 30 50 77 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE N BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY COINCIDENT WITH DUKE ENERGY - 0 500 1.000 PROPERTY BOUNDARY MODEL DOMAIN Feet Figure 156. "Existing Conditions" Scenario 1 - 2115 Predicted Vanadium (pg/L) in the Deep Groundwater Zone Figure 157. "Existing Conditions" Scenario 1 - 2115 Predicted Vanadium (pg/L) in the Bedrock Groundwater Zone Figure 158. "Cap -in -Place" Scenario 2 - 2115 Predicted Vanadium (pg/L) in the Shallow Groundwater Zone Figure 159. "Cap -in -Place" Scenario 2 - 2115 Predicted Vanadium (pg/L) in the Deep Groundwater Zone / Mf7 LEGEND 0,30 15 30 50 77 — — DUKEENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE _ BOUNDARY CO4NCIDENT .� WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN N A 0 500 1,000 Feet Figure 160. "Cap -in -Place" Scenario 2 - 2115 Predicted Vanadium (pg/L) in the Bedrock Groundwater Zone LEGEND 0,30 2 5 15 30 50 77 DUKE ENERGY PROPERTY BOUNDARY ASH BASIN WASTE BOUNDARY LANDFILL/ASH STORAGE AREABOUNDARY ASH BASIN COMPLIANCE BOUNDARY ASH BASIN COMPLIANCE BOUNDARY COINCIDENT WITH DUKE ENERGY PROPERTY BOUNDARY MODEL DOMAIN 1 ! I I I I 1 N A 0 500 1.000 Feet Figure 161. "Excavation" Scenario 3 - 2115 Predicted Vanadium (fag/L) in the Shallow Groundwater Zone Figure 162. "Excavation" Scenario 3 - 2115 Predicted Vanadium (pg/L) in the Deep Groundwater Zone Figure 163. "Excavation" Scenario 3 - 2115 Predicted Vanadium (pg/L) in the Bedrock Groundwater Zone