NC0004979_C. Andrews - Final Allen Expert Report _20160630

Expert Report of
Charles B. Andrews
Allen Steam Station
Belmont, North Carolina
S.S. PAPADOPULOS & ASSOCIATES, INC.
Environmental & Water -Resource Consultants
June 30, 2016
7944 Wisconsin Avenue, Bethesda, Maryland 20814-3620 9 [phone]

Expert Report of
Charles B. Andrews
Allen Steam Station
Belmont, North Carolina
Prepared for:
Duke Energy Carolinas, LLC
Prepared by:
Charles B. Andrews, PhD
S.S. PAPADOPULOS & ASSOCIATES, INC.
Environmental & Water -Resource Consultants
June 30, 2016
7944 Wisconsin Avenue, Bethesda, Maryland 20814-3620 9 [phone]

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Table of Contents
Page
Listof Tables
.................................................................................................................................. ii
Listof Figures................................................................................................................................. ii
Listof Appendices.......................................................................................................................... ii
Section1
Introduction................................................................................................................ 1
Section2
Background................................................................................................................ 2
Section 3
Groundwater Contamination from Ash Basins.......................................................... 4
Section 4
Remedial Actions for Groundwater...........................................................................
7
Section5
Opinions..................................................................................................................... 9
Section6
Bases for Opinions...................................................................................................
10
AvailableData..........................................................................................................
10
Boronas a Tracer.....................................................................................................
10
Migration of Coal Ash -Related Constituents...........................................................
11
Groundwater does not flow under the Catawba River .............................................
12
PrivateWells............................................................................................................
13
Background Concentrations.....................................................................................
13
GroundwaterModel.................................................................................................
14
Monitored Natural Attenuation................................................................................
15
Cap -in -Place Remedy..............................................................................................
15
Section 7
Rebuttal of Plaintiff's Experts.................................................................................
16
PhilipB. Bedient, Ph.D............................................................................................
16
RobertParette, Ph.D.................................................................................................
17
DouglasJ. Cosler, Ph.D...........................................................................................
17
Section8
References................................................................................................................
21
Tables
Figures
Appendices
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List of Tables
Table 1 Monitoring Wells Identified in Cosler (2016) with Exceedances of Groundwater
Standards
List of Figures
Figure 1 Boron Concentrations in Ash Porewater
Figure 2 Boron Concentrations in Shallow Groundwater
Figure 3 Boron Concentrations in Deep Groundwater
Figure 4 Boron Concentrations in Bedrock Groundwater
List of Appendices
Appendix A Curriculum Vitae of Charles B. Andrews and Rate of Compensation
ii

REPORT

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Section 1
Introduction
I was retained by Duke Energy Carolinas, LLC (Duke) to evaluate the nature, extent, and
appropriate remedial actions for groundwater contamination from ash basins at the Allen Steam
Station, Belmont, North Carolina. The work was completed to assist in litigation regarding alleged
violations of state laws related to discharges to groundwater and surface water systems.
My expertise includes the evaluation of the origin, distribution, fate, and transport of
contaminants in the environment and selection of appropriate remedial actions. I am a Senior
Principal at S.S. Papadopulos & Associates, Inc. (SSP&A) in Bethesda, Maryland. I have a Ph.D.
in geology from the University of Wisconsin, and have over thirty-five years of professional
experience in water -resource consulting. My qualifications, publications, trial and deposition
experience are included in Appendix A.
In the preparation of this report, I have reviewed and/or relied on technical reports, site
documents, and records maintained by government agencies that describe facility characteristics,
facility history, and groundwater and surface -water conditions at and in the vicinity of the facility.
The list of documents I reviewed is contained in Section 8.
The documents upon which I have relied are the types of documents typically used by
experts to evaluate the nature, fate, extent, timing and progression of contaminants in groundwater
at a site, and to select an appropriate remedial action. In addition, I visited the Allen Steam Station
facility on September 21, 2015. Finally, I have relied upon my extensive education, training and
experience in the field of hydrology in formulating the opinions expressed in this report.
Active Ash Basin — September 21, 2015
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Section 2
Backizround
The Allen Steam Station is a coal-fired electric generating station with a capacity of 1,155
megawatts located adjacent to Lake Wylie, just west of Charlotte, North Carolina. The station
began operation in 1957. Lake Wylie was created by a dam on the Catawba River near Indian
Hook, South Carolina. The station is located on a peninsula between the Catawba River and the
South Fork Catawba River. The average annual flow of the Catawba River is reported to be 3,011
cubic feet per second and the 7-day 10-year low flow is reported to be 263 cfs (HDR, 2016). The
stream classification is Class WS-IV B.
Coal ash from the station, consisting of fine particles captured by the pollution control
equipment (fly ash) and larger particles that fall to the bottom of the boilers (bottom ash), was
sluiced historically to ash basins with water from the Catawba River. Since 2009, fly ash has been
dry handled and placed in the on -site ash landfill. Bottom ash is still sluiced to the ash basin.
The current footprint of the ash basins is 322 acres. The ash basin system consists of an
inactive ash basin and an active ash basin. There are an estimated 19.3 million tons of ash within
the footprint of the ash basins, which includes the ash in the retired ash landfill located within the
footprint of the inactive ash basin (Duke Energy, 2016). The ash basins are operated as a part of
the station's wastewater treatment system. In addition to the sluiced ash, it receives water from
coal pile runoff, flue -gas desulfurization
wastewater, station yard drain sumps, and
site storm water.
The inactive ash basin, which is
about 132 acres, was used from 1957 until
1973, when the active ash basin was
constructed. Both ash basins were
constructed by building dikes across small
tributaries of the Catawba River and filling
in behind the dikes. There are two dikes:
the East Dike located along the west bank
of the Catawba River, and the North Dike
which separates the active and inactive ash
basins. Water discharges from the active
ash basin via a permitted discharge located
at the southeast corner of the basin (NPDES
Permit NC0004979, Outfall 0002).
Average daily discharge from the outfall is
estimated to be 8.3 million gallons (HDR,
2015a, page 12). The water level in the
pond at the discharge location is about 66
feet higher than the water level in the
adjacent Catawba River (HDR, 2015a,
page 10).
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Within the footprint of the inactive ash basin is located an ash landfill unit, referred to as
the Retired Ash Basin Ash Landfill. This landfill began operation in 2009 and is projected to
encompass 62 acres when complete. The landfill is constructed with a leachate collection system
and liner system. Two unlined structural ash fills, used from 2003 through 2009, are located on
top of the western portion of the inactive ash basin. Two unlined ash storage areas, constructed in
1996 by excavating ash from the north portion of the active ash basin, are also located on the
western portion of the inactive ash basin. Ash thicknesses of up to about 55 feet are reported (HDR,
2015b, page 46).
An extensive evaluation of groundwater and surface water conditions has been conducted
over the past two years. These evaluations were conducted to comply with the requirements of
the North Carolina Coal Ash Management Act of 2014, requiring groundwater monitoring,
assessment, and remedial activities, if necessary. The results of these evaluations are described in
three reports that were prepared as of June 2016: "Comprehensive Site Assessment Report — Allen
Steam Station Ash Basin" (HDR, 2015a), "Corrective Action Plan Part 1" (HDR, 2015b), and
"Corrective Action Plan Part 2 — Allen Steam Station Site" (HDR, February, 2016). These reports
are referred to as the CSA report, the CAP1 report, and the CAP2 report, respectively. The data
and evaluations contained in these reports have been used to define a volume of groundwater that
contains ash -related constituents.
The groundwater conceptual model developed in the CAP2 report describes the
groundwater system as an unconfined aquifer system consistent with the LeGrand slope -aquifer
system model (LeGrand, 2004). The groundwater system is divided into three layers referred to as
the shallow, deep (transition), and bedrock zones. The shallow zone consists of alluvium and/or
saprolite. The deep zone consists of the weathered and/or fractured bedrock zone from auger
refusal to the top of intact bedrock. The bedrock consists of meta -quartz diorite and meta-diabase.
Thicknesses of the shallow and deep zones range from 0 to 82 feet for the shallow zone and 0 to
33 feet for the deep zone (CAP1, page 46). Groundwater flow is generally from west to east
beneath the ash basin toward the Catawba River. Along the northern perimeter of the inactive ash
basin, there is a northern component of flow to the discharge channel. Along the southern perimeter
of the active ash basin there is southeastern component of groundwater flow toward the Catawba
River. A groundwater divide exists to the west of the ash basins. East of the divide, groundwater
flow is toward the Catawba River. West of the divide, groundwater flow is toward the South Fork
Catawba River.
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SLI
Section 3
Groundwater Contamination from Ash Basins
Porewater within the ash basin contains a number of dissolved inorganic constituents at
concentrations that are greater than those typically found in groundwater in the vicinity of the
Allen facility. As a result, porewater percolating into groundwater has the potential to influence
the water quality characteristics of the underlying and adjacent groundwater. In the CAP2, thirteen
constituents of interest were identified for groundwater: antimony (Sb), arsenic (As), barium (Ba),
boron (B), chromium (Cr), hexavalent chromium (CrVI), cobalt (Co), iron (Fe), manganese (Mn),
pH, sulfate (SO4), total dissolved solids (TDS), and vanadium (V). These constituents of interest
were identified based on exceedances of North Carolina's 2L Groundwater Standards (2L
Standards) and exceedances of North Carolina's Interim Maximum Allowable Concentrations
(IMAC).1
The water quality of the porewater in the ash basins has been characterized by porewater
samples collected from 18 monitoring wells installed within the ash basins and screened in the ash.
The table below lists the median, 75-percentile, and 90-percentile concentrations for the porewater,
based on the samples collected from the monitoring wells screened in the ash for all constituents
of interest except for pH, iron and manganese. These three potential constituents of concern are
discussed in the expert report of Dr. Remy Hennet. The data on the table below provides
information on the dissolved concentrations in the porewater that can potentially migrate to
groundwater. Only two of the constituents of interest exceed the 2L Standards based on the median
and 75-percentile concentrations: arsenic and boron. The measured concentrations of boron in the
porewater are shown in map view on Figure 1.
Concentrations of Potential Constituents of Interest in Ash Porewater
2L Standard
IMAC
Median
Concentration
75-Percentile
Concentration
90-Percentile
Concentration
Antimony (ug/L)
1
ND
1.2
8.1
Arsenic (ug/L)
10
95.5
746
867
Barium (m /L)
0.7
0.17
0.27
0.32
Boron (ug/L)
700
830
2300
7300
Chromium (ug/L)
10
ND
ND
0.64
Chromium VI u
ND
ND
0.66
Cobalt (ug/L)
1
ND
2.7
12
Sulfate (mg/L)
250
80
143
275
TDS m /L)
500
277
425
741
Vanadium (ug/L)
20
2.2
18.4
46.6
I The 2L groundwater quality standards are established under Chapter 15A of the North Carolina Administrative Code
Subchapter 02L.0202 (15A NCAC 02L.0101). Interim Maximum Allowable Concentrations (IMAC) are
established under 15A NCAC 02L.0202. The value for vanadium discussed in this report is based on a memorandum
from Mollie Young, Director of Legislative Affairs North Carolina Department of Environmental Quality to the
Environmental Review Commission and the Joint Legislative Oversight Committee on Health and Human Services,
dated April 1, 2016.
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The long-term leachability of the constituents of interest from the ash within the ash basins
was evaluated by conducting leaching tests, using EPA Method 1312 (Synthetic Leaching Test
Procedure — SPLP), on 14 ash samples collected from borings advanced within the ash basins
(CSA Report). This test method provides an estimate of leaching potential for the conditions
utilized in the test procedure. The median, 75-percentile, and 90-percentile concentrations reported
in the leaching liquid from these tests are listed on the table below. Arsenic is the only constituent
of interest that exceeds the 2L Standards based on median and 75-percentile concentration.
Antimony, cobalt and vanadium exceed their respective Interim Maximum Allowable
Concentration (IMAC) based on median and/or 75-percentile concentrations.
Concentrations of Constituents of Interest in Ash Leachate from Method 1312
2L Standard
IMAC
Median
Concentration
75-Percentile
Concentration
90-Percentile
Concentration
Antimony (ug/L)
1
3.55
4.4
5.4
Arsenic (ug/L)
10
28.1
66.4
115
Barium (mg/L)
0.7
0.177
0.289
0.295
Boron (ug/L)
700
88
94.7
234
Chromium (ug/L)
10
0.73
9.7
10.8
Cobalt (ug/L)
1
0.94
1.7
3.2
Selenium (ug/L)
20
9.8
15.1
25.9
Sulfate (mg/L)
250
7.9
8.2
23
Vanadium (ug/L)
20
35.2
129
153
Boron and sulfate are the most mobile of the constituents of interest listed on the tables
above, as these compounds are generally non -reactive in groundwater and migrate at the rate of
groundwater. These constituents are widely recognized as leading indicators of contamination
from coal ash.Z Boron concentrations in the ash porewater are elevated much more above
background levels than is sulfate at the Allen facility. Thus, boron is the better tracer for the extent
of groundwater contamination related to the ash basins.
A series of maps were prepared to illustrate the magnitude and spatial extent of boron in
groundwater in the vicinity of the ash basins. Boron concentrations in shallow groundwater are
displayed on Figure 2, boron concentrations in deep groundwater are displayed on Figure 3, and
boron concentrations in bedrock are displayed on Figure 4. The boron concentration data displayed
on these figures are based on 1) the maximum of reported concentrations for monitoring wells and
the water supply wells at the Allen facility as reported in the CAP2 report, and 2) the results of the
sampling of the private bedrock wells as reported in Appendix B of the CSA report. The typical
detection limit for boron used in the analyses conducted for the CSA was 50 ug/l. As a result, only
reported values of greater than 50 ug/L are posted on Figures 2 to 4.
The highest boron concentrations are located beneath the ash basins and adjacent to the
river. The pattern of elevated boron concentrations are consistent with percolation of water from
the ash basins to the groundwater, and migration of groundwater with elevated concentrations of
2 U.S. EPA's Final Rule regarding Disposal of Coal Combustion Residuals from Electric Utilities, 40 CFR Parts 257
and 261, specifies that detection monitoring constituents are boron, calcium, fluoride, pH, sulfate and total dissolved
solids, as these parameters are known to be leading indicators of releases of contaminants associated with coal
combustion residues.
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boron toward and into the river. Some seeps have been observed along the toe of the East Dike,
and elevated boron concentrations have been measured in the seeps consistent with migration from
the ash basins toward the river. Boron was detected in only three bedrock wells at concentrations
greater than 50 ug/L. There wells are all located along the East Dike adjacent to the Catawba River
within the compliance boundary.
The extent to which constituents of concern are retarded (attenuated) in groundwater
relative to boron is illustrated by reported concentrations of all of the other potential constituents
of interest as not detected or less than the 2L Standards or IMAC at many of the monitoring wells
with reported boron concentrations greater than 50 ug/L.3 Arsenic, which is reported in ash
porewater at concentrations well above the 2L Standards, is only reported in one monitoring well,
excluding those completed in the ash, at concentrations above the 2L Standards (GWA-6S)g. This
well is located along the northern perimeter of the inactive ash basin within the compliance
boundary.
s This includes monitoring wells AB-26S, A13-2213, AB-2713, A13-2913, A13-3313, A13-3913, A13-913, GWA-313, GWA-
413, GWA-3BR, GWA-SBR.
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Section 4
Remedial Actions for Groundwater
The North Carolina Coal Ash Management Act of 2014 requires that a corrective action
for the restoration of groundwater quality shall be implemented at the Allen facility. This
corrective action is required to be sufficient to protect public health, safety, welfare, the
environment and natural resources, and to be consistent with Chapter 15A of the North Carolina
Administrative Code Subchapter 02L (15A NCAC 02L).
The CAP2 report states that Duke is planning to utilize cap -in -place as a source control
measure at the Allen ash basins, by constructing an engineered cap system over the ash basins, in
conjunction with monitored natural attenuation (MNA) as the corrective action for groundwater.
In addition, the CAP2 report states that if monitoring determines that MNA is insufficient for
restoration of groundwater quality, that additional remedial alternatives will be considered and
implemented, if warranted.
As described in the CAP2 report, with a cap -in -place remedy, infiltration of water from the
ash to the underlying groundwater will be significantly reduced. Even with this reduced
infiltration, there will remain some saturated ash. Groundwater will continue to flow through the
saturated ash toward the river into the future, but the amount of flow through the ash will be
significantly less than under current conditions. As a result, constituents of interest from the ash
basin will continue to migrate toward and diffuse discharge into the river. The analyses that were
conducted for the CAP2 report indicate that this continuing discharge to the river will be protective
of public health, safety and welfare, the environment, and natural resources, and is consistent with
15A NCAC 02L. In addition, as monitoring is an integral component of the remedy, data will be
collected on an ongoing basis to verify that the remedy remains protective.
An expert for the Plaintiffs in this litigation opines that the appropriate corrective action
for groundwater at the Allen facility is removal of all of the ash within the ash basins. The expert's
opinion is:
"Successful remediation of groundwater will require excavation and removal coupled with
additional measures, such as hydraulic groundwater containment" (Bedient, 2016b, page 10).
In addition, others of Plaintiffs' experts opine that:
"Monitored Natural Attenuation is not an appropriate remedy for constituents of interest (COls)
at the Allen site" (Parette, 2016, page 10).
"Source -area mass removal included in the Excavation Scenario results in COI concentration
reductions at the Compliance boundary that are generally two to four times greater compared to
Cap -In -Place, best reduces impacts to surface water, and reduces cleanup times by a factor of 2.S-
S. Additional excavation of secondary sources would further accelerate concentration
reductions. " (Cosler, 2016b, page 4).
The experts for the Plaintiffs' opine that a source removal corrective action is preferred
over the cap -in -place remedy for two main reasons: 1) they believe there is a significant risk of
migration of ash basin related constituents to nearby private wells with a cap -in -place remedy, and
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2) the time frame for groundwater restoration would be shorter with an ash removal corrective
action than a cap -in -place corrective actions. The experts provide no quantification of the risk to
nearby wells with a cap -in -place remedy. Rather, it is a generic conclusion based on the
complexities of groundwater flow in fractured bedrock aquifers. As discussed later in this report,
my opinion is that the risk to nearby wells is insignificant and based on the available information
can be mitigated with groundwater monitoring.
An evaluation of corrective action plans for groundwater, as specified in 15A NCAC 02L, shall
consider the following;
• The extent of any violations;
• The extent of any threat to human health or safety;
• The extent of damage or potential adverse impact to the environment;
• Technology available to accomplish restoration;
• The potential for degradation of contaminants in the environment;
• The time and costs estimated to achieve groundwater quality restoration; and
• The public and economic benefits to be derived from groundwater quality restoration.
The time to achieve groundwater quality restoration is only one of several factors to be considered
in evaluating corrective actions. The Plaintiffs' expert reports contain limited or no discussion of
these other factors.

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Section 5
Opinions
Based on the data and information that I have reviewed and my experience and education,
I have formulated the following opinions:
• The data on ash and groundwater characteristics collected in the investigations conducted
at the Allen facility provide an adequate and appropriate foundation for selecting an
appropriate remedy for the alleged violations (releases from the ash basins).
• Boron is an excellent tracer of groundwater migration from the ash basins. As a result, it
is not probable that groundwater with boron concentrations at background levels has been
affected by constituents that have migrated from the ash basins.
• Coal ash -related constituents have been infiltrating into and migrating with groundwater
since the first ash basin was constructed and used in 1957. Boron has migrated in
groundwater from the ash basins to groundwater discharge areas along and beneath the
Catawba River. The extent of groundwater contamination resulting from migration of coal
ash -related constituents is defined by elevated boron concentrations in groundwater, and
the extent is limited. Site data indicate that migration of ash -related constituents, other than
boron and sulfate, in groundwater are significantly attenuated relative to boron.
• Groundwater in the vicinity of the ash basins does not flow under the Catawba River.
• Groundwater sample results from private wells in the vicinity of the ash basins are an
excellent foundation for evaluating potential past migration, and potential future migration,
of groundwater from the ash basins toward these wells.
• Constituents in coal ash occur naturally. The background concentration of a specific
constituent is not a single value but is rather a range that represents, in part, the
characteristics of the source material and potential anthropogenic factors.
• The groundwater model developed for the site is a useful tool for integrating the available
groundwater data, interpreting groundwater flow and water -quality conditions, and
evaluating the relative performance of alternative remedial actions.
• Dispersion and dilution are natural attenuation processes to be considered in MNA
evaluations.
• A cap -in -place remedy, with monitoring, can be protective of water quality in nearby
private and public wells and water -quality in the Catawba River. Similar remedies have
been successfully utilized at numerous sites in the United States.
• Consideration of the factors specified in 15A NCA 02L for evaluation of corrective action
does not support excavation and removal of the contents of the ash basins at Allen.
I hold these opinions with a reasonable degree of scientific certainty. I reserve the right to
modify and supplement these opinions should additional information become available.
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Section 6
Bases for Opinions
The foundation for each of my opinions is described below.
Available Data
Extensive data on groundwater and subsurface conditions at the Allen facility have been
collected as part of the investigations conducted at the facility. Groundwater quality data are
available from approximately 85 monitoring wells, over 100 private wells in the vicinity of the
site, and seeps at the site. In addition, ash and soil mineralogy and chemistry data are available
from a large number of samples collected during the advancement of borings; leaching data are
available for ash samples; and laboratory sorption data are available for selected subsurface
samples. Data on the physical characteristics of the subsurface are available from boring logs and
from slug tests conducted at each of the monitoring wells, and water -level monitoring data. These
data are sufficient for defining the extent of groundwater contamination and potential migration
pathways for purposes of selecting an appropriate groundwater corrective action. This does not
imply that additional data are not, and will not, be needed to design an appropriate remedy.
Boron as a Tracer
Boron is an excellent tracer for two primary reasons.
First, dissolved boron is present in the ash porewater at
concentrations significantly elevated above background levels.
Boron concentrations in ash porewater range up to 7,400 ug/L
(which is more than 150 times greater than the background boron
concentration). Second, dissolved boron, which is typically as
boric acid, has minimal interaction with the solid phases in the
subsurface. An Eh -pH diagram for boron, illustrating that boric
acid (H31303) is the stable form of dissolved boron at conditions
encountered in the vicinity of the ash basins, is shown to the right
(Brookins, 1988).
Migration of the constituents of interest away from the
ash basins occurs primarily as dissolved transport of the
constituents of interest with migrating groundwater. Boron
dissolved in groundwater as boric acid is relatively non -reactive
1.2
t0
25TC 1 bar
RO
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ea,
0.6
0:6
0.4
K,BOb
0.2
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0.0
►Dt3°-
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-0.4
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in the subsurface as it is not sorbed onto mineral surfaces and is Eh -pH Diagram for BAH SyStem
stable under a range of Eh and pH conditions. Many of the dissolved constituents of interest,
unlike boron, sorb to mineral surfaces and/or form metal oxides complexes. This results in an
apparent rate of migration of the constituent that is slower than the rate of groundwater flow (and
the rate of boron migration). Since boron migrates as fast as or faster than other constituents of
interest, and is still present in porewater in the ash basins, boron is a reliable indicator of ash -
related contamination. A corollary to this last sentence is that when elevated boron concentrations
in a groundwater sample is absent, it is unlikely that the groundwater sample has been
contaminated by the migration of any ash related constituents from the ash basins. A possible
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exception may occur in very acidic groundwater where cobalt may leach from the ash and native
materials, and migrate at approximately the speed of groundwater (U.S. EPA, 2015a).
Migration of Coal Ash -Related Constituents
Since dissolved boron migrates at approximately the speed of groundwater, the percolation
of water from the ash basins since 1957 into the underlying groundwater can be considered as a
nearly 60-year long tracer test. The results of this nearly 60-year long tracer test are depicted on
Figures 2, 3, and 4, which present the measured boron concentration in groundwater in 2015 in the
shallow, deep and bedrock groundwater zones. The extent of groundwater impacted by migration
of ash -related constituents is defined by measured boron concentrations in monitoring wells that
are greater than the normal detection limit of 50 ug/L. An examination of the spatial distribution
of monitoring wells on Figures 2, 3 and 4 with boron concentrations greater than 50 ug/L indicate
that the extent of impacted groundwater is limited. The distribution of boron in groundwater
indicate that boron has migrated from the ash basins to groundwater discharge areas along and
beneath the Catawba River.
Experts for the Plaintiffs have compiled lists of exceedances of groundwater standards and
exceedances of IMACs for ash -related constituents and have implied that these exceedances define
the extent of contamination from the ash basins Cosler, 2016, Table 1; Bedient, 2016b, Figure 2).
Many of these exceedances occur at monitoring wells in which boron concentrations were below
the method detection limit. The experts provide no scientific foundation for concluding that these
exceedances at wells with boron concentrations less than 50 ug/L are the result of migration of
ash -related constituents from the ash basins.
Examples of monitoring wells with exceedances listed on Table 1 in Cosler (2016b)
include:
GWA-7S —Cobalt concentrations in two rounds of water samples from this well have been
reported as 43 ug/l and 52 ug/L. These concentrations exceed the IMAC for cobalt of 1
ug/L. These cobalt concentrations are among the highest measured in monitoring wells and
are significantly higher than the 90-percentile cobalt concentration in ash porewater (12
ug/L). The boron concentration in this well, though, is less than 50 ug/L. This indicates
that migration of ash -related constituents from the ash basins to this location has been at
most negligible.
• AB-25BR — Vanadium concentrations in two rounds of water samples from this well have
been reported as 27 ug/L and 11 ug/L. These vanadium concentrations are in the range of
the 75-percentile vanadium concentration in ash porewater (18.4 ug/L). The boron
concentration in this well, though, is less than 50 ug/L. This indicates that migration of ash -
related constituents from the ash basins to this location has been at most negligible.
• AB-23BRU — Chromium concentrations in two rounds of water samples from this well
have been reported as 37 ug/L and 66 ug/L. These concentrations exceed the 2L Standard
for chromium (10 ug/L) and exceed the 90-percentile concentration in ash porewater (12
ug/L). The boron concentration in this well, though, is less than 50 ug/L. This indicates
that migration of ash -related constituents from the ash basins to this location has been at
most negligible.
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The monitoring data from the Allen facility clearly illustrate that migration of most of the
identified constituents of interest in groundwater is retarded relative to the rate of migration of
boron in groundwater. For example, as noted in Section 3, arsenic concentrations in ash porewater
are much greater than the 2L Standards of 10 ug/L. Unlike boron, arsenic concentrations greater
than the 2L Standards are only detected in one monitoring well that is completed in native
materials: GWA-6S. This provides strong and irrefutable evidence that arsenic migration is
significantly retarded relative to boron. Also, as noted in Section 3, there are many monitoring
wells in which boron was detected at a concentration greater than 50 ug/L, and other constituents
of interest were not detected at concentrations greater than their respective 2L Standards or
IMACs. This provides strong evidence that the migration of these constituents are retarded relative
to boron in groundwater at the Allen facility.
Groundwater does not flow under the Catawba River
Groundwater in the vicinity of the ash basins flows toward and into the Catawba River or
in the northern portion of the inactive basin, toward and into the drainage canal. Groundwater
levels in the shallow, deep and bedrock monitoring wells along the river have water levels
significantly above river levels. As discussed in the following paragraph, these groundwater
levels, which are higher than the river level, indicate that the hydraulic gradient under the river is
toward the river. Typically, groundwater discharge to lakes and rivers is focused near the shoreline
and declines markedly with distance from the shore (Winters, 1976).
The Catawba River and Lake Wylie represent topographic lows in the region. For
groundwater to flow under the river, rather than into the river, it would be necessary for there to
be a downward hydraulic gradient beneath the river. Such a gradient is not consistent with
available water level data and is inconsistent with the regional setting of the Allen facility.
Dr. Cosler, an expert for the Plaintiffs noted, in his deposition noted that there are strong
downward hydraulic gradients in monitoring wells along the East Dike. This is as expected when
water levels in the ash basins are more than 35 feet higher than river levels. These downward
hydraulic gradients merely indicate that groundwater recharge is occurring at the ash basins under
current conditions (except beneath the Retired Ash Basin Ash Landfill as it is lined). At the river,
however, the water table is equivalent to river stage, which is lower than water levels in the deep
and bedrock wells at the facility. Thus, groundwater flow from the ash basin system is upward to
the river, where it discharges. This is consistent with the findings of a U.S. Geological Survey
research study of groundwater flow in the Piedmont Region of North Carolina, where it was
concluded that "Groundwater flow discharges to a surface -water boundary (Lake Norman), and
vertical hydraulic gradients generally are downward in recharge areas and upwards in discharge
areas. " (Pippin and others, 2008, page 1).
With a cap -in -place remedy, recharge from the ash basins will be reduced to negligible
levels, and as a result downward hydraulic gradients will be reduced in magnitude beneath the ash
basins and the gradient may become upward near the river. Dr. Cosler in his deposition on June 1
and 2, 2016 described hydraulic gradients in well clusters between the river and the lined Retired
Ash Basin Ash Landfill (Cosler, 2016c). At two of the well clusters between the lined landfill and
the river, GWA-5 and AB-9, the hydraulic gradient currently is upward from the deep groundwater
zone to the shallow groundwater zone, indicating that at these locations groundwater flow is from
the deep zones toward the river (CAP2, Figures 2-2 and 2-3).
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MSU
Private Wells
Approximately 119 private wells within one-half mile of the Allen facility were sampled
between February and July 2015. Typically, private wells in the area are open hole completions in
the bedrock, with well depths ranging to several hundred feet (CSA, Table 4-1). The water quality
results from these wells provide an excellent database of groundwater quality in the bedrock in the
vicinity of the Allen facility. Boron concentrations in these well ranged from ND to 27 ug/L.4
Thus, in no well did the boron concentration exceed 1/20 of the 2L Standards. Concentrations of
all other potential ash basin -related constituents were within the range of background
concentrations. These results are consistent with the direction of groundwater flow from the
residential area toward the South Fork Catawba River to the west, and toward the Catawba River
to the east (as indicated by the groundwater level data). These flow patterns are also consistent
with the observation that the highest nitrate concentrations in groundwater occur in the monitoring
wells located along the western perimeter of the ash basins, consistent with nitrate sources in the
upgradient residential areas.
The use of water -quality data from private wells to define the extent of contamination is
often incorrectly criticized because such wells are not constructed in the same manner as
monitoring wells. For example, the private wells frequently have long open intervals in the
bedrock, and for many wells the length of the open interval is unknown. In the vicinity of the Allen
facility, where groundwater flow in the bedrock is primarily through fractures, private wells
intersect the fractures through which the groundwater flows. In fact, the depth of private wells is
variable because fracture density is variable. Wells are typically drilled until sufficient fractures
have been intersected to supply sufficient water to the well. Since the wells intersect the water -
yielding fractures, if migration of constituents of interest has occurred in the fractures, the water
produced from these wells for sampling will contain the constituents of interest.
Background Concentrations
A complexity in defining the extent of groundwater affected by migration of ash -related
constituents occurs because all of the identified constituents of interest in groundwater occur
naturally in soil and groundwater in the vicinity of the Allen facility, and because the naturally -
occurring concentrations of several of the constituents of interest are greater than either the 2L
Standards or the IMACs. The naturally -occurring concentration 5of a specific constituent of
concern is a function of many factors including, but not limited to, the nature of geologic materials,
redox conditions in groundwater, groundwater age, land use, and anthropogenic factors.' As a
result of the many factors that influence naturally -occurring concentrations of the constituents of
interest in groundwater, naturally -occurring concentrations (also known as background
4 A boron concentration of 38.8 ug/L was reported for a public water supply well located on Waterview Drive, which
appears to be located more than '/z mile from the Allen facility.
5 In the report, "naturally -occurring concentration" refers to the concentration that would occur in groundwater if the
ash basins had not been constructed and operated.
6 Refer to papers by Oze and others (2007) and Wright and Belitz (2010) for a discussion of the influence of
characteristics of geologic materials on hexavalent chromium and vanadium, respectively, in groundwater.
13

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concentrations) represent a range of concentrations in the vicinity of the Allen facility and vary
among the aquifer zones and with spatial location.
The range of background concentrations is well illustrated from the results of the private
well sampling and analysis for vanadium and total dissolved solids, as in my opinion, the water -
quality results from these wells represent background groundwater quality. One hundred and
sixteen wells were sampled within one-half mile of the Allen facility, and an additional seven wells
were sampled that are located much further from the facility. The results from the sampling of the
wells within one-half mile of the facility indicate that vanadium concentrations in bedrock range
from <0.03 ug/L to 26.5 ug/L, with a median value of 8.3 ug/L and a 75-percentile value of 10
ug/L. In the samples collected from wells located more than one one-half mile from the facility,
vanadium concentrations ranged from <1 to 23.7 ug/L. The total dissolved solids concentrations
in the wells within one-half mile of the facility ranged from <25 mg/L to 675 mg/L with a median
value of 84 mg/L and a 75-percentile value of 119 mg/L. These results provide information on the
wide range of naturally -occurring vanadium and total dissolved solids concentrations in bedrock
groundwater in the vicinity of the Allen facility. As a result of this large range in naturally -
occurring vanadium and total dissolved solids concentrations, there can be ambiguity regarding
the source of vanadium and total dissolved solids in any given groundwater sample. This ambiguity
can be resolved by using multiple lines of evidence, including an evaluation of the presence or
absence of a tracer of ash -related migration (such as boron) at concentrations above background
levels and by evaluating the processes responsible for migration of ash related constituents in
groundwater.
Groundwater Model
A groundwater model of the Allen facility and vicinity is described in the CAP 1 and CAP2
reports. This model was prepared primarily to integrate available information on groundwater
conditions at the facility, such that the future distribution of ash -related constituents in
groundwater and the mass flux of ash -related constituents to surface water could be compared in
a relative manner under three future scenarios: existing conditions, cap -in -place, and source
removal. The model that was developed provides a framework for making this type of relative
evaluation.
The model that was developed is a simplified representation of a complex groundwater
system as are all models. As a representation of a system, rather than an exact replica, the goal of
the model is not to incorporate all details of the subsurface environment, but rather only those
details and processes relevant to the objectives of the modeling analyses (Anderson and others,
2015). The appropriate details and processes have been represented in the model.
The use of the model, as described in the CAP and CAP2 reports, has provided insight on
migration of constituents of interest in groundwater. As modeling is an iterative process, these
insights and additional information are being incorporated into the model to make it a better tool
for evaluating future scenarios. Appropriately, the model is not a static tool, but rather a dynamic
one that is being used to evaluate future scenarios. The model, though, is only a tool -- it is only
one component of the evaluations being conducted to choose an appropriate corrective action for
groundwater.
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MSU
Monitored Natural Attenuation
Monitored Natural Attenuation (MNA), as defined by the U.S. EPA includes:
"....biodegradation; dispersion; dilution; sorption; volatilization; radioactive decay; and
chemical or biological stabilization, transformation, or destruction of contaminants " (USEPA,
1999, page 3; USEPA 2015b, page 7). The primary natural attenuation processes for boron at the
Allen facility are dilution and dispersion. These processes result in a reduction in boron
concentration downgradient of the ash basin and thus a reduction in potential exposure levels. For
constituents other than boron and sulfate, attenuation mechanisms include geochemical processes
and surface interactions, in addition to dilution and dispersion.
Cap -in -Place Remedy
A cap -in -place remedy will reduce to negligible levels the amount of water that percolates
from the ground surface vertically through the ash residing in the ash basins to the groundwater
system. Based on the recharge rate for the ash basins specified in the groundwater model described
in the CAP2 report, capping the ash basins will reduce groundwater recharge by approximately 90
million gallons per year. This recharge reduction will result in a nearly identical reduction in
groundwater discharge from beneath the Allen facility to the Catawba River. This reduction in
diffuse groundwater discharge to the Catawba River will, by itself, result in a reduction in the mass
flux of ash related constituents to the Catawba River from current levels.
The water table beneath the ash basins will decline from current levels following capping,
due to the reduction in groundwater recharge. The decline in the water table will not be sufficient
to dewater the ash within the basins, as the ash fills tributary valleys that prior to construction of
the basins were groundwater discharge areas. As a result, groundwater will continue to migrate
through the remaining saturated ash and discharge to the Catawba River. The decline in the water -
table beneath the ash basins and adjacent areas, will result in the groundwater divide on the
peninsula between the Catawba River and the South Fork Catawba River moving westward. This
will result in groundwater levels, that demonstrate more clearly than current groundwater levels,
the eastward components of groundwater flow beneath the ash basins.
The cessation of vertical water movement through the ash following capping is not
anticipated to result in significant changes in oxidation-reduction conditions in groundwater within
and beneath the ash basins. Ash porewater, based on data collected for the CSA, currently is
reducing, with Eh readings typically in the range of -100 to -200. Similar Eh conditions are
expected to persist in the ash porewater following capping. As a result, the sorption characteristics
of the ash and underlying geologic materials are not anticipated to change following capping.
Water quality standards for ash -related constituents are not currently exceeded in the
Catawba River, based on the analyses conducted for the CAP2 report. With a cap -in -place remedy,
the mass flux to the river of ash -related constituents will be reduced, and as a result water quality
standards in the river will not be exceeded in the future.
A cap -in -place remedy will be protective of public health, safety and welfare, the
environment, and natural resources. With a cap -in -place remedy, groundwater flow in the vicinity
of the ash basins will be toward the river, not toward areas with private wells, and water -quality
standards in the river will not be exceeded.
15

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lSu
Section 7
Rebuttal of Plaintiffs Experts
Philip B. Bedient, Ph.D.
Dr. Bedient in his expert report states:
"I have focused my analysis on different methods of preventing continued transport of coal
ash contaminants across the compliance boundary in groundwater at concentrations that exceed
relevant groundwater standards. " (Bedient, 2016b, page 1).
Dr. Bedient's analysis is flawed for three primary reasons:
1. He implicitly assumes that all exceedances of relevant groundwater standards for
constituents detected at the monitoring wells at the Allen facility are the result of
migration of these constituents from the coal ash basins. For example, his report
includes Figure 2 titled "Locations of Wells and Groundwater Standard
Exceedances for Any COI" to depict the monitoring wells where coal -ash related
constituents occur in groundwater at concentrations greater than groundwater
standards. As described in Section 6 and visually displayed on Figures 2 through
4 of this report, the exceedances of groundwater standards at most of the wells
shown on Figure 2 of the Bedient report are not the result of migration of
constituents from the ash basins.
2. He concludes on page 10 of his report, with no analysis or bases that a cap -in -place
remedy with a groundwater extraction control system would not be a feasible
method of groundwater remediation. On the other hand, he opines on page 10 of
the expert report that a groundwater extraction system would need to be
implemented with a source removal (excavation) remedy, and that such an
extraction system would create a hydraulic barrier that prevents impacted
groundwater from crossing the compliance boundary. In my opinion, effective
groundwater extraction control systems could be designed and operated that
prevent continued migration of ash -derived constituents across the compliance
boundary for both a capping and a source removal remedy. In fact, the system
designed for the source removal remedy may well need to have greater capacity
than the system designed for the capping remedy, as groundwater recharge rates at
the ash basins and groundwater flow across the compliance boundary will be larger
with the source removal remedy. As noted in Appendix G to the CAP2 report, a
groundwater containment system would need to be operated for a long time and
there are a number of factors that make implementation of such a system
problematic.
3. He assumes that an appropriate remedy must prevent any migration of coal ash
derived constituent across the compliance boundary. This assumption is incorrect.
For a site where groundwater is expected to intercept surface water, the conditions
specified in 15A NCAC 2L allow a remedy with continued migration across a
compliance boundary "...if the contaminant plume is expected to intercept surface
water, the groundwater discharge will not possess contaminant concentrations that
16

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would result in violations of standards for surface waters contained in 1 SA NCAC
2B.0200. "
Robert Parette, Ph.D.
Dr. Parette in his expert report states his major opinion as follows:
"Monitored natural attenuation is not an appropriate remedy for constituents of interest
(COls) at the Allen site. " (Parette, 2016, page 10).
Dr. Parette's opinion is inconsistent with the extensive groundwater quality data collected
at the Allen facility that demonstrate that constituents of interest are naturally attenuated with
distance downgradient of the ash basin, as described in Section 6. For constituents other than boron
and sulfate, this attenuation is the result of geochemical processes and surface interactions, in
addition to dilution and dispersion. Dr. Parette incorrectly assumes that physical attenuation
processes, such as dilution and dispersion, are not appropriate for consideration in a natural
attenuation remedy, as described in Section 6.
Dr. Parette opines that conditions for monitored natural attenuation will be less favorable
following capping. as capping he believes will lead to more anoxic conditions. As explained in
Section 6, groundwater conditions are not likely to become more anoxic following capping. Dr.
Parette also opines that natural attenuation is not appropriate for arsenic. As described in Section
6, the available monitoring data clearly and unambiguously demonstrate that arsenic migration in
groundwater in the vicinity of the ash basins is strongly attenuated relative to boron. The data also
show significant retardation of antimony, chromium and cobalt relative to boron. These site -
specific data clearly demonstrate that natural attenuation processes are effective in reducing
concentrations of constituents of interest, and will be favorable for natural attenuation in the future.
Douglas I Cosler, Ph.D.
Dr. Cosler lists twelve opinions in his expert report (2016b, page 4). He opines that
groundwater quality restoration will occur more slowly with a cap -in -place remedy than with a
source removal remedy, but he notably does not opine that a cap -in -place remedy is inappropriate
for the Allen facility. A short rebuttal to each of Dr. Cosler's opinions follows.
Opinion #1 "A total of 44 Compliance Boundary samples exceeded North Carolina
groundwater standards for these COI.- boron, chromium, cobalt, iron, manganese, sulfate,
total dissolved solids, and vanadium. "
It is unscientific to imply that the extent of groundwater contamination from the ash basins
is defined by exceedances of 2L Standards for IMACs at compliance boundaries. The monitoring
wells that Cosler listed in this expert report as having exceedances of groundwater standards are
tabulated on Table 1. Also listed on the table, for each well, are reported boron concentrations
and reported concentration of the other constituents of interest if they exceeded their 2L Standard
or the IMAC.7 The reported boron concentrations at 20 of the 31 monitoring wells listed on Table
7 The concentrations reported on Table 1 are the maximum dissolved concentrations from the CSA sampling.
Dissolved, rather than total, concentrations are listed because these more closely reflect the concentrations of the
constituents migrating in groundwater.
17

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�S
I are less than 50 ug/L; groundwater quality impacts at these wells from constituents of interest
are at most minor. Most of the eleven wells with boron concentrations greater than 50 ug/L are
located along the East Dike that separates the ash basins from the Catawba River. This is an area
where groundwater flow from the ash basins toward the river has occurred, and is occurring under
current conditions, due to the large hydraulic gradients between the ash basins and the river.
Some of the exceedances at the compliance boundary that are described by Dr. Cosler are
based on calculations he made with an analytical groundwater transport model. These calculations
are incorrect because they assume that groundwater containing the constituent of interest migrates
beneath the river from wells along the shoreline, where the constituent of interest was measured,
to the compliance boundary located almost 500 feet from the shoreline. In actuality, shallow
groundwater along the shoreline discharges to the river along the shoreline, and near the shoreline,
and does not migrate to the compliance boundary. For example, one of the wells for which Dr.
Cosler uses his model to calculate the concentration at the compliance boundary is well GWA-4S.
This well is located near the shoreline and is screened from approximately 11 feet above river
(lake) level to about -4 feet below river level.$ It is not physically possible that groundwater
flowing eastward past this well could migrate downward and flow under the river for almost 500
feet.
Opinion #2 "Most of the background wells are either likely to be downgradient from coal -
ash source areas, or appear to be downgradient from coal ash. "
The background wells for the site consist of three sets of monitoring wells BG-1 S/D, BG-
2/D/ BR, and BG-3S/D. These monitoring wells are upgradient of the ash basins based on
available water level and water quality data.
Opinion #3 "The statistical analysis of background groundwater concentrations at the
Allen site (well AB-1 R) are invalid due to the characteristically slow rate of COI migration
in groundwater. "
Dr. Cosler incorrectly interprets USEPA guidance on monitoring at RCRA sites (2009). If
Dr. Cosler's interpretation was correct, it would not be possible to estimate background
concentrations for compounds with large Kd's, as the required sampling frequency would be so
long as to be impractical. Dr. Cosler has confused the physical rate of groundwater migration with
the "apparent rate" of contaminant migration as a guiding principal for sampling frequency. The
issue of sampling frequency is described in detail in Barcelona and others (1989).
Opinion #4 "There is a significant risk of chemical migration from the ash basins to
neighboring private and public wells in fractured bedrock. "
Dr. Cosler correctly notes that the private wells are located in fractured bedrock near the
ash basins. He does not discuss the extensive sampling data from these wells that show that these
wells have not been impacted by groundwater from the ash basins. In addition, he neglects to note
that groundwater flow conditions will change in the future as the result of a cap -in -place remedy.
8 Based on a river level of 565.5 feet MSL.
IN

2-2- bVbVDObnr02 9� V220CIV1E2' JWC'
Opinion #S "Major limitations of the CAP groundwater flow model and chemical transport
models prevent simulation and analysis of off -site migration. "
The groundwater flow and transport model is a tool that was developed to evaluate in a
relative manner future corrective action scenarios. The model has the ability to simulate off -site
migration of COIs to the Catawba River.
Opinion #6 "The CAP Closure Scenario simulation greatly underestimate (by factor of
10 or more) the time required to achieve meaningful groundwater concentration
reductions in response to remedial actions. "
This opinion is based on the observation that Ka values used in the transport model were,
in his opinion, an order of ten times lower than appropriate. It is scientifically inappropriate to
conclude on this observation alone that restoration time frames are underestimated by a similar
order of magnitude. A meaningful evaluation of the magnitude of overestimate or underestimation
of cleanup times by the model requires an understanding of why an apparent calibration of the
model was obtained with Kd values that are believed by Dr. Cosler to be too small. Dr. Cosler
made no evaluation of this issue.
Opinion #7 "For either the Existing Condition or Cap -in -Place Model Scenario
groundwater concentrations of coal -ash constituents much higher than background levels
will continue to exceed North Carolina groundwater standards at the Compliance
Boundary because saturated coal -ash material and secondary sources will remain in
place. "
As noted above, saturated coal ash will remain with a cap -in -place remedy. It has yet to
be demonstrated that concentrations at compliance wells will exceed applicable criteria with a Cap-
in -place remedy.
Opinion #8 "Source -area mass removal included in the Excavation Scenario results in
COI concentration reductions at the Compliance Boundary that are generally two to four
times greater compared to Cap -in -Place and best reduces impacts to surface water. "
Concentrations of constituents of interest in monitoring wells along the river most likely
will decline more slowly with a cap -in -place remedy than with a source removal remedy. Existing
conditions do not result in the exceedance of water quality standards in the river and future
conditions with both a cap -in -place remedy and a source removal remedy would be protective of
surface water quality.
Opinion #9 "The CAP Closure Scenarios do not address either concentration reduction
or off -site migration control in the fractured bedrock.
A cap -in -place remedy with MNA does address groundwater contamination in the bedrock.
A cap -in -place remedy will reduce downward groundwater flow beneath the ash basin toward the
bedrock and will eventually result in restoration of groundwater quality in the bedrock. A
hydraulic containment component is not included in the cap -in -place remedy as it is not needed to
meet remedial objectives.
19

2-2- bVbVDObnr02 9� V220CIV1E2' IMC'
�S
Opinion #10 "Due to an incorrect boundary condition representation of the active ash
basin, the CAP models underestimate by more than a factor of two both the mass loading
of COI into the Catawba River and the corresponding Catawba River Water
Concentrations.... "
The mass flux calculated for the cap -in -place scenario is not underestimated by a factor of
two due to an incorrect boundary condition. The water flux to the Catawba River is primarily a
function of the recharge rate within the model domain. The recharge rate for the cap -in -place
scenario is appropriate.
Opinion #11 "The CAP Part 2 geochemical modeling and monitored natural attenuation
(MNA) evaluation do not provide the required quantitative analysis of COI attenuation
rates necessary to support MNA as a viable corrective action "
Quantitative analysis of COI attenuation rates are ongoing.
Opinion #12 "Future Compliance Monitoring should include much more closely spaced
monitoring wells to provide more accurate detection.... "
This opinion, if correct, applies equally to all future scenarios. I have not evaluated an
appropriate monitoring plan for a cap -in -place remedy, though monitoring will be a component of
the corrective action.
20

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Section 8
References
Anderson, M.P., W.W. Woessner, and R.J. Hunt. 2015. Applied Groundwater Modeling.
Simulation of Flow and Advective Transport (2nd ed.): Elsevier.
Barcelona, M.J., H.A. Wehrmann, M.R. Schock, M.E. Sievers, and J.R. Karny. 1989. Sampling
Frequency for Ground -Water Quality Monitoring. U.S. Environmental Protection Agency.
EPA/600/S4-89/032. September.
Bedient, P.B. 2016a. Amended Expert Opinion of Philip B. Bedient, Ph.D., P.E. Remediation of
Soil and Groundwater at the Allen Steam Station Operated by Duke Energy Carolinas,
LLC. April 13.
Bedient, P.B. 2016b. Expert Opinion of Philip B. Bedient, Ph.D., P.E. Remediation of Soil and
Groundwater at the Allen Steam Station Operated by Duke Energy Carolinas, LLC.
February 29.
Brookins, D.G. 1988. Eh pH Diagrams for Geochemistry: Springer-Verlag Berlin Heidelberg.
Cosler, D.J. 2016a. Amended Expert Opinion of Douglas J. Cosler, Ph.D., P.E. Allen Steam
Station Ash Basins. April 13.
Cosler, D.J. 2016b. Expert Opinion of Douglas J. Cosler, Ph.D., P.E. Allen Steam Station Ash
Basins. February 29.
Cosler, D.J. 2016c. Videotaped Deposition of Douglas .I. Cosler, Ph.D., P.E. State of North
Carolina ex rel. North Carolina Department of Environment and Natural Resources vs.
Catawba Riverkeeper Foundation Inc., Appalachian Voices, Yadkin Riverkeeper,
Mountaintrue, Dan River Basin Association, Roanoke River Basin Association, Southern
Alliance for Clean Energy, and Waterkeeper Alliance. June 1 and 2.
Duke Energy. 2016. Duke Energy Coal Plants and Ash Management. https://www.duke-
energy.com/pdfs/duke-energy-ash-metrics.pdf. June 2.
Haley & Aldrich. 2016. Report on Evaluation of Water Supply Wells in the Vicinity of Duke
Energy Coal Ash Basins in North Carolina — Appendix A — Allen Steam Station. April.
Haley & Aldrich. 2015. Report on Evaluation of NC DEQ Private Well Data. Volumes 1 and 2.
December.
HDR Engineering Inc of the Carolinas. 2015a. Comprehensive Site Assessment Report. Allen
Steam Station Ash Basin. August 23.
HDR Engineering Inc of the Carolinas. 2015b. Corrective Action Plan Part 1. Allen Steam Station
Ash Basin. November 20.
HDR Engineering Inc of the Carolinas. 2016. Corrective Action Plan Part 2. Allen Steam Station
Ash Basin. February 19.
21

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LeGrand, H.E. 2004. A Master Conceptual Model for Hydrogeological Site Characterization in
the Piedmont and Mountain Region of North Carolina. A Guidance Manual. North
Carolina Department of the Environmental and Natural Resources.
North Carolina Department of Environmental Quality. 2016. Press Release: "State Releases
Deadlines for Coal Ash Pond Closures, Will Request Changes to Coal Ash Law". May
18. Links for map of the proposed classifications and table of risk factors for
classification are:
http://portal.ncdenr.org/c/document —
library/get_file?p_I_id=1169848&folderld=268 8409
6&name=DLFE-125497.pdf, and
http://portal.ncdenr.org/c/document—library/get—file?pj_ld=l 169 84 8 &folderld=26 8 8409
6&name=DLFE-125496.pdf.
Oze, C., D.K. Bird, and S. Fendorf. 2007. Genesis of Hexavalent Chromium from Natural Sources
in Soil and Groundwater: PNAS 104, no. 16: 6544-6549.
Parette, R. 2016. Opinions on the Appropriateness of Monitored Natural Attenuation in
Conjunction with Cap -in -Place at the Allen Steam Station. May 13.
Pippin, C.G., M.J. Chapman, B.A. Huffman, M.J. Heller, and M.E. Schelgel. 2008. Hydrogeologic
Setting, Ground -Water Flow, and Ground -Water Quality at the Langtree Peninsula
Research Station, Iredell County, North Carolina, 2000-2005. Scientific Investigations
Report. U.S. Geological Survey. 2008-5055.
U.S. Environmental Protection Agency (USEPA). 1999. Use of Monitored Natural Attenuation at
Superfund, RCRA Corrective Action, and Underground Storage Tank Sites. 9200.4-17P.
Washington, D.C. April 21.
U.S. Environmental Protection Agency (USEPA). 2009. Statistical Analysis of Groundwater
Monitoring Data at RCRA Facilities Unified Guidance. EPA 530-R-09-007. March.
U.S. Environmental Protection Agency (USEPA). 2015a. Hazardous and Solid Waste
Management Systems: Disposal of Coal Combustion Residuals from Electric Utilities.
Federal Register. Vol. 80 No. 74. April 17.
U.S. Environmental Protection Agency (USEPA). 2015b. Use of Monitored Natural Attenuation
for Inorganic Contaminants in Groundwater at Superfund Sites. Directive 9283.1-36.
August.
Winters, T.C. 1976. Numerical Simulation Analysis of the Interaction of Lakes and Ground Water.
Professional Paper 1001. U.S. Geological Survey.
Wright, M.T., and K. Belitz. 2010. Factors Controlling the Regional Distribution of
Vanadium in Groundwater: Ground Water 47, no. 4: 515-525.
22

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Boron Concentration
0
6800
Rd
5e�r\SOn
Ree
AB-28S
1000 560
AB-25S
AB-24SL 2800
AB-24S A 650
658 AB-25SL
AB-23S 1700
561
S AB-21 S
AB-21SL 3800
7400
Catawba River
Figure 1

2-2- bVbVDObnr02 9 V220CIVlE2' [VIC'
Canal Rd
A
N
N
Ga�ON w r
e
GWA-6S
n Plant Allen Rd c5nn
0
River Run
GWA-15S
96
Warren C
ye
CL
dfh
e� n
G/en �n 3
d
1
Armstrong Rd�
n Ner
lllghland
c
0
o.
r
0
0
Wood Bend Dr
U
Boron Concentration
0
Rd Z-21
eOvalon
�s
oc
\y
o y
dq,
Q-
B-9S
10
Catawba River
VA-3S
D
A
OS
f�a
�
h
so
7�
h
Figure 2

2-2- bVbVDObnr02 9 V220CIV.LE2' jVIC'
Canal Rd
N
N
Ga�ON w r
e
0 is
Grat9
'�F4,
n
0
Plant Allen Rd
River Run
AB-14D
:Z��
159
Warren Dr �C
O'\(\
y oot
edfh s\0
e� n
R.
G/en �n 3
nFarm Rd
mMld`r1Ood Ln
�v+er Armstrong Rd o
a
lllghland WaY 3 Wildlife Rd
c
0
r
0
0
Wood Bend Dr It
U
S
Boron Concentration
0
O
A
BG-1 D f'PP
51.5 sP
A �o
7
oc
\y
,
y�
dq,
Q-
n
AB-33D
AB-32D
GWA-5D
180
490
673
n
AB-31 D
GWA-4D
300
740
AB-9D
AB-29D
AB-39D
595
Q
274
® 86.7
-
/\
AB-27D
� 1500
Catawba River
AB-25BRU
54.6
AB-26D
GWA-3D
G
A
242 A
110
AB-22D
1720
A
n
A
0
A
OS
f�a
�
h
so
7�
h
Figure 3

2-2- bVbVDObnrO2 9 V220CIV.LE2' jVIC'
Canal Rd
N
N
w r
Ga�a�
0
-
Plant Allen Rd
A
GWA-5BR
720
0
River Run
A
DI
Warren Dr
outhP°%\'\t
her n
Glen Ln c
O
Rd
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Rd
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9
0 62
a
Highland Way e grfe Rd,
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t
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U
-
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PH WELL
J
95.5
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o Rd
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,
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Figure 4

TABLES

2-2- bV6VDO6nroa g VaaociviEa' jwc-
Table 1
Monitoring Wells Identified in Cosler (2016) with Exceedances of Groundwater Standards
Well
Constituents of Interest (ug/L)
Comment
B
Sb
As
Ba
Cr
Co
Fe
Mn
SO4
TDS
V
Criteria
1 700
1
10
700
10
1
1 300
1 50
250,000
500,000
20
2L Standard or IMAC
Wells with Elevated Boron
AB-26S
1100
3.1
East Dike - active basin
AB-31 S
2200
12
26800
6,600
East Dike - inactive basin
AB-33S
750
670
337,000
761,000
near coal pile - inactive basin
AB-9S
660
7.1
4700
8560
East Dike at North Dike
GWA-3S
510
16.3
5600
3200
East Dike - active basin
GWA-4S
2600
5.2
600
East Dike - inactive basin
AB-26D
250
3.5
12.2
56.7
East Dike - active basin
GWA-4D
780
89
East Dike - inactive basin
GWA-5D
560
2.7
20.7
East Dike - inactive basin
GWA-5BR
750
East Dike - inactive basin
AB-25BRU
54
20
Beneath Pond 3 - active basin
Wells with Boron less than 50 ug/L
AB-10S
<50
1.5
556
AB-13S
<50
1
AB-2
<50
3.3
80
AB-4S
<50
110
AB-10S
<50
1.5
556
GWA-1S
<50
10.5
350
98
GWA-2S
<50
4.7
170
GWA-5S
<50
39.5
450
8100
GWA-7S
<50
56.7
400
GWA-8S
<50
GWA-9S
<50
7.1
420
GWA-15S
39J
230
AB-14D
37J
9.2
mislabeled by Cosler as AB-14S
GWA-2D
31J
GWA-15D
<50
69
GWA-913
<50
7.1
420
GWA-1BR
<50
GWA-6BR
<50
630J
250
AB-21BR
<50
17.9
AB-23BRU
35J
1.4
68.7
590,000
38
Notes: The monitoring wells listed are those included on Table 1 in Cosler (2016). For constituents other than boron, concentration listed only if reported concentration greater than 2L Standard or IMAC.

APPENDIX A

Appendix A
Curriculum Vitae of
Charles B. Andrews and
Rate of Compensation

2.2- bV6VD06nr oe 8F b220CIb.LE2' INC'
CHARLES B. ANDREWS
Hydrologist
AREAS OF EXPERTISE
■ Simulation of Groundwater and
Surface -Water Flow / Contaminant
Fate and Transport
■ Water Resource and Water Rights
Evaluations
SUMMARY OF QUALIFICATIONS
Dr. Andrews is nationally known for his creative solutions
to difficult water -resource problems. His areas of expertise
include the assessment and remediation of contaminated
sites; formulation of water -resource projects; assessment
of surface -water and groundwater flow and quality
conditions at hazardous waste sites; design of water
remediation systems; and development of new and
modification of off -the -shelf numerical simulation models
for adaptation to specific field projects. He has provided
technical guidance to significant water -rights litigation.
Dr. Andrews is a frequently requested member of
groundwater advisory panels for the evaluation of state-of-
the-art hydrology and for pioneering research and
evaluation of contaminant transport in the subsurface. He
is the author and co-author of numerous publications on
modeling of groundwater flow and transport of chemical
constituents, and the use of analytical models in identifying
appropriate remediation alternatives for a site.
REPRESENTATIVE EXPERIENCE
S.S. Papadopulos & Associates, Inc., Bethesda, MD
■ Agricultural Issues, Wisconsin — Worked with
operators and DAFOs of large irrigated farms and
dairies to develop crop -rotation and nutrient -
management plans to minimize potential for nitrogen
contamination of groundwater. For one project
involving the conversion of 4000 acres from pine
plantation to irrigated agriculture, developed a detailed
nitrogen balance of the expected agricultural practices
and a groundwater transport model. Subsequently
used these tools to develop cropping and nutrient
application schedules that minimize potential for
nitrogen contamination of groundwater. These
evaluations were incorporated into an environmental
impact statement for the project. Provided several
presentations regarding this work to State regulatory
agency and growers' associations.
• Contaminated Site Investigation and
Remediation
■ Expert Testimony
■ Peer Review
YEARS OF EXPERIENCE: 30+
EDUCATION
PhD, Geology, University of Wisconsin,
Madison, 1978
MS, Geology, University of Wisconsin,
Madison, 1976
MS, Water Resources, University of
Wisconsin, Madison, 1974
BA, Geology, Carleton College, 1973
American University of Beirut, Beirut,
Lebanon,1971-1972
REGISTRATIONS
Registered Geologist:
Alabama No. 1175
California No. 3853
Georgia No. PGO01689
Illinois No. 196001360
Mississippi No.859
Washington No. 2841
PROFESSIONAL HISTORY
S.S. Papadopulos & Associates, Inc.,
Principal, 1984 to present
President, 1994-2012
South University of Science and
Technology of China, Shenzhen
Visiting Professor, 2015 to present
Woodward - Clyde Consultants
Hydrogeologist and head of
Groundwater Section, 1980-1984
Northern Cheyenne Indian Tribe
Scientist, 1978-1980
Wisconsin State Government
Dept. of Justice and Dept. of Natural
Resources, Consultant,
1977-1978
University of Wisconsin, Madison
Dept. of Geology & Geophysics,
Research Assistant, 1975-1978
Dept. of Water Resources, Researcher,
1974-1975
Onondaga Lake, Syracuse, New York —Headed the
groundwater modeling effort for design of remedial
alternatives for this reputed -to -be the most contaminated lake in the U.S. Remediation costs

2.2- bV6VD06nr oe 8F b220CIVIE2' INC'
CHARLES B. ANDREWS
Hydrologist Page 2
projected to cost several hundreds of millions of dollars. Interacted frequently with and made many
presentations to the New York State Department of Environmental Conservation. This work is
ongoing.
• Large Industrial Site, Georgia — Conducted a detailed field and laboratory evaluation of the
leachability of PCBs from contaminated soils at this site. Developed innovative methods to
distinguish dissolved- and particulate -phase PCBs in leachate from batch tests.
• U.S. Army Corps of Engineers, Washington — Conducted detailed modeling evaluations of
seepage through the Howard Hanson Dam on the Green River. The evaluations were conducted
to assist in evaluations of dam stability and actions required to improve that stability as dam failure
would have large impacts on the lower river valley, including the Lower Duwamish Waterway.
■ Oregon Department of Environmental Quality and Cascade Corporation, Oregon — Assisted
the Department of Environmental Quality during the RI/FS process for the East Multnomah County
Groundwater Contamination Superfund Site and designed the extensive pump -and -treat system
for the site. In recent years, provided assistance to Cascade Corporation, one of the PRPs, on
methods to enhance remedial progress.
■ Confidential Client, Michigan —Conducted a detailed laboratory evaluation of analytical methods
for phenols in water samples. Determined that certain analytical methods were prone to false -
positive readings due to reactions with dissolved natural organic matter during the analytical
procedure. Identified the probable reaction pathways for the reactions that create phenols from the
dissolved organic matter.
• Williams Companies —Participated as a technical expert for a major pipeline company in a year-
long Consent Decree negotiations with the U.S. Dept. of Justice regarding soil and groundwater
contamination issues at 30 compressor station sites. Developed a comprehensive framework,
which was incorporated in the Consent Decree, for efficient, cost-effective investigation and
remediation of compressor stations. Subsequent to Consent Decree, provided (and continue to
provide) technical oversight for site investigation and remediation.
• Major Bottled -Water Company, Michigan —Providing on -going groundwater consulting services
for the identification and development of spring -water sources. This work involves development of
groundwater models to identify potential production rates, optimal pumping rates and locations,
and environmental effects of water production. Developed long-term monitoring plans and served
as expert witness in litigation related to development and operation of spring -water sources.
• Professional Review and Services, miscellaneous U.S. sites —Served as Chair of External Peer
Review Panel for Frenchman Flat CAU at the Nevada Test Site (2010). Served on a review panel
for the Hanford (Washington) site -wide groundwater flow -and -transport model (1989-2001).
Developed a groundwater model of the A- and M- areas at the Savannah River site, South Carolina,
(1985-1986).
■ Texas Eastern Pipeline Company, Eastern U.S. —Directed a study to evaluate the mobility and
fate of polychlorinated biphenyl compounds (PCBs) in the subsurface for over 30 contaminated
sites. These studies involved laboratory and field experiments to investigate the interactions
between PCBs and the subsurface materials, and to investigate the potential degradation of PCBs
in the subsurface. Long-term monitoring was selected as the appropriate remedial action at all the
sites.
■ New Mexico Attorney General: Hueco Bolson and the Mesilla Basins, New Mexico —
Evaluated the long-term availability of groundwater and the associated water -quality problems of
these large regional aquifers in southern New Mexico. Served as an expert witness in litigation
involving the proposed development of large water supplies from these basins.

2.2- bV6VD06nr oe 8F b22OCIVIE2' INC'
CHARLES B. ANDREWS
Hydrologist Page 3
• Industrial Sites, California and New Jersey —Managed remediation activities, including remedial
investigations, feasibility studies, remedial design and implementation, for industrial sites that are
extensively contaminated with arsenic and associated heavy metals. Several of these
investigations involved the evaluation of geochemical parameters that govern arsenic mobility in
the subsurface and groundwater/surface-water interactions.
Woodward -Clyde Consultants, San Francisco and Walnut Creek, California
Senior Project Manager of the 15-person Ground -Water Group: Responsible for water -resource
business development, technical review of all water -resource projects, and staff administration. As
Project Manager and Hydrology Task Leader, examples of projects included the development of
groundwater flow models of Madison Aquifer in Wyoming and the San Juan Basin in New Mexico;
analysis of reservoir -induced seismicity at the Aswan Dam; and development of a groundwater
model and remediation plan for a 12,000-acre site having 200 major source areas. Responsible
for developing the firm's state -of -the -practice capabilities in quantitative hydrology.
Northern Cheyenne Indian Tribe, Lame Deer, Montana
Directed and helped establish a comprehensive surface -water and groundwater monitoring
program, and established and managed the tribal computer system. Trained tribal members in the
operation and management of the hydrologic monitoring system and the computer system.
Participated in numerous administrative and legislative proceedings as an advocate for tribal
management of the reservation's natural resources.
Wisconsin Department of Justice and Department of Natural Resources, Madison, Wisconsin
Served as an expert witness for several judicial and administrative proceedings on cases involving
groundwater contamination and wetland drainage.
University of Wisconsin, Department of Geology and Geophysics, Madison, Wisconsin
Researched the impacts of heated -water seepage from a power plant cooling lake. Developed a
finite -element computer code to simulate water and heat transfer in shallow unconfined aquifers,
and designed and maintained an extensive field monitoring program to collect the data needed for
model verification.
University of Wisconsin, Department of Water Resources, Madison, Wisconsin
Conducted research that was funded by the U.S. Environmental Protection Agency -Denver, on the
impact of oil shale development to the groundwater and surface -water resources of northwestern
Colorado.
APPOINTMENTS
Trustee and Treasurer, Geological Society of America, 200 to present
Board of Visitors, Department of Geology, University of Wisconsin, 2004-2012
Water -Quality Advisory Group, Chairman, Montgomery County, Maryland, 2003-2007
Associate Editor, Ground Water, 1998-2013
Board of Directors of the Association of Groundwater Scientists and Engineers Division of the
National Ground Water Association, 1997-2001
National Research Council Committee on Groundwater Cleanup Alternatives, National Academy of
Sciences, 1991-1994

2.2- bV6VD06nr oe 8F b220CIVIE2' INC'
CHARLES B. ANDREWS
Hydrologist Page 4
National Research Council Committee on Groundwater Modeling Assessment, National Academy of
Sciences, 1987-1988
PROFESSIONAL SOCIETIES
American Chemical Society
National Ground Water Association
American Association for the Advancement of Science
Geological Society of America
PUBLICATIONS & PRESENTATIONS
Huang, X., C.A. Andrews, J. Liu, Y. Yao, C. Liu, S.W. Tyler, J.S. Selker, and C. Zheng. (in press).
Assimilation of Temperature and Hydraulic Gradients for Quantifying the Spatial Variability of
Streambed Hydraulics. Water Resources Research. Paper # 2015WR018408RR.
Andrews, C., 2011. How Much Modeling is Enough? Presentation at MODFLOW and More 2011:
Integrated Hydrologic Modeling. International Groundwater Modeling Center (IGWMC), Colorado
School of Mines, Maxwell, P., Hill, and Zheng, eds.
Andrews, C., 2011. Urban Recharge Myth: Case Study of Montgomery County, Maryland.
Presentation at the 2011 Ground Water Summit and 2011 Ground Water Protection Council
Spring Meeting. National Ground Water Association, Baltimore, MD.
Root, R.A., D. Vlassopoulos, N.A. Rivera, M.T. Rafferty, C. Andrews, and P.A. O'Day, 2009.
Speciation and Natural Attenuation of Arsenic and Iron in a Tidally Influenced Shallow Aquifer:
Geochimica et Cosmochimica Acta, Science Direct.
Johnson, T., C. Andrews, and M. Hennessey, 2009. Development of Chloride Profiles to Estimate
Groundwater Discharge for Cap Design in Onondaga Lake. Presentation at the Fifth International
Conference on Remediation of Contaminated Sediments, Jacksonville, FL. February 2-5, 2009.
Barth, G., and C. Andrews, 2009. Practical Problems, Practical Solutions. Presentation at the
National Groundwater Association's Annual Groundwater Summit, Tucson, AZ, April 19-23,
2009.
Andrews, Charles, 2008. One Hydrogeology —A New Paradigm for Model Construction: Modeling
with Google Earth. Presentation at MODFLOW and More 2008: Ground Water and Public Policy
Conference, May 18-21, 2008, Golden, CO.
Andrews, C.B., 2008. Review of "Effective Groundwater Model Calibration: With Analysis of Data,
Sensitivities, Predictions, and Uncertainty": Ground Water, v. 46, no. 1, p. 5.
Spiliotopoulos, A., and C.B. Andrews, 2007. Analysis of Aquifer Test Data - MODFLOW and PEST.
in Groundwater and Wells.(3rd ed.). Sterrett, R.J., ed. Johnson Screens, New Brighton, MN,
812 p.
Karanovic, M., C.J. Neville, and C.B. Andrews, 2007. BIOSCREEN-AT: BIOSCREEN with an Exact
Analytical Solution: Ground Water, v. 45, no. 2, pp. 242-245.
Andrews, C.B., and G. Swenson, 2006. Simulation of Brine Movement into Onondaga Lake.
Presentation at MODFLOW and More 2006: Managing Ground -Water Systems. International
Ground Water Modeling Center, Colorado School of Mines Golden, CO, May 22-24, 2006. v. 2,
pp. 480-483.
Neville, C.J., and C.B. Andrews, 2006. Containment Criterion for Contaminant Isolation by Cutoff
Walls: Ground Water, v. 44, no. 5, September -October, pp. 682-686.
Spiliotopoulos, A.A., and C.B. Andrews, 2006. Analysis of Aquifer Test Data - MODFLOW and
PEST. Presentation at MODFLOW and More 2006: Managing Ground -Water Systems.

2.2- bV6VD06nr oe 8F b220CIVIE2' INC'
CHARLES B. ANDREWS
Hydrologist Page 5
International Ground Water Modeling Center, Colorado School of Mines, Golden, CO, May
22-24, 2006. v. 2, pp. 569-573.
Vlassopoulos, D., N. Rivera, P.A. O'Day, M.T. Rafferty, and C.B. Andrews, 2005. Arsenic Removal
by Zerovalent Iron: A Field Study of Rates, Mechanisms, and Long -Term Performance. in
Advances in Arsenic Research: Integration of Experimental and Observational Studies and
Implications for Mitigation. O'Day, P., D. Vlassopoulos, X. Meng, and L. Benning, eds. ACS
Symposium Series, v. 915. Washington, DC: American Chemical Society, pp. 344-360.
Andrews, C., and C. Neville, 2003. Ground Water Flow in a Desert Basin: Challenges of Simulating
Transport of Dissolved Chromium. Ground Water, v. 41, no. 2, pp. 219-226.
Rafferty, M.T., C.B. Andrews, D. Vlassopoulos, D. Sorel, and K.M. Binard, 2003. Remediation of an
Arsenic Contaminated Site. Presentation at the 2261h American Chemical Society National
Meeting, September 7-11, 2003, New York City, NY.
Vlassopoulos, D., C.B. Andrews, M. Rafferty, P.A. O'Day, and N.A. Rivera Jr., 2003. In Situ Arsenic
Removal by Zero Valent Iron: An Accelerated Pilot Test Simulating Long -Term Permeable
Reactive Barrier Performance. Presentation at the 2261h American Chemical Society National
Meeting, September 7-11, 2003, New York City, NY.
Sorel, D., C.J. Neville, M.T. Rafferty, K. Chiang, and C.B. Andrews, 2002. Hydraulic Containment
Using Phytoremediation and a Barrier Wall to Prevent Arsenic Migration. In Proceedings of the
Third International Conference on Remediation of Chlorinated and Recalcitrant Compounds, May
20-23, 2002, Monterey, CA. Gavaskar, A.R., and A.S.C. Chen, eds. Battelle Press.
Vlassopoulos, D., J. Pochatila, A. Lundquist, C.B. Andrews, M.T. Rafferty, K. Chiang, D. Sorel, and
N.P. Nikolaidis, 2002. An Elemental Iron Reactor for Arsenic Removal from Groundwater. in
Proceedings of the Third International Conference on Remediation of Chlorinated and
Recalcitrant Compounds, May 20-23, 2002, Monterey, CA. Gavaskar, A., and A.S.C. Chen, eds.
Battelle Press.
Andrews, C., and C. Neville, 2001. Groundwater Flow in a Desert Basin: Complexity and
Controversy. in Proceedings of MODFLOW 2001 and Other Modeling Odysseys, September
11-14, 2001, International Groundwater Modeling Center, Colorado School of Mines, Golden,
CO, pp.770-775.
Andrews, C.B, 2000. The Great American Experiment: Pump -and -Treat for Groundwater Cleanup.
in Proceedings of the International Symposium on Groundwater Contamination, Japanese
Association of Groundwater Hydrology, Tokyo, Japan. June 26, 2000.
Andrews, C.B, 2000. The Meaning of Success in Assessing Groundwater Remediation.
Presentation at the Western Pacific Geophysics Meeting, June 27-30, 2000, Tokyo, Japan. Eos,
v. 81, no. 22, May 30, 2000.
Andrews, C.B., and D. Vlassopoulos, 2000. Modeling the Migration of Arsenic in Groundwater:
Understanding the Processes. Geological Society of America, Annual Meeting, October 2000,
Reno, NV. in Geological Society of America Abstracts with Programs, A406-7.
Vlassopoulos, D., and C.B. Andrews, 2000. The Intertwined Fate of Iron and Arsenic in
Contaminated Groundwater Entering a Tidal Marsh, San Francisco Bay. Invited Speaker
Presentation at the National Ground Water Association Theis 2000 Conference on Iron in
Groundwater, September 15-18, 2000, Jackson Hole, WY.
Lolcama, J.L., and C.B. Andrews, 1999. Catastrophic Flooding of a Quarry in Karstified Dolomite
(Abstract). Presentation at the NGWA National Convention and Exposition, December 3-6, 1999,
Nashville, TN. in Ground Water Supply Issues in the Next Century, 1999 Abstract Book.
Nashville, TN: National Groundwater Association.

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CHARLES B. ANDREWS
Hydrologist Page 6
Vlassopoulos, D., C. Andrews, R. Hennet, and S. Macko, 1999. Natural Immobilization of Arsenic in
the Shallow Groundwater of a Tidal Marsh, San Francisco Bay. Presentation at the American
Geophysical Union 1999 Spring Meeting, May 31-June 4, Boston, MA.
Andrews, C.B, 1998. MTBE: A Long -Term Threat to Ground Water Quality: Ground Water, v. 36,
no. 5, pp. 705-706.
Hennet, R., D.A. Carleton, S.A. Macko, and C.B. Andrews, 1997. Environmental Applications of
Carbon, Nitrogen, and Sulfur Stable Isotope Data: Case Studies (abstract). Invited Speaker
Presentation at the Geological Society of America Annual Meeting, Salt Lake City, UT, November
1997.
Zhang, Y., C. Zheng, C.J. Neville, and C.B. Andrews, 1996. ModIME User's Guide: An Integrated
Modeling Environment for MODFLOW, PATH3D, and MT3D. Version 1.1. Bethesda, MD: S.S.
Papadopulos & Associates, Inc.
Larson, S.P., C.B. Andrews, and C.J. Neville, 1995. Parameter Estimation in Groundwater
Modeling: Research, Development, and Application (abstract). American Geophysical Union
(AGU) Spring Meeting, Baltimore, May 30-June 2, 1995, Hydrology Sessions. S145, Abstract
H51C-02 0835h.
Andrews C.B. (co-author), 1994. Chapter 3—Performance of Conventional Pump -and -Treat
Systems, and Chapter 5--Characterizing Sites for Ground Water Cleanup. in Alternative Ground
Water Cleanup. Washington, DC: National Academy Press.
Hennet, R.J.-C., and C.B. Andrews, 1993. PCB Congeners as Tracers for Colloid Transport in the
Subsurface --A Conceptual Approach. in Manipulation of Groundwater Colloids for
Environmental Restoration. Ann Arbor, MI: Lewis Publishers, pp. 241-246.
Zheng, C., G.D. Bennett, and C.B. Andrews, 1992. Reply to the Preceding "Discussion by Robert D.
McCaleb of'Analysis of Ground -Water Remedial Alternatives at a Superfund Site'": Ground
Water, v. 30, no. 3, pp. 440-442.
Zheng, C., G.D. Bennett, and C.B. Andrews, 1991. Analysis of Ground -Water Remedial Alternatives
at a Superfund Site: Ground Water, v. 29, no. 6, pp. 838-848.
Andrews C.B. (co-author), 1990. Chapter 5--Experience with Contaminant Flow Models in the
Regulatory System. in Ground Water Models: Scientific and RegulatoryApplications.
Washington, DC: National Academy Press.
Andrews, C.B., D.L. Hathaway, and S.S. Papadopulos, 1990. Modeling the Migration and Fate of
Polychlorinated Biphenyls in the Subsurface. in Proceedings of the PCB Forum, Second
International Conference for the Remediation of PCB Contamination, April 2-3, 1990, Houston,
TX, pp. 64-82.
Hathaway, D., and C. Andrews, 1990. Fate and Transport Modeling of Organic Compounds from a
Gasoline Spill. in Proceedings of Petroleum Hydrocarbons and Organic Chemicals in Ground
Water; Prevention, Detection, and Restoration, National Water Well Association and American
Petroleum Institute, Houston, TX, October 31-November 2, 1990. Ground Water Management,
v. 4, pp. 563-576.
Stephenson, D.E., G.M. Duffield, D.R. Russ, C.B. Andrews, and E.C. Phillips, 1989. Practical Use
of Models in Ground Water Assessment and Protection Programs at the Savannah River Site:
Three Case Histories. Presentation at the Joint USA/USSR Conference on Hydrogeology,
Moscow, USSR, June 30-July 11, 1989.
Andrews, C.B., and S.P. Larson, 1988. Evolution of Water Quality in the Lower Rio Grande Valley,
New Mexico. Eos, v. 69, no. 16, p. 357.

2.2- bV6VD06nr oe 8F b220CIVIE2' INC'
CHARLES B. ANDREWS
Hydrologist Page 7
Larson, S.P., C.B. Andrews, M.D. Howland, and D.T. Feinstein, 1987. Three -Dimensional Modeling
Analysis of Groundwater Pumping Schemes for Containment of Shallow Groundwater
Contamination. Presentation at Solving Ground Water Problems with Models, Association of
Ground Water Scientists and Engineers, Denver, CO, February 10-12, 1987. in Solving Ground
Water Problems with Models: An Intensive Three -Day Conference and Exposition Devoted
Exclusively to Ground Water Modeling. Vol. 1. Dublin, OH: National Water Well Association,
pp. 517-536. February 11.
Looney, B.B., R.A. Field, G.B. Merrell, G. Duffield, and C.B. Andrews, 1987. Analyses of the Validity
of Analytical Models Used for Assessment of Forty -Five Waste Site Areas: Subsurface Flow and
Chemical Transport. in Solving Ground Water Problems with Models. Dublin, OH: National
Water Well Association, pp. 954-982.
Stephenson, D.E., B.B. Looney, C.B. Andrews, and D.R. Buss, 1987. Three -Dimensional
Simulation of Groundwater Flow and Transport of Chemical and Low -Level Radioactive
Constituents within Two Production Areas of the Savannah River Plant. in Proceedings of the 9th
Annual Low -Level Radioactive Waste Conference, U.S. Department of Energy, Washington, DC,
pp. 472-481.
Auerbach, S.I., C. Andrews, D. Eyman, D.D. Huff, P.A. Palmer, and W.R. Uhte, 1984. Report of the
Panel on Land Disposal. in Disposal of Industrial and Domestic Wastes: Land and Sea
Alternatives. Washington, DC: National Academy Press, pp. 73-100.
Andrews, C.B., 1983. Hydrogeology in North America —1932 to 1982. in The Revolution in Earth
Sciences: Advances in the Past Half -Century. Boardman, S., ed. Kendall/Hunt Publishing
Company.
Andrews, C.B., 1979. Impacts of Coal -Fired Power Plants on Local Ground -Water Systems.
Wisconsin Power Plant Impact Study. U.S. Environmental Protection Agency. EPA 600/3-80-
079. p.203.
Andrews, C.B., 1979. Statement of Dr. Charles Andrews, Hydrologist, Northern Cheyenne Tribe.
Hearings before the Select Committee on Indian Affairs. U.S. Senate, 96th Congress, pp. 412-
432.
Andrews, C.B., and M.P. Anderson, 1979. Thermal Alteration of Groundwater Caused by Seepage
from a Cooling Lake: Water Resources Research, v. 15, no. 3, pp. 595-602.
Andrews, C.B., W. Woessner, and T. Osborne, 1979. The Impacts of Coal Strip Mining on the
Hydrogeologic System of the Northern Great Plains —Case Study of Potential Impacts on the
Northern Cheyenne Reservation. Journal of Hydrology, v. 43, pp. 445-467.
Andrews, C.B., 1978. The Impact of the Use of Heat Pumps on Groundwater Temperatures.
Ground Water, v. 16, no. 6, pp. 437-443.
Andrews, C.B., and M.P. Anderson, 1978. The Impact of a Power Plant on the Groundwater System
of a Wetland. Ground Water, v. 16, no. 2, pp. 105-111.
Andrews, C.B., and E. Quigley, 1975. Designing and Maintaining Ponds for Swimming. University
of Wisconsin -Madison, Extension Publication G2678, p. 22.
DEPOSITION AND TESTIMONY EXPERIENCE
DEPOSITIONS
2015 Duke Energy Progress, Inc. v. N.C. Department of Environment and Natural Resources,
Division of Water Resources. State of North Carolina, Wake County in the Office of
Administrative Hearings. Case No. 15 HER 02581. July 31.

2.2- bV6VD06nr oe 8F b220CIVIE2' INC'
CHARLES B. ANDREWS
Hydrologist Page 8
2014 Emhart Industries, Inc. vs. New England Container Company, Inc., et al. vs. United States
Department of the Air Force, et al. vs. Black & Decker, Inc. United States District Court for
the District of Rhode Island. C.A. 06-218S and C.A 11-023S (Consolidated). November
17-18.
2014 Emhart Industries, Inc. vs. New England Container Company, Inc., et al. vs. United States
Department of the Air Force, et al. vs. Black & Decker, Inc. United States District Court for
the District of Rhode Island. C.A. 06-218-S and C.A 11-023-S (Consolidated). May 28.
2012 Commissioner of the Department of Planning and Natural Resources, Alicia V. Barnes, et al.
Century Alumina Company, et al. District Court of the Virgin Islands Division of St. Croix.
Civil No. 2005-0062. June 28-29.
2010 United States Virgin Islands Department of Planning and Natural Resources vs. St. Croix
Renaissance Group, L.L.L.P., et al. District Court of the Virgin Islands Division of St. Croix.
Civil No. 2007/114. October 20.
2010 United States Virgin Islands Department of Planning and Natural Resources v. St. Croix
Renaissance Group, L.L.L.P., et al. District Court of the Virgin Islands Division of St. Croix.
Civil No. 2007/114. October 22.
2010 New Jersey Department of Environmental Protection, The Commissioner of the New Jersey
Department of Environmental Protection and the Administrator of the New Jersey Spill
Compensation Fund vs. Essex Chemical Corporation. Superior Court of New Jersey Law
Division: Middlesex County. Docket No.: MID-L-5685-07. February 22.
2009 United States of America vs. Norfolk Southern Railway Company. U.S. District Court for the
District of South Carolina, Aiken Division. Civil Action No. 1:08-CV-01707-MBS. August 5.
2009 Michigan Citizens for Water Conservation, et al. vs. Nestle Waters North America, Inc.
State of Michigan Mecosta County Circuit Court. File No. 01-14563-CE. February 11 and
March 6.
2008 The Gillette Company vs. Onebeacon America Insurance Company, et al. Commonwealth
of Massachusetts Superior Court. 05-5102-BLS. December 4.
2008 Brian Wayne Meixner et al. vs. Emerson Electric Co. et. al. U.S. District Court for the
District of South Carolina, Aiken Division. 06-CV-01359-MBS. April 29.
2007 Glenn Gates and Donna Gates v. Rohm & Haas Company, et al. U.S. District Court for the
Eastern District of Pennsylvania. Civil Action No. 2:06-CV-01743-GP. November 16, 19.
2007 Methyl Tertiary Butyl Ether (MTBE) Products Liability Litigation, County of Suffolk and
Suffolk County Water Authority vs. Amerada Hess Corporation et al., United Water New
York, vs. Amerada Hess Corporation et al. U.S. District Court Southern District of New
York. 04 CIV. 5424 and 04 CIV. 2389. November 27, 28.
2007 Kay Ryan Corley, et al. v. Colonial Pipeline Company, et al. Hale County Circuit Court,
Alabama. CV-2005-138. September 6-7.
2003 American Home Products Corporation vs. Adriatic Insurance Company. Superior Court of
New Jersey Law Division: Hudson County. Docket No. HUD-L-5002-92. April 29.
2003 H. Todd Brinckerhoff, Jr., Harriet B. Haslett and MBM Company I, LLC vs. Shell Oil
Company and Motiva Enterprises, LLC. U.S. District Court, Southern District of New York.
Civil Action No. 02cv939. March 27.

2.2- bV6VD06nr oe 8F b220CIVIE2' INC'
CHARLES B. ANDREWS
Hydrologist Page 9
2003 Bernice Samples et al. vs. Conoco, Inc.; Agrico Chemical Company and Escambia Treating
Company, Inc. Circuit Court of the First Judicial Circuit in and for Escambia County, Florida.
No. 01-631-CA-01. March 18.
2002 Michigan Citizens for Water Conservation et al. vs. Nestle Waters North America, Inc. et al.
State of Michigan in the Circuit Court for the County of Mecosta. Case No. 01-14563-CE.
October 14.
2001 JBG/JER Shady Grove, LLC vs. Eastman Kodak Company. Circuit Court for Montgomery
County, Maryland. Civil No. 214877. October 25.
1999 Associated Aviation Underwriters, Inc. vs. Purex Industries, Inc. et al. Superior Court of the
State of California for the County of Los Angeles. No. ECO21744. August 9.\
1999 Flintkote Company and Genstar Corp. vs. Liberty Mutual Insurance Company et al. Superior
Court of New Jersey, Law Division, Bergen County. Docket No. 10288-97. March 26.
1998 GenCorp Inc. vs. Adriatic Insurance. Superior Court of New Jersey. Case No. 5:95CV 2464.
September.
1997 C-I-L Corporation of America and Marsulex, Inc. vs. NL Industries, Inc. et al. U.S. District
Court, District of New Jersey. Civil Action No. 93-2157 (WHW). January 21.
1995 Freehold -Carthage, Inc. vs. Lumbermans Mutual Casualty et al. vs. Hartford Insurance
Company vs. Minnesota Mining and Manufacturing Company. Superior Court of New Jersey.
Docket No. L-56812-90.
1995 Hughes Aircraft Company vs. Brian Eustace Beagley et al. Superior Court of the State of
California, County of Los Angeles. No. BC062120. February 10.
1993 Martin Marietta Corporation vs. Aetna Casualty & Surety et al. Superior Court of the State of
California for the County of Los Angeles. Case No. C610358.
1992 In re: Demand for Arbitration filed by Richard and Susan Ritchie and Exxon Corporation.
State of New Jersey, Department of Environmental Protection. Damage Claim No. 86-54-
0033. February 29.
TESTIMONY
2015 Emhart Industries, Inc. v. New England Container Company, Inc., et al. and Emhart Industries,
Inc. v. United States Department of the Air Force, et al. v. Black & Decker, Inc., et al. United
States District Court for the District of Rhode Island. C.A. Nos.: 06-218 S and 11-023 S. June
25.
2014 In the Matter of a Conditional High Capacity Well Approval for Two Potable Wells to be
Located in the Town of New Chester, Adams County, Issued to New Chester Dairy, Inc. and
Milk Source, Holding, LLC. Case No. DNR-13-011. State of Wisconsin Division of Hearings
and Appeals. January 16-17.
2013 In the Matter of a Conditional High Capacity Well Approval for Two Potable Wells to be
Located in the Town of Richfield, Adams County, Issued to Milk Source Holding, LLC. Case
Nos. IH-12-03, IH-12-04, IH-12-05, and IH-12-08. State of Wisconsin Division of Hearings
and Appeals. June 24, 25 and December 16, 20.
2010 Branham v. Rohm & Hass Company et al. Court of Common Pleas of Philadelphia County.
October 12-18.

2.2- bV6VD06nr oe 8F b220CIVIE2' INC'
CHARLES B. ANDREWS
Hydrologist Page 10
2010 New Jersey vs. Essex Chemical Corporation. Superior Court of New Jersey Law Division:
Middlesex County. Docket No.: MID-L-5685-07. March 19.
2008 Attorney General of the State of Oklahoma and Oklahoma Secretary of the Environment vs.
Tyson Foods Inc. et al. U.S. District Court for the Northern District of Oklahoma. 4:05-CV-
00329-TCK-SAJ. March 10.
2003 Michigan Citizens for Water Conservation et al. vs. Nestle Waters North America Inc. et al.
State of Michigan in the Circuit Court for the County of Mecosta. 01-14563-CE. June 6.
2003 Michigan Citizens for Water Conservation et al. vs. Nestle Waters North America Inc. et al.
State of Michigan in the Circuit Court for the County of Mecosta. 01-14563-CE. May 21.
2003 Michigan Citizens for Water Conservation et al. vs. Nestle Waters North America Inc. et al.
State of Michigan in the Circuit Court for the County of Mecosta. 01-14563-CE. May 19.
2001 JBG/JER Shady Grove, LLC vs. Eastman Kodak Company. Circuit Court for Montgomery
County, Maryland. Civil No. 214877. December 13.
1995 Anderson et al. vs. Pacific Gas and Electric Company. Superior Court of the State of
California for the County of San Bernardino. Case No. BCV00300. July.
1995 Hughes Aircraft Company vs. Brian Eustace Beagley et al. Superior Court of the State of
California, County of Los Angeles. No. BC062120.
1995 Anderson et al. vs. Pacific Gas and Electric Company. Superior Court of the State of
California for the County of San Bernardino. Case No. BCV00300. February 13.
RATE OF COMPENSATION
Mr. Andrews' rate of compensation is $272.00 per hour.