Lee Email Attachments_

SOUTHERN ENVIRONMENTAL LAW CENTER
Telephone [phone] WEST ROSEMARY STREET, SUITE 220 Facsimile 919-929-9421
CHAPEL HILL, NC 27516-2356
April 18, 2016
VIA EMAIL AND U.S. MAIL
N.C. Department of Environmental Quality
Attn: Debra Watts
Division of Water Resources, Groundwater Protection Section
1636 Mail Service Center
Raleigh, NC 27699-1611
[e-mail]
Re: Comments on Draft Risk Classifications — H.F. Lee
Dear Ms. Watts:
On behalf of Sound Rivers and Waterkeeper Alliance, the Southern Environmental Law
Center submits the following comments on the draft Coal Combustion Residual Impoundment
Risk Classifications proposed by the N.C. Department of Environmental Quality (DEQ) for
Duke Energy's H.F. Lee Steam Station facility ("Lee") near Goldsboro, N.C.
Lee is a High Risk site. Duke Energy admits the impoundments are not suitable for the
long-term storage of coal ash, they are constructed in wetlands and have streams running through
them, they are located in the floodplain of the Neuse River, and they have caused what may be
the worst groundwater arsenic contamination of any coal ash site in North Carolina.
The Lee site stores nearly six million tons of coal ash in four unlined coal ash basins, plus
a small polishing pond connected to the active basin. The active unlined coal ash lagoon on the
bank of the Upper Neuse River was constructed in 1980. The lagoon is 143 acres in size,
contains coal ash stored in a wet state, and is unlined. The Lee site also includes at least three
inactive unlined pits constructed in the 1950s and 1960s according to EPA, which are full of old
coal ash and also are located on the banks of the Upper Neuse River. All these impoundments
are in the flood plain of the Neuse River.
The Lee coal ash site and its dangerous dams, located in the floodplain of the Neuse
River, and its ongoing, unpermitted discharges, are located upstream of the drinking water intake
for over 34,000 people in Goldsboro and for over 93,000 people served by the Neuse Regional
Water & Sewer Authority. The coal ash lagoon and inactive pits are constructed in the middle of
wetlands, and the ground is swampy around these coal ash storage areas. See Wetlands Maps
attached as Attachment 1. Moreover, several streams, including Half Mile Branch, run through
the inactive coal ash pits at Lee. See Map Identifying Blue Line Streams, Attachment 2.
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The existing Lee facility and a Cap in Place approach pollute surface water now and for
decades to come; obliterate surface water resources of the state; fill and pollute groundwater
forever; and contaminate for decades to come the water resources of the Neuse River Basin.
Below, we set out some of the most prominent defects in the proposed classifications and
Duke Energy's studies to date, all of which demonstrate that Cap in Place cannot be allowed as a
closure option for the Lee impoundments. As a result, the Lee active basin with its polishing
pond and three inactive basins should all be designated High Risk.
I. Damages and Threats to Natural Resources
A. Dam Safety Risks
1. The Lee Coal Ash Cannot Be Stored In the Floodplain of the Neuse River
All the Lee impoundments are located in the Neuse River floodplain, and thus cannot be
used for the long-term storage of coal ash. Duke Energy admits as much in a recent closure
update, noting the flood risk and stating that "the basins are not suited for long-term permanent
storage" of coal ash. Attachment 3 (emphasis added).
In its January 2016 Coal Combustion Residual Impoundment Risk Classifications
narrative document ("Narrative"), DEQ has correctly classified all the impoundments at Lee as
High Risk for its Surface Water key factor, "Landscape Position and Floodplain." Narrative at
58. However, it has abandoned its own "key factor" approach by downgrading all five
impoundments to "Intermediate" in its overall classification, without explanation or justification.
All the Lee impoundments should be High Risk based on DEQ's correct determination of the
flood risk to the public'at this site.
When the river floods, these coal ash sites are literally surrounded by water and are at
great risk. Their location within the river system itself underscores not only the risk of
catastrophic failure, but also the fact that they inevitably pollute groundwater, surface water, and
the entire river system. As set out below, the earthen dikes that contain the coal ash are
dangerous, and their presence in the floodplain and directly on the river's banks makes them
even more dangerous.
2. The Lee Dams Are High Risk
The berm of the Active Lee coal ash lagoon was classified as "High Hazard" by the State
of North Carolina and given a rating of "Significant Hazard" by the EPA. A least one section of
the lagoon "does not meet the minimum standard" for slope stability according to EPA's 2011
dam inspection report.
Due to its proximity to the river, the Lee active coal ash lagoon has been damaged
repeatedly by flooding. EPA noted that in 1999, existing sloughing worsened and new sloughs
were created on the interior of the dam, and new sloughing and cracks formed in the exterior of
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the crest of the dam along the Upper Neuse River. The EPA report also described "significant
erosion" at Inactive Ash Pond 2.
A 2011 EPA dam inspection report also identified seeps discharging from the
downstream berm of the coal ash lagoon. These seeps identified by EPA continue today, despite
numerous attempts to repair and prevent them both before and after the EPA inspection.
The Lee active coal ash lagoon has had problems for years with seeps that have caused
ongoing maintenance and erosion problems around the coal ash lagoon. In 2000, the Lee lagoon
suffered "significant interior slope slumping and distress" due to seepage. In 2002, contaminated
water was observed leaking under the ash lagoon discharge pipe. In 2004, a riser pipe in the Lee
lagoon broke off and fell over into the lagoon, causing the water level to drop rapidly.
Inspections from 1990 and 2004 reported indications of slope movement on the east berm of the
coal ash lagoon.
In addition to these ongoing problems with the Lee coal ash lagoon, EPA has identified
an "active stream" flowing from the toe of Inactive Ash Pond 2, known as Half Mile Branch.
See Stream Map, Attachment 2. And multiple other blue line streams also flow through and
beneath the inactive coal ash pits, as indicated in Attachment 2. These streams are surface
waters being polluted illegally by Duke Energy, but they are also structural risks for the inactive
impoundments that DEQ has ignored in its draft classifications.
Similarly, DEQ has ignored the fact that Duke's own CAP studies show that the Inactive
Basins 1-3 are submerged in the groundwater, so while they may appear dry on the surface (as
claimed in the Narrative, p. 125), they are in fact largely saturated and thus have a higher risk of
structural failure as well as ongoing pollution. See CAP Pt. 1, Fig. ES-3 to ES-5.
3. Proximity to Waters of the State
By ignoring Half Mile Branch and the other blue line streams in and around the Inactive
Basins 1-3 (as explained below), DEQ has mistakenly assigned a lower risk classification for the
Dam Safety factor for Proximity to Waters of the State. The Inactive Ash Basins 1-3 are not
"approximately 350 feet" away from waters of the state they are immediately adjacent to, and
in some cases directly on top of, tributary streams, including Half Mile Branch and other
unnamed streams as shown in Attachment 2. They are also sitting in wetlands, which are waters
of the state. Attachment 1. Moreover, they are also submerged in the groundwater, which is also
a water of the state.
In addition, DEQ's analysis of the position of the Inactive Ash Basins relative to the
Neuse River fails to take into account the significant effects of flooding, which brings the river
far closer to these impoundments. Since flooding is one likely source of dam safety risk, DEQ's
analysis fails to adequately evaluate the true proximity of the inactive impoundments to the
Neuse River.
For all these reasons, the Inactive Basins are High Risk for this factor.

4. Offsite Drainage Area
DEQ has mistakenly stated that the offsite drainage area for Inactive Basin 1 is 0 acres.
Narrative at 127. This is clearly an error and must be corrected. The Inactive Basin is not "Low
Risk" for this factor.
B. Surface Water Risks
1. "Cap in Place" Would Destroy and Pollute Surface Waters
Multiple blue line streams flow through the Inactive Ash Basins. See Stream Map,
Attachment 2. Duke Energy has no permit to pollute these streams, which flow around and
beneath the Inactive impoundments, and also carry pollutants to the Neuse River. These streams
are recharged by groundwater from the area of the inactive basins, and if the ash is capped in
place in contact with the groundwater, the streams will continue to receive pollution from the
basins via the connected groundwater. The contaminated groundwater at Lee also flows directly
into the Upper Neuse River.
In addition, several of the inactive basins have actually been constructed on top of the
tributary streams. If the ash is capped in place, these streams would be buried in coal ash
forever.
2. The Lee Coal Ash Is In And On Top of Natural Drainage Ways and Streams
According to DEQ's classification system, if a coal ash impoundment is "sited in or located
on top of... a natural drainage way or stream" then for this surface water factor the
impoundment should be rated "Low/Intermediate." For this factor, all the Lee coal ash
impoundments were rated "Low Risk" because of the conclusion that none of them was sited in
or located on top of a natural drainage way or stream. That conclusion is not correct.
As shown on the attached National Wetland Inventory map, the Lee impoundments are
in, on top of, and partially surrounded by wetlands (Attachment 1). All these wetlands are
connected to tributaries that flow directly into the Neuse River. Further, the Inactive Basins 1-3
are on top of tributaries that flow to the Neuse River. Attachment 2. All these impoundments
should have received at least a "Low/Intermediate" risk rating under DEQ's classification
system.
3. The Amount of Coal Ash at Lee Is High Risk
While groundwater risk was evaluated based on the total amount of coal ash at Lee, for
no apparent reason the surface water risk was evaluated separately at each lagoon based on the
amount of ash in each lagoon. Narrative at 123.
There is no basis for this distinction and particularly no basis for this distinction Lee. As
DEQ sets out, the Lee coal ash is in a floodplain. In the case of a flood -caused catastrophe, the
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entire site is at risk, not one coal ash storage site or another. By splitting the ash up among the
various coal ash lagoons at this site, DEQ has artificially and wrongly reduced the risk
calculation for the site.
Further, Inactive Basins 1 and 2 share common dams and functionally are one coal ash
storage unit, while Inactive Basin 3 is separated from them only by Half -Mile Branch stream,
which is an additional risk factor. All these lagoons are in a wetlands complex. See Attachment
1. The Polishing Pond is functionally part of the Active Basin footprint, it shares dams with the
Active Basin, and should not be treated any differently in terms of dam safety risk. A major
flood catastrophe is likely to cause it to fail as well. There is no reason to split up these sites and
thereby inaccurately understate the risk of the Cape Fear site.
Under DEQ's rating system, since Cape Fear has more than 4,255,000 tons, the site should
have been rated High Risk for this factor.
Further, the entire system of dividing up the impoundments into tonnage categories is, as in
other instances, wrongly based on the notion that DEQ is grading on a curve, where some
impoundments will be low risk, some intermediate, and some high. As set out above, there is no
basis in law or fact for this approach. This approach ignores the fact that every coal ash lagoon
can be high risk, and this approach has no basis in CAMA. The Legislature did not mandate that
some percentage of sites be designated low risk, some intermediate, and some high. DEQ's
approach minimizes the risks to the public, the environment, and natural resources by artificially
forcing coal ash impoundments into low and intermediate categories.
Indeed, DEQ expressly did exactly that. The Narrative (page 23) expressly states that
DEQ picked tonnage cutoffs for low, intermediate, and high risk so that the ratings would be
distributed across the percentiles of the coal ash lagoons in the state. Thereby, DEQ forced some
coal ash lagoons into a low risk category and some into an intermediate category based on
arbitrary percentiles.
The fallacy of this approach is demonstrated by the Dan River site. It has a total of 1.6
million tons of coal ash in two lagoons. Under DEQ's method of splitting sites and forcing sites
into categories based on amount of ash stored, Dan River's two lagoons would only be
considered by DEQ to be "intermediate" risks. Yet, this site is the site of the state's worst coal
ash disaster that led to the enactment of CAMA itself. Dan River was and is a High Risk site
based on the amount of coal ash stored there, even if there are bigger sites in the state. This
DEQ-created curve for grading coal ash sites is contrary to reality.
By splitting up sites and creating a curve, DEQ has said that impoundments that contain
up to 4,255,000 tons of coal ash are not high risk, and that sites that do not contain a single
impoundment of that more than 4,255,000 tons cannot by definition be high risk. The fact is that
storing tens of thousands of tons, hundreds of thousands of tons, or millions of tons in unlined
leaking pits next to waterways is High Risk. The risk of these huge coal ash storage sites cannot
be diminished by the fact that Duke Energy has irresponsibly created enormous unlined coal ash
storage sites.
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In short, for this factor, Lee and all other coal ash sites are High Risk.
C. Groundwater Risks
There is no separation between the Lee impoundments and the groundwater at the site.
Indeed, the Inactive impoundments are submerged in the surficial aquifer. See CAP Pt. 1, Fig.
ES-3 to ES-5. Cap in Place would not stop the ash from leaching contaminants into the
groundwater at the site and the Neuse River and its tributaries, and thereby continuing to pollute
public waters for decades to come.
1. Serious Groundwater Pollution
Since at least 2007, elevated levels of pollutants from the coal ash have been documented
in groundwater under, at, and around the Lee facility. These substances include toxic and
cancer -causing pollutants including arsenic, lead, chromium, cadmium, and beryllium; as well as
other coal ash pollutants including boron, iron, manganese, and total dissolved solids. Years of
groundwater monitoring well data from the site show the unlined coal ash pits have caused
numerous pollutants to exceed their respective standards, including:
• Arsenic at over 66 times the standard
• Beryllium at over 2 times the standard
• Boron at over 7 times the standard
• Cadmium at over 231 times the standard
• Chromium at 5 times the standard
• Lead in excess of the standard
• Iron at 112 times the standard
• Manganese at over 61 times the standard
• Total dissolved solids of almost 4 times the standard
In addition, the groundwater at Lee is acidic, with a pH as low as 4.8, well below the state
groundwater standard.
Although Duke's consultant has claimed in the CAP Pt. 2 that the area around Lee is
served by public water, residents around the inactive basins use well water, and at least nine
residents nearby have received "do not drink" letters for a variety of pollutants associated with
coal ash detected in their well water. CAP Pt. 2 at pp. ES-1-2.
2. DEQ's Groundwater Rating Ignores Data Gaps and Uncertainty
DEQ claims the Lee impoundments are all "Low Risk" for its groundwater key factor.
But DEQ explains that its rating for this factor is "[b]ased on the data provided in CSA Report
and results of the groundwater modeling results presented in the CAP Report." Narrative at 57
(emphasis added). And for each of the five impoundments, DEQ says "[t]here are no reported
supply wells within 1500 feet downgradient of the impoundment compliance boundary." Id.
(emphasis added). In other words, DEQ has relied for its "key factor" on whether or not Duke
Energy chose to admit it is contaminating neighboring wells, and DEQ has looked only at what
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Duke did include in its reports, rather than evaluating the data gaps and uncertainty in these
reports. In short, because Duke did not report that drinking wells were affected, DEQ gives
these impoundments a "Low Risk" rating.
There is no support for this approach.
DEQ's own classification report recognizes that uncertainty creates more, not less, risk:
"Components of the conceptual site model related to a CCR impoundment that are incomplete or
inadequately characterized contribute a degree of uncertainty that translates to an increased
potential risk to the classification evaluation process." Narrative at 21 (emphasis added).
At Lee, for the groundwater factor "Data Gaps and Uncertainty," DEQ found that the
extent of the contamination has not been adequately defined for any of the impoundments.
Narrative at 122. DEQ gave the Active Ash Basin, the Polishing Pond, and Inactive Basin 1 an
"Intermediate Risk" rating because of this uncertainty.
For the Active Basin and Polishing Pond, DEQ noted radial flow and mounding around
the basin, , which could move contaminants in the direction of nearby drinking wells. and found
the horizontal extent of the contamination was not adequately defined. Id. For Inactive Basin 1,
DEQ found that the vertical extent of the contamination is not defined, and also noted mounding
and radial flow around this basin, which could move contaminants in the direction of nearby
drinking wells. For Inactive Basin 2, DEQ found the vertical extent of the contamination is not
defined. And for Inactive Basin 3, DEQ found the same gaps as listed above, and also noted that
the horizontal extent of the contamination is not adequately defined.
Given that the extent of the contamination has not been adequately defined for any of
these five impoundments, and that there is mounding and radial flow around them, DEQ cannot
give these five impoundments a "Low Risk" rating for potential contamination of drinking well
receptors. DEQ should give these basins High Risk ratings unless and until Duke Energy can
prove whether its coal ash is contaminating neighboring drinking wells.
3. Inadequate Groundwater Modeling
The Lee model is fundamentally flawed because it ignores a dominant feature of the site,
namely its location in the floodplain of the Neuse River. Ignoring this extremely significant
factor, Duke Energy's model sets a constant head boundary for the Neuse River. CAP Pt: 1,
Appendix E, p. 10. That means that for purposes of the model, the river never rises or falls.
W

In reality, the river regularly rises and falls dramatically. The USGS stream flow gauging
station on the Neuse River near Goldsboro, NC shows that the elevation of water in the river
routinely changes with high elevations associated with rainfall events. As the chart shows, these
elevations regularly vary by more than 15 feet.
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When the water level in the river rises, water flows out of the river and into the floodplain
sediments, causing groundwater elevations to rise and the direction of flow to be more from the
river toward the uplands. The groundwater flow direction returns to the normal direction
generally toward the river once river level goes back down. Reversals of groundwater flow
direction in floodplains is a well-known and expected characteristic that can spread released
contaminants in unexpected directions from the source area and result in high variation in
groundwater quality measurements due to changes in flow direction.
By ignoring this basic feature of the Lee site, Duke has set up its model with completely
unrealistic conditions that do not account for groundwater movement at the site. Because of this
serious deficiency in the model, it is not known how far the groundwater may be pushed up from
the basins. But it is certain that Duke Energy's model is not reliable and cannot support the
conclusions about groundwater flow that Duke has presented to DEQ.
A second issue related to the location of the Lee ash basins in an active floodplain is that
the ash in the unlined basins should be assumed to be regularly re -saturated. With each high

water event in the Neuse River, the elevation of groundwater beneath the basins will increase.
Since the basins have been constructed with their bottoms at the water table, increased
groundwater elevations associated high water events along the river will re -saturate ash within
the basins and renew generation of leachate from the buried waste.
Because the groundwater regularly re -saturates the ash in the unlined impoundments,
capping the waste in place cannot separate the ash from groundwater and eliminate the ongoing
contamination. The effect of modeling the Lee site with a constant head boundary at the river is
to impose a constant groundwater elevation and flow direction on the model of a system that can
be shown to exhibit neither. The Lee groundwater model, constructed as described, is artificially
constrained to show the waste located primarily just above the water table and contaminant
transport consistently toward the river. Neither of these Conditions is correct in the real world.
In addition, the description of the Ash Basin Capping scenario indicates that this scenario
uses a zero recharge rate to the groundwater system in the vicinity of the ash basins. This is the
assumption that allows the contaminant transport results for the cap in place scenario to perform
similarly to the ash removal scenario. Unfortunately, zero recharge will not be achieved by
capping the ash. The groundwater system beneath the ash basins is not a static system with
groundwater be assumed to consistently be located beneath the bottom of the ash. As was
described above, the real -world groundwater system will be influenced by the changing stage of
the Neuse River. The water table will rise during high flow events causing rewetting of the ash
and generation of leachate.
By ignoring the groundwater movement at the site, Duke's model distorts the comparison
between "Cap in Place" and excavation. In reality, excavation is the only closure method that
will remove the source of the pollution — the coal ash in the basin — from direct contact with
public waters, where it is burying streams and leaching out pollutants into the groundwater, the
Neuse River, its tributary streams, and adjacent wetlands.
4. Faulty Provisional Background Concentrations
The "background" concentrations used in the CAP to propose site -specific pollutant
levels are not reliable. Duke's CAP Pt. 1 acknowledges that groundwater flows radially away
from the basins, pp. 1-8 and 2-2, and that several of the monitoring wells do not represent
background conditions, p. 4-3. The groundwater monitoring systems used to this point has been
inadequate and reliable background values for groundwater contaminants have yet to be
developed.
5. Recovery Wells/Interceptor Trenches and Attenuation Are Not Appropriate
Remedial Measures At Lee
The CAP Part 2, pp. 6-26 and 6-29, evaluates the use of recovery wells or an interceptor
trench to control migration of ash contaminants downgradient of the active ash basin. Each of
these options includes routing of the collecting water into a basin for pH buffering prior to
discharge into the Neuse River under an NPDES permit. But this plan requires no treatment for
the high levels of arsenic and other pollutants in the groundwater. The effect of these
6

"remediation" scenarios would be to collect the contaminated groundwater and discharge it into
the river. This essentially by-passes any natural attenuation that may be happening and actually
speeds discharge of contaminated water into the river. Thus, this approach is likely worse for the
river and natural environment even than doing nothing would be.
Nor is attenuation a valid approach at Lee. EPA and North Carolina rules require that a
corrective action plan that proposes to utilize monitored natural attenuation (MNA) as a remedy
demonstrate that that the contaminant has the capacity to degrade or attenuate under site -specific
conditions. Section 6.6.1.3 of the CAP Pt. 2 claims that the primary attenuation mechanism at
H.F. Lee is the advective groundwater flow regime, which is controlled by the close proximity of
the Neuse River. However, advective groundwater flow is not the same as contaminant
attenuation. Attenuation occurs when contaminants interact with the soil or rock through which
the water is flowing and contaminants are removed from the groundwater. Advective now
means the pollution is simply flushed beyond Duke Energy's property boundary and compliance
boundary, straight into the Neuse River. Dilution of contaminants facilitated by advective flow
and/or discharge into the Neuse River are not forms of attenuation. Duke has provided no data
supporting attenuation as a mechanism controlling the spread of the boron plume.
Section 6.6 of the CAP Pt. 2 indicates that MNA may be a potential groundwater remedy
for certain areas of the site. In addition to the problems described above, MNA does not appear
to be a viable closure option for this site because:
• NCAC 02L .0106 (1)(1) requires a demonstration that all sources of contamination and
free product have been removed or controlled. Duke is not proposing removal of the
waste for disposal in a secure location. Controlling the waste will likely require active
operation of remedial systems for many decades if groundwater impacts are to be
controlled. The portion of the ash that is continually or intermittently saturated will
continue to leach metals into groundwater that will flow toward and eventually discharge
into the Neuse River.
• NCAC 02L .0106 (1)(2) requires a demonstration that the contaminant has the capacity to
degrade or attenuate under site -specific conditions. Many of the ash -related constituents
in groundwater at this site neither degrade nor attenuate. Contrary to what is stated in
this report, advective groundwater flow and discharge into the river is not a form of
attenuation.
Instead, DEQ must require removal of the source of the pollution: the coal ash in the
unlined impoundments.
D. CAMA Requires Duke Energy to Comply with the Groundwater Standard
CAMA requires compliance with North Carolina's groundwater protection rules found at
15A N.C. Admin. Code 2L .0101 et. seq. ("21, Rule"). Under the 2L Rule, any polluter that
contaminates groundwater must develop a corrective action plan "using the best available
technology for restoration of groundwater quality to the level of the standards ...." 15A N.C.
Admin. Code 2L .01060). This general mandate is subject to limited exceptions for a specific
category of polluters who qualify for flexible remediation standards under 2L .0106(k) (allowing
restoration to less than the standard), 2L .0106(1) (allowing restoration through natural
10

attenuation), or 2L .0106(m) (allowing termination of corrective action without achieving the
standard). See 2L .01060). Each of those sections, in turn, applies only to a "person required to
implement an approved corrective action plan for a non permitted site ...." See 2L .0106(k),
(1), (in).' Under the plain text of the 2L Rule, facilities with state -issued NPDES permits do not
qualify for the flexible remediation options afforded by 2L .0106(k), (1), and (m) because they
are permitted.
In the past, Duke Energy has argued that its NPDES-permitted coal ash basins are
nonetheless eligible for the flexible- remediation measures reserved for "non permitted sites"
because under the 2L Rule, older basins first issued permits before December 30, 1983, are
"deemed not permitted" for some purposes. See 2L .0106(e). But recent legislative changes
altered these rules mandating that "[w]here operation of a disposal system permitted under this
section results in exceedances of the groundwater quality standards at or beyond the compliance
boundary the [EMC] shall require the permittee to undertake corrective action, without regard to
the date that the system was first permitted, to restore the groundwater quality ...." N.C. Sess.
Laws 2014-122, § 12(a) (codified at N.C. Gen. Stat. § 143-215.1(k)) (emphasis added). In other
words, the only question now is whether a facility has a permit, not when it was issued.
Under this recent revision to North Carolina's water pollution control statute, Duke
Energy must restore groundwater around its permitted coal ash disposal sites at the Roxboro
facility to the applicable standard, without regard to the date the impoundments were first
permitted. To further clarify the application of flexible remediation to coal ash ponds, the
General Assembly recently declared that the benefits afforded by its risk -based remediation
statute "shall not apply to contaminated sites subject to remediation pursuant to ... [t]he Coal
Ash Management Act of 2014." Id. (codified at N.C. Gen. Stat. § 130A-310.67(4)). As a
permitted facility subject to remediation under CAMA, Duke is barred from using flexible
remediation, such as monitored natural attenuation, as a groundwater remediation method and
instead must implement -the best available technology to restore groundwater to the standards.
E. The Lee Impoundments Also Are Not Eligible for Closure by Capping in Place
Under the CCR Rule.
On October 19, 2015, the EPA's Disposal of Coal Combustion Residuals rule (the "CCR
Rule") became effective, providing the first comprehensive federal regulation of coal ash
disposal. DEQ asserts that "[t]he requirements set forth in CAMA ... will complement or
exceed" the CCR Rule's requirements, but this is only true if DEQ demands more than cap -in -
place where groundwater is already contaminated by unlined impoundments.
The tension between the new federal mandates and capping -in -place at Duke's sites
exists in the CCR Rule's Groundwater Monitoring and Corrective Action section. 40 C.F.R.
§ § 257.90-98. This section provides that if monitoring detects a statistically significant
exceedance of the groundwater protection standards established for a constituent in Appendix IV
of the CCR Rule, then, barring certain exceptions, the owner or operator of an unlined surface
'Flexible remediation is also available under 2L .0106(r) & (s). Those sections only apply to underground storage
tanks and are inapplicable to the coal ash ponds at issue in this litigation.
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impoundment must engage in two tracks of remedial measures. Id. § 257.95(g). First, the owner
or operator of the unlined impoundment must begin the CCR Rule's normal remedial process,
including the assessment of corrective measures, selection of remedy, and implementation of a
corrective action plan. Id. §§ 257.95(g)(3)(i), 257.96-98. Second, within six months of the
detection, the waste streams into the impoundment must cease and the process of closing or
retrofitting the impoundment must begin. Id. §§ 257.95(g)(5), 257.101(a)(1). The CCR Rule's
preamble makes clear that this close or retrofit requirement for leaking unlined impoundments is
"in addition to complying with all of the corrective action requirements." 80 Fed. Reg. 21406
(emphasis added). Thus it is not enough to satisfy only § 257.102's closure requirements the
requirements for remedies and implementation of the corrective action plan under § § 257.97-98
must also be met.
This point is critical because Duke's own data show that capping -in -place will not meet
the CCR Rule's requirements for remedy selection or corrective action plan implementation.
Among other things, the remedy selected must "[b]e protective of human health and the
environment," "[a]ttain the groundwater protection standard" set forth in § 257.95(h) (the MCL
or other level, as specified therein), "[c]ontrol the source(s) of releases so as to reduce or
eliminate, to the maximum extent feasible, further releases of Appendix IV constituents, and
"[r]emove from the environment as much of the contaminated material that was released from
the CCR unit as is feasible." 40 C.F.R. §§ 257.97(b)(1)-(4). The remedy will not be considered
complete until groundwater protection standards are met for three consecutive years.
§ 257.98(c)(2).
The CCR rule measures compliance with groundwater protection standards at the site's
waste boundary, see 40 C.F.R. § 257.91(a)(2), a much closer limit that is within the compliance
boundary. Therefore, capping -in -place also will not meet the CCR Rule's requirement that the
remedy selected attains compliance with groundwater protection'standards, let alone for three
consecutive years. Nor will capping -in -place satisfy the requirements that the remedy control the
source material and remove as much contaminated material as is feasible —indeed, the cap -in -
place plan seems to call for removing as little as is feasible. And leaving the toxic ash in
vulnerable communities adjacent to precious waterways will certainly not protect human health
and the environment. The only remedy that will meet the CCR Rule's requirements, and the
only remedy DEQ should consider for these sites, is removal of the ash and placement in dry
lined storage facilities. .
F. Duke Energy Admits Coal Ash Must Be Separated from Groundwater
On April 7, 2016, in prepared remarks at a hearing before the North Carolina Advisory
Committee to the United States Civil Rights Commission, the Duke Energy representative told
the Committee and thereby the Commission that Duke Energy was committed to protecting
groundwater: "Duke Energy's closure work is really driven by a series of guiding principles.
And the first of those is ensuring that ground water is protected. We cannot develop a closure
plan that does not protect groundwater" (emphasis added). A "Low Risk" rating and Cap in
Place at Roxboro would be directly contrary to this official pledge, and would deposit millions of
tons of coal ash in groundwater.
12

In South Carolina, Duke Energy has acknowledged that it must remove all of its ash in
the state from the unlined basins where it is currently submerged in groundwater, to lined, dry
storage or recycling.
Duke Energy's own public statements admit that coal ash cannot be safely stored sitting
in groundwater. At a recent ex parte briefing before the South Carolina Public Service
Commission, Duke Energy explained that excavating all the coal ash from its Robinson coal ash
site in Darlington County, S.C. to lined, dry landfill storage on site will ensure "groundwater is
protected" because "[a]sh will be removed and placed in an engineered landfill, segregated from
groundwater." PSC Transcript, Attachment 4, at 18. At Robinson, the coal ash in the basin is
submerged 18 feet deep in groundwater that flows directly to Lake Robinson. By comparison,
the coal ash at Roxboro is submerged well over 70 feet deep in the groundwater that flows
directly to Hyco Lake. DEQ must require what has already been recognized in South Carolina —
coal ash cannot be safely stored unless it is separated from groundwater.
In its briefing, Duke also explained that the advantages of its coal ash excavation plans
for Robinson and for its W.S. Lee facility on the Saluda River include the fact that they will
"eliminate[] the existing impoundments," ensuring "groundwater is protected. That landfill will
be lined and capped, leachate will be collected, and we will continue to perform groundwater
monitoring to ensure that these controls function as designed." Attachment 4, at 14, 18.
In South Carolina — a state where the environmental agency has not hampered citizen law
enforcement against coal ash pollution — Duke has been forced to recognize that even in sparsely
populated areas, it cannot safely close its ash basins without eliminating all its unlined
impoundments and separating the coal ash from groundwater through storage in a properly
designed, synthetically lined landfill.
North Carolinians deserve these same protections for Goldsboro and the Neuse River.
G. Experience Has Shown that Excavation and Removal is Effective in Reducing
Groundwater Pollution
Experience from coal ash excavation sites in South Carolina demonstrates that excavation
to dry lined storage is the effective means of eliminating serious groundwater contamination
from unlined coal ash lagoons. Excavation and removal to dry lined storage also eliminates the
threat of catastrophic failure and the unlined riverside storage of millions of tons of toxics-laden
waste.
The Wateree plant of SCE&G is on the banks of the Catawba-Wateree River — a river
that runs through both South and North Carolina — near Columbia, South Carolina. Duke Energy
also stores coal ash on that river, at its Marshall, Riverbend, and Allen facilities.
In January 2012, the Southern Environmental Law Center filed suit against SCE&G on
behalf of the Catawba Riverkeeper Foundation to require removal of coal ash from unlined pits
on the banks of the River. For years, these coal ash pits had contaminated the groundwater — and
thereby the adjacent Catawba-Wateree River — with large amounts of arsenic. In one test,
13

groundwater in one of the monitoring wells contained arsenic at 5,000 parts per billion (ppb), or
500 times South Carolina's standard of 10 ppb for arsenic. Attachment 5, at 12.
In August of 2012, SELC and the Catawba Riverkeeper Foundation negotiated a
settlement with SCE&G that requires removal of the coal ash from the riverside pits to safe, dry,
lined storage away from the waterway. Since ash removal began in earnest, arsenic groundwater
contamination has plummeted at the site.
As of its January 2016 report, SCE&G has removed over 876,000 tons of coal ash from
the site, or about one-third of the coal ash. Attachment 5, at 2. At the same time, groundwater
contamination at the site has dropped significantly. In one monitoring well, arsenic had
contaminated the groundwater at 432 ppb, or 43 times the legal limit. In the latest report, arsenic
groundwater contamination has dropped to 2.9 ppb, or a 99 percent decrease. Id. at 6-7. In
another monitoring well, arsenic contamination had been over 1,000 ppb, ranging as high as
5,000 ppb. In the latest report, arsenic contamination had dropped to 58.6 ppb, or at least a 95
percent reduction in arsenic contamination. Id. at 12. Other pollutants, including lead, cadmium,
and sulfate, are also reported at lower levels.
8co
7c0
a 600
n.
c 500
O
400
L
300
Qj
C 200
O
V
100
Arsenic Levels at Wateree
May Aug 2012 May Oct 2013 Apr 2014 Oct 2014 Apr 2015 Oct 2015
2012 2013
Sampling Dates
Monitoring
Well
—+-3
fll
In June of 2012, the Southern Environmental Law Center filed suit against Santee Cooper
for its coal ash pollution at its Grainger facility on the Waccamaw River in Conway, South
Carolina. In this instance, SELC represented the Waccamaw Riverkeeper, a program of the
Winyah Rivers Foundation; the South Carolina Coastal Conservation League; and the Southern
Alliance for Clean Energy. The Waccamaw River — like the Catawba-Wateree River — flows
14

through both North and South Carolina. The Waccamaw River is also part of the Winyah Bay
Watershed, which encompasses both states, including the Lumber River on which Duke Energy
stores coal ash at its Weatherspoon facility.
In November 2013, the parties announced the settlement of this suit, under which Santee
Cooper agreed to remove all the ash from the unlined Grainger pits to safe, dry, lined storage or
to recycle it for concrete. Since ash removal began at that site, coal ash groundwater
contamination has dropped significantly.
As of its January 2016 report, Santee Cooper had removed about 450,000 tons of ash.
Attachments 6 & 7. The Grainger site has consistently reported some of the highest arsenic
groundwater contamination in the region. However, as the ash is being removed, the arsenic
groundwater contamination has been decreasing. One monitoring well reported arsenic in 2013
at 1,097.9 ppb, or over 109 times the South Carolina standard of 10 ppb. Attachment 8, at 5. By
the end of 2015, the arsenic contamination in that monitoring well had dropped to 558.9 ppb —
still very high, but about one half the level before excavation began. Attachment 9, at 4. At
another monitoring well, in September 2013, arsenic groundwater contamination was measured
at 941.9 ppb, or over 94 times the South Carolina standard. Attachment 8, at 5. By the end of
2015, arsenic contamination had dropped to 198.4 ppb - about an 80% reduction from pre -
excavation. Attachment 9, at 4. One other monitoring well also showed an 80% reduction, from
450 in 2013 to 108.5 by the end of 2015. Attachment 8, at 5; Attachment 10, at 8.
Arsenic Levels at Grainger
4000
3500
Monitoring
Well
.0
CI
3000
-� 1
Q
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2500
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t9
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t10
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-
500
12
0
Sept -Oct 2013 Mar -Apr 2014 Sept -Oct 2014 April 2015 Nov -Dec 2015
Sampling Dates
As excavation continues, the measurements of arsenic contamination in groundwater may
vary. But the trend is clear. As ash is removed, groundwater contamination from arsenic has
been decreasing.
15

H. Cap in Place Increases Groundwater Contamination
Far from protecting groundwater, capping in place can increase harmful contamination by
creating an oxygen -free environment that makes arsenic leaching worse. Arsenic in coal ash has
higher leaching potential in an anaerobic environment than in an aerobic environment because of
the different potential for reduction -oxidation reactions. A recent study found dissolved arsenic
concentrations under anaerobic conditions were as much as 50 times higher than they were under
aerobic conditions. Grace E. Schwartz et al., Leaching potential and redox transformations of
arsenic and selenium in sediment microcosms with fly ash, Applied Geochemistry 67 (2016):
177-185. DOI: 10. 10 1 6/j.apgeochem.2016.02.013, Attachment 11. Research at coal ash ponds
and the TVA Kingston spill site have similarly found that oxygen conditions at a site affect the
amount of arsenic leaching. The study authors conclude that "capping methods that might
induce anaerobic conditions should be avoided in the closure of unlined impoundments." Id. at
184. Covering ash that remains in unlined pits, in the groundwater, could deprive the ash of .
oxygen, and the resulting anaerobic conditions could increase arsenic pollution of groundwater.
Around the country and in North Carolina specifically, "cap in place" has failed to remedy
coal ash pollution.
• Roxboro. Duke Energy has sometimes cited experience at nearby Roxboro for proof that
cap in place can work, but in fact coal ash pollution has continued at Roxboro despite an
attempt to cap in place.
At Roxboro, a lined coal ash landfill has been constructed on top of an unlined coal ash
landfill and unlined coal ash lagoon. Duke Energy has claimed this lined landfill acts as
a cap over the unlined ash and that groundwater monitoring data around this lined landfill
area demonstrate the success of a cap -in -place closure plan. Duke has stated that the
lined landfill was designed to minimize recharge to the aquifer and act as a corrective
action to improve groundwater quality. And Duke's Corrective Action Plan Part 1 (CAP
Pt. 1) claims that in monitoring wells GMW-06, GMW-10, and GMW-11, "the lined
landfill is reducing the migration of constituents to Site groundwater." CAP Pt. 1 at 1-8
(emphasis added)
In fact, groundwater monitoring data show that this "Cap in Place" approach has failed to
protect groundwater at Roxboro.
First, Duke's assertion ignores the increasing concentration trends for boron, sulfate,
and selenium detected in samples from wells GMW-06, GMW-09 and GMW-11
collected since 2011. Concentrations were very high initially, likely due to improper well
development or sampling techniques early on, and began decreasing prior to installation
of the cap/lined landfill, but in recent years, the concentrations have increased. Graphs of
boron, sulfate and selenium results from wells GMW-06, GMW-09 and GMW-11 are
included with the attached expert report of Mark Hutson (Attachment 12 at 26-27). The
graphs show increasing concentration trends since 2011-12 for boron, sulfate and
selenium in well GMW-06, and for selenium, sulfate, and total dissolved solids in GMW-

11. In well GMW-06, boron has been steadily increasing for years and in September
2015 reached 2,460 ppb, well over three times the groundwater standard. CAP Pt. 1 at
Table 2-9.
Contrary to Duke's claims, wells GMW-06 and GMW-11 show no consistent decreasing
trend for sulfate, a pollutant that has been above standards around the lined landfill since
it was constructed. Selenium in GMW-06 has also shown no consistent decreasing trend,
and in fact has been increasing in recent years and was last measured at 94.3 ppb, a
concentration virtually identical to that measured in 2002 when the lined landfill project
began.
Moreover, there is another downgradient monitoring well ignored by Duke, GMW-08,
that disproves Duke's claim that the capping effect of the lined landfill is protecting
groundwater. Duke has mislabeled this well as an upgradient or sidegradient well in its
submissions to the state (for example, CSA Section 2.10.2), but that is plainly incorrect.
The CSA's Bedrock Water Level Map (Figure 6-5) shows that well GMW-08 is located
downgradient of both the unlined and lined landfills. Analytical results from GMW-08
show concentrations of boron, chloride, iron, manganese, sulfate, and total dissolved
solids (TDS) that are greater than 21, standards and are increasing (Attachment 12, at 26-
27). The location of GMW-8 downgradient of the landfills is consistent with the
observed elevated and increasing concentrations of ash -related constituents.
In particular, boron in GMW-08 has increased dramatically since 2011, reaching
shockingly high levels above 4,000 ppb, and as high as 4,240 ppb, in the sampling data
from April and September 2015 included in the CAP Pt. 1 (Table 2-10). Similarly,
sulfate concentrations in GMW-08 have increased steadily over the past several years and
are now far higher than they were at their previous peak around the time the landfill was
constructed; they are now as high as 780 mg/L, over three times the 2L standard. Id.
And total dissolved solids concentrations in 'GMW-08 have been increasing as well, and
are now almost twice as high as in 2002 and are four times higher than the 2L standard.
Thus, contrary to Duke Energy's claims, multiple monitoring wells downgradient of the
lined landfill at Roxboro show steadily increasing concentrations of coal ash pollutants,
and many others show no consistent decrease in pollutant concentrations. This is
unsurprising, given that the CAP Pt. 1 and CSA show that the unlined coal ash at
Roxboro sits deep in the groundwater, where it will continue to leach out pollutants even
if it is capped in place.
Belews Creek, NC — the Pine Hall Road coal ash landfill is unlined and was closed with
synthetic cap in 2008. The Pine Hall Road landfill was listed by EPA as a potential
damage case in 2010 due to continuing groundwater contamination, including
exceedences for arsenic, boron, iron, manganese, nitrate, selenium, and
sulfate. http://www.astswmo.org/Files/Policies and Publications/Cross-
program/Coal Combustion Residuals/2011.11-
NODA Comments/North Carolina NODA Comments.pdf
17

Chesapeake Energy Center, VA — an unlined coal ash landfill has been capped by
installing a synthetically lined landfill on top of it, so the liner is supposed to serve as a
cap on top of the old coal ash. "The landfill, built over an older and unlined ash pond,
was lined with polyethylene, but as The Pilot's Jeff Sheler has reported, tests of wells at
the site have repeatedly detected arsenic and other pollutants at levels exceeding
government safety standards." "Company reports to the state Department of
Environmental Quality obtained by The Virginian -Pilot showed that arsenic in one well
in 2006 was 40 times the standard," Sheler wrote. "Results in May 2013 and April 2014
showed levels 30 times the standard. Levels of cobalt and sulfide also exceeded
government standards. Other pollutants, including barium, beryllium, lead, selenium and
zinc, were detected at `significant levels above background."'
http•//hamptonroads com/2014/08/protectin -cg hesgpeake-dominion-shuts-plant
• Colstrip, MT — "Built in 1976 with a clay buffer, the Stage 1 Pond began oozing
pollutants as far back as 1979 and has continued to do so — even though it was
"capped"— covered over with a liner — in 1997."
http://www.publicintegril.org/2009/02/19/2942/coal-ash-hidden-story
• B.C. Cobb, MI — years after lowering water levels, capping, and constructing a slurry
wall around a coal ash lagoon, groundwater monitoring shows extremely high boron
concentrations (10,400 µg/L) and lithium concentrations (215 µg/L) continuing to enter
the North Branch of the Muskegon River.
• We Energies Oak Creek, WI — buried coal ash that was paved over with an industrial
site on top spontaneously collapsed into Lake Michigan in 2011.
http•//www.publicintegrii org/2011/11/01/7240/coal-ash-spills-lake-michigan-after-
bluff-collapse
I. Industry Claims About the Supposed Dangers of Transporting Coal Ash Are a Red
Herring
. DEQ officials have stated publicly that they have received a letter from a coal ash
industry group arguing that it would be better to leave all the coal ash in Duke Energy's unlined
basins across North Carolina because cleaning up and transporting coal ash is somehow unsafe.
This is a hackneyed argument with no basis in fact. Industry opponents of coal ash cleanup use
general statistics that include every truck driver in America, not those managed or overseen by
contract by utilities, and specifically by Duke Energy. Duke Energy has never contended that it
shouldn't clean up coal ash because its truck drivers or those of its contractors will kill people. If
that were true, then Duke's construction, maintenance, and other activities should be severely
curtailed and investigated. And Duke's management should be investigated for its dangerous
operation and oversight of trucking.
In fact, Duke Energy conducts extensive trucking operations every day throughout North
Carolina and its service area. Duke Energy Business Services, the trucking subsidiary of Duke
18

Energy, has had just 12 injuries and zero fatalities over the past 24 months.2 Duke's trucks drove
37 million miles in the U.S. in the last reporting year alone.
Moreover, Charah, the company responsible for transporting much of Duke Energy's
coal ash from the sites already being cleaned up, has had zero crashes in the last 24 months with
no injuries or fatalities.3 Charah has also won several awards for employee safety from the N.C.
Department of Labor.4
Industry arguments about trucking fatalities are not only totally irrelevant to Duke Energy
and Charah's safety records, but they also misrepresent the issue by including tractor trailer
trucks and other trucks, in addition to dump trucks. According to the National Highway Traffic
Safety Administration, of the large trucks involved in fatal crashes, 66% are classified as truck
tractors, while only 29% are single -unit trucks, which includes the dump trucks used in coal ash
transportation.5
Duke Energy has also expressed its preference for rail transport in all future offsite
storage of coal ash .6 Though coal ash transportation by truck is safe, rail is an even safer
alternative .
Economic activity and environmental remediation cannot be stopped or hindered because
of fears that incompetent coal companies or utilities will poorly manage and/or select their
truckers and kill people. If they have that problem, the management should be investigated,
replaced, or taken legal action against. If this problem exists, this is a feature of incompetent and
unsafe management and selection, not a reason to leave another threat to human health and the
environment in place.
Nor is it a reason to stop economic activity or environmental cleanup because drunk
drivers or other at fault drivers cause accidents with trucks. If that were an argument against
doing something, it would be an argument against all economic, recreational, and personal
activity that involves driving.
2 Federal Motor Carrier Safety Administration, Company Snapshot: Duke Energy Business Services, Inc.,
b.9p:Hsafer fmcsa dot gov/query asp?searchtype=ANY&query type=queryCarrierSnapshot&query param=USDOT
&original query param=NAME&query string=94646.
3, Federal Motor Carrier Safety Administration, Company Snapshot: Charah Inc.,
http•//safer fncsa dot goy/query asp?searchtWe=ANY&query type=queryCarrierSnapshot&query param=USDOT
&original query param=NAME&query string=671494&originalquery string=CHARAH INC
4 Charah, Inc., Charah Receives Additional Awards for Employee Safety from North Carolina Department of Labor,
July 2014, hq://charah.com/charah-receives-additional-awards-employee-safety-north-carolina-department-labor/.
5 Fatality Analysis Reporting System (FARS) Encyclopedia: Vehicles http://www-
fars.nhtsa.dot. govNehiclesNehiclesAll Vehicles.aspx.
6 N.C. Coal Ash Commission Meeting Transcript, November 2014, http://www.duke-energy.com/pdfs/nc-coal-ash-
commission-transcript 11142014.pdf
19

II. Other Mistakes in DEQ's Risk Ratinlz Analysis
A. DEQ's Method of Calculating Risk Ratings for the December 31, 2015 Ratings
Violates CAMA and Ignores the Environmental Damages and Risks at Lee
A risk ranking process was specified in CAMA to determine the type of closure permitted at
each facility. The law specifically requires NCDEQ to classify each impoundment as either
high -risk, intermediate -risk, or low -risk, based on consideration, at a minimum, of all of the
following criteria.
(1) Any hazards to public health, safety, or welfare resulting from the impoundment.
(2) The structural condition and hazard potential of the impoundment.
(3) The proximity of surface waters to the impoundment and whether any surface waters
are contaminated or threatened by contamination as a result of the impoundment.
(4) Information concerning the horizontal and vertical extent of soil and groundwater
contamination for all contaminants confirmed to be present in groundwater in exceedance
of groundwater quality standards and all significant factors affecting contaminant
transport.
(5) The location and nature of all receptors and significant exposure pathways.
(6) The geological and hydrogeological features influencing the movement and chemical
and physical character of the contaminants.
(7) The amount and characteristics of coal combustion residuals in the impoundment.
(8) Whether the impoundment is located within an area subject to a 100-year flood.
(9) Any other factor the Department deems relevant to establishment of risk.
Environmental and ecologic damages and risks posed by the Lee site — and the factors
designated by the legislature in CAMA — were not fully considered by DEQ when establishing
the overall site risk and clean-up priority for Lee. This resulted in an overall Intermediate Risk
rating, which requires excavation and removal, but does not fully recognize the risks of the Lee
coal ash pits. For example, ten groundwater risk factors were established and received ratings by
DEQ. Of the 10 rated factors for old and failing 1956 lagoon, 5 received low ratings because of
the lack of drinking water wells or residents nearby. And the one "Key" factor that DEQ
established for groundwater turns on the number of people using well water within 1500 feet.
This approach fails to take into account the overall dangers of the Lee site, set out above,
as well as the fact that this contaminated groundwater flows directly into one of the state's most
important rivers, just upstream of a drinking water intake for thousands of people. In magnitude
and importance, those factors overwhelm issues such as the number of people who may ingest
soil. Yet, location near a drinking water intake is treated as just one factor in a process, and is
not a "Key" factor. This approach prevents an accurate evaluation in two different ways: on the
one hand, it picks out three "Key" factors when the entire site needs to be evaluated for all risks
with an eye to the magnitude of risks, and it analyzes the site by counting a list of factors, when
in general and as applied to a site, one or two factors may in fact be much more important that
many or all of the rest.
FIX

Further, an approach that emphasizes current human use by key factors and a number of
individual factors effectively ignores impacts to the natural environmental and natural resources.
The General Assembly tasked DEQ with assessing the risk posed by these failing impoundments
and directed DEQ to base its classifications on these sites' "risks to public health, safety, and
welfare; the environment; and natural resources ...." N.C. Gen. Stat. § 130A-309.211(a)
(emphasis added). To that end, CAMA requires consideration of "all receptors," which includes
ecological receptors. DEQ failed to adequately consider these impacts.
DEQ's approach also looks only at current human users and ignores future users of the
groundwater and surface water resources. The purpose of CAMA and any environmental
protection has to include protecting resources for future uses, not just current ones. Overall,
DEQ did not consider adequately all the factors, as required by CAMA.
If all factors are appropriately examined, Lee is a High Risk site.
B. It is Irrational to Reduce the Risk Rating of a Site With Millions of Tons of Coal
Ash Based on the Quantity of Coal Ash Stored
In its January 2016 Report, DEQ states that it assessed risk at coal ash sites based on
volume, and through unexplained and arbitrary distinctions DEQ thus lowered the groundwater
risk at many sites below high risk for this factor. According to the DEQ treatment of this risk
factor, any site under 3,240,10,3 tons is considered low risk; and any site (including Lee) under
12,512,755 tons is considered intermediate risk. There is no basis in law or fact for these
distinctions, and the DEQ Report offers no scientific or legal basis for these distinctions.
This analysis is based on the faulty assumption that some of the coal ash lagoons in the
state will be low risk, some intermediate, and some high. There is no basis for this assumption in
CAMA or in fact. CAMA does not grade on a curve, presuming some As, some Bs, and some
Cs, Ds, and Fs. There is no reason to assume that there is any coal ash lagoon that is low risk.
By making this assumption, the DEQ rankings rewrite the CAMA statute to guarantee that some
sites will be low risk, rather than consider the true risk of every site.
In fact, at least any unlined pit where millions of tons of coal ash are stored is high risk
for groundwater contamination. One, two, or three million tons — and of course Lee's nearly six
million tons — of coal ash are huge amounts of coal ash; they only appear to be lesser amounts
when compared to the tremendous quantities of ash that Duke Energy has irresponsibly placed in
some unlined pits over the years. When millions of tons of coal ash and other pollutants are in
contact with a large surface area of unlined soil near bodies of water (as at Lee), then there is a
high risk of coal ash groundwater contamination.
Under this analysis, the Dan River site — which was the site of the catastrophic spill,
which has serious groundwater contamination including arsenic, and which the Legislature itself
ranked as a high risk site — is a low risk site for this groundwater contamination risk factor.
Asheville, which the Legislature also determined to be high risk, is almost low risk and barely
21

rates intermediate. Sutton and Riverbend, which the Legislature also ranked as high risk, get
only an intermediate ranking for this feature.
Further, DEQ's own 2013 enforcement actions details serious groundwater contamination
at sites throughout the state, regardless of the amount of ash stored at a particular site.
Another striking example is Grainger in South Carolina. Less than 2 million tons of coal
ash are stored at that site, yet it has had some of the highest — if not the highest — arsenic
contamination of groundwater in the region. Its arsenic groundwater contamination has reached
over 3000 ppb, or over 300 times the legal standard.
One, two, or three million tons of coal ash, stored in unlined pits next to waterways, by
definition pose a high risk to groundwater. That is certainly true of the nearly six million tons of
coal ash stored at Lee directly on the river's banks, as demonstrated by the serious seeps at the
site, the poor status of the dams, the site's presence in a floodplain, and established groundwater
contamination. There is no basis for finding otherwise. In short, for this factor, Lee and all other
coal ash sites are High Risk.
C. DEQ's Groundwater Risk Evaluation Methodology Is Fundamentally Flawed
DEQ's approach to classifying groundwater risk is fundamentally flawed because it is
arbitrary, is not authorized by the CAMA statute, and it ignores the data gaps and uncertainty in
Duke's reports.
1. Arbitrary Cutoff
DEQ has decided arbitrarily that 10 North Carolinians' well water can be poisoned
without requiring Duke to excavate its coal ash to lined, dry storage. DEQ only requires
excavation — via an "Intermediate" risk classification — if 11 or more people's drinking water is
actually or potentially contaminated. Narrative at 15. There is no support for such an arbitrary
cutoff.
Allowing even one North Carolinian's water to be poisoned is unacceptable. For DEQ to
knowingly allow the actual or potential contamination of any family's drinking water fails the
agency's most basic responsibility to the state. Allowing Duke Energy to leave coal ash in
contact with groundwater supplies under a cap -in -place scenario would be just such a failing.
This arbitrary approach also ignores the likelihood that a family served by contaminated
well water could have more children, or the house could be sold to a larger family, so that more
than 10 people would now be affected. Basing the key decision about lined storage of coal ash
on an arbitrary snapshot is short-sighted and indefensible.
More fundamentally, DEQ's approach ignores the importance of protecting groundwater
as a public resource. If groundwater is being contaminated beyond Duke Energy's property
boundary, an important public resource that belongs to all North Carolinians is being harmed. In
addition, future economic development and new housing in rural areas not served by municipal
22

water depend on clean drinking water supplies. Duke cannot be allowed to leave its coal ash in
contact with these groundwater supplies in perpetuity — it must be required to place the ash in
lined, dry storage.
For the same reasons, DEQ's claim that a "Low Risk" classification for groundwater is
appropriate if "alternate water is made available to all residents whose wells are being impacted
by coal ash impoundments" is unsupportable. Narrative at 70. This approach ignores the
importance of protecting the resource for future uses, and of protecting the Neuse River, its
tributaries and adjacent wetlands, and the natural environment for all North Carolinians.
It is also inconsistent with the General Assembly's approach under CAMA. CAMA
separately requires the provision of alternate water where a coal ash impoundment has
contaminated a drinking water well. NCGS § 130A-309.211(c). That requirement applies
irrespective of the impoundment risk classification required by CAMA, and there is no basis for
using the separately required provision of alternate water to downgrade the risk rating for an
impoundment.
In addition, at Duke Energy's Sutton site in Wilmington, Duke was forced under public
pressure to agree to fund a water line to residents of the Flemington community, yet even after
that announcement, the General Assembly still rated the site High Priority and mandated
excavation to lined, dry storage, thereby removing the source of the ongoing groundwater
pollution. In a deposition this summer, DEQ Assistant Secretary Tom Reeder pointed out that
Duke Energy's groundwater pollution at Sutton had "nuked this whole drinking water source for
the Wilmington area." John Murawski, Top NC environmental official wanted to fine Duke
Energy $50 million over coal ash, Charlotte Observer (Oct. 8, 2015),
http://www.charlotteobserver.com/news/business/article38272179.html#stolylink=cpy. DEQ's
groundwater risk classifications cannot use the separately required provision of alternate water to
allow Duke to "nuke" public drinking water supplies and avoid having to remove the source of
the pollution.
2. Invalid "Low -Intermediate" Classification
For certain factors, such as if up to ten people are exposed to contaminated groundwater,
and for overall ratings of sites where it says it does not have adequate information, DEQ has
proposed an invented rating of "Low/Intermediate Risk." Narrative at 15. This is not a valid
classification under LAMA. The statute required DEQ to propose ratings for all of Duke
Energy's impoundments by December 31, 2015. N.C.G.S. § 130A-309.213(a). There are only
three options — Low, Intermediate, and High Risk., id. at § 130A-309.213(b), and with good
reason. After the Dan River spill and a federal criminal grand jury investigation into Duke
Energy and DEQ's handling of coal ash, the law is supposed to ensure that the inaction that has
characterized coal ash regulation in North Carolina for decades did not continue. The statute
required DEQ to make a clear recommendation at every site whether to require lined storage, and
allow the public to comment on a definite rating. Instead, DEQ has punted, avoiding that key
decision and incentivizing Duke Energy to keep delaying and obscuring the extent of its
contamination.
23

DEQ states, correctly, that Duke Energy's submissions have been deficient. The question
is whether Duke Energy should be allowed to benefit from these shortcomings. The answer
should be no.
Duke appears to view uncertainty as a means to obscure risk. Duke has encouraged DEQ
to act without knowing the extent of contamination to "make decisions before complete
information about a site is available." Duke Energy, "Memorandum Regarding CAMA
Requirements," Attachment 13, at 4. In a Duke Energy memo submitted to DEQ, Duke argues
that CAMA "does not require the Department to completely know the vertical and horizontal
extent for soil and groundwater contamination at each site." Id. By giving uncertainty and data
gaps no real weight in the risk classifications, DEQ's key factor approach allows Duke to slant
the prioritization process towards lower risk by withholding and/or obscuring unfavorable
information.
DEQ should take the approach that lined, dry storage is required until proven otherwise,
and place the burden on Duke Energy to demonstrate that the coal ash could be safely stored
without a liner. But instead, DEQ'has proposed a non -classification that fails to answer the key
question for protection of groundwater: whether or not Duke will be required to store its coal ash
in a lined, dry, properly designed facility.
There is no legal basis for the "Low -Intermediate" classification. If there is not clear and
convincing evidence to demonstrate that cap -in -place would protect public resources, excavation
should be required.
D. Ratings Based on "Key Factors" Are Illegal
CAMA sets out an extensive list of factors that DEQ must consider in proposing its
classifications. N.C.G.S. § 130A-309.213(a). CAMA requires DEQ to consider all of these
factors, rather than ignoring most of them in favor of a handful of supposed "key factors." It
plainly states that DEQ "shall ... at a minimum, consider all of the following" factors listed in
the statute. DEQ's "key factor" approach violates this requirement.
DEQ's staff compiled detailed ratings that fully analyzed these factors, but DEQ
ultimately has put forward an approach that does not consider the required factors in any
identifiable way. Instead, DEQ has arbitrarily invented a single "key factor" for groundwater,
surface water, and dam safety, and ignored all the other factors. It has even moved these other
factors to an appendix at the back of its Narrative, indicating their marginalized status. DEQ
candidly admits that its discussion of other groundwater factors beyond the "key factor" is an
empty exercise: "The decision -making process allows for scoring of high, intermediate, or low
risk for all factors that relate to those criteria identified in CAMA, but is focused on assigning the
overall groundwater risk classification based on" a single "key factor." Narrative at 13. In other
words, all factors were assigned an individual rating, but only one factor determined the overall
groundwater risk classification.
The folly of this approach is evident from the example given in Part I.C.2 above: for the
"key factor" that determined the groundwater risk rating, DEQ relied on Duke's self-serving
24

claims that it is not contaminating neighboring wells, while ignoring the uncertainties regarding
groundwater flow direction and extent of the contamination that directly affect that very issue.
DEQ acknowledged this uncertainty in the factors buried in the appendix, but ignored it for
purposes of the groundwater key factor.
Another example is dam safety. CAMA requires DEQ to consider "any hazards to public
health, safety, or welfare resulting from the impoundment," the "hazard potential of the
impoundment," "the proximity to surface waters to the impoundment," and "[w]hether the
impoundment is located in an area subject to a 100-year flood."
The Active Ash Basin is High risk based on current conditions, and is also High or
Intermediate Risk for all but one of the other Dam Safety factors:
• Hazard Classification: High Risk
• Proximity to Waters of the State: High Risk
• Volume of Facility: Intermediate Risk
• Offsite Drainage Area: Intermediate Risk
• Overall Dam Safety: High Risk
In spite of these ratings, and solely on the basis of speculation about the effect of future
repairs (discussed below), DEQ assigned the Active Basin a "Low Risk" rating for dam safety.
However, the first four factors listed above are not affected by repairs — they are inherent
risks of the design and location of the impoundment. That includes the flood plain issue as well.
Even Duke has admitted the impoundments are not suitable for long-term storage of coal ash.
Yet DEQ rated the Active Basin "Low Risk" for dam safety. Thus, the "key factor" approach
has failed to meaningfully consider the factors required by CAMA for dam safety related issues.
In sum, the "key factor" approach to groundwater, surface water, and dam safety adopted
by DEQ fails to consider the required factors and violates LAMA.
E. DEQ's Dam Safety Risk Evaluation Is Fundamentally Flawed
DEQ's dam safety risk evaluation is fundamentally flawed. First, by using the "key
factor" approach DEQ has given no identifiable weight to numerous dam safety considerations
required by CAMA, as explained above.
Second, DEQ has downgraded the dam safety risk for the Lee Active Basin based solely
on the fact that Duke Energy proposes to perform various repairs. But speculations about future
risk are not warranted under the Coal Ash Management Act.
CAMA requires DEQ to take into account "the structural condition and hazard potential
of the impoundment," among other factors. The Lee active impoundment has been given a
"High Hazard" rating by the State of North Carolina. And all the impoundments have had
numerous structural problems for many years, as set out in numerous inspection reports. CAMA
does not ask DEQ to speculate about the possible risk level of coal ash impoundments after
25

future repairs may be approved and eventually completed; instead, it asks for a classification of
the risks posed by the impoundments at the time of the evaluation.
It is inappropriate to consider future repairs and speculate on their effectiveness. The Lee
dams are dangerous because of their history, location, and basic design and structure. CAMA
directs DEQ to consider "Any hazards to public health, safety, or welfare resulting from the
impoundment" and "The structural condition and hazard potential of the impoundment."
CAMA does not instruct DEQ to consider "structural condition and hazard potential if the dam is
repaired at some future date," for example. DEQ must take the Lee dams as they exist.
Otherwise, DEQ is looking at some future state of affairs and speculating on the effectiveness, if
any, of proposed repairs over time.
CAMA can be meaningful only if DEQ evaluates the Lee dams as they are, in the
present, and not speculate on what may or may not transpire in the future. Indeed, the Dan River
spill occurred because DEQ and Duke Energy counted on some future possible inspections or
maintenance to take care of what was a dangerous and high risk coal ash storage facility.
Second, the basic dangers of the Lee dams cannot be repaired. As set out above, the
siting, hazard classification, volume, and other factors are inherent flaws in the Lee dams. These
fundamental problems are not subject to adequate repair. And, to make matters worse, all these
old, poorly designed, and failing dams are in a floodplain and most of them are directly on the
Neuse River. These fundamental defects and risks cannot be repaired.
In addition, elsewhere in the Narrative DEQ states that it included dewatering in its dam
safety evaluation. But including speculation about the dam safety effects of dewatering is not an
appropriate analysis under the CAMA statute. CAMA's classifications determine the schedule
and closure methods available for each impoundment. Dewatering is part of the closure process,
not part of the risk evaluation process, which logically must come before a classification and
determination of a closure plan. Thus, trying to short-circuit the analysis set out in CAMA to
incorporate part of the closure process into the Department's risk classifications is inappropriate.
Volume, Free Water Content, and Drainage Area. The DEQ Classification system
also artificially lowers the dam risk at Lee by breaking the site up into the separate
impoundments for the Volume, Free Water Content, and Drainage Area factors. As set out
above, Inactive Basins 1 and 2 are connected. They and Inactive Basin 3 are practically one unit,
because they occupy the same wetland area, the same floodplain, and are alongside and on top o
Half -Mile Branch and the other tributary streams, and the Cape Fear River as a unit. Active
Basin and Polishing Pond together are separated from the Inactive Basins, but are part of the
same floodplain.
By breaking these impoundments apart and thereby assigning each of them a lower risk
classification, the DEQ classifications for these factors tremendously understate the true risk of
the Lee site. For these factors and others related to dam safety, Lee is High Risk.
26

F. Inappropriate Consideration of Cost
The General Assembly did not include cost of closure and remediation in the list of
studies and information Duke Energy is required to submit to DEQ in preparation for
classification. See N.C. Gen. Stat. § 130A-309.209, 210. Nor is cost a factor the General
Assembly identified for DEQ to consider as it develops proposed classifications. See id. § 130A-
309.213. CAMA does not permit DEQ to temper its analysis of the options and timetable for
closure and remediation of coal ash impoundments. Indeed, CAMA specifically leaves any cost
consideration until later in the process, at the closure plan stage: The only permissible
consideration of costs under CAMA is by the Coal Ash Management Commission with respect
to a coal ash impoundment closure plan — not the risk classifications. N.C. Gen. Stat. Ann. §
130A-309.214(d).
Nonetheless, cost concerns permeated DEQ's prioritization analysis. The very first
paragraph of DEQ's Narrative is dedicated to cost concerns: "[These classifications] are of
critical importance because of the environmental impact and closure costs associated with each
classification. Impoundments classified as intermediate or high must be excavated at a potential
cost of up to $10 billion for all impoundments, while environmentally protective, less costly
options are available for low priority impoundments. Closure costs could be passed on to the
ratepayer. " Narrative at 2 (emphasis added). DEQ's own press release announcing public
hearings on the draft classifications provided that "[t]he classification process is an important
step in cleaning up coal ash to protect the environment and ratepayers." 7 DEQ apparently views
its role in this process as integral to protecting ratepayers by insuring cleanup is not too costly.
Concerns over cost permeated DEQ's analysis in violation of CAMA.
Moreover, the numbers quoted by DEQ are Duke's numbers, not an independent
evaluation.. Santee Cooper is excavating about 10% of the amount that Duke would be required
to excavate for its entire fleet for $220 million. In fact, Duke itself has not claimed that the
excavation and removal of ash will cost $10 billion. Duke admits that $2 billion of the number is
the cost of going to dry storage in the future, and that excavation and removal will cost $6 to $8
billion. Duke's current activities will cost, according to Duke, $4 billion. So, the incremental
cost — even according to Duke — should be $2 to $4 billion. DEQ, even according to Duke's
numbers, is overstating the amount at issue tremendously. Moreover, using Santee Cooper real
world experience, DEQ, by accepting Duke's numbers, is overstating the cost by 3x to 5x.
hops://www.duke-energy.com/news/releases/2014042201.asp. Further, both SCE&G and Santee
Cooper in South Carolina have stated that the excavations of all their coal ash will not require
rate increases. An independent study of Duke Energy's claims has shown the same thing.
http://www.ieefa.org/wp-content/uploads/2014/06/IEEFA-Duke-Study-Summary-Final-6-10-
141.pdf.
7 https://deq.nc.gov/press-release/deq-announces-l4-public-meetings-draft-coal-ash-pond-closure-deadlines.
27

G. The State of North Carolina Has Already Identified the Ongoing Pollution at Lee as
High Risk
CAMA requires DEQ to base its proposed classifications on "these sites' risks to public
health, safety, and welfare; the environment; and natural resources ...." N.C.G.S. § 130A-
309.213 (a).
On at least three other occasions, DEQ has determined that the Lee coal ash pollution is
high risk.
In March of 2014, DEQ conducted risk evaluations of all Duke Energy coal ash sites in
the state. Attachment 14. Considering the factors at issue in the CAMA ratings, DEQ gave the
Lee Active Basin a risk rating of 40. This rating is higher than the risk ratings for the Riverbend
and Sutton sites designated by CAMA as High Priority. By definition, then, the Lee coal ash
impoundments are high risk.
In addition, DEQ has filed an enforcement action against Duke Energy for, among other
things, unpermitted discharges to public waters at the Lee site. The State has said in its sworn
complaint that these unpermitted discharges "pose[] a serious danger to the health, safety and
welfare of the people of the State of North Carolina and serious harm to the water, resources of
the State." State of North Carolina ex rel. North Carolina Department of Environmental Quality
v. Duke Energy Progress, No. 13 CVS 11032 (Wake Co.), 1204 (emphasis added).
The March 2014 evaluation and this sworn conclusion show that the "Intermediate" risk
rating for the Lee impoundments does not adequately account for all the risks posed by this site.
Finally, in a November 2015 comprehensive evaluation of groundwater, surface water,
and dam safety factors, DEQ's professional staff rated all five of the Lee impoundments as
"High Risk" after all modifications — including dam safety repairs and dewatering were taken
into account — and also rated all five impoundments High Risk under current conditions.
Attachment 15. Without any change in facts or law or any new information of any substance (or
any new information at all, to our knowledge), DEQ has downgraded that rating to
"Intermediate." There is no justification for this change.
Finally, in April 2016, the North Carolina Superior Court ordered excavation and
removal of ash from Lee as a remedy for water pollution at the Lee site. This ruling also
amounts to a finding that the Lee site is High Risk.
DEQ's risk classifications should reflect these serious threats to the public and our shared
water resources, as CAMA explicitly requires.
28

Conclusion
For all these reasons, the Lee Active Basin and Polishing Pond, and Inactive Basins 1-3,
are High Risk and the coal ash must be excavated to lined, dry storage.
Thank you for your consideration of these comments.
SincqFr'
rely, �—
VS.ollem(a1n
III
Nicholas S. Torrey
29

Attachment 1
National Wetlands Inventory Map
N.C. Division of Coastal Management
Wetlands Map

Attachment 2
H.F. Lee —Stream Map

Lee Power Station
t�"v—
��• '--ram/ '
i
Oj�lrpj/P
N ck Lake
d / -
L
QkQ,ke ydk -�
\ ' Neck;
s'� • �� r �\ � fir,"/� � %- / I` � 1 � _
CZ
ElPff - _ !
o ,J ens sYBreau Copyr_ight:© 2013 National_G.eograplii •_Socl'ety, i-cubed
Additiornal Data Sources USGS EPA US Q
DISCLAIMER: Map intended for illustrative purposes only. Ash 0 0.325 0.65 1.3 Miles
pond and landfill boundaries are best estimates based on
documents from EPA and the utilities themselves. Locations of
existing and retired ash ponds and landfills were created by heads- Scale varies throughout map series
up digitizing of aerial imagery and USGS 7.5 min. topographic Legend It
maps. Outlined areas appearing to be void of a pond or landfill are
thought to be retired units that are now covered in place. For Coal Ash Pond/Landfill
Faciiit
additional information see SoutheastCoalAsh.Org Stream/River � Southern
—
Y Map createdbyJovianSackett (jsackettCselcnc.org) Environmental
Location Last Updated:412112014 Canal/Pipeline/other J' Law Center

Attachment 3
Duke Energy — Safe Basin Closure Update

Safe Basin Closure Update
H.F. Lee Plant
Duke Energy is committed to closing ash basins in ways
that put safety first, protect the environment, minimize
impacts to communities and manage costs.
Building on the momentum of coal ash excavation work
already underway at several Carolinas sites, the company
announced its recommendations to fully excavate all five
basins at the H.F. Lee Plant in Goldsboro, N.C.
While the basins are currently operating safely, the basins
are not suited for long-term permanent storage of the
material.
Based in science and engineering: Outside experts, along
with Duke Energy engineers and environmental experts,
conducted research at every basin, developed unique
closure recommendations for each site and tested them
against strict new state and federal regulations.
Extensive science and engineering studies tell us that
we need to excavate the 5.9 million tons of ash located
in basins at the H.F. Lee Plant property and safely store
the material in a fully lined solution. Studies noted the
possible risk of flooding at the plant site, which
makes excavation the best option for long-term safe
storage of the material.
Transportation: A transportation method and schedule
will be determined in the coming months, but wherever
possible the company wants to use rail to move the
material and lessen the impact on local communities.
('DUKE
ENERGY
H.F. Lee Plant
County: Wayne
Commercial date: 1951
Retirement date: 2012
We're closing ash basins in ways that:
C) 0
Put safety Protect the
first environment
L02
ripk.
()
Minimize impact Manage
to communities costs
Meeting state and federal standards: Duke Energy is
committed to the health, safety and well-being of the
communities we serve and to protecting the environment and natural resources. The company's proposed strategy
is subject to the state's basin classification, public input and necessary approvals from the North Carolina Department
of Environmental Quality.
All recommendations comply with the U.S. Environmental Protection Agency's recently published federal Coal
Combustion Residual (CCR) regulations and North Carolina's Coal Ash Management Act (CAMA).

Site overview: When coal is burned, it creates multiple coal combustion products (CCPs), including fly ash, a fine material
similar to the consistency of talcum powder, and bottom ash, which is a coarser, granular material collected from the
bottom of coal-fired boilers. That material, totaling approximately 6 million tons at H.F. Lee, is safely stored on plant
property, and the company continuously evaluates those storage methods. Because the H.F. Lee Plant has been retired,
there is no coal combustion taking place and no additional ash being added to the ash basins. Over time, Duke Energy and
the rest of the utility industry have changed and improved ash management practices.
For more information about coal ash safe basin closure, please visit duke-energy.com/SafeBasinClosure.
©2016 Duke Energy Corporation 153890 2/16

Attachment 4
PSC-SC Duke Ex Parte Briefing
re Coal Ash Disposal
2/10/16

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

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

Attachment 5
SCE&G Wateree Semi -Annual
Status Report (relevant pages)
July — December 2015

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

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

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

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

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

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

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

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

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

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

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

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

Attachment 6
GGS Ash Removal Report 2014 YTD
1/14/15

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

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

Attachment 7
GGS Ash Removal Report 2015 YTD
1/11/16

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

Attachment 8
Grainger Groundwater Monitoring Results
11/22/13

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Attachment 9
GGS NPDES Supplemental Sampling
3/1/16

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

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

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

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

Attachment 10
GGS NPDES Sampling DHEC Transmittal
11/24/15

4q
SantCE', C40pelr"
CERTIFIED MAIL
November 24, 2015
Mr. Chris Forrest
Groundwater Protection Section
SCDHEC
Bureau of Water
2600 Bull Street
Columbia, South Carolina 29201
Mr. Gary Stewart
State Voluntary Cleanup Section
SCDHEC
Bureau of Land and Waste Management
2600 Bull Street
Columbia, SC 29201
Dear Mr. Forrest:
Re; South Carolina Public Service Authority
Santee Cooper Grainger Generating Station, Horry County
NPDES Permit# SCO001104
NPDES Groundwater Semi-annual Report for 2015
Attached are results from the November 2-5, 2015 groundwater and surface water sampling
event. Separate maps showing sampling locations and arsenic concentrations are included.
Two of the wells, GGSMW-10 and GGSMW-3, both located on Ash Pond 1, and the three
piezometers, located near Ash Pond 2, were inaccessible due to remaining floodwaters from the
l 000-year flood in early October 2015. Several photographs are attached. These sites will be
monitored as soon as the floodwaters retreat and the wells can be safely accessed. The results
will be reported as a separate transmittal.
Lab results showed measurable concentrations of arsenic in four of the sixteen locations where
water samples were analyzed. One was a groundwater well along the down gradient edge of Ash
Pond 1 and three were groundwater wells along the down gradient edge of Ash Pond 2.
An arsenic concentration map is provided to show the distribution of data points across the site.
Non -detectable results in the river, the intake canal, and most of the groundwater wells prevent
the use of isoconcentration lines. Ongoing ash removal activities, which began on March 17,
2014, will cause the groundwater geochemistry to fluctuate.
Dne Rir omuod Drivs � Moncks Corner, SC 29461-2'901 1 (84C) 7E1.8000 { RO. Box 294B101 I Moncks Corner, SC 29461-6101

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

s m V -

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Grainger Generating Station
NPDES Groundwater Monitoring
Potentiometric Map
November 2015
Groundwater Contour Interval
23 Groundwater Elevation (feet)
Well ID TOC GW GW
Elevation Depth Elevation
(feet) (feet) (feet)
MW-1 13.32 9.51 3.81
M W-2 11.06 3.32 7.74
MW-3 6.72 NA
MW-4 12.01 12.01 0
M W-5 9.09 4.15 4.94
MW-6 8.19 4.75 3.44
MW-12 14.9 9.49 5.41
MW-9 8.24 2.95 5.29
MW-10 8.92 NA
MW-11 9.63 4.36 5.27
PZ-1 6.66 NA
PZ-2 6.82 NA
PZ-3 7.25 NA
Water levels collected on November 2, 2015.
However, due to the 1000-year flood, several wells
and piezometers were inaccessible (NA).
11/23115:MDG
i

11/23/15:MDG

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One Box 2 461
01 saood Drive
M lee coupe Moncks Camer, SC 29461-2901
[phone]
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34595 Location: GW Well GGSMW-1 Date: 11/02/2015 Sample Collector:
Loc. Cade GGSMW-1
Time: 13:40
Analysis
Result QUAL
Units
Test Date
Analyst
Method
Arsenic
t10
ug/L
11/12/2015
KLMORAN
EPA200.7
Arsenic - Dissolved
<10
ug/L
11/12/2015
KLMORAN
EPA 200.7
Barium
73.2
ug/L
11/1212015
KLMORAN
EPA200.7
Cadmium
<5
ug/L
11112/2015
KLMORAN
EPA 2003
Chloride
6.25
mg/L
11/0412015
LCWILLIA
EPA 300.0
Spec. Cond.
168
us
11/02/2015
MDGOINGS
Chromium
<5
ug/L
11/12/2015
KLMORAN
EPA200.7
Copper
<10
ug/L
1111212015
KLMORAN
EPA 200.7
Depth
9.51
Feet
11/02/2015
MDGOINGS
Elevation
3.81
Feet
11102/2015
MDGOINGS
Iron
148873.0
ug/L
11/16/2015
KLMORAN
EPA200.7
Oxidation Reduction Potential
2
my
11/0212015
MDGOINGS
SM2580
Lead
<10
ug/L
11/12/2015
KLMORAN
EPA 200.7
pH
5.93
SU
11/02/2015
MDGOINGS
Selenium
<10
ug/L
11/12/2015
KLMORAN
EPA200.7
Sulfate
843
mg/L
11/04/2015
LCWILLIA
EPA300.0
Total Dissolved Solids
1416
mg1L
11/1112015
AJBROWN
SM 2540C
Temp
22.53
C
11/02/2015
MDGOINGS
Thallium
<1.0 U
ug/L
11/13/2015
TESTAMERICA
EPA 200-7 / 6010
Total Suspended Solids
16.35
mg/L
11/11/2015
AJBROVVN
SM 2540D
Turbidity
0
NTU
11/02/2015
MDGOINGS
Zinc
62.4
ug/L
11/12/2015
KLMORAN
EPA200.7
Independent Laboratory Results: "GEL" - GEL Laboratories LLC - Lab ID # 10120, "Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001;
"DavisBrown"- Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
Analysis Validated:
Debra K. Guerry - Supervisor, Analytical Services

One Rx 294 Drive
P.Q. Boox 2846101
'Psantee cooper MQMks Comer, 5C 29461-2901
(843) 7e1-BOOD
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34596 Location: GW Well GGSMW-2
Loc. Code GGSMW-2
Analysis
Arsenic
Arsenic - Dissolved
Barium
Cadmium
Chloride
Spec. Cond.
Chromium
Copper
Depth
Elevation
Iron
Oxidation Reduction Potential
Lead
pH
Selenium
Sulfate
Total Dissolved Solids
Temp
Thallium
Total Suspended Solids
Turbidity
Zinc
Date. 11/02/2015 Sample Collector:
Time: 14:25
Result QUAL
Units
Test Date
Analyst
Method
<10
ug/L
11/12/2015
KLMORAN
EPA200.7
<10
ug/L
11/12/2015
KLMORAN
EPA 200.7
59.9
ug/L
11/12/2015
KLMORAN
EPA200.7
<5
ug/L
11/12/2015
KLMORAN
EPA200.7
5.15
mg/L
11/04/2015
LCWILLIA
EPA 300.0
339
us
11102/2015
MDGOINGS
<5
uglL
11/12/2015
KLMORAN
EPA200.7
<10
uglL
11/12/2015
KLMORAN
EPA200.7
3.32
Feet
11/02/2015
MDGOINGS
7.74
Feet
11/0212015
MDGOINGS
3601.4
ug/L
11/12/2015
KLMORAN
EPA200.7
-61
my
11/02/2015
MDGOINGS
SM2580
<10
ug/L
11/12/2015
KLMORAN
EPA200.7
6.5
SU
11/02/2015
MDGOINGS
<10
ug/L
11/12/2015
KLMORAN
EPA200.7
3.89
mg/L
11/04/2015
LCWILLIA
EPA 300.0
206.0
mg1L
11/11/2015
AJBROWN
SM 2540C
22.85
C
11/02/2015
MDGOINGS
<1.0 U
ug/L
11/13/2015
TESTAMERICA
EPA 200.7 / 6010
7.95
mg/L
11/1112015
AJBROWN
SM 2540D
16.7
NTU
1V0212015
MDGOINGS
<10
ug/L
1111212015
KLMORAN
EPA 200.7
Independent Laboratory Results: "GEL" - GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001:
"DavisBrown"- Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc,- Lab ID# 32010
Analysis Validated: }�
Debra K. Guerry - Supervisor, Analytical Services

Santee cooper
Sample # AD34598 'Location:
Loc. Code GCSMW-4
Analysis
Arsenic
Arsenic - Dissolved
Barium
Cadmium
Chloride
Spec. Cond.
Chromium
Copper
Depth
Elevation
Iron
Oxidation Reduction Potential
Lead
pH
Selenium
Sulfate
Total Dissolved Solids
Temp
Thallium
Total Suspended Solids
Turbidity
Zinc
One Riverwood Drive
P_0, box 29461 a1
Moncks Comer, SC 29461-2901
[phone]
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
G1/V Well GCSMW-4 Date: 11/02/2015 Sample Collector:
Time: 15:52
Result QUAL
Units
Test Date
Analyst
Method
<10
ug1L
11112/2015
KLMORAN
EPA200.7
<10
uglL
11/12/2015
KLMORAN
EPA 200.7
29.8
ug/L
11/12/2015
KLMORAN
EPA 200.7
<5
ug/L
11/1212015
KLMORAN
EPA 200.7
23.5
mg/L
11/0412015
LCWILLIA
EPA300.0
288
u5
11/0212015
MDGOINGS
<5
ug/L
1111212015
KLMORAN
EPA 200.7
<10
ug/L
11/12/2015
KLMORAN
EPA200.7
8.34
Feet
11/02/2015
MDGOINGS
3.67
Feet
11/02/2015
MDGOINGS
21599.1
ug/L
11/12/2015
KLMORAN
EPA 200.7
0
my
11/02/2015
MDGOINGS
SM2580
<10
ug/L
11/12/2015
KLMORAN
EPA 200.7
5,51
Su
11/02/2015
MDGOINGS
10.5
ug/L
11/12/2015
KLMORAN
EPA200.7
2.94
mg/L
11/04/2015
LCWILLIA
EPA300.0
228.0
mg/L
11f11/2015
AJBROWN
SM 2540C
19.7
C
1110212015
MDGOINGS
<1.0 U
ug/L
11/1312015
TESTAMERICA
EPA 200.7 / 6010
1.50
mg/L
11/1112015
AJBROWN
SM 2540D
0
NTU
11102/2015
MDGOINGS
<10
ug/L
11 /1212015
KLMORAN
EPA 200.7
Irdepende,nt Laboratory Results; "GEL" - GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001;
"DavisBrown"- Davis & Brown Lab ID # 21117; 'Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
Analysis Validated:
Debra K. Guerry - Supervisor, Analytical Services

Santee doper
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
One Rlvern+ood Drive
P.0 Box 2946101
Moncks Comer, SC 29461-2901
(843)761-BOOn
Sample # AD34599 Location: GW Well GGSMW-5 Date: 11/03/2015 Sample Collector:
Loc. Code GGSMW-5 Time: 12:09
Analysis
Arsenic
Arsenic - Dissolved
Barium
Cadmium
Chloride
Spec. Cond.
Chromium
Copper
Depth
Elevation
Iron
Oxidation Reduction Potential
Lead
pH
Selenium
Sulfate
Totat Dissolved Solids
Temp
Thallium
Total Suspended Solids
Turbidity
Zinc
Result QUAL
Units
Test Date
Analyst
Method
11.9
ug/L
11/12/2015
KLMORAN
EPA 200.7
14.4
ug/L
11/12/2015
KLMORAN
EPA 200.7
49.8
ug/L
11/12/2015
KLMORAN
EPA 200.7
C5
ug/L
11/12/2015
KLMORAN
EPA 200.7
5.48
mg1L
11/06/2015
LCWILLIA
EPA300.0
354
us
11103/2015
MDGOINGS
<5
ug/L
1111212015
KLMORAN
EPA 200.7
<10
ug/L
11/12/2015
KLMORAN
EPA 200.7
4.15
Feet
11/0312015
MDGOINGS
4.94
Feet
11/03/2015
MDGOINGS
4213.1
ug/L
11/12/2015
KLMORAN
EPA 200.7
-112
my
11/03/2015
MDGOINGS
SM2580
<10
ug1L
11/12/2015
KLMORAN
EPA 200.7
5.66
SU
11/03/2015
MDGOINGS
<10
ug/L
11/1212015
KLMORAN
EPA 200.7
111
MOIL
11/06/2015
LCWILLIA
EPA300.0
263.0
MOIL
11/11/2015
AJBROWN
SM 2540C
19.863
C
11/03/2015
MDGOINGS
<1.0 U
ug/L
11/13/2015
TESTAMERICA
EPA 200.7 16010
<1.0
mg/L
11/11/2015
AJBROWN
SM 2540D
0
NTU
11/03/2015
MDGOINGS
29.0
ugIL
11/12/2015
KLMORAN
EPA 200.7
Independent Laboratory Results: "GEL" -GEL Laboratories LLC -Lob ID # 10120; 'Test America" - TestAmeriea Laboratories, Ine. -Lab ID# 96001;
"DavisBrown"- Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
Analysis Validated: --�,
Debra K. Guerry - Supervisor, Analytical Services

Cne Riverwood Drive
P.Q. Box 2946101
Santee Cooper Moncks Corner, SC 29461-2901
(843) 761-800D
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34600 Location: G4/V Well GGSMW-6 Date: 11/0212015 Sample Collector:
Loc. Code GGSMW-6
Time: 15:15
Analysis
Result
QUAL Units
Test Date
Analyst
Method
Arsenic
<10
ug1L
11/12/2015
KLMORAN
EPA 200.7
Arsenic - Dissolved
<10
uglL
11/12/2015
KLMORAN
EPA 2003
Barium
72.0
ug/L
11112/2015
KLMORAN
EPA 200.7
Cadmium
<5
ug/L
11/12/2015
KLMORAN
EPA 200.7
Chloride
9.43
mglL
11/0412015
LCWILLIA
EPA300.0
Spec. Cond.
928
us
11/02/2015
MDGOINGS
Chromium
<5
ug/L
11/12/2015
KLMORAN
EPA200.7
Copper
<10
ug/L
11/12/2015
KLMORAN
EPA200.7
Depth
4.75
Feet
11/02/2015
MDGOINGS
Elevation
3.44
Feet
11/02/2015
MDGOINGS
Iron
4521.7
ug/L
11/12/2015
KLMORAN
EPA 200.7
Oxidation Reduction Potential
-18
my
11/0212015
MDGOINGS
SM2580
Lead
<10
ug/L
11/12/2015
KLMORAN
EPA 200.7
pH
6.09
SU
11102/2015
MDGOINGS
Selenium
11.2
ugIL
11/12/2015
KLMORAN
EPA200.7
Sulfate
26.8
mg/L
11/04/2015
LCWILLIA
EPA300.0
Total Dissolved Solids
651.0
mg/L
11111/2015
AJBROWN
SM 25440C
Temp
21.12
C
11/02/2015
MDGOINGS
Thallium
<1.0
U ug/L
11/1312015
TESTAMERICA
EPA 200.7 / 6010
Total Suspended Solids
3,95
mglL
11/11/2015
AJBROWN
SM 2540D
Turbidity
0
NTU
11/02/2015
MDGOINGS
Zinc
<10
ugh-
11/12/2015
KLMORAN
EPA200.7
Independent Laboratory Results: "GEL" - GEL Laboratories LLC - Lab ID # 10120; 'Test America" - TestAmerica Laboratories, Inc, - Lab ID# 98001;
"DavisBrown"- Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
Analysis Validated: - ,
Debra K. Guerry - Supervisor, Analytical Services

erwood
One Box 29461 Drive
} p cooper
/� [� �/ P-0. Box 29d6101
'qpsan ee k mil_ ope Marcks Comer, SC 29461-2901
[phone]
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34601 Location: GW Well GGSMW-9 'Date: 11/02/2015 Sample Collector:
Loc. Code GGSMW-9
Time: 00:00
Analysis
Result QUAL
Units
Test Date
Analyst
Method
Arsenic
1241.3
ug/L
11/12/2015
KLMORAN
EPA 200.7
Arsenic -Dissolved
1077.7
ug/L
11/12/2015
KLMORAN
EPA200.7
Barium
493
ug/L
11/1212015
KLMORAN
EPA 200.7
Cadmium
<5
ug1L
11112/2015
KLMORAN
EPA 200.7
Chloride
165
mg1L
11/06/2015
LCWILLIA
EPA 300.0
Spec. Cond.
1014
u8
11105/2015
MDGOINGS
Chromium
<5
ug/L
11/12/2015
KLMORAN
EPA 2007
Copper
<10
ug/L
11/12/2015
KLMORAN
EPA 200.7
Depth
2.95
Feet
11/05/2015
MDGOINGS
Elevation
5.29
Feet
11105/2015
MDGOINGS
Iron
16768.3
ug/L
11/12/2015
KLMORAN
EPA 200.7
Oxidation Reduction Potential
78
my
11/05/2015
MDGOINGS
SM2580
Lead
<10
ug/L
11112/2015
KLMORAN
EPA 200.7
pH
5.47
SU
11/0512015
MDGOINGS
Selenium
<10
ug/L
11/1212015
KLMORAN
EPA 200.7
Sulfate
231
mg/L
11/06/2015
LCWILLIA
EPA300.0
Total Dissolved Solids
752.0
mg1L
11/11/2015
AJ13ROWN
SM 2540C
Temp
20.91
C
11/0512015
MDGOINGS
Thallium
<1.0 U
ug1L
11/13/2015
TESTAMERICA
EPA 200.716010
Total Suspended Solids
4.10
mg1L
11/11/2015
AJBROWN
SM 2540D
Turbidity
8.7
NTU
11/0512015
MDGOINGS
Zinc
22.4
ug/L
11112/2015
KLMORAN
EPA 200.7
Independent Laboratory Results: "GEL" - GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. - Lab ID# 98001;
"DavisBrown"- Davis & Brawn Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
r
Analysis Validated:
Debra K. Guerry - Supervisor, Analytical Services

Santee cooper
Sample # AD34603 Location
Lac. Code GGSMW-11
Analysis
Arsenic
Arsenic - Dissolved
Barium
Cadmium
Chloride
Spec, Cond.
Chromium
Copper
Depth
Elevation
Iron
Oxidation Reduction Potential
Lead
pH
Selenium
Sulfate
Total Dissolved Solids
Temp
Thallium
Total Suspended Solids
Turbidity
Zinc
One Rivenvood Drive
P.O. Box 2946101
Monrks Carrer, SC 28461-2901
[phone]
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
GW Well GGSMW-11 date: 11/0312015 Sample Collector:
Time: 13:53
Result QUAL
Units
Test Date
Analyst
Method
108.5
ug/L
11/12/2015
KLMORAN
EPA200.7
43.3
ug/L
11/12/2015
KLMORAN
EPA 200.7
78.3
ug/L
11/12/2015
KLMORAN
EPA 200.7
<5
ug/L
11/12/2015
KLMORAN
EPA 200.7
5.40
mg/L
11/04/2015
LCWILLIA
EPA300.0
545
us
11/03/2015
MDGOINGS
<5
ug/L
11/1212015
KLMORAN
EPA 200.7
<10
ug/L
11/12/2015
KLMORAN
EPA 200.7
4.36
Feet
11/03/2015
MDGOINGS
5.27
Feet
1110312015
MDGOINGS
10171.5
ug/L
1111212015
KLMORAN
EPA 200.7
-4
my
11/03/2015
MDGOINGS
SM2580
<10
ug/L
11/12/2015
KLMORAN
EPA 200.7
6.24
Su
11/03/2015
MDGOINGS
<10
ug/L
11/12/2015
KLMORAN
EPA 200.7
65.2
mg/L
11/04/2015
LCWILLIA
EPA300.0
347.0
mgll
1111V2015
AJBROWN
SM 2540C
19.51
C
11/0312015
MDGOINGS
<1.0 LI
ug/L
1111312015
TESTAMERICA
EPA 200.7 / 6010
16.08
mg1L
11/11/2015
AJBROWN
SM 2540D
20
NTu
11/0312015
MDGOINGS
44.1
uglL
11/12/2015
KLMORAN
EPA 200.7
Independent Laboratory Results; "GEL" - GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. - Lab JD# 98001;
"DavisBrown"- Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc,- Lab ID# 32010
Analysis Validated:
Debra K. Guerry - Supervisor, Analytical Services

One Riverwt4od drive
P.O. Box2946101'Psantee
cooper
Muncks Corner, SC 29461-2901
(843}761-80M
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34604 Location: GW Well GGSMW-12 Date: 11/03/2015 Sample Collector:
Loc. Code GGSMW-12 Time: 11:19
Analysis Result QUAL Units Test Date Analyst Method
Arsenic 40.8 ug/L 11112/2015 KLMORAN EPA 200.7
Arsenic- Dissolved 46.5 ug/L 11/12/2015 KLMORAN EPA 200.7
Barium 71.4 ug/L 11/12/2015 KLMORAN EPA200.7
Cadmium <5 ug/L 11/12/2015 KLMORAN EPA200.7
Chloride 5.73 mg/L 11/04/2015 LCWILLIA EPA300.0
Spec. Cond. 508 u6 11/03/2015 MDGOINGS
Chromium <5 ug/L 11/12/2015 KLMORAN EPA 2007
Copper <10 ug/L 11/12/2015 KLMORAN EPA200.7
Depth 9.49 Feet 11J0312015 MDGOINGS
Elevation 5.41 Feet 11/03/2015 MDGOINGS
Iron 14070.7 ug/L 11/12/2015 KLMORAN EPA200.7
Oxidation Reduction Potential -50 my 11/03/2015 MDGOINGS SM2580
Lead <10 ug/L 11112/2015 KLMORAN EPA 200,7
pH 5.89 Su 11/0312015 MDGOINGS
Selenium <10 ug/L 11112/2015 KLMORAN EPA 200.7
Sulfate 138 mg/L 11109/2015 LCWILLIA EPA 300.0
Total Dissolved Solids 435.0 mg/L 11/11/2015 AJBROWN SM 2540C
Temp 21.32 C 11/03/2015 MDGOINGS
Thaliium <1,0 U ug/L 11/13/2015 TESTAMERICA EPA200.716010
Total Suspended Solids <1.0 mg1L 11111/2015 AJBROWN SM 2540D
Turbidity 0.3 NTU 11/03/2015 MDGOINGS
Zinc <10 ug/L 11/1212015 KLMORAN EPA200,7
Independent Laboratory Results: "GEL" - GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc, - Lab ID# 98001;
"DavisBrown"- Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
Isef
Analysis Validated: -
Debra K. Guerry - Supervisor, Analytical Services

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4q
Ono Riverwnoci Drive
Psantee �S P.O. Box 29461ai
cooper Moncks Corner, SC 2IJ461-2901
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34038 Location: Lower Waccamaw River Date: 10/26/2015 Sample Collector: CM/EG
Loc. Code WAC—LOW Time: 11:52
Analysis
Result QUAL
Units
Test Date
Analyst
Method
Air Temp
17
C
10/29/2015
CWMOORER
Arsenic
e3.0 U
ug/L
11/09/2015
TESTAMERICA
EPA200.8
Arsenic - Dissolved
<3.0 U
ug/L
11/09/2015
TESTAMERICA
EPA 200.8
Collection Depth
2.25
m
10/29/2015
CWMOORER
Field Conductivity
59
us
1012912015
CWMOORER
Field pH
5.72
su
10/29/2015
CWMOORER
Flow
4660
cfs
10129/2015
CWMOORER
Gauge heigh
11.07
ft
10/2912015
CWMOORER
Oxidation Reduction Potential
205
my
10/29/2015
CWMOORER
SM2580
Weather
2
other
10/29/2015
CWMOORER
Water Temp
17.42
C
10/29/2015
CWMOORER
Independent Laboratory Results: "GEL" -GEL Laboratories LLC -Lab ID # 10120; "Test America"-TestAmerica Laboratories, Inc. -Lab 0# 98001; "DavisBrown"-
Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab 1D# 32010
Analysis Validated:
Debra K. Guerry - Supervisor, Analytical Services

One Riverwood Ddve
P O, 6101 JJantecooper Moncks Comer, SC 29461-2901
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION 408552
Sample # AD34039 Location: GGS Cooling Pond Date: 10/26/2015 Sample Collector: MEG
Loc. Code GGS_CP Time: 12:18
Analysis
Result QUAL
Units
Test Date
Analyst
Method
Air Temp
17
C
1012912015
CWMOORER
Arsenic
<3.0 U
ug/L
11/09/2015
TESTAMERICA
EPA200.8
Arsenic - Dissolved
<3.0 U
ug1L
11/0912015
TESTAMERICA
EPA 200.8
Collection Depth
0.3
m
10/29/2015
CWMOORER
Field Conductivity
58
us
10/29/2015
CWMOORER
Field pH
5.69
Su
10/29/2015
CWMOORER
Gauge heigh
under water
ft
10/29/2015
CWMOORER
Oxidation Reduction Potential
201
my
10129l2015
CWMOORER
SM2580
Weather
2
other
10129/2015
CWMOORER
Water Temp
18.31
C
10/29/2015
CWMOORER
Independent Laboratory Results: "GEL" -GEL Laboratories LLC -Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc, -Lab ID# 98001; "DavisBrown"-
Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
Analysis Validated:
Debra K. Guerry - Supervisor, Analytical Services

One Riverwood Vve
cooper
Box29461©1
'qp(�
santee `-"-' `�' per Moncks Corner, SC 29461-2961
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34040 Location: Waccamaw River Oxbow Date: 10/26/2015 Sample Collector: CM/EG
Loc. Code WAC_OX
Time: 12:42
Analysis
Result QUAL
Units
Test Date
Analyst
Method
Air Temp
17
C
10/29/2015
CWMOORER
Arsenic
<3.0 U
ug/L
M09/2015
TESTAMERICA
EPA 200.8
Arsenic - Dissolved
<3.0 U
ug/L
11/0912015
TESTAMERICA
EPA200.8
Collection Depth
2.4
m
10/29/2015
CWMOORER
Field Conductivity
59
us
10/29/2015
CWMOORER
Field pH
5.45
5U
1012912015
CWMOORER
Oxidation Reduction Potential
219
my
10129/2015
CWMOORER
SM2580
Weather
2
other
10129/2015
CWMOORER
Water Temp
17.46
C
10/29/2015
CWMOORER
Independent Laboratory Results: "GEL" -GEL Laboratories LLC -Lab iD # 10120; "Test America" - TestAmerica Laboratories, Inc. -Lab ID# 98001; "DavisBrown"-
Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc,- Lab ID# 32010
Analysis Validated:
Debra K. Guerry - Supervisor, Analytical Services

One Riverwood Drive
P_DBox 26461013at✓e cooper
MnncksCorner. SC29461-2901
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34041 Location: Ditch beside HWY 501 off Date: 10/26/2015 Sample Collector: CM/EG
Waccamaw River
Loc. Code 501_DITCH
Time: 12:49
Analysis
Result QUAD
Units
Test Date
Analyst
Method
Air Temp
17
C
10/29/2015
CWMOORER
Arsenic
<3.0 J
ug/L
11109/2015
TESTAMERICA
EPA 200.8
Arsenic- Dissolved
<3.0 J
ug/L
11/09/2015
TESTAMERICA
EPA 200.8
Collection Depth
2.5
m
10/29/2015
CWMOORER
Field Conductivity
63
us
10/29/2015
CWMOORER
Field pH
5.79
Su
10/29/2015
CWMOORER
Gauge heigh
5.9
ft
10/29/2015
CWMOORER
Oxidation Reduction Potential
186
my
1012912015
CWMOORER
SM2580
Weather
2
other
10/2912015
CWMOORER
Water Temp
17.36
C
10/2912015
CWMOORER
Independent Laboratory Results: "GEL" -GEL Laboratories LLC -Lab ID # 10120; "Test America-TestAmerica Laboratories, Inc. - Lab 0# 98001; "DavisBrown"-
Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
Analysis Validated: #
Debra K. Guerry - Supervisor, Analytical Services

One rtiverwood Drive
'Psantee cooper P-0Box2946101
Moncks Corner, SC 29461-2901
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34042 Location: Waccamaw River Monitoring Well Date: 10126/2015 Sample Collector: CM/EG
Loc. Code WRMW 5
Time: 12:58
Analysis
Result QUAL
Units
Test Date
Analyst
Method
Air Temp
17
C
1012912015
CWMOORER
Arsenic
<3.0 U
ug/L
11/1)9/2015
TESTAMERICA
EPA200.8
Arsenic - Dissolved
<3 0 U
ug/L
11/09/2015
TESTAMERICA
EPA 200.8
Collection Depth
1.7
m
10/29/2015
CWMOORER
Field Conductivity
58
us
10/29/2015
CWMOORER
Field pH
5.48
SU
10/29/2015
CWMOORER
Flow
4750
cfs
10/29/2015
CWMOORER
Gauge heigh
11.05
ft
10/29/2015
CWMOORER
Oxidation Reduction Potential
161
my
10/29/2015
CWMOORER
SM2580
Weather
2
other
10/29/2015
CWMOORER
Water Temp
17.44
C
10/29/2015
CWMOORER
Independent Laboratory Results: "GEL" - GEL Laboratories LLC -Lab ID # 10120; "TestAmerica' - TestAmerica Laboratories, Inc. - Lab ID# 98001; '"DavisBrown"-
Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
r-
j�L�Ct2_ - f_dCE i}c
Analysis Validated:
Debra K. Guerry - Supervisor, Analytical Services

One Riverwood Drive
P-O.. Box2946101
'Psantee cooper Mancks Corner, SC 29451-2901
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample ## AD34043 Location: Waccamaw River Monitoring Well Date: 10/26/2015 Sample Collector: CM/EG
Lac. Code WRMW_4R Time: 13:03
Analysis
Result QUAL
Units
Test Date
Analyst
Method
Air Temp
17
C
1012912015
CWMOORER
Arsenic
<3.0 U
ug1L
11/09/2015
TESTAMERICA
EPA200.8
Arsenic - Dissolved
<3.0 U
ug/L
11/09/2015
TESTAMERICA
EPA 200.8
Collection Depth
1.7
m
10/29/2015
CVMOORER
Field Conductivity
59
us
10/29/2015
CWMOORER
Field pH
5.33
SU
10/29/2015
CWMOORER
Flow
4750
cfs
10/29/2015
CWMOORER
Gauge heigh
11.05
ft
10/29/2015
CWMOORER
Oxidation Reduction Potential
192
my
10/29/2015
CWMOORER
SM2580
Weather
2
other
10/29/2015
CWMOORER
Water Temp
17.45
C
10129/2015
CWMOORER
Independent Laboratory Results: "GEL" - GEL Laboratories LLC - Lab ID # 10120; "Test America" - TestAmerica Laboratories, Inc. - Lab 1D# 98001; "DavisBrown"-
Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
Analysis Validated:
Debra K. Guerry - Supervisor, Analytical Services

One Rlverwood Drive
, a 1 tee Cooper P.O, ks Corner.
S
1 � L Mancks Carver, SC 29461-2909
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34044 Location: Waccarnaw River Monitoring Well Date: 10/26/2015 Sample Collector: CWEG
Loc. Code WRMW_3R Time: 13:07
Analysis
Result QUAL
Units
Test date
Analyst
Method
Air Temp
17
C
10/29/2015
CWMOORER
Arsenic
<3.0 U
ug1L
11/0912015
TESTAMERICA
EPA200.8
Arsenic -Dissolved
c3.0 U
ug1L
11/09/2015
TESTAMERICA
EPA200.8
Collection Depth
2.7
m
10/29/2015
CWMOORER
Field Conductivity
59
us
10/29/2015
CWMOORER
Field pH
5.31
SU
10/29/2015
CWMOORER
Flow
4750
cfs
10/29/2015
CWMOORER
Gauge heigh
11.05
ft
10129/2015
CWMOORER
Oxidation Reduction Potential
191
my
10129/2015
CWMOORER
SM2580
Weather
2
other
1012912015
CWMOORER
Water Temp
17.45
C
10/2912015
CWMOORER
Independent Laboratory Results: "GEL'- GEL Laboratories LLC - Lab ID # 10120; "Test America"-TestAmerica Laboratories, Inc. - Lab ID# 98001; "DavisBrown"-
Davis & Brown Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
Analysis Validated: _ }
Debra K. Guerry - Supervisor, Analytical Services

One Rvenvood Drive
Psr7 fj� cooper r P.Q Box 2946101
., n Cee Moncks Corner, SC 29461-2901
SANTEE COOPER ANALYTICAL SERVICES
CERTIFICATE OF ANALYSIS
LAB CERTIFICATION #08552
Sample # AD34045 Location: Upper Waccamaw River Date: 10126/2015 Sample Collector: Ci
Loc. Code WAC`UP Time: 13:21
Analysis
Result QUAL
Units
Test Date
Analyst
Method
Air Temp
17
C
10/29/2015
CWMOORER
Arsenic
<3.0 U
ug/L
11/0912015
TESTAMERICA
EPA 200.8
Arsenic -Dissolved
<3.0 U
ug1L
1V0912015
TESTAMERICA
EPA200.8
Collection Depth
3.40
m
1012912015
CWMOORER
Field Conductivity
58
us
1012912015
CWMOORER
Field i
5,29
SU
10/29/2015
CWMOORER
Flow
4940
cfs
10/29/2015
CWMOORER
Gauge heigh
11.06
it
10/29/2015
CWMOORER
Oxidation Reduction Potential
213
my
10129/2015
CWMOORER
SM2580
Weather
2
other
10129/2015
CWMOORER
Water Temp
17.47
C
10/2912015
CWMOORER
Independent Laboratory Results: "GEL" -GEL Laboratories LLC -Lab ID # 10120; 'Test America" - TestAmerica Laboratories, Inc, -Lab ID# 98001; "DavisBrown"-
Davis & Brawn Lab ID # 21117; "Shealy"- Shealy Environmental Services, Inc.- Lab ID# 32010
Analysis Validated:
Debra K. Guerry - Supervisor, Analytical Services

Attachment 11
Schwartz, et al. Article
Leaching Potential and Redox Transformations
of As and Se
February 2016

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

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

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

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

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

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

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

184
G.E. Schwartz et al. / Applied Geochemistry 67 (2016) 177-185
organoselenium species, which are highly bioaccumulative (Fan
et al., 2002; Simmons and Wallschlager, 2005). Accumulation of
Se in sediments also presents a risk to benthic organisms that
ingest Se(0) and Se( -II) species and convert them to organo-
selenium species (Fan et al., 2002). Anaerobic sediments also act
as a source of selenium to the water column if the sediments are
disturbed in a way that results in the oxidation and remobilization
of reduced Se species (Belzile et al., 2000; Simmons and
Wallschlager, 2005). The constant risk of bioaccumulation, and
the latent risk of remobilization in Se -contaminated sediments
should be a major consideration for ash spill remediation.
3.5. Implications for coal ash management
This study's confirmation that redox potential is a key param-
eter in controlling As and Se mobilization during an ash spill brings
into question the applicability of the leaching tests currently used
to assess environmental risks. Coal ash management is guided by
the EPA's Toxicity Characteristic Leaching Protocol (US EPA,1992), a
leaching test performed under aerobic conditions at a single pH
value (pH = 4.9 or 2.4). Other EPA methods such as the Leaching
Environmental Assessment Framework evaluates contaminant
leaching over a wide range of pH values, but the tests still fail to
account for complexity in the real environment (US EPA, 2012b,
2012c, 2013b, 2013c). Likewise, previous experiments with N2-
purged water -ash mixtures did not result in changes to Se and As
speciation in coal ash (Bednar et al., 2010; Liu et al., 2013). The data
from our study suggests that the absence of oxygen, alone, is
insufficient for testing contaminant mobilization in anaerobic
conditions relevant for ash impoundments and ash spill sites.
Instead, microbially-driven redox transitions, which can be stimu-
lated by sulfate from the coal ash, are more environmentally rele-
vant and necessary for attaining sufficiently reducing conditions for
transformations of As, Se, and possibly other contaminants (e.g.,
mercury, chromium, etc.). Moreover, the impacts of the redox
transitions are likely to vary in degree according to the geochemical
properties of the coal ash, the sediment, as well as the composition
of the microbial community. All these considerations are needed in
the future improvements of standardized methods for coal ash risk
assessments.
Finally, these results are helpful for identifying suitable closure
methods for ash impoundments. The U.S. EPA now requires the
closure of ash ponds that show a risk of groundwater contamina-
tion or that are improperly sited (US EPA, 2014b). Likewise, recent
regulations in North Carolina require the closure of all the State's
ash impoundments by 2029; those designated as high -risk must be
closed by 2020 (US EPA, 2014a). One proposed closure method is
the "Cap in Place" approach, where the ash pond would be de -
watered and then covered with a porous or non -porous cap
(Duke Energy, 2015). One concern with this method is that the cap
could alter redox conditions in the impoundment, and this study
shows that such changes could enhance the release of soluble
arsenic into local groundwater. Thus, even if no previous ground-
water contamination issues have been reported, capping methods
that might induce anaerobic conditions should be avoided in the
closure of unlined impoundments. Overall, this research shows the
need to consider both coal ash characteristics and environmental
parameters when assessing the environmental risks of ash disposal.
Acknowledgments
We thank the Tennessee Valley Authority, Restoration Services,
and Environmental Services for their assistance with field sample
collection. We also thank Kaitlyn Porter for her assistance with ICP-
MS measurements. This work was supported by the National
Science Foundation (CBET-1235661). G. Schwartz was also partly
supported by a doctoral scholarship from the Environmental
Research and Education Foundation.
Appendix ASupplementary data
Supplementary data related to this article can be found at http://
dx.doi.org/10.1016/j.apgeochem.2016.02.013.
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Attachment 12
GHI Roxboro Report Final
March 2016

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

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

GEO-HYDRO, INC
2. Introduction
Duke Energy (Duke) reportedly stores approximately 33,390,000 tons of coal ash in various areas
around the Roxboro facility, including ash stored in two unlined ash basins (East and West), lined
and unlined landfills, and other ash filled areas'. An additional poorly identified and
uncharacterized Unnamed Eastern Extension impoundment was recently reported to NCDEQ. The
location and volume of additional coal ash contained in the Unnamed Eastern Extension
impoundment was not identified in any of the documents reviewed. Pollution caused by the coal ash
at this site is currently the subject of an enforcement action brought by the NCDEQ. Organizations
represented by the Southern Environmental Law Center are also parties to this litigation.
North Carolina General Assembly Session Law 2014-122, the Coal Ash Management Act (LAMA)
of 2014, required the owner of coal combustion waste surface impoundments to conduct
groundwater monitoring, assessment and remedial activities at coal ash basins across the state, as
necessary. The owner of the coal ash surface impoundments was required to submit a Groundwater
Assessment Plan (GAP) to NCDEQ by December 31, 2014. Comprehensive Site Assessment (CSA)
reports that reported the results of site characterization activities were required to be submitted
within 180 days of approval of the GAP. Information developed under the CSA provided the data to
be used to prepare Corrective Action Plans (CAP) that were to be submitted to NCDEQ within 90
days of submittal of the CSA. An agreement between Duke Energy and NCDEQ resulted in
breaking the CAP into Parts I and 2. As of this date only the CAP Part I has been produced for the
Roxboro site.
Further, CAMA specifies that any impoundments classified by NCDEQ as high -risk be closed no
later than December 31, 2019 by dewatering the waste and either, a) excavating the ash and
converting the impoundment to an industrial landfill, or b) excavating and transporting the waste off -
site for disposal in an appropriately licensed landfill. Intermediate -risk impoundments are required
to be closed similarly to high -risk impoundments, but under a relaxed closure deadline of December
31, 2024. Impoundments classified as low -risk by NCDEQ must be closed by December 31, 2029
either similarly to the high and intermediate -risk sites, or by dewatering to the extent practicable and
capping the waste in place.
In January 2016 the NCDEQ issued Draft Proposed Risk Classifications (NCDEQ, 2016) for 10 ash
impoundment sites, including Roxboro. NCDEQ assigned separate proposed risk classifications for
the West, East, and Unnamed Eastern Extension ash ponds. The East Ash Basin (EAB) was rated
low to intermediate risk and the West Ash Basin (WAB) was rated low risk, thus allowing for
closure of these impoundments by capping waste in place. The Unnamed Eastern Extension (UEE)
' Synterra, 2015a
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GEO-HYDRO, INC
impoundment was rated intermediate risk pending further assessment. On behalf of the Southern
Environmental Law Center, I have reviewed the Groundwater Assessment Plan (SynTerra, 2014),
Comprehensive Site Assessment (SynTerra, 2015a), the Corrective Action Plan Part 1 (SynTerra,
2015b), the Draft Proposed Risk Classifications (NCDEQ, 2016), and three National Pollutant
Discharge Elimination System (NPDES) discharge monitoring reports (DMR's) for Roxboro (Duke
Energy, 2014).
This report details my opinions regarding: the source of groundwater and surface water pollution at
Roxboro, potential remedies for that pollution discussed in the Corrective Action Plan, and the
proposed risk classification for the Roxboro site.

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

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4. Site Background
The Roxboro plant is a coal-fired electricity -generating facility located near Semora, in Person County
North Carolina. Hyco Reservoir borders the Roxboro plant to the north and west. Coal ash generated
at the plant has been sluiced to the ash basins and hauled to landfill overlying the ash basins since
operations commenced in 1966. The EAB was constructed in 1966 by constructing an earthen dam
across two unnamed creeks located southeast of the power station (Figure 1). An unlined landfill was
constructed over the top of the sluiced ash in the EAB in the late 1980s and a lined landfill was
constructed over the unlined landfill in 20042.
The ground surface elevation below the EAB dam was reported to be between 390 and 400 feet mean
sea level (msl) 3. Groundwater elevations in EAB monitoring wells are reported to be between 464 and
469 ft ms14. The difference between the reported ash basin groundwater elevations and the natural
ground surface elevations underlying the EAB indicates that from 64 to 79 feet of saturated coal ash is
present within the EAB.
The WAB was constructed in 1973 by installing a dam across Sargents Creek, located south of the
power station. Coal combustion waste was historically sluiced into the WAB. A Flue Gas
Desulfurization (FGD) System, including a lined gypsum settling pond was constructed over a portion
of the WAB. The WAB currently remains in operation, receiving sluiced bottom ash from the power
station and surface waters discharged from the EAB and overlying lined landfill.
The ground surface elevation along the buried Sargents Creek was reported to be between 390 and 410
feet msl prior to construction of the WAB 5 Groundwater elevations in WAB monitoring wells are
reported to be between 448 and 463 ft ms16. The difference between the reported ash basin
groundwater elevations and the natural ground surface elevations underlying the basin indicates that
from 38 to 73 feet of saturated coal ash is present within the WAB.
The CSA describes three natural hydrogeologic units or zones of groundwater flow at the Roxboro
Plant. Coal ash is considered as its own hydrogeologic unit that is localized to the ash basins. The
zone closest to the surface is the shallow or surficial flow zone encompassing saturated conditions,
where present, in the saprolite and alluvium beneath the Site. A transition zone is encountered below
the shallow zone and is characterized primarily by partially weathered rock of variable thickness. The
bedrock flow zone occurs below the transition zone and is characterized by the storage and
2 SynTerra, 2015b, p. 1-2.
3 SynTerra, 2015b, Appendix E, p.3.
4 SynTerra, 2015a, Figure 6-5.
5 SynTerra, 2015b, Appendix E, p.4.
6 SynTerra, 2015a, Figure 6-5.
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transmission of groundwater in water -bearing fractures. Due to its limited occurrence and extent, the
shallow zone is considered part of the transition zone. Where present, groundwater exists under
unconfined conditions in each of the hydrogeologic units. The surficial/transition zone and bedrock
aquifers are interconnected.
On a regional scale groundwater appears to flow from highland areas in the south and southeast, to the
northwest toward Hyco Lake. On a local scale groundwater flow directions are poorly defined. Large
areas of the Bedrock Water Level Map included with both the CSA and CAP (Figure 2) show neither
groundwater elevation data nor contours. Due to the scarcity of head data the description of the
groundwater flow system included in the Groundwater Modeling Reports describes groundwater flow
in terms of inferred flows. The groundwater flow system beneath the eastern lobe of the EAB is
inferred to receive recharge from uplands to the south and east9, and discharge from the eastern lobe
by flowing toward the water intake canal, or northeast to a stream that drains the lake (now identified
as the unnamed eastern extension) that flows along the eastern side of the EAB and discharges into the
water intake canal10. Groundwater flow into the western lobe of the EAB is inferred to occur from the
west, south and east' 1. Groundwater discharges from the western lobe of the EAB are inferred to
occur to the north toward the plant. Further, the modeling report infers that groundwater beneath the
EAB flows toward discharge areas in wetlands and/or ponds located north of the EAB dam.
Groundwater flow into the WAB is inferred to flow into the basin from upland areas to the east.
Groundwater appears to discharge from the WAB to the north, west and south. Groundwater is
inferred to discharge from the WAB by flow to the north through and around the dam, through and
beneath the dam on the south end of the WAB, and to discharge into the canal located west of the
WAB.
Surface waters from the EAB, including groundwater that has discharged to surface water, are routed
to the west where it enters the northern end of the WAB. Sluice water used to transport bottom ash to
the WAB also discharges into the northern end of the WAB. Surface water from these sources, along
with precipitation and groundwater that discharges from the WAB, discharges through the filter dam at
the south end of the WAB and into the discharge canal. The discharge canal wraps around the west
side of the WAB, ultimately discharging into Hyco Lake. The CAP indicates12 that seeps and surface
7 SynTerra, 2015a, p.26.
8 SynTerra, 2015b, Appendix E
9 The discussion of groundwater flow included in Appendix E (p. 4) erroneously indicates that flow toward the EAB is from
uplands to the north and west. Examination of head distribution maps included with the modeling report make it clear that
this statement in the text is in error.
10 SynTerra, 2015b, Appendix E, Section 2.2.
11 The Groundwater Modeling Report actually says recharge is from the north rather than the south. It appears that this was
a mistake as the limited groundwater head data shows higher heads located south of the west lobe.
12 SynTerra, 2015b, Section 2.2.3.
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water drain into NPDES-permitted surface water bodies, but fails to recognize that the parameters
required for testing under the NPDES permit are not those that are elevated by coal ash impacts.
Data collected during the CSA show that groundwater is impacted by the ash basins with boron,
strontium, sulfate, total dissolved solids (TDS) and to a lesser extent, cobalt, iron, manganese, and
vanadium.13 The CSA also determined that Hyco Lake and the plants cooling water intake and
discharge canals are the primary receptors of impacted groundwater and seeps, and that groundwater
flow direction data and surface water data indicate that constituents of interest are migrating to the
reservoir14
Considering the various sources of water that is transferred from the WAB to Hyco Lake through the
discharge canal, it is very likely that the water contains high concentrations of ash -related constituents.
Unfortunately, no samples of discharge canal water were collected during the CSA. The CSA and
CAP each refer to surface water monitoring conducted under NPDES Permit NC0003425 as if that
monitoring augments the CSA surface water characterization. Review of three 2014 Discharge
Monitoring Reports 15 (DMRs) for the Roxboro site showed that NPDES surface water monitoring
requirements do not include the most common analytical parameters that are found in ash impacted
waters. This means that a major discharge of likely ash -impacted water from the Roxboro site into
Hyco Lake was not sampled as part of the CSA and is not being appropriately monitored under
NPDES requirements.
The groundwater flow and transport model of the site was constructed and used in the CAP to evaluate
groundwater flow and investigate three remedial scenarios. The scenarios investigated included the
No Action scenario, a Capping Ash in Place scenario, and a Complete Ash Removal scenario. The
model was used to predict contaminant distributions for the next 5, 15 and 30 years, under each
scenario.
The No Action scenario 16 relies on natural attenuation processes to reduce contaminant concentrations
over time. The ash basin remains in place without modification and "the assumption is made that
current recharge and contaminant loading rates from the ash to the underlying formations are held
constant". "The flow system is assumed to be at steady state with respect to the conditions in 2015."
"Concentrations in the ash were held constant at the measured concentrations." Using these
assumptions the model predicts that the boron plumes will continue to expand laterally and downward,
and increase in concentration over time. The predicted increases in plume size are predicted to be from
on the order of few hundred feet to very small. This result is likely due to constraints on plume size
13 SynTerra, 2015b, p. 3-8
14 SynTerra, 2015a, p.114
15 Duke Energy, 2014
16 The entire description of this scenario is presented in the CAP, Appendix E, Section 6.1.
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related to known hydrologic boundaries as were described above. Once a plume reaches a hydrologic
boundary the constituents migrating with groundwater are transferred to the surface water system and
the groundwater plume does not continue to grow in size though contaminants continue to migrate
with surface water.
The Capping Ash in Place scenario17 involves placing a low permeability liner over the ash basin to
prevent infiltration. The description of this scenario assumes that there is no recharge within the basin
and that contaminant concentrations in the ash were allowed to vary (even though concentrations were
fixed in the No Action scenario). Results of this model predict that zones of boron concentration
increase in size and concentration relative to 2015 conditions, but the magnitude of the increases are
less that those calculated under the No Action scenario. Concerns with the Capping Ash Basin
scenario include the assumption of no recharge within the basin and changing the way that
contaminant concentrations in the source material are handled. The hydrogeology of the Roxboro
impoundments (see description of groundwater flow above) includes recharge into the basins from
higher elevation areas to the south and east. Capping of the ash in the basin will not control influx of
groundwater from upland areas. Discharges of groundwater into the ash basins are likely significant as
groundwater discharges into the basin were sufficient to maintain streams prior to their being buried
under coal waste.
The concentration of contaminants in the ash were held constant in the No Action simulation but were
allowed to vary in the Capping Ash in Place scenario. This change in assumptions allowed the
concentration in the ash to decrease more rapidly in the Capping Ash in Place scenario than in the No
Action simulation. The rationale for changing the method of handling source concentrations between
simulations was not discussed. It is unclear if the noted reduction in plume size and concentration is a
result of cap installation, or if it is an artifact of the change in assumptions.
The Complete Ash Removal18 scenario represents complete removal of the ash by inactivating the
upper four model layers, adding drain cells to simulate drainages, and setting recharge within the ash
basin to ambient levels. The Complete Ash Removal scenario predicts the largest reduction in ash -
related contaminant concentrations of any of the tested scenarios.
17 The entire description of this scenario is presented in the CAP, Appendix E, Section 6.2
18 The entire description of this scenario is presented in the CAP, Appendix E, Section 6.3
N.

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5. Opinion 1: Coal Ash Stored in the Roxboro Ash Basins is the
Source of Contamination Detected in Groundwater
Coal ash is the source of contaminants detected in groundwater at concentrations above applicable
standards in the vicinity and downgradient of the ash basin. Data collected during the CSA show
that groundwater is impacted by the ash basins with boron, strontium, sulfate, TDS and to a lesser
extent, cobalt, iron, manganese, and vanadium.19 The lateral extent of groundwater impacts outside
of the ash basins is limited by the presence of water local discharge areas. The contaminated pore
water migrates out of the ash basins and either directly into surface water, or into groundwater that
subsequently discharges to surface water, and eventually into Hyco Lake. This interpretation is
consistent with the CSA which states that:
Hydrologic boundaries are present downgradient of the ash basins in the form of the
intake canal, the discharge canal and the cooling reservoir which discharges to Hyco
Lake. When the CCR constituents reach these hydrologic boundaries, they are
removed from the groundwater system, and they enter the surface water system. At
the Site, boron is the primary constituent that is migrating from the ash basins. 20
19 SynTerra, 2015b, p. 3-8
20 SynTerra 2015b, p.3-8
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6. Opinion 2: Capping Coal Ash Located Within the Roxboro Ash
Basin Will Not Protect Groundwater Quality Downgradient of the
Basins
The CAMA process proposed designation of the Roxboro Site as low -risk creates the possibility that
Duke could pursue closure of the Roxboro impoundment by capping the disposed ash in place.
Capping the waste within the footprint of the ash basin will not be protective of groundwater quality
downgradient of the basin.
Environmental contaminants contained in coal ash are leached into groundwater when precipitation
infiltrates through the waste or, when groundwater flows through waste that has been placed below
the water table. In the case of the Roxboro ash basins, both of these processes are currently acting to
create the contaminated ash porewater, groundwater, and surface water that discharge into local
surface waters and eventually into Hyco Lake. The cap -in -place remedy would likely reduce the
amount of water that enters the waste from precipitation. This remedy would however do nothing to
reduce the amount of groundwater that flows laterally into the basin from surrounding geologic
units, through the capped waste, into downgradient groundwater, and eventually into Hyco Lake.
The lined landfill that was constructed over a portion of the EAB should function as a cap over the
ash disposed in the unlined landfill and ash basin. The CSA21 indicates that construction of a lined
landfill has resulted in decreasing concentrations of iron, manganese and chromium in three
monitoring wells (GMW-06, GMW-10 and GMW-11). The available data set does not show a clear
pattern of decreasing contaminant concentrations related to construction of the lined landfill.
Review of the comprehensive analytical results from Roxboro22 shows that large decreases in
several parameters were observed in some monitoring wells during the first few sampling events and
prior to construction of the lined landfill. Figures 3 and 4 show graphs of boron, sulfate, selenium
and TDS concentrations measured in samples from wells in the immediate vicinity of the lined
landfill. Sulfate, TDS, and selenium23 concentrations in some wells were very high initially and
show rapid declines in concentration between the initial sampling event in 2002 and 2004 when the
lined landfill was constructed. This is an indication that decreased contaminant concentrations in
wells since their early sampling events appear to have been due to improper well development or
sampling techniques rather than improving water quality resulting from landfill construction.
Even if it is assumed that construction of the lined landfill has had a positive effect on groundwater
quality, the graphs show that concentrations of ash -related parameters in some monitoring wells has
21 SynTerra, 2015b, p.1-8
22 SynTerra, 2015a, Attachment 3
23 Note that boron was not included in the tested parameters until 2002, so the early concentrations of boron are
unknown.
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remained at or above water quality standards in wells GMW-06, GMW-08 and GMW-11 despite the
presence of the lined landfill. In fact, boron, sulfate, and TDS concentrations have been increasing
rapidly in monitoring well GMW-8 since 2013. Continued detections of elevated concentrations24
of ash -related contaminants at in groundwater around the lined landfill indicates that ash underlying
the lined landfill continues to release contaminants to groundwater, even though most infiltration
from above has presumably been eliminated by the landfill liner. This result is to be expected at any
location where ash remains submerged below the local water table. Continued generation and
downgradient migration of leachate will occur in the Roxboro Ash basins unless all of the ash in the
basin is dewatered and remains above the high water table, a scenario that is unlikely to occur at
Roxboro.
Groundwater modeling performed for the CAP provided no estimation of the amount of saturated
ash that would remain at Roxboro should the capping in place remediation scenario be implemented.
An estimate of the thickness of the remaining thickness of saturated ash can be obtained by
comparing the elevation of the natural ground surface beneath the basins to the groundwater
elevation in wells just outside of the basins 25. The ground surface elevation below the EAB dam
was reported to be between 390 and 400 feet ms126. Groundwater elevations in EAB monitoring
wells located just outside of the basin are reported to be between 462 and 513 ft ms127. The
difference between the lowest measured groundwater elevation in wells located just outside the ash
basin and the highest natural ground surface elevations underlying the EAB indicates that at least 62
feet of saturated coal should be expected to be present beneath the EAB were the cap in place
remediation scenario implemented.
The natural ground surface elevation beneath the WAB was reported to be between 390 and 410 feet
ms128. Groundwater elevations in WAB monitoring wells located just outside the ash basin are
reported to be between 452 and 456 ft ms129. The difference between the lowest measured
groundwater elevation in wells located just outside the ash basin and the highest natural ground
surface elevations underlying the EAB indicates that at least 42 feet of saturated coal should be
expected to be present beneath the EAB were the cap in place remediation scenario implemented.
The relative effects of the cap in place and removal of the ash scenarios on groundwater quality were
evaluated as part of the groundwater modeling exercise. The modeling report indicates that removal
24 above 2L standards
25 Estimates of the thickness of saturated ash that would likely remain were the capping ash in place scenario
implemented are provided since the groundwater modeling report did not provide an estimation. Further modeling, or
better model reporting, should be conducted to refine these estimates.
26 SynTerra, 2015b, Appendix E, p.3.
27 SynTerra, 2015a, Figure 6-5.
28 SynTerra, 2015b, Appendix E, p.4.
29 SynTerra, 2015a, Figure 6-5.
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of the ash reduces the concentration of boron in groundwater more than either the No Action or
Capping Ash in Place scenarios. This indicates that removal of the Roxboro coal ash is the most
effective option for improving groundwater quality and minimizing future discharges to Hyco Lake.
This is as would be expected considering that the cap in place scenario would leave a significant
thickness of saturated ash in place that would continue to leach ash constituents into the groundwater
far into the future.
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7. Opinion 3: Monitored Natural Attenuation Is Not An Acceptable
Groundwater Remediation Strategy at Roxboro
The CAp30 indicates that Duke may evaluate Monitored Natural attenuation as a potential
groundwater remedy for certain area of the Roxboro site. The CAP attempts to make it appear that
Monitored Natural Attenuation (MNA) is a viable remedial option for impacted groundwater
downgradient of the Roxboro ash basin. From a technical standpoint, MNA remedies typically
require:
• That there are no current receptors, including surface water or wetland discharges and water
supply wells.
• That there is sufficient lateral space between the contaminant source and groundwater
discharge areas to allow natural attenuation to reduce contaminant concentrations prior to
reaching a receptor.
• Evidence that the location of the leading edge of the contaminant plumes be stable (not be
expanding).
• That there is a natural reduction in contaminant concentrations along flow paths.
• That there is sufficient space between the contaminant source and groundwater discharge
areas to allow a monitoring system to be established, including sentry wells located ahead of
the leading edge of the contaminant plume.
None of these technical factors for considering MNA as an appropriate remedial strategy at the
Roxboro site are met. From a scientific standpoint there is no justification for considering MNA.
There are also legal requirements that must be met in North Carolina in order to utilize MNA as a
groundwater remedy, including:
• NCAC 02L .0106 (1)(1) requires a demonstration that all sources of contamination have been
removed or controlled. So far, Duke Energy has not proposed removal of the waste for
disposal in a secure location. Hydrogeologic conditions presented in this document shows
that some of the ash would remain saturated after capping. Saturated ash will continue to
leach metals into groundwater that will flow toward and eventually discharge into Hyco
Lake. As a practical matter, in the absence of removal all sources of contamination cannot be
controlled
• NCAC 02L .0106 (1)(2) requires a demonstration that the contaminant has the capacity to
degrade or attenuate under site -specific conditions. Many of the ash -related constituents in
groundwater at this site neither degrade nor attenuate. The Geochemical Site Conceptual
30 SynTerra, 2015b, p.5-1
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Model31 states that boron is an indicator of coal ash impacts to groundwater because it "is
essentially inert, has limited potential for sorption and lacks an affinity to form complexes
with other ions." The characteristics of the contaminant plumes alone are sufficient to render
the Roxboro site ineligible to use MNA as a remediation strategy.
31 SynTerra, 2015b, Section 3.3
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8. Opinion 4: Capping Coal Ash Located Within the Roxboro Ash
Basin Will Not Be Protective of Surface Water Quality
The most problematic issues at the Roxboro plant are related to the interaction of groundwater and
surface water bodies on and around the plant site. The CAP indicates in several locations that the
lateral extent of groundwater contamination is generally limited to areas beneath or immediately
downgradient of the ash basins. These statements would often be interpreted as indicating that
contamination has not spread far from the source and the problem should be readily remedied.
However, at the Roxboro site the ash basins are bounded by drainage features on around the
perimeter of the basins that act as groundwater discharge areas. Ash -impacted groundwater plumes
are not restricted to the immediate area of the basins by a lack of migration; their size is restricted
only because the contaminated groundwater discharges to surface water features. This is particularly
problematic since water quality in the channel that carries most of the discharge from this site has
not been characterized. No surface water samples were collected from the outflow channel even
though the combined drainage from the East and West Ash Basins are passed through this channel to
Hyco Reservoir. In addition, surface water monitoring conducted under NPDES Permit NC0003425
does not include the most common analytical parameters that are found in ash impacted waters. This
means that a major discharge of likely ash -impacted water from the Roxboro site into Hyco Lake
was not sampled as part of the CSA and is not being appropriately monitored under NPDES
requirements. The chemistry and volume of water that flows through canals and into Hyco Lake
under current and expected closure conditions must be evaluated to assure that the selected remedy
is protective of water quality in Hyco Lake.
A cap -in -place remedy would not be protective of surface water quality. While a cap would likely
reduce the amount of water that enters the waste from precipitation, this remedy would do nothing to
reduce the amount of groundwater that flows laterally into the basin from surrounding geologic
units, through the capped waste, into downgradient surface water drainages, and eventually into
Hyco Lake. Groundwater would continue to flow into the ash basins from adjacent upland areas.
Groundwater that flows through the ash will continue to leach metals from the ash and transport
those metals down -gradient before discharging into adjacent surface water features.
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9. Opinion 5: Removal of the Coal Ash Will Remove the Source and
Reduce the Concentration and Extent of Groundwater
Contaminants
Removal (excavation) of the coal ash from the Roxboro ash basin is the only remediation scenario
that will separate the coal ash source materials from groundwater and eliminate flow of
contaminated groundwater and surface water into Hyco Lake. Excavation of the ash will remove the
source of groundwater and surface water contaminants, and reduce the concentration and extent of
current contaminants. The groundwater flow and transport model of the site was used in the CAP to
evaluate groundwater flow and investigate three remedial scenarios. The scenarios investigated
included the Existing Conditions scenario, a Capping Ash in Place scenario, and a Removal of Ash
scenario. The model was used to predict contaminant distributions for the next 5, 15 and 30 years,
under each scenario. The model showed that the Removal of Ash scenario resulted in the largest
reduction in ash -related contaminant concentrations of any of the modeled scenarios.
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10. Opinion 6: The Coal Combustion Residual Impoundment Risk
Classification Proposed by NCDEQ Improperly Minimizes
Protection of Environmental Quality
A risk ranking process was specified in CAMA to determine the type of closure permitted at each
facility. The law specifically requires NCDEQ to classify each impoundment as either high -risk,
intermediate -risk, or low -risk, based on consideration, at a minimum, of all of the following criteria.
(1) Any hazards to public health, safety, or welfare resulting from the impoundment.
(2) The structural condition and hazard potential of the impoundment.
(3) The proximity of surface waters to the impoundment and whether any surface waters are
contaminated or threatened by contamination as a result of the impoundment.
(4) Information concerning the horizontal and vertical extent of soil and groundwater
contamination for all contaminants confirmed to be present in groundwater in exceedance of
groundwater quality standards and all significant factors affecting contaminant transport.
(5) The location and nature of all receptors and significant exposure pathways.
(6) The geological and hydrogeological features influencing the movement and chemical and
physical character of the contaminants.
(7) The amount and characteristics of coal combustion residuals in the impoundment.
(8) Whether the impoundment is located within an area subject to a 100-year flood.
(9) Any other factor the Department deems relevant to establishment of risk.
In order to evaluate each impoundment on the nine criteria the NCDEW established a risk
classification group32. The Risk Classification Group was broken into three sub -groups of people
based on areas of expertise (Groundwater, Surface Water, and Dam Safety) to develop a set of risk
factors to address each of the nine required criteria. Each subgroup reportedly placed a primary
emphasis on risk as it relates to the public from a groundwater, surface water, and dam safety
perspective and established one key factor that "plays a significant role in assigning an overall
classification" for that group. Other factors not identified as Key Factors were supposedly used to
"refine the risk classification and address the actual or potential risk to the environment and natural
resources."
The result of the risk classification methodology utilized by NCDEQ is that environmental and
ecologic risks posed by the Roxboro site were not fully considered by NCDEQ when establishing
the overall site risk and clean-up priorities. This resulted in the West, East, and Unnamed Eastern
Extension ash ponds being assigned Low, Low to Intermediate, and Intermediate risk ratings,
32 NDEQ, 2016, p. 13, Classification Methodology
17

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

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

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

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

GEO-HYDRO, INC
Figures

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60
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1968
Photorevised 1994
GEO-HYDRO, INC
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f'
Figure l
Ash Basin Locations and Site
Topography
Roxboro Steam Electric Plant

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Image taken from Figure 2
SynTerra, 2015b Bedrock Water Level Map
Figure 3-1 1 Roxboro Steam Electric Plant

Boron Concentration
May 2009 - April 2015
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4000
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3000
2500
rn 2000
0
o
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1000
500
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t°N -S&Nb, 1a
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December 2002 -April 2015
1800
1600
1400
1200
1000
800
600
400
200
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t GMW-07
GMW-08
--X—GMW-09
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+GMW-11
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Data From:
SynTerra, 2015a,
Attachment 3
GMW-06
f-GMW -07
GMW-08
X GMW-09
—X GMW-10
—41 W-11
2L Standard (250 mg/I)
Data From:
SynTerra, 2015a,
Attachment 3
Figure 3
Boron and Sulfate Concentrations
Lined Landfill area Monitoring Wells
Roxboro Steam Electric Plant

Selenium Concentration
December 2002 - April 2015
400
350
300
250
rn
E 200
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150
100
50
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--0--G MW-11
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Data From:
Syn Terra, 2015a,
Attachment 3
—4-- GMW-06
t G M W-07
GMW-08
GMW-09
--)K—GMW-10
—e GMW-11
2L Standard (500
mg/I)
Data From:
S ynTe rra, 2015a,
Attachment 3
Figure 4
Selenium and TDS Concentrations
Lined Landfill area Monitoring Wells
Roxboro Steam Electric Plant

Attachment 13
Duke Energy
Memorandum Regarding CAMA Requirements

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

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

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

This section requires the Department to make decisions based on the available evidence
regarding each of the listed factors.' It would not be consistent with this requirement for the Department
to make a classification decision based solely on one factor and disregard valid information about the
others. Further, the section anticipates that the Department will make decisions before complete
information about a site is available. For example, it does not require the Department to completely know
the vertical and horizontal extent of soil and groundwater contamination for each site; rather it requires
that the Department consider information concerning the vertical and horizontal extent. Similarly, it does
not require the Department to know all factors that might conceivably affect contaminant transport or all
conceivable exposure pathways; it requires the consideration only of significant factors affecting
contaminant transport and significant exposure pathways.
Additional support for this conclusion is found in the fact that this section defines an iterative
process by which evolving data, review, and commentary are used to classify surface impoundments as
low, intermediate, or high risk. This iterative process begins with a provisionally proposed classification by
the Department by December 31, 2015 and extends for a minimum (no maximum) of six months while
feedback and additional data are received and evaluated by the Department and the Coal Ash
Management Commission.
Taken as a whole, this section requires the Department to make evidence -based decisions using
the best available information in the record. Duke Energy has submitted substantial evidence into the
administrative record. Any classification should be based on this evidence, with the understanding that
additional information requests may be relevant to the degree of certainty in the classification but do not
undermine the validity of the classification.
IV. Conclusion
The Groundwater Assessment Plans, Groundwater Assessment Reports, and Groundwater
Corrective Action Plans submitted by Duke Energy to the Department meet the requirements of CAMA
and provide vast data, analysis, and findings. Chief among the findings is a determination by licensed
' Aside from CAMA, the North Carolina Administrative Procedure Act requires that agency decisions be
supported "by substantial evidence ... in view of the entire record as submitted." G.S. 150B-51(b)(5).
4
NCDENRO194491

environmental geologists that none of the sites pose an imminent hazard to human health or the
environment.
Duke Energy is committed to meeting the Department's expectations by providing additional data,
fully leveraging the time provided by CAMA's iterative process to ensure final classifications reflect the
best science and engineering. Nonetheless, Duke Energy has compiled with all of CAMA's requirements
to date, and available information is sufficient for the Department to develop classifications as required by
CAMA.
5
NCDENRO194492

Attachment 14
DEQ Sutton Ash Pond Ratings Detailed
3/11/14

ASH POND RATING FORM
FACILITY NAME: Allen
REGION: Mooresville
NPDES PERMIT NO.: NC0004979
COUNTY: Gaston
Instructions: Rate each facility using the potential rating in the left column and the descriptions in the middle
column. A score of 1 indicates the best case whereas a score of 5 indicates the worst case. For the final rating
column, put the number next to the description that best matches the facility in consideration. If you believe a
different rating is warranted for any category (other than what is listed), then justify alternate rating in the
comment section.
Section 1— Water Quality Considerations
1. Groundwater Standards
Potential
Rating
Rating Description
Final
Rating
1
An exceedance of pH, iron or manganese
2
Exceedance of chloride, nitrate, sulfate, or TDS
3
Exceedance of aluminum, barium, copper, nickel or zinc
3
4
Exceedance of boron, cadmium, chromium, selenium, or antimony
5
Exceedance of arsenic, lead, mercury, or thallium
Comments: Allen groundwater exceedances consist of pH, Fe, Mn, and Ni.
2. Drinking Water Intakes
Potential
Rating
Rating Description
Final
Rating
0
No intake
2
Greater than 50 miles downstream
3
Greater than 20 miles, but less than orequal to 50 miles downstream
4
Greater than 10 miles, but less than orequal to 20 miles downstream
4
5
Less than orequal to 10 miles downstream
Comments: The NC/SC state line is —3 miles downstream from Allen. The Rock Hill, SC, intake is located
on the Catawba River/Lake Wylie —16 miles downstream. Additional SC communities with intakes located
along the Catawba are expected at greater distances.
March 11, 2014 Ash Pond Rating Form Page 1 of 6

4. Classification Downstream and Discharge Points (use worst case scenario)
Potential
Ratfnt; Description
b
Final.
Rating
Rating
1
Class C
4
Class B
4
5
High Quality Waters, Outstanding Resource Waters, Threatened or
Endangered Species present
Comments:
Classification in the immediate vicinity of Buck is WS-V. Downstream of Buck, the
classification changes to WS-IV, B in the lower portion of High Rock Lake.
5. Distance of Water Supply Wells from the Compliance Boundary (CB)
Potential
Rating Description
Final
Rating
Rating
i
Wells greater than 1/2 mile (2,640 feet) of the CB
2
Wells within 2,000 to 2,640 feet of CB
3
Wells within 1,500 to 2,000 feet of CB
4
Wells within 1,000 to 1,500 feet of CB
5
Wells within 1,000 feet of CB
5
Comments: The area in the vicinity of the plant is served by wells and a formal well survey has not been
conducted. The closest private wells are along Dukeville and Leonard Roads and a couple of small spur roads
off of these. The closest private wells are roughly 200 ft from the CB and there may be roughly 50 private
water supply wells within 1500 ft. Additionally, there is a public water supply well for Duke employees on
site at Buck (0180647) and two PWS well systems at nearby churches (Trading Ford Baptist 0180594,
Yadkin Grove Missionary Baptist 0180633). These PWS systems are roughly 800-1300 ft from the CB.
Note: Hydrogeotogic considerations -- Use to adjust rating due to unique characteristics that should be
considered such as wells upgradient, cross gradient, etc.
March 11, 2014 Ash Pond Rating Form Page 2 of 5

ASH POND RATING FORM
FACILITY NAME: Allen
REGION: Mooresville
NPDES PERMIT NO.: NC0004979
COUNTY: Gaston
Instructions: Rate each facility using the potential rating in the left column and the descriptions in the middle
column. A score of 1 indicates the best case whereas a score of 5 indicates the worst case. For the final rating
column, put the number next to the description that best matches the facility in consideration. If you believe a
different rating is warranted for any category (other than what is listed), then justify alternate rating in the
comment section.
Section 1— Water Quality Considerations
1. Groundwater Standards
Potential
Rating
Rating Description
Final
Rating
1
An exceedance of pH, iron or manganese
2
Exceedance of chloride, nitrate, sulfate, or TDS
3
Exceedance of aluminum, barium, copper, nickel or zinc
3
4
Exceedance of boron, cadmium, chromium, selenium, or antimony
5
Exceedance of arsenic, lead, mercury, or thallium
Comments: Allen groundwater exceedances consist of pH, Fe, Mn, and Ni.
2. Drinking Water Intakes
Potential
Rating
Rating Description
Final
Rating
0
No intake
2
Greater than 50 miles downstream
3
Greater than 20 miles, but less than orequal to 50 miles downstream
4
Greater than 10 miles, but less than orequal to 20 miles downstream
4
5
Less than orequal to 10 miles downstream
Comments: The NC/SC state line is —3 miles downstream from Allen. The Rock Hill, SC, intake is located
on the Catawba River/Lake Wylie —16 miles downstream. Additional SC communities with intakes located
along the Catawba are expected at greater distances.
March 11, 2014 Ash Pond Rating Form Page 1 of 6

3. Total Population Served by Intakes
Potential
Rating
Rating Description
Final
Rating
1
1 - 500 served
2
501 - 3,300 served
3
3,301 - 10,000 served
4
10,001 - 100,000 served
4
5
> 100,000 served
Comments: Per Rock Hill's website, they serve —96,000 people including the communities of Fort Mill,
Tega Cay, River Hills and the Catawba Indian Nation.
4. Classification Downstream and Discharge Points (use worst case scenario)
Potential
Rating Description
Final
Rating
Rating
1
Class C
4
Class B
4
5
High Quality Waters, Outstanding Resource Waters, Threatened or
Endangered Species present
Comments:
Most of Allen fronts the Catawba River/Lake Wylie, which is classified as WS-V, B. The
primary thermal discharge and a number of stormwater outfalls discharge to the South Fork Catawba
River/Lake Wylie, which is classified as WS-V.
March 11, 2014 Ash Pond Rating Form Page 2 of 6

5. Distance of Water Supply Wells from the Compliance Boundary (CB)
Potential
Rating
Rating Description
Final
Rating
1
Wells greater than 1/2 mile 2,640 feet of the CB
2
Wells within 2,000 to 2,640 feet of CB
3
Wells within 1,500 to 2,000 feet of CB
4
Wells within 1,000 to 1,500 feet of CB
5
Wells within 1,000 feet of CB
5
Comments: No formal well survey has been conducted near Allen, however DWR-WQROS has sampled 3
private water supply wells just W of the ash ponds and near monitoring well AB-141), which has shown the
only Ni exceedances. The sampled supply wells did not have exceedances. The neighborhood including those
private wells is also served by several dozen (40-50?) private wells and, though presumably hydraulically
upgradient of the ash ponds, these supply wells are same side of a hydrologic divide as the ponds. This
neighborhood's private wells are approximately located within a range of about 75 feet to 1200 feet from the
compliance boundary. Though public water is available along South Point Road/NC273, and newer
subdivisions are typically connected to it, there are also older homes served by wells along the road and
additional private wells in a neighborhood to the S of the plant at a slightly greater distance away.
There are several public water supply systems with wells in relative proximity. South Point Landing
(0136192) is —1000 ft from the CB. Heather Glen/Highland S/D (0136255) has two supply wells located
—1500 ft from the CB. The River Lakes S/D (0236011) is located —2900 ft from the CB. There are additional
PWS well systems north of the facility at greater distances.
Note: Hydrogeologic considerations -- Use to adjust rating due to unique characteristics that should be
considered such as wells upgradient, cross gradient, etc.
6. Population Served by Water Supply Wells (referenced above)
Potential
Rating
Rating Description
Final
Rating
1
0 population
2
0 - 25 people
3
26 - 100 people
4
101 - 200 people
5
> 200 people
5
Comments: Without a well survey, the population served by private wells was estimated in the following
manner: a very rough approximation of 75 wells within 1500 feet and 3 people per well results in 225 people
served. This is an estimate and the actual number could vary significantly from that value.
The population served by the PWS systems mentioned in #2 totals 226.
March 11, 2014 Ash Pond Rating Form Page 3 of 6

Section 2 — Dam Safety Considerations
7. Hazard Classification
Potential
Rating
Rating Description
Final
Rating
1
Low hazard - Small size
2
Low Hazard - Large size
3
Intermediate Hazard
4
High Hazard - Environmental Concerns
4
5
1 High Hazard - Loss of Life
Comments:
8. Proximity to Waters of the State
Potential
Rating
Rating Description
Final
Rating
I
Located within/above a larger ash reservoir with large amount of
available storage
3
Potential coal ash migration constrained by physical barrier
5
Directly adjacent
5
Comments:
9. State of Structural Stability & Maintenance (use historical worst case scenario)
Potential
Rating
Rating Description
Final
Rating
1
Notice of Inspection OI with no recommendations
2
NOI with maintenance recommendations
3
Notice of Deficiency OD
3
4
Dam Safety Order DSO
5
Enforcement action required
Comments:
March 11, 2014 Ash Pond Rating Form Page 4 of 6

10. Volume of Facility
Potential
Rating
Rating Description
Final
Rating
1
< 300 acre-feet
2
300 to 1,500 acre-feet
3
1,500 to 3,000 acre-feet
4
3,000 to 9,000 acre-feet
4
5
> 9,000 Acre-feet
Comments:
11. Free Water Content
Potential
Rating
Rating Description
Final
Rating
1
D - heavy natural vegetation and tree growth
2
D - no standing water, sparse tree growth
3
25% of reservoir area water covered
4
25% to 75% of reservoir area water covered
4
5 1
100% of reservoir area water covered
Comments:
12. Offsite Drainage Area (DA = Drainage Area, A = Reservoir Area)
Potential
Rating
Rating Description
Final
Rating
1
Drainage
area = Reservoir area
2
Drainage
area = 1 to 3 times reservoir area
2
3
Drainage
area = 3 to 6 times reservoir area
4
Drainage
area = 6 to 10 times reservoir area
5
Drainage
area = > 10 times reservoir area
Comments:
March 11, 2014 Ash Pond Rating Form Page 5 of 6

Section 3 — Final Ratings
Rating Areas
irr�rl
FFinal 75
Section 1: Water Quality Considerations
1. Groundwater Standards
3
2. Drinking Water Intakes
4
3. Total Population Served by Intakes
4
4. Classification Downstream and Discharge Points
4
5. Distance of Water Supply Wells from the Compliance Boundary
5
6. Population Served by Water Supply Wells
5
SECTION 1 TOTAL
25
Section 2: Dam Safety Considerations
7. Hazard Classification
4
8. Proximity to Waters of the State
5
9. State of Structural Stability & Maintenance
3
10. Volume of Facility
4
11. Free Water Content
4
12. Offsite Drainage Area
2
SECTION 2 TOTAL
22
SECTION 1 + SECTION 2 TOTAL
47
Additional Comments:
March 11, 2014 Ash Pond Rating Form Page 6 of 6

ASH POND RATING FORM
FACILITY NAME: Asheville NPDES PERMIT NO.: NC0000396
REGION: Asheville COUNTY: Buncombe
Instructions: Rate each facility using the potential rating in the left column and the descriptions in the middle
column. A score of 1 indicates the best case whereas a score of 5 indicates the worst case. For the final rating
column, put the number next to the description that best matches the facility in consideration. If you believe a
different rating is warranted for any category (other than what is listed), then justify alternate rating in the
comment section.
Section 1— Water Quality Considerations
Comments' Exceedance of thallium.
2. Drinking Water Intakes
Potential
Rating
Rating Description
Final
Rating
0
No intake
2
Greater than 50 miles downstream
2
3
Greater than 20 miles, but less than orequal to 50 miles downstream
4
Greater than 10 miles, but less than orequal to 20 miles downstream
5
Less than orequal to 10 miles downstream
Comments: Newport Utilities per Gay Irwin, Johnson City Water Resources, TDEC 3/21/2014 (6 MGD
capacity, 10,300 served). None located between Asheville Plant and State line per Jim Adams, PWS
3/19/2014.
March 11, 2014 Ash Pond Rating Form Pagel of 5

3. Total Population Served by Intakes
Potential
Rating
Rating Description
Final
Rating
1
1 - 500 served
2
501 - 3,300 served
3
3,301 - 10,000 served
4
10,001 - 100,000 served
4
5
> 100,000 served
Comments: See comment above.
5. Distance of Water Supply Wells from the Compliance Boundary (CB)
Potential
Rating
Rating Description
Final
Rating
1
Wells greater than 1/2 mile (2,640 feet) of the CB
2
Wells within 2,000 to 2,640 feet of CB
3
Wells within 1,500 to 2,000 feet of CB
4
Wells within 1,000 to 1,500 feet of CB
5
Wells within 1,000 feet of CB
5
Comments: **DENR DWR has requested Duke provide alternate water to one active well with high levels of
iron and manganese. Duke is providing alternate (bottled) water to this home and the adjacent home currently.
Note: Hydrogeologic considerations -- Use to adjust rating due to unique characteristics that should be
considered such as wells upgradient, cross gradient, etc.
March 11, 2014 Ash Pond Rating Form Page 2 of 5

6. Population Served by Water Supply Wells (referenced above)
Potential
Rating
Rating Description
Final
Rating
1
0 o ulation
2
0 - 25 people
2
3
26 - 100 people
4
101 - 200 people
5 1
> 200 people
Comments: See notes above.
Section 2 — Dam Safety Considerations
7. Hazard Classification
Comments:
8. Proximity to Waters of the State
Potential
Rating
Rating Description
Final
Rating
I
Located within/above a larger ash reservoir with large amount of
available storage
3
Potential coal ash migration constrained by physical barrier
4
5
1 Directly adjacent
Comments:
Interstate-26 is between the dam and the French Broad River. River is approximately 1070 feet
from the dam.
March 11, 2014 Ash Pond Rating Form Page 3 of 5

9. State of Structural Stability & Maintenance (use historical worst case scenario)
Potential
Rating Description
Final
Rating
1
Notice of Inspection (NOI) with no recommendations
2
NOI with maintenance recommendations
2
3
Notice of Deficiency (NOD)
4
Dam Safety Order (DSO)
5
Enforcement action required
Comments:
11. Free Water Content
Potential
Rating
Rating Description
Final
Rating
1
Dry - heavy natural vegetation and tree growth
2
Dry - no standing water, sparse tree growth
3
25% of reservoir area water covered
4
25% to 75% of reservoir area water covered
4
5
100% of reservoir area water covered
Comments:
March 11, 2014 Ash Pond Rating Form Page 4 of 5

12. Offsite Drainage Area (DA = Drainage Area, A = Reservoir Area)
Potential
Rating
Rating Description
Final
Rating
1
Drainage area
= Reservoir area
2
Drainage area
= 1 to 3 times reservoir area
2
3
Drainage area
= 3 to 6 times reservoir area
4
Drainage area
= 6 to 10 times reservoir area
5
Drainage area
= > 10 times reservoir area
Comments:
Section 3 — Final Ratings
Rating Areas
Final
Rating
Section 1: Water Quali Considerations
1. Groundwater Standards
5
2. Drinking Water Intakes
2
3. Total Population Served by Intakes
4
4. Classification Downstream and Discharge Points
4
5. Distance of Water Supply Wells from the Compliance Boundary
5
6. Population Served by Water Supply Wells
2
SECTION I TOTAL
22
Section 2: Dam Safety Considerations
7. Hazard Classification
5
S. Proximity to Waters of the State
4
9. State of Structural Stability & Maintenance
2
10. Volume of Facility
2
11. Free Water Content
4
12. ©ffsite Drainage Area
2
SECTION 2 TOTAL,
19"
SECTION 1 + SECTION 2 TOTAL
41
Additional Comments:
March 11, 2014 Ash Pond Rating Form Page 5 of

ASH POND RATING FORM
FACILITY NAME: Belews Creek NPDES PERMIT NO.: NCO024406
REGION: Winston-Salem COUNTY: Stokes
Instructions: Rate each facility using the potential rating in the left column and the descriptions in the middle
column. A score of 1 indicates the best case whereas a score of 5 indicates the worst case. For the final rating
column, put the number next to the description that best matches the facility in consideration. If you believe a
different rating is warranted for any category (other than what is listed), then justify alternate rating in the
comment section.
Section 1— Water Quality Considerations
1. Groundwater Standards
Potential
Rating
Rating Description
Final
Rating
1
An exceedance of pH, iron or manganese
2
Exceedance of chloride, nitrate, sulfate, or TDS
3
Exceedance of aluminum, barium, copper, nickel or zinc
4
Exceedance of boron, cadmium, chromium, selenium, or antimony
5
Exceedance of arsenic, lead, mercury, or thallium
5
Comments: Exceedance of thallium.
2. Drinking Water Intakes
Potential
Rating
Rating Description
Final
Rating
0
No intake
2
Greater than 50 miles downstream
3
Greater than 20 miles, but less than orequal to 50 miles downstream
4
Greater than 10 miles, but less than orequal to 20 miles downstream
4
5
Less than orequal to 10 miles downstream
Comments: Town of Madison intake —12.5 miles downstream (2,787) also serves Rockingham Water
pop (251)
Town of Eden intake — 34 miles downstream (15, 908) also serves Dan River Water (11,890)
March 11, 2014 Ash Pond Rating Form Pagel of 5

3. Total Population Served by Intakes
Potential
Rating
Rating Description
Final
Rating
1
1 - 500 served
2
501 - 3,300 served
3
3,301 - 10,000 served
4
10,001 - 100,000 served
4
5
> 100,000 served
Comments: Pop 3,038 served by 1" intake; 27,798 served by 2nd intake
4. Classification Downstream and Discharge Points (use worst case scenario)
Potential
Rating
Rating Description
Final
Rating
1
Class C
1
4
Class B
5
High Quality Waters, Outstanding Resource Waters, Threatened or
Endangered Species present
Comments:
Belews Lake is Class C; Dan River is WS-IV
5. Distance of Water Supply Wells from the Compliance Boundary (CB)
Potential
Rating
Rating Description
Final
Rating
1
Wells greater than 1/2 mile 2,640 feet of the CB
2
Wells within 2,000 to 2,640 feet of CB
3
Wells within 1,500 to 2,000 feet of CB
4
Wells within 1,000 to 1,500 feet of CB
5
Wells within 1,000 feet of CB
5
Comments:
Wells on Middleton Loop & Pine Hall Road
Note: Hydrogeologic considerations -- Use to adjust rating due to unique characteristics that should be
considered such as wells upgradient, cross gradient, etc.
March 11, 2014 Ash Pond Rating Form Page 2 of 5

6. Population Served by Water Supply Wells (referenced above)
Potential
Rating
Rating Description
Final
Rating
1
0 population
2
0 - 25 people
3
26 - 100 people
3
4
101 - 200 people
5
> 200 people
Comments: Estimate 14 homes with average of 4 occupants per home
Section 2 — Dam Safety Considerations
7. Hazard Classification
Potential
Rating
Rating Description
Final
Rating
1
Low hazard - Small size
2
Low Hazard - Large size
3
Intermediate Hazard
4
High Hazard - Environmental Concerns
5
High Hazard - Loss of Life
5
Comments:
8. Proximity to Waters of the State
Potential
Rating
Rating Description
Final
Rating
1
Located within/above a larger ash reservoir with large amount of
available storage
3
Potential coal ash migration constrained by physical barrier
3
5
Directly adjacent
Comments:
March 11, 2014 Ash Pond Rating Form Page 3 of 5

9. State of Structural Stability & Maintenance (use historical worst case scenario)
Potential
Rating
Rating Description
Final
Rating
1
Notice of Inspection OI with no recommendations
2
NOI with maintenance recommendations
2
3
Notice of Deficient OD
4
Dam Safety Order DSO
5
Enforcement action required
Comments:
10. Volume of Facility
Potential
Rating
Rating Description
Final
Rating
1
< 300 acre-feet
2
300 to 1,500 acre-feet
2
3
1,500 to 3,000 acre-feet
4
3,000 to 9,000 acre-feet
5
> 9,000 Acre-feet
Comments:
11. Free Water Content
Potential
Rating
Rating Description
Final
Rating
1
D - heavy natural vegetation and tree growth
2
D - no standing water, s arce tree growth
3
25% of reservoir area water covered
4
25% to 75% of reservoir area water covered
5
100% of reservoir area water covered
5
Comments:
March 11, 2014 Ash Pond Rating Form Page 4 of 5

12. Offsite Drainage Area (DA = Drainage Area, A = Reservoir Area)
Potential
Rating
Rating Description
Final
Rating
1
Drainage area =
Reservoir area
2
Drainage area =
1 to 3 times reservoir area
2
3
Drainage area =
3 to 6 times reservoir area
4
Drainage area =
6 to 10 times reservoir area
5
Drainage area = > 10 times reservoir area
Comments:
Section 3 — Final Ratings
Rating Areas
Final
Rating
Section 1: Water Quality Considerations
1. Groundwater Standards
5
2. Drinking Water Intakes
4
3. Total Population Served by Intakes
_ 4
4. Classification Downstream and Discharge Points
1
5. Distance of Water Supply Wells from the Compliance Boundary
5
6. Population Served by Water Supply Wells
3
SECTION 1 TOTAL
22
Section 2: Dam Safe Considerations
7, Hazard Classification
5
8. Proximity to Waters of the State
3
9. State of Structural Stability & Maintenance
2
10. Volume of Facility
I
11. Free Water Content
5
12. Offsite Drainage Area
2
SECTION 2 TOTAL
19
SECTION 1 + SECTION 2 TOTAL
41
Additional Comments:
March 11, 2014 Ash Pond Rating Form Page 5 of.s

ASH POND RATING FORM
FACILITY NAME: Buck
REGION: Mooresville
NPDES PERMIT NO.: NC0004774
COUNTY: Rowan
Instructions: Rate each facility using the potential rating in the left column and the descriptions in the middle
column. A score of 1 indicates the best case whereas a score of 5 indicates the worst case. For the final rating
column, put the number next to the description that best matches the facility in consideration. If you believe a
different rating is warranted for any category (other than what is listed), then justify alternate rating in the
comment section.
Section 1— Water Quality Considerations
1. Groundwater Standards
Potential
Rating
Rating Description
Final
Rating
1
An exceedance of pH, iron or manganese
2
Exceedance of chloride, nitrate, sulfate, or TDS
3
Exceedance of aluminum, barium, copper, nickel or zinc
4
Exceedance of boron, cadmium, chromium, selenium, or antimony
4
5
Exceedance of arsenic, lead, mercury, or thallium
Comments:
o date MWs at Buck have shown consistent exceedances for pH, Fe, Mn, B, sulfate, and TDS.
2. Drinking Water Intakes
Potential
Rating
Rating Description
Final
Rating
0
No intake
2
Greater than 50 miles downstream
3
Greater than 20 miles, but less than orequal to 50 miles downstream
4
Greater than 10 miles, but less than orequal to 20 miles downstream
4
5
Less than orequal to 10 miles downstream
Comments: The Town of Denton intake is approximately 13 miles downstream on the lower portion of High
Rock Lake. Additional intakes for communities like Albemarle would be further (-21 miles) downstream on
along the Yadkin River's chain of reservoirs.
March 11, 2014 Ash Pond Rating Form Page 1 of 5

3. Total Population Served by Intakes
Potential
Rating
Rating Description
Final
Rating
1
1 - 500 served
2
501 - 3,300 served
2
3
3,301 - 10,000 served
4
10,001 - 100,000 served
5
> 100,000 served
Comments: Denton's PWS system serves 3,080. Albemarle's two WTPs serve 16,500. Given the nature of
the chain of lakes and dams that would likely capture material associated with a potential catastrophic release
at Buck, the risk rating is probably best approximated by using just the population numbers for Denton
4. Classification Downstream and Discharge Points (use worst case scenario)
Potential
Rating
.Rating Description
Final
Rating
1
Class C
4
Class B
4
5
High Quality Waters, Outstanding Resource Waters, Threatened or
Endangered Species present
Comments: Classification in the immediate vicinity of Buck is WS-V. Downstream of Buck, the
classification changes to WS-IV, B in the lower portion of High Rock Lake.
5. Distance of Water Supply Wells from the Compliance Boundary (CB)
Potential
Rating
Rating Description
Final
Rating
1
Wells greater than 1/2 mile 2,640 feet) of the CB
2
Wells within 2,000 to 2,640 feet of CB
3
Wells within 1,500 to 2,000 feet of CB
4
Wells within 1,000 to 1,500 feet of CB
5
Wells within 1,000 feet of CB
5
Comments: The area in the vicinity of the plant is served by wells and a formal well survey has not been
conducted. The closest private wells are along Dukeville and Leonard Roads and a couple of small spur roads
off of these. The closest private wells are roughly 200 ft from the CB and there may be roughly 50
private
water supply wells within 1500 ft. Additionally, there is a public water supply well for Duke employees on
site at Buck (0180647) and two PWS well systems at nearby churches (Trading Ford Baptist 0180594,
Yadkin Grove Missionary Baptist 0180633). These PWS systems are roughly 800-1300 ft from the CB.
Note: Hydrogeologic considerations -- Use to adjust rating due to unique characteristics that should be
considered such as wells upgradient, cross gradient, etc.
March 11, 2014 Ash Pond Rating Form Page 2 of 5

6. Population Served by Water Supply Wells (referenced above)
Potential RFinal
Rating Rating Description
Rating
1 0 population
2 0 - 25 2eople
3 26 -100 people
4 101 - 200 people
5 f > 200 people 5
Comments: Without a well survey, the population served by private wells near Buck was estimated in the
following manner: a very rough approximation of 50 wells within 1500 feet and 3 people per well results in
150 people served. This is an estimate and the actual number could vary significantly from that value. The
population served by the PWS systems mentioned #2 is estimated at 200 (75 on site, 100 at Trading Ford, 25
at Yadkin Grove).
Section 2 — Dann Safety Considerations
March 11, 2014 Ash Pond Rating Form Page 3 of 5

9. State of Structural Stability & Maintenance (use historical worst case scenario)
Potential
Rating
Rating Description
Final
Rating
1
Notice of Inspection (NOI) with no recommendations
2
NOI with maintenance recommendations
2
3
Notice of Deficient (NOD)
4
Dam Safety Order (DSO)
5
Enforcement action required
Comments:
10. Volume of Facility
Potential
Rating
Rating Description
Final
Rating
1
< 300 acre-feet
2
300 to 1,500 acre-feet
3
1,500 to 3,000 acre-feet
3
4
3,000 to 9,000 acre-feet
5
> 9,000 Acre-feet
Comments:
11. Free Water Content
Potential
Rating
Rating Description
Final
Rating
1
Dry - heavy natural vegetation and tree growth
2
D - no standing water, sparse tree gowth
3
25% of reservoir area water covered
4
25% to 75% of reservoir area water covered
4
5
100% of reservoir area water covered
Comments:
March 11, 2014 Ash Pond Rating Form Page 4 of 5

12. Offsite Drainage Area (DA = Drainage Area, A = Reservoir Area)
Potential
Rating
Rating Description
Final
Rating
1
Drainage area = Reservoir area
2
Drainage area = 1 to 3 times reservoir area
2
3
Drainage area = 3 to 6 times reservoir area
4
Drainage area = 6 to 10 times reservoir area
5
Drainage area = > 10 times reservoir area
Comments:
Section 3 — Final Ratings
Rating Areas
Final
Rating
Section 1: Water Quality Considerations
1. Groundwater Standards
4
2. Drinking Water Intakes
4
3. Total Po ulation Served by Intakes
2
4. Classification Downstream and Discharge Points
4
5. Distance of Water Supply Wells from the Compliance Boundary
5
6. Population Served by Water Supply Wells
5
SECTION' l TOTAL'
4 .
Section 2: Dam Safety Considerations
7. Hazard Classification
4
8. Proximity to Waters of the State
5
9. State of Structural Stability & Maintenance
2
10. Volume of Facility
3
11. Free Water Content
4
12. Offsite Drainage Area
2
SECTION 2.TOTAL
20
SECTION I + SECTION 2 TOTAL
44
Additional Comments:
March 11, 2014 Ash Pond Rating Form Page 5 of 5

FACILITY NAME: Cape Fear
REGION: Raleigh
ASH POND RATING FORM
NPDES PERMIT NO.: NC0003433
COUNTY: Chatham
Instructions: Rate each facility using the potential rating in the left column and the descriptions in the middle
column. A score of 1 indicates the best case whereas a score of 5 indicates the worst case. For the final rating
column, put the number next to the description that best matches the facility in consideration. If you believe a
different rating is warranted for any category (other than what is listed), then justify alternate rating in the
comment section.
Section 1— Water Quality Considerations
1. Groundwater Standards
Potential
Rating
` '
Rating Description
Final
Rating
1
An exceedance of pH, iron or manganese
2
Exceedance of chloride, nitrate, sulfate, or TDS
3
Exceedance of aluminum, barium, copper, nickel or zinc
4
Exceedance of boron; cadmium, chromium, 'selenium, or antimony
5
Exceedance of arsenic, lead, mercury, or thallium
5
Comments:
Exceedance of arsenic.
2. Drinking Water Intakes
Potential
Rating
Rating Description
Final
Rating
0
No intake
2
Greater than 50 miles downstream
3
Greater than 20 miles, but less than orequal to 50 miles downstream
4
Greater than 10 miles, but less than orequal to 20 miles downstream
5
Less than orequal to 10 miles downstream
5
Comments: One water supply intake is less than 10 miles downstream.
March 11, 2014 Ash Pond Rating Form Page 1 of 5

3. Total Population Served by Intakes
Potential
Rating
Rating Description
Final
Rating
1
1 - 500 served
2
501 - 3,300 served
3
3,301 - 10,000 served
4
10,001 - 100,000 served
4
5
> 100,000 served
Comments: Based on normal population served by the surface water supply intakes downstream of the
Cape Fear Facility. Potential population served through emergencyconnections not included.
4. Classification Downstream and Discharge Points (use worst case scenario)
Potential
Rating Description
Final
Rating
Rating
1
Class C
1
4
Class B
5
High Quality Waters, Outstanding Resource Waters, Threatened or
Endangered Species present
Comments:
*Cape Fear Steam Electric facility is located adjacent, to the Cape Fear River just below the confluence
of the Haw and Deep Rivers.
From the junction of the Deep and Haw River to a point 0.5 miles upstream of NC Hwy 42 the Cape
Fear River is classified as WS-IV From 0.5 miles upstream of NC Hwy 42 to NC Hwy 42 the Cape
Fear River is classified as WS-IV Critical Area (CA) and pis the location of the City of Sanford's Water
Supply intake.
5. Distance of Water Supply Wells from the Compliance Boundary (CB)
Potential'
Rating
Rating Description
Final
Rating
1
Wells greater than 1/2 mile 2,640 feet of the CB
1
2
Wells within 2,060 to 2,640 feet of CB
3
Wells within 1,500 to 2,000 feet of CB
4
Wells within 1,000 to 1,500 feet of CB
5
Wells within 1,000 feet of CB
Comments: Cape Fear- there are several residence/structures that fall within the "Potential Rating 3"
however the wells are located on the opposite site of the Cape Fear River in regards to the facility. This
survey was completed with GoogleEarth with the assumption that specific structures are utilizing well
water. The source of water for the plywood manufacturing plants is unknown.
Note: Hydrogeologic considerations -- Use to adjust rating due to unique characteristics that should be
considered such as wells upgradient, cross gradient, etc.
March 11, 2014 Ash Pond Rating Form Page 2 of 5

6. Population Served by Water Supply Wells (referenced above)
Potential
Rating
Rating Description
Final
Rating
1
0 population
2
0 - 25 people
3
26 - 100 people
3
4
101 - 200 people
5
>200 people
Comments: Based on the assumption that there are four persons living in each residence/structure. No
service population for PWS wells.
Section 2 — Dam Safety Considerations
7. Hazard Classification
Potential
Rating
Rating Description
Final
Rating
1
Low hazard - Small size
2
Low Hazard - Large size
3
Intermediate Hazard
4
High Hazard -Environmental Concerns
4
5
High Hazard - Loss of Life
Comments:
8. Proximity to Waters of the State
Potential
Rating
Rating Description
Final
Rating
I
Located within/above a larger ash reservoir with large amount of
available storage
3
Potential coal ash migration constrained by physical barrier
5
Directly adjacent
5
Comments:
March 11, 2014 Ash Pond Rating Form Page 3 of 5

9. State of Structural Stability & Maintenance (use historical worst case scenario)
Potential
Rating
Rating Description
Final
Rating
1
Notice of Inspection OI with no recommendations
2
NOI with maintenance recommendations
3
Notice of Deficiency OD
3
4
Dam Safety Order DSO
5
Enforcement action required
Comments:
10. Volume of Facility
Potential
Rating
Rating Description
Final
Rating
1
< 300 acre-feet
2
300 to 1,500 acre-feet
3
1,500 to 3,000 acre-feet
3
4
3,000 to 9,000 acre-feet
5
> 9,000 Acre-feet
Comments:
11. Free Water Content
Potential
Rating
Rating Description
Final
Rating
1
D - heavy natural vegetation and tree growth
2
D - no standing water, sparse tree growth
3
25% of reservoir area water covered
4
25% to 75% of reservoir area water covered
4
5
100% of reservoir area water covered
Comments:
March 11, 2014 Ash Pond Rating Form Page 4 of 5

12. Offsite Drainage Area (DA = Drainage Area, A = Reservoir Area)
Potential
Rating
Rating Description
Final
Rating
1
Drainage area = Reservoir area
2
Drainage area = 1 to 3 times reservoir area
2
3
Drainage area = 3 to 6 times reservoir area
4
Drainage area = 6 to 10 times reservoir area
Drainage area = > 10 times reservoir area
Corninents:
Section 3 — Final Ratings
Rating Areas
Final
Rating
Section 1: Water Quality Considerations
1. Groundwater Standards
5
2. Drinking Water Intakes
5
3. Total Population Served by Intakes
4
4. Classification Downstream and Discharge Points
_
1
5, Distance of Water Supply Wells from the Compliance Boundary
1
6. Population Served by Water Sup -ply Wells
3
SECTION 1 TOTAL
19
Section 2: Dam Safety Considerations
7. Hazard Classification
4
8, Proximity to Waters of the State
5
9. State of Structural Stability & Maintenance
3
10. Volume of Facility
3
11. Free Water Content
4
12. Offsite Drainage Area
2
SECTION 2 TOTAL
21
SECTION 1 + SECTION 2 TOTAL
40
Additional Comments:
March 11, 2014 Ash Pond Rating Form Page 5 of 5

ASH POND RATING FORM
FACILITY NAME: Cliffside NPDES PERMIT NO.: NC0005088
REGION: Asheville COUNTY: Rutherford
Instructions: Rate each facility using the potential rating in the left column and the descriptions in the middle
column. A score of 1 indicates the best case whereas a score of 5 indicates the worst case. For the final rating
column, put the number next to the description that best matches the facility in consideration. If you believe a
different rating is warranted for any category (other than what is listed), then justify alternate rating in the
comment section.
Section 1— Water Quality Considerations
2. Drinking Water Intakes
Potential
Rating
Rating Description
Final
Rating
0
No intake
2
Greater than 50 miles downstream
3
Greater than 20 miles, but less than orequal to 50 miles downstream
4
Greater than 10 miles, but less than orequal to 20 miles downstream
5
Less than orequal to 10 miles downstream
5
Comments: City of Shelby proposed intake approximately 6 miles downstream of plant. Intake developed
during previous droughts, not currently used. Shelby has capability to pump from Broad during an emergency
such as a drought. Next nearest intake is Gaffney, SC (18 MGD) located approx.. 18 miles from Cliffside
plant per Rob Devlin, SCDHEC. 3/21/2014
March 11, 2014 Ash Pond Rating Form Pagel of 5

3. Total Population Served by Intakes
Potential
Rating
Rating Description
Final
Rating
1
1 - 500 served
2
501 - 3,300 served
3
3,301 - 10,000 served
3
4
10,001 - 100,000 served
5
> 100,000 served
Comments: Rating is for Gaffney, SC intake; does not account for proposed Shelby intake.
4. Classification Downstream and Discharge Points (use worst case scenario)
Potential Final
Rating Description
Rating . Rating
5. Distance of Water Supply Wells from the Compliance Boundary (CB)
Potential
Rating
Rating Description
Final
Rating
1
Wells greater than 1/2 mile (2,640 feet) of the CB
2
Wells within 2,000 to 2,640 feet of CB
3
Wells within 1,500 to 2,000 feet of CB
4
Wells within 1,000 to 1,500 feet of CB
5
Wells within 1,000 feet of CB
5
Comments: Multiple single family home wells in proximity (no water supply well survey conducted)
Note: Hydrogeologic considerations -- Use to adjust rating due to unique characteristics that should be
considered such as wells upgradient, cross gradient, etc.
March 11, 2014 Ash Pond Rating Form Page 2 of 5

6. Population Served by Water Supply Wells (referenced above)
Potential
Rating
Rating Description
Final
Rating
1
0 population
2
0 - 25 people
2
3
26 -100 people
4
101 - 200 people
5
> 200 people
Comments: Estimated number only, yet to be verified with proper survey.
Section 2 — Dam Safety Considerations
7. Hazard Classification
PotenhaL Rating Description Final
Rating Rating
1 Low hazard - Small size
2 Low Hazard - Lar a size
3 Intermediate Hazard
4 High Hazard - Environmental Concerns
5 High Hazard - Loss of Life 5
Comments:
8. Proximity to Waters of the State
Potential
Rating
Rating Description
Final
Rating
1
Located within/above a larger ash reservoir with large amount of
available storage
3
Potential coal ash migration constrained by physical barrier
5
Directly adjacent
5
Comments:
March 11, 2014 Ash Pond Rating Form Page 3 of 5

9. State of Structural Stability & Maintenance (use historical worst case scenario)
Potential
Rating
Rating Description
Final
Rating
1
Notice of Inspection (NOI) with no recommendations
2
NOI with maintenance recommendations
3
Notice of Deficiency (NOD)
3
4
Dam Safety Order (DSO)
5
Enforcement action required
Comments:
10. Volume of Facility
Potential
Rating Description
'h`Mal
Rating
Rating
1
< 300 acre-feet '
2
300 to 1500 acre-feet
3
1,500 to 3,000 acre.=feet::
4
4
3NO t6 9,000 acre-feet 7'.
5
> 9,000 Acre-feet
Comments:
11. Free Water Content
Potential
Rating
Rating Description
Final
Rating
1
Dry - heavy natural vegetation and tree growth
2
D - no standing water, sparse tree growth
3
25% of reservoir area water covered
4
25% to 75% of reservoir area water covered
4
5
100% of reservoir area water covered
Comments:
March 11, 2014 Ash Pond Rating Form Page 4 of 5

Section 3 — Final Ratings
Rating Areas
Section 1: Water Quality Considerations
1. Groundwater Standards
2. Drinking Water Intakes
3. Total Population Served by Intakes _
4. Classification Downstream and Discharge Points
S. Distance of Water Supply Wells from the Compl
b. Population Served by Water Supply Wells
Section 2: Dam Safety Considerations
7. Hazard Classification
8. Proximity to Waters of the State
9. State of Structural Stability & Maintenance
10. Volume of Facility
11. Free Water Content
121. Offsite Drainage Area
Additional Comments:
Final
Rating
2
5
3
1
Boundary 5
2
SECTION I TOTAL, 18
SECTION 2 TOTAL
SECTION 1 + SECTION 2 TOTAL
5
5
3
4
4
4
25
43
March 11, 2014 Ash Pond Rating Form Page 5 of 5

ASH POND RATING FORM
FACILITY NAME: Dan River
REGION: Winston-Salem
NPDES PERMIT NO.: NC0003468
COUNTY: Rockingham
Instructions: Rate each facility using the potential rating in the left column and the descriptions in the middle
column. A score of 1 indicates the best case whereas a score of 5 indicates the worst case. For the final rating
column, put the number next to the description that best matches the facility in consideration. If you believe a
different rating is warranted for any category (other than what is listed), then justify alternate rating in the
comment section.
Section 1— Water Quality Considerations
1. Groundwater Standards
Potential
Rating
Rating Description
Final
Rating
1
An exceedance of pH, iron or manganese
2
Exceedance of chloride, nitrate, sulfate, or TDS
3
Exceedance of aluminum, barium, copper, nickel or zinc
4
Exceedance of boron, cadmium, chromium, selenium, or antimony
5
Exceedance of arsenic, lead, mercury, or thallium
5
Comments:
Exceedance of arsenic.
2. Drinking Water Intakes
Potential
Rating
Rating Description
ti
Final
Rating
0
No intake
2
Greater than 50 miles downstream
3
Greater than 20 miles, but less than orequal to 50 miles downstream
3
4
Greater than 10 miles, but less than orequal to 20 miles downstream
5
Less than orequal to 10 miles downstream
Comments:
Service.
City of Danville WTP is approximately 25 river miles downstream as per US Fish and Wildlife
March 11, 2014 Ash Pond Rating Form Page 1 of 5

3. Total Population Served by Intakes
Potential
Rating
Rating Description
Final
Rating
1
1 - 500 served
2
501 - 3,300 served
3
3,301 - 10,000 served
4
10,001 - 100,000 served
5
> 100,000 served
5
Comments: City of Danville water customers in addition to those potential users through inter -governmental
agreements for emergency water supply.
4. Classification Downstream and Discharge Points (use worst case scenario)
Potential
Rating
Rating Description
Final
Rating
1
Class C
4
Class B
5
High Quality Waters, Outstanding Resource Waters, Threatened or
Endangered Species present
5
Comments:
Actually Class C waters, but there are identified endangered species.
5. Distance of Water Supply Wells from the Compliance Boundary (CB)
Potential
Rating
Rating Description
Final
Rating
1
Wells greater than 1/2 mile 2,640 feet of the CB
1
2
Wells within 2,000 to 2,640 feet of CB
3
Wells within 1,500 to 2,000 feet of CB
4
Wells within 1,000 to 1,500 feet of CB
5
Wells within 1,000 feet of CB
Comments: As per Rockingham County Environmental Health Dept (RCEHD). Agricultural supply wells
are not accounted for by RCEHD.
Note: Hydrogeologic considerations -- Use to adjust rating due to unique characteristics that should be
considered such as wells upgradient, cross gradient, etc.
March 11, 2014 Ash Pond Rating Form Page 2 of 5

6. Population Served by Water Supply Wells (referenced above)
Potential
Rating
Rating Description
Final
Rating
1
0 population
1
2
0 - 25 people
3
26 - 100 people
4
101 - 200 people
5
> 200 people
Comments: As per Rockingham County Environmental Health Dept (RCEHD). Agricultural supply wells
are not accounted for by RCEHD.
Section 2 — Dam Safety Considerations
7. Hazard Classification
Potential
Rating
Rating Description
Final
Rating
1
Low hazard - Small size
2
Low Hazard - Large size
3
Intermediate Hazard
4
High Hazard - Environmental Concerns
4
5
High Hazard - Loss of Life
Comments:
8. Proximity to Waters of the State
Potential
Rating
Rating Description
Final
Rating
I
Located within/above a larger ash reservoir with large amount of
available storage
3
Potential coal ash migration constrained by physical barrier
5
1 Directly adjacent
5
Comments:
March 11, 2014 Ash Pond Rating Form Page 3 of 5

9. State of Structural Stability & Maintenance (use historical worst case scenario)
Potential
Rating
Rating Description
Final
Rating
1
Notice of Inspection (NOI) with no recommendations
2
NOI with maintenance recommendations
3
Notice of Deficiency (NOD)
4
Dam Safety Order (DSO)
5
Enforcement action re uired
5
Comments:
10. Volume of Facility
Potential
Rating
Rating Description
Final
Rating
1
< 300 acre-feet
2
300 to 1,500 acre-feet
2
3
1,500 to 3,000 acre-feet
4
3,000 to 9,000 acre-feet
5
> 9,000 Acre-feet
Comments:
11. Free Water Content
Potential
Rating
Rating Description
Final
Rating
1
D - heavy natural vegetation and tree growth
2
D - no standing water, sparse tree growth
3
25% of reservoir area water covered
4
25% to 75% of reservoir area water covered
5
100% of reservoir area water covered
5
Comments:
March 11, 2014 Ash Pond Rating Form Page 4 of 5

12. Offsite Drainage Area (DA = Drainage Area, A = Reservoir Area)
Potential
Ratio g
Rating Description
Final
Rating
1
Drainage area = Reservoir area
2
Drainage area = i to 3 times reservoir area
2
3
Drainage area = 3 to 6 times reservoir area
4
Drainage area = 6 to 10 times reservoir area
5
Drainage area = > 14 times reservoir area
Comments:
Section 3 -- Final Ratings
Rating Areas
Final
Rating
Section 1: Water Quality Considerations
1.
Groundwater Standards
5
2.
Drinking Water Intakes
3
3.
Total Population Served by Intakes
5
4.
Classification Downstream and Discharge Points
5
5.
Distance of Water Supply Wells from the Compliance Boundary
1
6.
Population Served by Water Supply Wells
I
SECTION I TOTAL
24
Section 2: Dam Safety Considerations
7.
Hazard Classification
4
8.
Proximity to Waters of the State
5
9.
State of Structural Stability & Maintenance
5
10. Volume of Facility
2
11.
Free Water Content
5
12.
Offsite Drainage Area
SECTION 2 TOTAL
23
SECTION 1 + SECTION 2 TOTAL
43
Additional Comments:
March 11, 2014 Ash Pond Rating Form Paige 5 of 5

ASH POND RATING FORM
FACILITY NAME: Lee
REGION: Washington
NPDES PERMIT NO.: NC0003417
COUNTY: Wayne
Instructions: Rate each facility using the potential rating in the left column and the descriptions in the middle
column. A score of 1 indicates the best case whereas a score of 5 indicates the worst case. For the final rating
column, put the number next to the description that best matches the facility in consideration. If you believe a
different rating is warranted for any category (other than what is listed), then justify alternate rating in the
comment section.
Section 1— Water Quality Considerations
1. Groundwater Standards
Potential
Rating
Rating Description
Final
Rating
1
An exceedance of pH, iron or manganese
2
Exceedance of chloride, nitrate, sulfate, or TDS
3
Exceedance of aluminum, barium, copper, nickel or zinc
4
Exceedance of boron, cadmium, chromium, selenium, or antimony
5
Exceedance of arsenic, lead, mercury, or thallium
5
Comments:
Exceedance of arsenic and lead.
2. Drinking Water Intakes
Potential
Rating
Rating Description
Final
Rating
0
No intake
2
Greater than 50 miles downstream
3
Greater than 20 miles, but less than orequal to 50 miles downstream
4
Greater than 10 miles, but less than orequal to 20 miles downstream
5
1 Less than orequal to 10 miles downstream
5
Comments:
Drinking water intake is located approximately six miles downstream.
L
March 11, 2014 Ash Pond Rating Form Page 1 of 5

3. Total Population Served by Intakes
Potential
Rating
Rating Description
Final
Rating
1
1 - 500 served
2
501 - 3,300 served
3
3,301 - 10,000 served
4
10,001 - 100,000 served
4
5
> 100,000 served
Comments: According to Public Water Supply Section website, the City of Goldsboro's public water system
served a year-round population of 36,437.
4. Classification Downstream and Discharge Points (use worst case scenario)
Potential
Rating
Rating Description
Final
Rating
1
Class C
4
Class B
5
High Quality Waters, Outstanding Resource Waters, Threatened or
Endangered Species present
5
Comments: This segment of the Neuse is classified as WS-IV; note the surface water intake located
approximately six miles downstream.
5. Distance of Water Supply Wells from the Compliance Boundary (CB)
Potential
Rating
Rating Description
Final
Rating
1
Wells greater than 1/2 mile (2,640 feet) of the CB
2
Wells within 2,000 to 2,640 feet of CB
2
3
Wells within 1,500 to 2,000 feet of CB
4
Wells within 1,000 to 1,500 feet of CB
5
Wells within 1,000 feet of CB
Comments: This estimate is based on "drive -by" receptor survey conducted by WaRO staff. Wells may be
located less than 1500 feet from Compliance Boundary; however, any supply wells would be located up -
gradient of the ash pond.
Note: Hydrogeologic considerations -- Use to adjust rating due to unique characteristics that should be
considered such as wells upgradient, cross gradient, etc.
March 11, 2014 Ash Pond Rating Form Page 2 of 5

6. Population Served by Water Supply Wells (referenced above)
Potential
Rating
R
Rating Description
Final
Rating
1
0 population
2
0 - 25 people
2
3
26 - 100 people
4
101 - 200 people
5
> 200 people
Comments: This estimate is based on the number of pump/well houses observed in the area. It is not certain
if these wells are still in service; and, as noted above, the wells are located up -gradient of the facility.
Section 2 — Dam Safety Considerations
7. Hazard Classification
Potential
Rating
R
Rating Description
Final
Rating
1
Low hazard - Small size
2
Low Hazard - Large size
3
Intermediate Hazard
4
High Hazard - Environmental Concerns
4
5 1
High Hazard - Loss of Life
Comments:
8. Proximity to Waters of the State
Potential
Rating
Rating Description
Final
Rating
I
Located within/above a larger ash reservoir with large amount of
available storage
3
Potential coal ash migration constrained by physical barrier
5
Directly adjacent
5
Comments:
March 11, 2014 Ash Pond Rating Form Page 3 of 5

9. State of Structural Stability & Maintenance (use historical worst case scenario)
Potential
Rating
Rating Description
Final
Rating
1
Notice of Inspection (NOI) with no recommendations
1
2
NOI with maintenance recommendations
3
Notice of Deficiency (NOD)
4
Dam Safety Order (DSO)
5
Enforcement action required
Comments:
10. Volume of Facility
Rating Potential
Rating Description
Final
Rating
1
< 300 acre-feet
2
300 to 1,500 acre-feet
3
1,500 to 3,000 acre-feet
3
4
3,000 to 9,000 acre-feet
5
> 9,000 Acre-feet
Comments:
11. Free Water Content
Potential
Rating
Rating Description
Final
Rating
1
Dry - heavy natural vegetation and tree growth
2
Dry - no standing water, sparse tree growth
3
25% of reservoir area water covered
3
4
25% to 75% of reservoir area water covered
5
1 100% of reservoir area water covered
Comments:
March 11, 2014 Ash Pond Rating Form Page 4 of 5

Section 3 — Final Ratings
Rating Areas
Final
Rating
Section 1: Water Quality Considerations
1. Groundwater Standards
5
2. Drinking Water Intakes
5
3. Total Po ulation Served by Intakes
4
4. Classification Downstream and Discharge Points
5
5. Distance of Water Supply Wells from the Compliance Boundary
2
6, Population Served by Water Supply Wells
2
SECTION 1 TOTAL.
23
Section 2: Dam Safety Considerations
7. Hazard Classification
4
8, Proximity to Waters of the State
5
9. State of Structural Stability & Maintenance
I
10. Volume of Facility
3
11. Free Water Content
3
12. Offsite Drainage Area
I
SECTION 2 TOTAL'.'17
SECTION 1 + SECTION 2 TOTAL
40
Additional Comments: A separate rating form has not been completed for the in -active ash pond down
Ferry Bridge Rd.
March 11, 2014 Ash Pond Rating; Form Page 5 of 5

ASH POND RATING FORM
FACILITY NAME: Marshall NPDES PERMIT NO.: NC0004987
REGION: Mooresville COUNTY: Catawba
Instructions: Rate each facility using the potential rating in the left column and the descriptions in the middle
column. A score of 1 indicates the best case whereas a score of 5 indicates the worst case. For the final rating
column, put the number next to the description that best matches the facility in consideration. If you believe a
different rating is warranted for any category (other than what is listed), then justify alternate rating in the
comment section.
Section 1— Water Quality Considerations
1. Groundwater Standards
Potential
Rating
Rating Description
Final
Rating
1
An exceedance of pH, iron or manganese
2
Exceedance of chloride, nitrate, sulfate, or TDS
3
Exceedance of aluminum, barium, copper, nickel or zinc
4
Exceedance of boron, cadmium, chromium, selenium, or antimony
4
5
Exceedance of arsenic, lead, mercury, or thallium
Comments: MWs at Marshall have shown consistent exceedances for pH, B, Fe, Mn, sulfate, and TDS.
2. Drinking Water Intakes
Potential
Rating Description
Final
Rating
Rating
0
No intake
2
Greater than 50 miles downstream
3
Greater than 20 miles, but less than orequal to 50 miles downstream
4
Greater than 10 miles, but less than orequal to 20 miles downstream
5
Less than orequal to 10 miles downstream
5
Comments: The Lincoln County intake is —6 miles downstream also on Catawba River/Lake Norman,
however, the intake is located off the main channel in a small cove. Charlotte's Lee S. Dukes WTP intake is
at the bottom of Lake Norman — 16 miles downstream. There would be additional intakes downstream from
that Lee S. Dukes WTP at greater distances (that list would begin to overlap with intakes noted below
Riverbend and Allen).
March 11, 2014 Ash Pond Rating Form Page 1 of 6

3. Total Population Served by Intakes
Potential
Rating
Rating Description
Final
Rating
1
1 - 500 served
2
501 - 3,300 served
3
3,301 - 10,000 served
4
10,001 - 100,000 served
5
> 100,000 served
5
Comments: The Lincoln County system serves 25,938. The Lee S. Dukes WTP is a portion of the
Charlotte -Mecklenburg system and there is not a population estimate exclusively for this facility. The overall
Charlotte system serves in excess of 800,000 people as noted under the write up for Riverbend and the risk _
has been rated accordingly.
4. Classification Downstream and Discharge Points (use worst case scenario)
Potential
Rating
Rating Description
Final
Rating
1
Class C
4
Class B
4
5
High Quality Waters, Outstanding Resource Waters, Threatened or
Endangered Species present
Comments: Surface water in proximity to Marshall is the Catawba River/Lake Norman. Classifications
include WS-IV, B; CA.
March 11, 2014 Ash Pond Rating Form Page 2 of 6

5. Distance of Water Supply Wells from the Compliance Boundary (CB)
Potential
Rating Description
Final
Rating
Rating
1
Wells greater than 1/2 mile (2,640 feet) of the CB
2
Wells within 2,000 to 2,640 feet of CB
3
Wells within 1,500 to 2,000 feet of CB
4
Wells within 1,000 to 1,500 feet of CB
4
5
Wells within 1,000 feet of CB
Comments: There has not been a formal water supply well survey conducted for Marshall. There is public
water available to portions of the area surrounding the facility and it is not clear which homes may be
connected. There may be wells along HWY 150, Sherrills Ford Road, and Island Point Road and spur roads
off of these. The closest locations to the CB would likely fall along Sherrills Ford Road to the W and off of
Island Point Road to the N, which could be on the order of hundreds of feet or more away from the CB and
hydraulically upgradient from the facility. The risk rating given is based on better known PWS well locations.
Additionally, there are several PWS well systems in proximity to Marshall:
• 0118589 Rehobeth UMC —4000 ft from CB
• 0118622 Midway Boat House Grill —1900 ft from CB
• 0115254 Riverwood S/D —4000 ft from CB
• 0118168 Pine Wood Acres —2200 ft from CB
• 0118780 Motts Grove UMC —1600 ft from CB
• 0118676 Duke -Marshall on site well —1700 ft from CB
• 0118736 Old Country Church —1200 ft from CB
Note: Hydrogeologic considerations -- Use to adjust rating due to unique characteristics that should be
considered such as wells upgradient, cross gradient, etc.
6. Population Served by Water Supply Wells (referenced above)
Potential
Rating
Rating Description
Final
Rating
1
0 population
2
0 - 25 people
3
26 - 100 people
4
101 - 200 people
5
> 200 people
5
Comments: Combined population served by the PWS systems is >200. Without a well survey, there is not
an estimate of private well users.
March 11, 2014 Ash Pond Rating Form Page 3 of 6

Section 2 — Dam Safety Considerations
7. Hazard Classification
Potential
Rating
Rating Description
Final
Rating
1
Low hazard - Small size
2
Low Hazard - Large size
3
Intermediate Hazard
4
High Hazard - Environmental Concerns
4
5
High Hazard - Loss of Life
Comments:
8. Proximity.to Waters of the State
Potential
Rating
Rating Description
Final
Rating
I
Located within/above a larger ash reservoir with large amount of
available storage
3
Potential coal ash migration constrained by physical barrier
5
Directly adjacent
S
Comments:
9. State of Structural Stability & Maintenance (use historical worst case scenario)
Potential
Rating
Rating Description
Final
Rating
1
Notice of Inspection (NOI) with no recommendations
2
NOI with maintenance recommendations
2
3
Notice of Deficiency (NOD)
4
Dam Safety Order (DSO)
5
Enforcement action required
Comments:
March 11, 2014 Ash Pond Rating Form Page 4 of 6

10. Volume of Facility
Potential
Rating
Rating Description
Final
Rating
1
< 300 acre-feet
2
300 to 1,500 acre-feet
3
1,500 to 3,000 acre-feet
3
4
3,000 to 9,000 acre-feet
5
> 9,000 Acre-feet
Comments:
11. Free Water Content
Potential
Rating
Rating Description
Final
Rating
1
D - heavy natural vegetation and tree growth
2
D - no standing water, sparse tree gowth
3
25% of reservoir area water covered
4
25% to 75% of reservoir area water covered
4
5
100% of reservoir area water covered
Comments:
12. Offsite Drainage Area (DA = Drainage Area, A = Reservoir Area)
Potential
Rating
Rating Description
Final
Rating
1
Drainage area = Reservoir area
2
Drainage area = I to 3 times reservoir area
2
3
Drainage area = 3 to 6 times reservoir area
4
Drainage area = 6 to 10 times reservoir area
5 1
Drainage area = > 10 times reservoir area
Comments:
March 11, 2014 Ash Pond Rating Form Page 5 of 6

Section 3 Final Ratings
Rating Areas
Section 1: Water Quality Considerations_
Final
Rating
1.
2.
3.
4.
5.
Groundwater Standards
Drinking Water Intakes
Total Po ulation Served by Intakes
Classification Downstream and Discharge Points
Distance of Water Supply Wells from the Compliance Boundary
4
S
5
4
4
6.
Population Served by Water Supply Wells
g
SECTION 1 TOTAL
27
Section 2: Dam Safety Considerations
7.
Hazard Classification
4
8.
Proximity to Waters of the State
5
9.
State of Structural Stability & Maintenance
2
10.
Volume of Facility
3
11.
Free Water Content
4
12.
Offsite Drainage Area
2
SECTION 2 TOTAL
20
SECTION 1 + SECTION 2 TOTAL
47
Additional Comments:
March 11, 2014 Ash Pond Rating Form Page 6 of 6

ASH POND RATING FORM
FACILITY NAME: Mayo NPDES PERMIT NO.: NCO038377
REGION: Raleigh COUNTY: Person
Instructions: Rate each facility using the potential rating in the left column and the descriptions in the middle
column. A score of 1 indicates the best case whereas a score of 5 indicates the worst case. For the final rating
column, put the number next to the description that best matches the facility in consideration. If you believe a
different rating is warranted for any category (other than what is listed), then justify alternate rating in the
comment section.
Section 1— Water Quality Considerations
1. Groundwater Standards
Potential
Rating
RatingDri
escption
Final
Rating
1
An exceedance of pH, iron of manganese
2
Exceedance of chloride, nitrate, sulfate, or TDS
3
Exceedance of aluminum, barium, copper, nickel or zinc
4
Exceedance of boron, cadmium, chromium, selenium, or antimony
5
Exceedance of arsenic, lead, merc , or thallium
5
Comments:
Exceedance of thallium.
2. Drinking Water Intakes
Potential
Rating
Rating Description
Final
Rating
0
No intake
2
Greater than 50 miles downstream
2
3
Greater than 20 miles, but less than orequal to 50 miles downstream
4
Greater than 10 miles, but less than orequal to 20 miles downstream
5
Less than orequal to 10 miles downstream
Comments: There are 3 surface water supply intakes greater than 50 miles downstream of the Mayo
Facility. (RRO PWS is unfamiliar with the SWTPs in Virginia.)
March 11, 2014 Ash Pond Rating Form Page 1 of 6

3. Total Population Served by Intakes
Potential
Rating
Rating Description
Final
Rating
1
1 - 500 served
2
501 - 3,300 served
3
3,301 - 10,000 served
4
10,001 - 100,000 served
5
> 100,000 served
5
Comments: Based on normal population served by the surface water supply intakes downstream of the
Mayo Facility. Potential population served through emergency connections not included.
4. Classification Downstream and Discharge Points (use worst case scenario)
Potential
Rating Description
Final
Rating
Rating
1
Class C
1
4
Class B
5
High Quality Waters, Outstanding Resource, Waters, Threatened or
Endangered Species Present
Comments:
*Mayo Reservoir is class WS-V waters. This reservoir outlets into Mayo Creek, a Class C waters.
Mayo Creek courses north into Virginia, flows into Hyco River, and then into the Dan River west of
Clarksville located near, headwaters of Kerr Lake.
5. Distance of Water Supply Wells from the Compliance Boundary (CB)
Potential
Rating
Rating Description
Final
Rating
1
Wells greater than 1/2 mile 2,640 feet of the CB
2
Wells within 2,000 to 2,640 feet of CB
2
3
Wells within 1,500 to 2,000 feet of CB
4
Wells within 1,000 to 1,500 feet of CB
5
Wells within 1,000 feet of CB
Comments: Mayo Reservoir - This survey was completed with google earth with the assumption that
specific structures are utilizing well water. City of Roxboro water serves some residences and
businesses in this area; rooftops identified in GoogleEarth survey within areas of concern were counted
as private wells.
Note: Hydrogeologic considerations -- Use to adjust rating due to unique characteristics that should be
considered such as wells upgradient, cross gradient, etc.
March 11, 2014 Ash Pond Rating Form Page 2 of 6

6. Population Served by Water Supply Wells (referenced above)
Potential
Rating
Rating Description
Final
Rating
1
0 population
2
0 - 25 people
3
26 - 100 people
3
4
101 - 200 people
5
>200 people
Comments
Section 2 — Dam Safety Considerations
7. Hazard Classification
Potential
Rating
Rating Description
Final
Rating
1
Low hazard - Small size
2
Low Hazard - Large size
3
Intermediate Hazard
4
High Hazard - Environmental Concerns `
4
5
High Hazard - Loss of Life
Comments:
8. Proximity to Waters of the State
Potential
Rating
Rating Description
Final
Rating
1
Located within/above a larger ash reservoir with large amount of
available storage
3
Potential coal ash migration constrained by physical barrier
5 1
Directly adjacent
5
Comments:
March 11, 2014 Ash Pond Rating Form Page 3 of 6

9. State of Structural Stability & Maintenance (use historical worst case scenario)
Potential
Rating
Rating Description
Final
Rating
1
Notice of Inspection OI with no recommendations
2
NOI with maintenance recommendations
2
3
Notice of Deficiency OD
4
Dam Safety Order DSO
5
Enforcement action required
Comments:
10. Volume of Facility
Potential
Rating
Rating Description
Final
Rating
1
< 300 acre-feet
2
300 to 1,500 acre-feet.
3
1,500 to 3000 acre-feet
4
3,000 to 9,000 acre-feet ,,;:
4
5
> 9,000 Acre-feet
Comments:
11. Free Water Content
Potential
Rating
Rating Description
Final
Rating
1
D - heavy natural vegetation and tree growth
2
Dry - no standing water, sparse tree growth
3
25% of reservoir area water covered
4
25% to 75% of reservoir area water covered
4
5
100% of reservoir area water covered
Comments:
March 11, 2014 Ash Pond Rating Form Page 4 of 6

12. Offsite Drainage Area (DA = Drainage Area, A = Reservoir Area)
Potential
Rating
Rating Description
Final
Rating
1
Drainage area = Reservoir area
2
Drainage area = 1 to 3 times reservoir area
2
3
Drainage area = 3 to 6 times reservoir area
4
Drainage area = 6 to 10 times reservoir area
5
Drainage area = > 10 times reservoir area
Comments:
Section 3 — Final Ratings
Rating Areas
Final
Rating
Section 1: Water Quality Considerations
1. Groundwater Standards
5
2. Drinking Water Intakes
2
3. Total Population Served by Intakes
5
4. Classification Downstream and Discharge Points
1
5. Distance of Water Su2ply Wells from the Compliance Boundary
2
6. Population Served by Water Supply Wells
3
SECTION 1 TOTAL
18
Section 2: Dam Safety Considerations
7. Hazard Classification
4
8. Proximity to Waters of the State
5
9. State of Structural Stability & Maintenance
10. Volume of Facility
4
11. Free Water Content
4
12. Offsite Drainage Area
2
SECTION 2 TOTAL
21
SECTION 1 + SECTION 2 TOTAL
39
Additional Comments:
March 11, 2014 Ash Pond Rating Form Page 5 of 6

G�

ASH POND RATING FORM
FACILITY NAME: Riverbend NPDES PERMIT NO.: NC0004961
REGION: Mooresville COUNTY: Gaston
Instructions: Rate each facility using the potential rating in the left column and the descriptions in the middle
column. A score of 1 indicates the best case whereas a score of 5 indicates the worst case. For the final rating
column, put the number next to the description that best matches the facility in consideration. If you believe a
different rating is warranted for any category (other than what is listed), then justify alternate rating in the
comment section.
Section 1— Water Quality Considerations
1. Groundwater Standards
Potential
Rating
Rating Description
Final
Rating
1
2
An exceedance of pH, iron or manganese
Exceedance of chloride, nitrate, sulfate, or TDS
1
3
Exceedance of aluminum, barium, copper, nickel or zinc
4
Exceedance of boron, cadmium, chromium, selenium, or antimony
5
Exceedance of arsenic, lead, mercury, or thallium
Comments:
Riverbend's groundwater exceedances are so far limited to pH, iron & manganese
2. Drinking Water Intakes
Potential
Rating
Rating Description
Final
Rating
0
No intake
2
Greater than 50 miles downstream
3
Greater than 20 miles, but less than orequal to 50 miles downstream
4
Greater than 10 miles, but less than orequal to 20 miles downstream
5
1
Less than orequal to 10 miles downstream
S
Comments: Charlotte's intake is —3.5 miles downstream, Gastonia and Mount Holly's intakes are —6.4 miles
downstream all within Mountain Island Lake. Belmont's intake is next, —14 miles downstream in Lake
Wylie.
March 11, 2014 Ash Pond Rating Form Page 1 of 5

3. Total Population Served by Intakes
Potential
Rating
RatingFinal
Description
Rating
1
1 - 500 served
2
501 - 3,300 served
3
3,301 - 10,000 served
4
10,001 - 100,000 served
5
> 100,000 served
5
Comments:
that number.
Charlotte system serves—805,000 or more. Additional intakes mentioned in #2 would increase
4. Classification Downstream and Discharge Points (use worst case scenario)
Rating Potential
Rating Description
Final
Rating
1
Class C
4
Class B
4
5
High Quality Waters, Outstanding Resource Waters, Threatened or
Endangered Species present
Comments:
Surface waters near Riverbend are classified WS-IV, B; CA.
S. Distance of Water Supply Wells from the Compliance Boundary (CB)
Potential
Rating
Rating Description
Final
Rating
g
1
Wells greater than 1/2 mile (2,640 feet) of the CB
1
2
Wells within 2,000 to 2,640 feet of CB
3
Wells within 1,500 to 2,000 feet of CB
4
Wells within 1,000 to 1,500 feet of CB
5
Wells within 1,000 feet of CB
Comments: No formal well survey has been conducted near Riverbend, but the Catawba Riverkeeper
reported a single old private well still in use in the neighborhood to the S of the ponds that is also served by
water lines (and presumably across a hydrologic divide) approximately 3000 feet from the CB. Additionally,
to the E and ESE of the ponds is a small neighborhood served by private wells, the closest of which is
approximately 3500 feet from the CB.
Note: Hydrogeologic considerations -- Use to adjust rating due to unique characteristics that should be
considered such as wells upgradient, cross gradient, etc.
March 11, 2014 Ash Pond Rating Form Page 2 of 5

6. Population Served by Water Supply Wells (referenced above)
Potential
Rating
Rating Description
Final
Rating
1
0 population
1
2
0 - 25 people
3
26 - 100 people
4
101 - 200 people
5
> 200 people
Comments: With no formal well survey and presumably the nearest groundwater users > 0.5 miles away, it
doesn't make a lot of sense to tally well users at those distances and greater in this measure as greater distance
would mean less risk.
Section 2 — Dam Safety Considerations
7. Hazard Classification
Potential
Rating
Rating Description
Final
Rating
1
Low hazard - Small size
2
Low Hazard - Large size
3
Intermediate Hazard
4
Hi h Hazard - Environmental Concerns
4
5
High Hazard - Loss of Life
Comments:
8. Proximity to Waters of the State
Potential
Rating
Rating Description
Final
Rating
1
Located within/above a larger ash reservoir with large amount of
available storage
3
Potential coal ash migration constrained by physical barrier
5
Directly adjacent
5
Comments:
March 11, 2014 Ash Pond Rating Form Page 3 of 5

9. State of Structural Stability & Maintenance (use historical worst case scenario)
Potential
Rating
Rating Description
Final
Rating
1
Notice of Inspection (NOI) with no recommendations
2
NOI with maintenance recommendations
2
3
Notice of Deficient (NOD)
4
Dam Safety Order (DSO)
5
Enforcement action required
Comments:
10. Volume of Facility
Potential
Rating
Rating Description
Final
Rating
1
< 300 acre-feet
2
300 to 1,500 acre-feet
2
3
1,500 to 3,000 acre-feet
4
3,000 to 9,000 acre-feet
5
> 9,000 Acre-feet
Comments:
11. Free Water Content
Potential
Rating
Rating Description
Final
Rating
1
D - heavy natural vegetation and tree growth
2
Dry - no standing water, sparse tree growth
3
25% of reservoir area water covered
4
25% to 75% of reservoir area water covered
4
5
100% of reservoir area water covered
Comments:
March 11, 2014 Ash Pond Rating Form Page 4 of 5

12. Offsite DrainageArea (DA = Drainage Area, A = Reservoir Area)
Potential
Rating
Rating Description
Final
Rating
1
Drainage area = Reservoir area
2
Drainage area = 1 to 3 times reservoir area
2
3
Drainage area = 3 to 6 times reservoir area
4
Drainage area = 6 to 10 times reservoir area
5
Drainage area = > 10 times reservoir area
Comments:
Section 3 — Final Ratings
Rating Areas
Final
Rating
Section 1: Water Quality Considerations
1.
Groundwater Standards
1
2.
Drinking Water Intakes
5
3.
Total Population Served by Intakes
5
4.
Classification Downstream and Discharge Points
4
5.
Distance of Water Supply Wells from the Compliance Boundary
1
6.
Population Served by Water Supply Wells
1
SECTION I TOTAL
17
Section 2: Darn Safety Considerations
7.
Hazard Classification
4
8.
Proximity to Waters of the State
9.
State of Structural Stability & Maintenance
10.
Volume of Facility
2
11.
Free Water Content
4
12.
Offsite Drainage Area
2
SECTION 2 TOTAL
19
SECTION 1 + SECTION 2 TOTAL
36
Additional Comments:
March 11, 2014 Ash Pond Rating Form Page 5 of 5

FACILITY NAME: Roxboro
REGION: Raleigh
ASH POND RATING FORM
NPDES PERMIT NO.: NCO003425
COUNTY: Person
Instructions: Rate each facility using the potential rating in the left column and the descriptions in the middle
column. A score of 1 indicates the best case whereas a score of 5 indicates the worst case. For the final rating
column, put the number next to the description that best matches the facility in consideration. If you believe a
different rating is warranted for any category (other than what is listed), then justify alternate rating in the
comment section.
Section 1— Water Quality Considerations
1. Groundwater Standards
Potential
Rating
Rating Description
Final
Rating
1
An exceedance of pH, iron or manganese
2
Exceedance of chloride, nitrate, sulfate, or TDS
3
Exceedance of aluminum, barium, copper, nickel or zinc
4
Exceedance of boron, cadmium, chromium; selenium, or antimony
4
5
Exceedance of arsenic,�lead, mercury, or thallium
Comments:
Exceedance of cadmium and chromium.
2. Drinking Water Intakes
Potential
Rating
Rating Description
Final
Rating
0
No intake
2
Greater than 50 miles downstream
2
3
Greater than 20 miles, but less than orequal to 50 miles downstream
4
Greater than 10 miles, but less than orequal to 20 miles downstream
5
Less than orequal to 10 miles downstream
Comments: There are 3 surface water supply intakes greater than 50 miles downstream of the Roxboro
Facility. (RRO PWS is unfamiliar with the SWTPs in Virginia.)
March 11, 2014 Ash Pond Rating Form Page I of 6

3. Total Population Served by Intakes
Potential
Rating
Rating Description
Final
Rating
1
1 - 500 served
2
501 - 3,300 served
3
3,301 - 10,000 served
4
10,001 - 100,000 served
5
> 100,000 served
5
Comments: Based on normal population served by the surface water supply intakes downstream of the
Roxboro Facility. Potential population served through emergency connections not included.
4. Classification Downstream and Discharge Points (use worst case scenario)
Potential
Rating Description
Final
Rating
Rating
1
Class C
4
Class B
4 (WS-V, B)
5
High Quality Waters, Outstanding Resource Waters, Threatened or
Endangered Species present
Comments:
*Hyco Reservoir is class WS-V, B waters. This reservoir outlets into Hyco River, a Class C waters.
The Hyco River courses north into Virginia and then flows into the Dan River west of Clarksville
(located near headwaters of Kerr Lake).
5. Distance of Water Supply Wells from the Compliance Boundary (CB)
Potential
Rating
Rating Description
Final
Rating
1
Wells greater than 1/2 mile 2,640 feet of the CB
2
Wells within 2,000 to 2,640 feet of CB
2
3
Wells within 1,500 to 2,000 feet of CB
4
Wells within 1,000 to 1,500 feet of CB
5
Wells within 1,000 feet of CB
Comments:
No public or private water supply wells within Y1 mile of the compliance boundary.
Note: Hydrogeologic considerations -- Use to adjust rating due to unique characteristics that should be
considered such as wells upgradient, cross gradient, etc.
March 11, 2014 Ash Pond Rating Form Page 2 of 6

6. Population Served by Water Supply Wells (referenced above)
Potential
Rating
Rating Description
Final
Rating
1
0 population
2
0 - 25 people
3
26 - 100 people
4
101 - 200 people
5
>200 eo le
5
Comments: : Woodland Elementary School has a service population of 225 located approx. 0.5 miles
from edge of possible coal ash. 89 employees served by PWS well at gypsum plant as of sanitary survey
(3/31/14), another approximately 50 people served by private wells, based on a GoogleEarth imagery
survey counting potential residences.
Section 2 — Dam Safety Considerations
7. Hazard Classification
Potential
Rating
Rating Description
Final
Rating
1
Low hazard - Small size
2
Low Hazard - Large size
3
Intermediate Hazard
4
High Hazard - Environmental Concerns
4
5
High Hazard - Loss of Life
Comments:
8. Proximity to Waters of the State
Potential
Rating
Rating Description
Final
Rating
1
Located within/above a larger ash reservoir with large amount of
available storage
3
Potential coal ash migration constrained by physical barrier
5
Directly adjacent
5
Comments:
March 11, 2014 Ash Pond Rating Form Page 3 of 6

9. State of Structural Stability & Maintenance (use historical worst case scenario)
Potential
Rating
Rating Description
Final
Rating
1
Notice of Inspection OI with no recommendations
2
NOI with maintenance recommendations
3
Notice of Deficiency OD
3
4
Dam Safety Order DSO
5
Enforcement action required
Comments:
10. Volume of Facility
Potential
Rating
Rating Description
Final
Rating
1
< 300 acre-feet
2
300 to 1,500 acre-feet
3
1,500 to 3,000 acre-feet
4
3,000'to 9,000 acre-feet
4
5
>'9,000 Acre-feet
Comments:
11. Free Water Content
Potential
Rating
Rating Description
Final
Rating
1
D - heavy natural vegetation and tree growth
2
D - no standing water, sparse tree growth
3
25% of reservoir area water covered
4
25% to 75% of reservoir area water covered
4
5
100% of reservoir area water covered
Comments:
March 11, 2014 Ash Pond Rating Form Page 4 of 6

12. Offsite Drainage Area (DA = Drainage Area, A = Reservoir Area)
Potential
Rating
Rating Description
Final
Rating
1
Drainage area = Reservoir area
2
Drainage area = 1 to 3 times reservoir area
3
Drainage area = 3 to 6 times reservoir area
3
4
Drainage area = 6 to 10 times reservoir area
5
Drainage area = > 10 times reservoir area
Comments:
Section 3 — Final Ratings
Rating Areas
Final
Rating
Section 1: Water Quality Considerations
1.
Groundwater Standards
4
2.
Drinking Water Intakes
2
3.
Total Population Served by Intakes
_
5
4.
Classification Downstream and Discharge Points
_
4
5.
Distance of Water Supply Wells from the Compliance Boundary
2
6.
Population Served by Water Supply Wells
5
SECTION 1 TOTAL
22
Section 2: Dam Safe Considerations
7.
Hazard Classification
4
8.
Proximity to Waters of the State
5
9.
State of Structural Stability & Maintenance
3
10.
Volume of Facility
4
11.
Free Water Content
4
12.
Offsite Draina,-e Area
3
SECTION 2.TOTAL
23
SECTION 1 + SECTION 2 TOTAL
Additional Comments:.
March 11, 2014 Ash Pond Rating )'Form Page 5 of 6

I �J z��si ii �• �+J
March 11, 2014 Ash Pond Rating Form Page 6 of 6

ASH POND RATING FORM
FACILITY NAME: Sutton
REGION: Wilmington
NPDES PERMIT NO.: NC0001422
COUNTY: New Hanover
Instructions: Rate each facility using the potential rating in the left column and the descriptions in the middle
column. A score of 1 indicates the best case whereas a score of 5 indicates the worst case. For the final rating
column, put the number next to the description that best matches the facility in consideration. If you believe a
different rating is warranted for any category (other than what is listed), then justify alternate rating in the
comment section.
Section 1— Water Quality Considerations
1. Groundwater Standards
Potential
Rating
Rating Description
Final
Rating
1
An exceedance of pH, iron or manganese
2
Exceedance of chloride, nitrate, sulfate, or TDS
3
Exceedance of aluminum, barium, copper, nickel or zinc
4
Exceedance of boron, cadmium, chromium, selenium, or antimony
5
Exceedance of arsenic, lead, mercury, or thallium
5
Comments: Exceedance of arsenic, lead, and thallium.
2. Drinking Water Intakes
Potential
Rating
Rating Description
Final
Rating
1
No intake
0
2
Greater than 50 miles downstream
3
Greater than 20 miles, but less than orequal to 50 miles downstream
4
Greater than 10 miles, but less than orequal to 20 miles downstream
5
Less than orequal to 10 miles downstream
Comments: No existing intake. Back up water supply designated at Toomer's Creek (Class WS IV)
approximately 2.8 miles downstream.
March 11, 2014 Ash Pond Rating Form Page 1 of 5

3. Total Population Served by Intakes
Potential
Rating
Rating Description
Final
Rating
1
1 - 500 served
0
2
501 - 3,300 served
3
3,301 - 10,000 served
4
10,001 - 100,000 served
5 1
> 100,000 served
Comments: See comment above.
4. Classification Downstream and Discharge Points (use worst case scenario)
Potential
Rating
Rating Description
Final
Rating
1
Class C
1
4
Class B
5
High Quality Waters, Outstanding Resource Waters, Threatened or
Endangered Species present
Comments:
Classified CSw. WS IV at Toomer's Creek located approximately 2.8 miles downstream.
5. Distance of Water Supply Wells from the Compliance Boundary (CB)
Potential
Rating
Rating Description
Final
Rating
1
Wells greater than 1/2 mile 2,640 feet of the CB
2
Wells within 2,000 to 2,640 feet of CB
2
3
Wells within 1,500 to 2,000 feet of CB
4
Wells within 1,000 to 1,500 feet of CB
5
Wells within 1,000 feet of CB
Comments: Cape Fear Public Utility Authority has two wells located approximately 2,200 feet from the
compliance boundary and approximately 2,700 feet from the edge of the ash ponds.
Note: Hydrogeologic considerations -- Use to adjust rating due to unique characteristics that should be
considered such as wells upgradient, cross gradient, etc.
March 11, 2014 Ash Pond Rating Form Page 2 of 5

6. Population Served by Water Supply Wells (referenced above)
Potential
Rating
Rating Description
Final
Rating
1
0 population
2
0 - 25 people
3
26 - 100 people
4
101 - 200 people
5
> 200 people
5
Comments: The water supply wells listed above serve a population of approximately 700.
Section 2 — Dam Safety Considerations
7. Hazard Classification
Potential
Rating
Rating Description
Final
Rating
1
Low hazard - Small size
1
2
Low Hazard - Large size
3
Intermediate Hazard
4
High Hazard - Environmental Concerns
5
Hi h Hazard - Loss of Life
Comments:
8. Proximity to Waters of the State
Potential
Rating
Rating Description
Final
Rating
1
Located within/above a larger ash reservoir with large amount of
available storage
3
Potential coal ash migration constrained by physical barrier
3
5
Directly adjacent
Comments:
March 11, 2014 Ash Pond Rating Form Page 3 of 5

9. State of Structural Stability & Maintenance (use historical worst case scenario)
Potential
Rating
Rating Description
Final
Rating
1
Notice of Inspection OI with no recommendations
2
NOI with maintenance recommendations
2
3
Notice of Deficient OD
4
Dam Safety Order DSO
5
Enforcement action required
Comments:
10. Volume of Facility
Potential
Rating
Rating Description
Final
Rating
1
< 300 acre-feet
2
300 to 1,500 acre-feet
2
3
1,500 to 3,000 acre-feet
4
3,000 to 9,000 acre-feet
5
> 9,000 Acre-feet
Comments:
11. Free Water Content
Potential
Rating
Rating Description
Final
Rating
1
D - heavy natural vegetation and tree growth
2
D - no standing water, sparse tree growth
3
25% of reservoir area water covered
3
4
25% to 75% of reservoir area water covered
5
100% of reservoir area water covered
Comments:
March 11, 2014 Ash Pond Rating Form Page 4 of 5

12. Offsite Drainage Area (DA = Drainage Area, A = Reservoir Area)
Potential
Rating
Rating Description
Final
Rating
1
Drainage area = Reservoir area
1
2
Drainage area = 1 to 3 times reservoir area
3
Drainage area = 3 to 6 times reservoir area
4
Drainage area = 6 to 10 times reservoir area
5
Drainage area = > 10 times reservoir area
Comments:
Section 3 — Final Ratings
Rating Areas
Final
Rating
Section 1: Water Quality Considerations
1.
Groundwater Standards
5
2.
Drinking Water Intakes
[)
3.
Total Population Served by Intakes
0
4.
Classification Downstream and Discharge Points
1
5.
Distance of Water Supply Wells from the Compliance Boundary
2
6.
Population Served by Water Supply Wells
5
SECTION 1 TOTAL
13
Section 2: Dam Safety Considerations
7.
Hazard Classification
1
8.
Proximity to Waters of the State
3
9.
State of Structural Stability & Maintenance
2
10.
Volume of Facility
2
11.
Free Water Content
3
12.
Offsite Drainage Area
1
SECTION 2 TOTAL
12
SECTION 1 + SECTION 2 TOTAL
25
Additional Comments:
March 11, 2014 Ash Pond Rating Form Page 5 of 5

ASH POND RATING FORM
FACILITY NAME: Weatherspoon
REGION: Fayetteville
NPDES PERMIT NO.: NC0005363
COUNTY: Robeson
Instructions: Rate each facility using the potential rating in the left column and the descriptions in the middle
column. A score of 1 indicates the best case whereas a score of 5 indicates the worst case. For the final rating
column, put the number next to the description that best matches the facility in consideration. If you believe a
different rating is warranted for any category (other than what is listed), then justify alternate rating in the
comment section.
Section 1— Water Quality Considerations
1. Groundwater Standards
Potential
Rating
Rating Description
Final
Rating
1
An exceedance of pH, iron or manganese
2
Exceedance of chloride, nitrate, sulfate, or TDS
3
Exceedance of aluminum, barium, copper, nickel or zinc
4
Exceedance of boron, cadmium, chromium, selenium, or antimony
5
Exceedance of arsenic, lead, mercury, or thallium
5
Comments: Exceedance of thallium.
2. Drinking Water Intakes
Potential
Rating
Rating Description
Final
Rating
0
No intake
0
2
Greater than 50 miles downstream
3
Greater than 20 miles, but less than orequal to 50 miles downstream
4
Greater than 10 miles, but less than orequal to 20 miles downstream
5
Less than orequal to 10 miles downstream
Comments:
March 11, 2014 Ash Pond Rating Form Page 1 of 5

3. Total Population Served by Intakes
Potential
Rating
Rating Description
Final
Rating
1
1 - 500 served
0
2
501 - 3,300 served
3
3,301 - 10,000 served
4
10,001 - 100,000 served
5
> 100,000 served
Comments:
4. Classification Downstream and Discharge Points (use worst case scenario)
Potential
Rating
Rating Description
Final
Rating
1
Class C
1
4
Class B
5
High Quality Waters, Outstanding Resource Waters, Threatened or
Endangered Species present
Comments:
5. Distance of Water Supply Wells from the Compliance Boundary (CB)
Potential
Rating
Rating Description
Final
Rating
1
Wells greater than 1/2 mile 2,640 feet of the CB
2
Wells within 2,000 to 2,640 feet of CB
3
Wells within 1,500 to 2,000 feet of CB
4
Wells within 1,000 to 1,500 feet of CB
5
Wells within 1,000 feet of CB
5
Comments:
Note: Hydrogeologic considerations -- Use to adjust rating due to unique characteristics that should be
considered such as wells upgradient, cross gradient, etc.
March 11, 2014 Ash Pond Rating Form Page 2 of 5

6. Population Served by Water Supply Wells (referenced above)
Potential
Rating
Rating Description
Final
Rating
1
0 population
2
0 - 25 people
3
26 - 100 people
4
101 - 200 people
4
5
> 200 eo le
Comments:
Section 2 — Dam Safety Considerations
7. Hazard Classification
Potential
Rating
Rating Description
Final
Rating
1
Low hazard - Small size
2
Low Hazard - Large size
3
Intermediate Hazard
3
4
1 High Hazard - Environmental Concerns
5
High Hazard - Loss of Life
Comments:
8. Proximity to Waters of the State
Potential
Rating
Rating Description
Final
Rating
1
Located within/above a larger ash reservoir with large amount of
available storage
3
Potential coal ash migration constrained by physical barrier
3
5
Directly adjacent
Comments:
March 11, 2014 Ash Pond Rating Form Page 3 of 5

9. State of Structural Stability & Maintenance (use historical worst case scenario)
Potential
Rating
Rating Description
Final
Rating
1
Notice of Inspection OI with no recommendations
2
NOI with maintenance recommendations
2
3
Notice of Deficiency OD
4
Dam Safety Order DSO
5
Enforcement action required
Comments:
10. Volume of Facility
Potential
Rating
Rating Description
Final
Rating
1
< 300 acre-feet
2
300 to 1,500 acre-feet
2
3
1,500 to 3,000 acre-feet
4
3,000 to 9,000 acre-feet
5
> 9,000 Acre-feet
Comments:
11. Free Water Content
Potential
Rating
Rating Description
Final
Rating
1
D - heavy natural vegetation and tree growth
2
D - no standing water, sparse tree growth
3
25% of reservoir area water covered
3
4
25% to 75% of reservoir area water covered
5
100% of reservoir area water covered
Comments:
March 11, 2014 Ash Pond Rating Form Page 4 of 5

12. Offsite Drainage Area (DA = Drainage Area, A = Reservoir Area)
Potential
Rating
Rating Description
Final
Rating
1
Drainage area = Reservoir area
1
2
Drainage area = 1 to 3 times reservoir area
3
Drainage area = 3 to 6 times reservoir area
4
Drainage area = 6 to 10 times reservoir area
5
Drainage area = > 10 times reservoir area
Comments:
Section 3 — Final Ratings
Rating Areas
Final
Rating
Section 1: Water Quali Considerations
1. Groundwater Standards
5
2. Drinking Water Intakes
0
3. Total Population Served by Intakes
0
4. Classification Downstream and Discharge. Points
1
5. Distance of Water Supply Wells from the Compliance Boundary
5
6. Population Served by Water Supply Wells
4
SECTION 1 TOTAL
15
Section 2: Dam Safety Considerations
7. Hazard Classification
3
8. Proximi to Waters of the State
3
9. State of Structural Stability & Maintenance
2
10. Volume of Facility
2
11. Free Water Content
3
12. Offsite Drainage Area
1
SECTION 2 TOTAL
14
SECTION 1 + SECTION 2 TOTAL
29
Additional Comments:
March 11, 2014 Ash Pond Rating Norm page 5 of 5

Attachment 15
Risk Classification Chart
11/30/15

BEGBATES
= NCDENR0188619
ENDBATES
= NCDENR0188624
BEGATTACH
NCDENR0188619
ENDATTACH
NCDENR0188624
CUSTODIAN
Smith, Eric
FILENAME
Draft of classification chart for coal ash facilities.pdf
DATECREATED
= 11/30/2015
DATELASTMOD
= 11/30/2015
MDSHASH
7762A494558A34EEAA2FDF1 F2593A267
DOCEXT
PDF
ATTACHCNT
0
RELATIVITIMA
6
TEXTFILE
TEXT\TEXT001\NCDENR0188619.txt

Note that the rAfat
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27
We.lj to 'esolve the
Sur lion about how to PAO:,! UTIFR)undmvnts appear to have jael!;l Stlk!d On 1.0p: Of fiv$l W 1RCOMI G:rdE.,r
m na I vf.�# Vaini%L wz3ys, '11?1'11r"�I.��rl�' tll"� j�!J I b;' n f�xApnnts we O'l Lop cS
taN, fachtics :f! Ilse 1 00
ye8�r flood plain and what was surfm','e ww:us', 2itream orlu`..tNr: an vm of ;he as reserwir. For the ash
burie'ql aI:Feaal ssg el E, the ekviAwn of die! Felii, wl ream bed thalE covrscs orougl i

April 16, 2016
Public Comments Presented at the DEQ Public Hearing on Rankings for Coal Ash Clean -Up in NC
H. F. Lee Plant
March 10, 2016
Wayne Community College
Goldsboro, NC
Presented and committed by Janet Smith.
Please note: I am submitting comments of what I said at the meeting, like a transcript, in first
person. As I spoke I used the words 'you' and 'y'all', sometimes referring to DEQ and
sometimes referring to affected residents in the audience. I will make a distinction in these
written comments, as to whom I am referring, if it might not be obvious.
I had not planned to speak at the Public Hearing. I planned to attend, but not to speak. I don't
live in Goldsboro. I don't live in Wayne County, but I grew up on the Neuse River, and all rivers
are precious.
DEQ gave the Lee Plant a Risk Classification of INTERMEDIATE. I started reading the Risk
Classifications for the H. F. Lee Complex in preparation for attending this Public Hearing. It's
fifteen pages long and required careful study to understand. I don't know about y'all (residents
in the audience); you may have read and understand this already. But there was a lot of
technical terminology and I had to look up a lot of terms to know and understand them.
I'd like to break it down for you (audience) in case you haven't read it or didn't understand it.
Basically at the Lee Plant you have the following:
• one active pond
• one polishing pond
• three inactive ponds
Right off the bat, the first question that comes to mind is why is there an active pond if the
plant is inactive?
Then, DEQ looked at three Key Factors about those five ponds:
1. Groundwater Key Factor
2. Surface Water Key Factor
3. Dam Safety Key Factor

• The Groundwater factor was ranked LOW, based on the information DEQ has, that there are
no downgradient receptors located 1,500 feet downgradient of the impoundment
compliance boundary. What they are saying is there are no contaminated wells
downstream of the coal ash ponds. (We all know that is not true.)
• The Surface Water factor was ranked HIGH, based on the fact that the ponds are in a 100-
year floodplain. With Hurricane Floyd in 1999, the ponds and all the ground surface at the
Lee Plant were underwater.
• The Dam Safety Water factor ranked the plant HIGH, before repairs are made, and LOW,
once the repairs are made. Since it appears these repairs have not been made, the ranking
would be HIGH. One of the repairs refers to the installation of a new spillway. That doesn't
sound good. Where would the spill go?
That is 2 Highs to 1 Low, so the overall ranking should be HIGH.
You (DEQ) said you would only consider technical facts presented at these public hearings.
Well, these are technical facts. These are your facts!
The next section of the report is labeled the Source Characterization Summary. It lists
constituents (potentially toxic chemicals) that exist in one or more of the:
• Active Basin
• Lay of the Land Area
• Inactive Basins
Note: The Active Basin, Lay of the Land Area, and Inactive Basins comprise the Ash
Management Area.
This part was unnecessarily complicated but, with enough careful scrutiny, the data can be
organized into a much more understandable format.
Below is a table of the constituents (potentially toxic chemicals) found in the Active Basin, Lay
of the Land Area and Inactive Basins. They were measured based on the Recommended Safe
Levels standard. The entire Ash Management Area exceeds the Recommended Safe Levels for
numerous chemicals, known to be toxic.

Recommended Safe Levels
Active Basin
Lay of the Land
Inactive Basins
Aluminum
Exceeded
Exceeded
Exceeded
Antimony
Exceeded
Exceeded
Exceeded
Arsenic
Exceeded
Exceeded
Exceeded
Barium
Exceeded
Exceeded
Exceeded
Beryllium
Exceeded
Exceeded
Exceeded
Cobalt
Exceeded
Exceeded
Exceeded
Cooper
Exceeded
Exceeded
Iron
Exceeded
Exceeded
Exceeded
Lead
Exceeded
Exceeded
Exceeded
Manganese
Exceeded
Mercury
Exceeded
Exceeded
Selenium
Exceeded
Exceeded
Exceeded
Thallium
Exceeded
Exceeded
Exceeded
Vanadium
Exceeded
Exceeded
Exceeded
The next 10 pages of the report are labeled Groundwater Supporting Factors and Other
Considerations. This appears to be the detailed categories and factors considered in evaluating
and determining the ratings or risk. Of the many numerous factors, it includes factors such as:
• How close the contamination is to North Carolina water bodies
• Whether the contaminated groundwater is being released into the Neuse River
• How close is the contamination to the water table
• What is the potential loss of life due to a structural breach in the dam
• How safe is the dam
I examined each factor and each rating. But, before considering any of the others, the report
ranks the Lee plant as High Risk, based simply on the Total Amount of Coal Ash at the plant.
In going through the 10 pages, I made a tick mark as to whether, based on the factor, the plant
was ranked Low, Intermediate, or High Risk.
Of the 22 factors...
• Seven were ranked as Low risk
• Eight were ranked as Intermediate risk, and
• Seven were ranked as High risk

I guess since eight is greater than seven is how you (DEQ) ranked the plant as Intermediate. But
having any ranking as High is High Risk. High Risk trumps all. Having Low or Intermediate risks
do not mitigate having High risks.
In terms of the safety of the dam, and the potential loss of life with a breach, the Dam Safety
Risk Classification is rated HIGH RISK, again before repairs are made and low risk once repairs
are made. So it's currently HIGH. And the potential loss of life was ranked HIGH RISK due to a
potential breach.
That clearly puts the Risk Classification at the Lee Plant as HIGH RISK.
I hope this helps you (the audience) understand what DEQ tested for and the results of those
tests. And I hope DEQ lives up to its commitment, which was stated in very strong language in
its press release about the meetings and on its website.
Curiously, Duke Energy completely changed its website during the Public Hearing process.
Documentation that was available at the beginning of the Public Hearing is no longer available.
On your (DEQ) original website, you (DEQ) stated that "Public participation is a critically
important part of the classification process. The information gathered through the public
participation process will help inform the department's final proposed classifications."
On the new website, it states "The public is encouraged to provide feedback on the draft
proposed classifications. Comments will be considered in determining final classification."
.... Either way, I hope that's true.

Re: Elected Leaders for Coal Ash Cleanup
H.F. Lee Steam Station
We, the undersigned elected officials, are concerned about the danger coal ash presents for our communities.
Coal ash is currently found in leaking, unlined pits across the state and contains a toxic slurry of heavy metals
that threaten nearby communities. We ask that state government leaders and state regulators take
appropriate action to require the removal of coal ash out of all unlined pits and into safer lined storage away
from our waterways. Please ensure that coal ash ponds and landfills do not put at risk the safety, health, and
economic well-being of downstream communities, receiving communities, and communities along
transportation routes.
Signed,
Joe Scott, Mt. Olive City Council Member
Ray Thompson, Mt. Olive City Council Member
Thomas P. Uzzell, Wayne County Soil and Water Conservation District Vice Chair

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

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

POPULATION
Selews
Allen Asheville Creek
30K
25K
20K
10K
5K
OK
.
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E
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Site Name ( Analysis Level
Suck Cape Fear Cliffs ide Ilan River Lee Marshall Mayo Riverbend Roxboro Sutton Weathers..
1000
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700
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300
200
100
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E E E E E E E E E E E E E E E E E E
Y Y Y s Y Y Y Y Y Y Y Y Y Y Y Y Y Y

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

LEE POWER STATION
DEMOGRAPHIC ANALYSIS
POPULATION Population Count Population Density
(people per sq. mi.)
Site Name 1km 3km 5km 1km 3km 5km
Lee 362 4,155 11,138 173 215 62
RACE/ % Non -white
% Black % Latino
ETHNICITY
Site Name
1km 3km 5km
km 3km 5km
1km 3km 5km
Lee 45.0% 27.2% 27.7%
[38.9%21.6% 19.1% 4.3% 3.7% 7.5%
INCOME Median Income Estimate
Site Name
1km 3km
5km
Lee
$ 37,929 $ 44,019
$ 45,132
CUMULATIVE IMPACTS
SITE NAME REFERENCE COUNTIES) ONE OR MORE TRI % OF COUNT(IES)' % OF COUNT(IES)' TRI
(*ACTIVE COAL SITES W/IN 5KM TRI SITES W/IN ONSITE RELEASES
PLANT) BUFFER 5KM BUFFER W/IN 5KM BUFFER
Lee Wayne Y 14% 6%
Closest City: Goldsboro
Plant Status: Closed
Coal Ash Pond Acreage: 516
DEQ Site Prioritization: Intermediate

ENVIRONMENTAL JUSTICE INDEX — LEE
Indicator
Race/Ethnicity
Income
C
Reference
Census
Region
State
County
Census Tract
State
County
Tract
Demographic Information
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x x
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7
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163 141 15
37,929
1 km
x
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44,019
3 km
x
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11,138
3,082 2,128 837
45,132
5 km
MEAN
4.00

North Carolina League of Slow
CONSERVATION VOTERS
PO Box 12671
Raleigh, NC 27605
www.ncicv.org 1 919.839.0006
To: Debra Watts, NC Division of Water Resources, Groundwater Protection
Section, NC Department of Environmental Quality
From: Members of the NC League of Conservation Voters
Date: April 18, 2016
Re: Reclassify H.F. Lee Power Station as "high risk"
Dear Ms. Watts:
We are writing to ask the NC Department of Environmental Quality to protect North Carolina's
clean water and communities from the dangers posed by arsenic, chromium and other pollutants
by re-classifying the H.F. Lee Power Station as "high risk."
Chromium, manganese, and other dangerous pollutants have been detected at levels well above
standards in groundwater near the coal ash pits. Chromium is a particularly dangerous
carcinogen, while manganese is associated with nervous system and muscle problems.
We simply cannot allow any additional delay in moving the dangerous coal ash from its current
leaking, unlined ponds at the Lee Power Station. Nearly 128,000 people rely on drinking water
intakes downstream — and they are relying on you to act now. Please reclassify the Lee Station as
"high risk."
Signed,
64 NCLCV members
Name
Zip Code
Katie Todd
27703
Carrie Clark
27604
jeff mcdermott
27607
Nelida Rivas
27616-7867
Cody Cavenaugh
28466
eileen juric
27605

Tom Winstead
27606
James Bengel
27591
Victor Lowell
27614
William Larson
27534
Lynne C.
27529
Jasmina Bricic
28504
Eloise Grathwohl
27514
Peter Hickey
28590
Travis Holland
28385
Deborah Campfield
27529
Jamie Heath
27834
Jay Newhard
27858
Jean White
27604
John Hinnant
27893
Connie Headrick
27896
Diane Foster
27529
Deborah Parker
27520
Michael Eisenberg
27613
Tish Gay
27597
Richard Hammer
27613
Rebecca Burmester
27612
Mary Loughlin
28716-2613
Henrietta Jenrette
27613
Ann Campbell
27614
Celeste Winterberger
27616
James Womble
27607
Shoshana Serxner-Merchant
27607
Cindy Davenport
27614
William Dawson
27616
Erin Hebbe
28803
Dale Bridgers
27534
Elizabeth McWhorter
27278
Bradford Crumb
28590-8688
Michael Pope
27502
Paul Taylor
27604
Steven Baldwin
27712
Carson Monteith
27609

Sara Felsen
27606
Janet Smith
27858
Kristine Stochaj
27871
Richard Arnow
27803
Russell James
28405
Maggie Hurst
28573
Laura Smith
27604
Donna Etheridge
27607
Ter Wils
27530
Pam Robbins
27604
D Brown
27624
Howard Lazoff
27591
robert hartwig
27607
Ercel Dotson
27523-5611
virginia clute
27527
Darlene Hamilton
27604
Lynne Carmichael
27803
Jim Amerault
27597-7312
Erika Moss
27601
Matt Revels
27604
Fred Exit
27611

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

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

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

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

North Carolina
Doug Franklin, Hayesville
Sally MacMillan, Arden
Jody McClung, Weaverville
Greg Hamby, Kitty Hawk
Doris Whitfield, Raleigh
David Loven, Chapel Hill
Chris Berg, Flat Rock
Connie Leeper, Durham
Frank Bennett, Raleigh
Marcia Bennett, Raleigh
Michael Morgan, Swannanoa
M. Hazeltine, Sunset Beach
Janet Smith, Greenville
Jennifer Weiss, Raleigh
Beth Ullmer, Asheville
Margaret Horner, Leland
Steve Miller, Asheville
Jeannie McKinney, Durham
Jane Laping, Asheville
Ellen Chelmis, Asheville
Sarah Gilliam, Asheville
Sarah Davis, Raleigh
Elizabeth Bonzo-Savage, Madison
Mamie Colburn, Asheville
Jackson Leonard, Greensboro
Maxwell DeHoll, Asheville
Graham March, Asheville
Victoria Carlisle, Asheville
Rhonda Bolton, Hendersonville
Evan Willeford, Asheville
Shelby Sopina, Raleigh
Miles Neyen, Belmont
Molly Turner, Asheville
Banna Weldense, Asheville
Kaia Rubin, Asheville
Anna Emslie, Asheville
Janet Smith, Greenville
Patricia Hedrick, Charlotte
Adam Reaves, Asheville
Alan Spencer, Waynesville
Nancy Hitchcock, Hendersonville
John Coyle, Leland
cleanenergy.org
Clean Energy w
Cathy Williams, Hayesville
Gary Clontz, Clyde
Doug Wingeier, Asheville
Ann Karson, Candler
Frank Contreras, Asheville
Ann Kieffer, Asheville
Elizabeth Adams, Cary
Tennessee
Marty Menane, Knoxville
Lorraine Barker, Nashville
Nicholas Stamper, Philadelphia
Florida
Britany Perry, Longwood
Kimber Strawbridge, Jacksonville
Janice Hallman, Clearwater Beach
Sean McLaughlin, Clermont