NC0004774_C. Andrews - Final Buck Expert Report_20160630

Expert Report of
Charles B. Andrews
Buck Steam Station
Salisbury, 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
Buck Steam Station
Salisbury, 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]

Table of Contents
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Page
Listof Figures................................................................................................................................. ii
Listof Tables
.................................................................................................................................. 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
PrivateWells............................................................................................................
11
Background Concentrations.....................................................................................
12
GroundwaterModel.................................................................................................
13
Monitored Natural Attenuation................................................................................
13
Cap -in -Place Remedy..............................................................................................
14
Section 7
Rebuttal of Plaintiffs' Experts.................................................................................
15
RobertParette...........................................................................................................
15
Steven Campbell and Richard Spruill......................................................................
15
Section8
References................................................................................................................
18
Figures
Tables
Appendices
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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 Tables
Table 1 Monitoring Wells with Boron Concentrations Greater than 50 ug/L and
Exceedances of Groundwater Criteria for Other Constituents of Interest
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 with respect to alleged releases from ash basins at the Buck Steam
Station, Salisbury, 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 governmental 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 Site on August 13,
2014 and September 22, 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.
Ash Basin Cell 1 with Buck Combined Cycle Station in Background — August 14, 2014
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Section 2
Background
The Buck Steam Station is a former six -unit coal-fired electric generating station that began
operation in 1926. The final coal-fired units were retired in April 2013. On the site is a 620 MW
natural gas facility, referred to as the Buck Combined Cycle Station (BCCS), that began operation
in late 2011. The site is located just south of the Yadkin River in Rowan County near Salisbury,
North Carolina. Water levels in the Yadkin River are influenced by the High Rock Dam located
about 13.5 miles downstream of the Buck facility. The average annual flow of the Yadkin River
is reported to be 4,237 cfs and the 7 -day 10 -year low flow is reported to be 702 cfs (HDR, 2016).
The river classification is Class WS -V.
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 Yadkin River. The current footprint of the
ash basins is 171 acres. The ash basin system consists of three cells. There are 5.3 million tons of
ash within the footprint of the ash basins, which includes the ash in the unlined ash storage area
(Duke Energy, 2016).
The ash basin system consist of three cells, earthen dikes, discharge structures and two
canals. The ash basins are operated as a part of the station's wastewater treatment system.
Currently, the ash basins receive
inflows from the station yard
drain sump, stormwater flows,
and BCCS wastewater.
Stormwater flows are estimated
to average about 0.36 million
gallons per day, and flows from
the BCCS average about 1.3
million gallons per day, with
most of the flow from the
cooling towers and condenser
system. During the later years
of operation of the coal-fired
units, flows to the ash basins
averaged 4.4 million gallons per
day.
The original ash basin,
which corresponds to the
current Cells 2 and 3, was
constructed in 1957 by building
a dam along the Yadkin River.
This original dam had a crest of
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680 feet MSL, approximately 60 feet above the level of the Yadkin River. The crest of the dam
was raised 10 feet in 1977 when the ash basin was subdivided into the current Cells 2 and 3. Cell
1 was constructed in 1982. The combined footprints of Cells 2 and 3 are approximately 81 acres
and the footprint of Cell 1 is 90 acres. In June 2015, the water levels in the ponds in Cells 1, 2 and
3 were 701 feet MSL, 682 feet MSL and 673 feet MSL, respectively (HDR, 2015a, page 12).
An unlined ash storage area is located adjacent to the east side of Cell 1. The area was
constructed in 2009 by removing ash from Cell 1 to increase storage for sluiced ash. The footprint
of the ash storage area is approximately 14 acres.
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 — Buck
Steam Station Ash Basin" (HDR, August, 2015a), "Corrective Action Plan Part 1 — Buck Stream
Station Site" (HDR, November 2015b), and "Corrective Action Plan Part 2 — Buck Steam Station
Site" (HDR, February, 2016). These reports are referred to as the CSA report, the CAPI 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 is primarily volcanic tuffs and flows with minor
intrusives that have been metamorphosed to upper amphibolite grade of metamorphism (CSA,
page 10). The alluvium is reported to be up to 32 feet thick, the saprolite and weathered rock is
reported to be between 24 and 117 feet thick, and the weathered/fractured bedrock zone is reported
to range up to 16 feet thick (CAP 1, page 38). Groundwater flow is generally from south to north
beneath the ash basins toward the Yadkin River. A topographic divide is located approximately
along Leonard Road to the south of the ash basins and the groundwater divide is likely located in
proximity to the topographic divide.
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1.1
Section 3
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Groundwater Contamination from Ash Basins
Porewater within the ash basins contains a number of dissolved inorganic constituents at
concentrations that are greater than those typically found in groundwater in the vicinity of the Buck
site. 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, sixteen
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),
nickel (Ni), selenium (Se), pH, sulfate (SO4), thallium (Tl) 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).'
The water quality of the porewater in the ash basins has been characterized by porewater
samples collected from 10 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 provide information
on the dissolved concentrations in the porewater that can potentially migrate to groundwater. Only
two of the constituents of interest exceed the 2L Standard 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 at Buck
2L Standard
IMAC
Median
Concentration
75 -Percentile
Concentration
90 -Percentile
Concentration
Antimony (u /L)
1
1.7
8.9
15
Arsenic (u L)
10
340
470
927
Barium (m /L)
0.7
0.30
0.43
0.57
Boron (ug/L
700
1,500
2,375
4,448
Chromium (ug/L)
10
1.5
4.2
8.4
Chromium VI (u )
0.01
0.02
0.4
Cobalt (u /L)
1
1.7
4.2
9.5
Nickel (u /L)
100
4.9
11
19
Selenium (ug/1-
20
0.21
0.52
0.93
Sulfate (mg/L)
250
78
128
198
Thallium (u L)
0.2
0.1
0.23
0.61
TDS (mg/L
500
277
425
741
' The 2L groundwater quality standards are established under 15A NCAC 02L.0202. 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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Vanadium (ug/L 20 9.8 1 40 166
The long-term leachability of the constituents of interest from the ash within the ash basin
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. This
test method provides an estimate of leaching potential for the conditions utilized in the test
procedure. The median, 75 -percentile and maximum concentrations reported in the leaching liquid
from these tests are listed on table below. Arsenic is the only constituent of interest that exceeds
the 2L Standard based on median and 75 -percentile concentration, and chromium exceeds based
on 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
Maximum
Concentration
Antimony (u /L)
1
4.4
6.0
8.5
Arsenic (u )
10
20
122
205
Barium m /L)
0.7
0.23
0.35
0.49
Boron (ug/L)
700
108
118
345
Chromium (u /L)
10
2.2
13
43
Cobalt (u /L)
1
0.5
2.0
30
Nickel u /L)
1.2
3.7
19
Selenium (ug/L
20
1.1
2.9
27.4
Sulfate (mg/L)
250
14.5
24.3
32.6
Thalium (ug/L)
0.2
0.02
0.09
0.5
Vanadium (u /L)
20
45
168
345
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.2 Boron concentrations in the ash porewater are elevated much more above
background levels than is sulfate at the Buck facility. Thus, boron is the better tracer for 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 well at the Buck 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
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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reported values of greater than 50 ug/L are posted on Figures 2 to 4. The analytical detection limit
for samples from some private wells were greater than 50 ug/L; these wells are not displayed on
Figure 4.
The highest boron concentrations in groundwater are located beneath the ash basins and
adjacent to the river. The pattern of elevated boron concentrations are consistent with infiltration
of water from the ash basins to the groundwater and migration of groundwater with elevated
concentrations of boron toward and into the river. Seeps have been observed along the small
tributary to the Yadkin River to the northeast of Cell 3, along the toe of the main dike for Cells 2
and 3 and along the small tributary to the Yadkin River to the northwest of Cell 1. The elevated
boron concentrations measured in some of these seeps is consistent with migration from the ash
basins toward the river.
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 less than the 2L standard or IMAC or detected at relatively low concentrations
(relative to concentrations in the ash porewater) at many of the monitoring wells with reported
boron concentrations greater than 50 ug/L. A tabulation of all monitoring wells with dissolved
boron concentrations greater than 50 ug/L and the concentrations of other constituents of interest,
if greater than groundwater criteria, are listed on Table 1. Over thirty percent of monitoring wells
with boron concentrations greater than 50 ug/L do not have exceedances of groundwater criteria
for the other constituents of interest3.
Arsenic, which is reported in ash porewater at concentrations well above the 2L standard,
was only reported in two monitoring wells, excluding those completed in the ash, at concentrations
above the 2L standard (AB-5BRU and GMA-18D). The dissolved arsenic concentrations in these
wells were reported as 26.7J+ ug/L and 15.2 ug/L, respectively. The total arsenic concentration in
AB-5BRU, though, was only 7.1 ug/L. The dissolved concentration, rather than the total
concentrations, reflects the arsenic with the potential to migrate with groundwater. Both of these
wells are located between Cell 3 and the river.
3 This includes monitoring wells A13-11), A13-813RU, A13-913, AS -113, MW -11D, MW -1D, MW -3D, MW -4D, MW -
5D, and MW -5S. In addition, monitoring wells GWA-413, MW -3D, and MW -4S only have exceedances of 2L
Standards for manganese. The maximum reported manganese concentrations in these three wells is 70 ug/L.
IN

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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 Buck facility. This corrective
action is required to be sufficient to protect public health, safety, and welfare; the environment;
and natural resources; and to be consistent with 15A NCAC 02L.
The CAP2 report states that Duke is planning to utilize cap -in-place as a source control
measure at the Buck 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 (recharge) of
water from the ash to the underlying groundwater will be significantly reduced. This reduced
infiltration will lower water levels within the ash, but will not completely dewater the ash. Some
groundwater will continue to flow through the remaining 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 with the
groundwater toward and diffusely discharge into the river. The analyses that were conducted for
the CAP2 report indicate that this continuing discharge to the river is 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.
Experts for the Plaintiffs in this litigation opine that the appropriate corrective action for
groundwater at the Buck facility is removal of all of the ash within the ash basins as well as
additional remedial components. The expert report of Campbell and Spruill states (Campbell and
Spruill, 2016b, page 36):
"We are more convinced than ever that Duke should do for the Buck site what is being [sic] doing
for seven of the other coal ash sites in North Carolina and all coal ash sites in South Carolina;
promptly excavate and transfer the coal ash to an engineered, encapsulating, water free, properly
maintained, and regularly -monitored repository. We also assert that coal ash derived
contamination impacting groundwater and surface water will require additional assessment after
the coal ash is removed, and that the contamination will require remediation using methods
protective of human health and the environment, in particular the potable groundwater resources
used by many hundreds of people living near the Buck site. "
In addition, another Plaintiffs' expert opines that:
"Monitored Natural Attenuation is not an appropriate remedy for constituents of interest (COIs)
at the Buck site " (Parette, 2016, page 10).
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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
2) due to saturated ash remaining in place ash basin related constituents will continue to migrate
to the river. 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 based on available information, and 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 Plaintiffs' expert reports contain limited or no discussion of most of these factors, even though
they opine on the appropriate corrective action.
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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 Buck 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 ash -related 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
Yadkin 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 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 corrective actions for groundwater.
• 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 Yadkin 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 Buck.
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 Buck facility have been
collected as part of the investigations conducted at the facility. Groundwater quality data are
available from 101 monitoring wells, over 75 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 8,800 ug/L
(which is more than 175 times greater than the background
boron concentration). Second, dissolved boron, which occurs
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 -° 0 2 Q 6 PH $ ao 12 14
constituents of interest with migrating groundwater. Boron E"H [] Wam for B -0-H system
dissolved in groundwater as boric acid is relatively non-reactive in
the subsurface as it is not sorbed onto mineral surfaces and is stable under a range of Eh and pH
conditions. Many of the dissolved constituents of interest, unlike boron, sorb to mineral surfaces
and/or complex with metal oxides. This results in an apparent rate of migration of these 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 since boron is still present in
porewater in the ash basins, boron is a reliable indicator of any ash -related contamination. A
corollary to this last sentence is that absent elevated boron concentrations in a groundwater sample,
it is unlikely that the groundwater sample has been contaminated by the migration of ash related
10

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constituents from the ash basins. A possible 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 (USEPA, 2015b).
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
indicates that boron has migrated from the ash basins to groundwater discharge areas along and
beneath the Yadkin River. Under current conditions, some groundwater with elevated
concentrations of boron discharges to seeps along the Yadkin River and tributaries. Groundwater
with elevated concentrations of boron also discharges diffusely to the wetlands adjacent to the
river and to the beds of the river and its tributaries. Groundwater with elevated concentrations of
boron does not migrate under the river, all groundwater containing elevated concentrations of
boron is flowing toward the north and discharges into the river and into low lying areas to the south
of the river.
The monitoring data from the Buck facility clearly illustrates that migration of most of the
identified constituents of interest in groundwater is retarded relative to the rate of migration of
boron in groundwater. A tabulation of all monitoring wells with dissolved boron concentrations
greater than 50 ug/L and the concentrations of other constituents of interest, if greater than
groundwater criteria, are listed on Table 1. Over thirty percent of monitoring wells with boron
concentrations greater than 50 ug/L do not have exceedances of groundwater criteria for the other
constituents of interest. This demonstrates that the migration in groundwater of other constituents
of interest is attenuated relative to the migration of boron.
Private Wells
Seventy-seven private wells within one-half mile of the Buck 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 Buck facility. Boron was detected only in two and the 77 wells sampled, at
concentrations of 5.8 ug/L and 7.7 ug/L, respectively (which are in range of background boron
concentrations).' Concentrations of all other potential ash basin -related constituents also were
within the range of background concentrations. These results are consistent with groundwater flow
4 The detection limit for 12 of the water samples from private wells were greater than 50 ug/L.
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�S
from beneath the ash basins towards the Yadkin River or its tributaries, and not toward the
upgradient residential wells. These flow patterns are also consistent with the observation that the
highest nitrate concentrations in groundwater occur in the monitoring wells located along the
southern and southeastern perimeter of the ash basins, consistent with nitrate sources in the
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 Buck
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. Drs. Campbell
and Spruill have opined that contaminated groundwater migrates rapidly in the fractured bedrock
aquifer in response to fracture orientation, fracture connectivity, head distribution and hydraulic
influences from pumping by area water -supply wells (2016a, pages 10-11). With rapid migration
in the fractures, it is expected that if migration of ash related constituents from the ash basins to
the private wells is occurring, that the migration of the more mobile of these constituents to the
private wells would have already occurred given the time since initial use of the ash basins.
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 Buck 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 concentrations of 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.6 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
concentrations) represent a range of concentrations in the vicinity of the Buck 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 for vanadium and total dissolved solids, as in my opinion, the water -quality results
from these wells represent background groundwater quality. Water -sample results are available
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 Dendorf (2007) and Wright and Belitz (20 10) for a discussion of the influence of nature
of geologic materials on hexavalent chromium and vanadium, respectively, in groundwater.
12

2.2- bVbVDObnrO2 9� V22OCIV1E2' JWC'
�S
for 77 wells within one-half mile of the Buck facility, and an additional nine wells that are located
much further from the facility. The results from the sampling of the wells within one-half mile of
the site indicate that vanadium concentrations in bedrock range from <1 ug/L to 25.6 ug/L with a
median value of 3.5 ug/L and a 75 -percentile value of 6.1 ug/L. The results from the sampling
indicate that total dissolved solids concentrations in bedrock range from <25 mg/L to 1,130 mg/L
with a median value of 89 mg/L and a 75 -percentile value of 113 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 Buck 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 a 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 Buck facility and vicinity is described in the CAP 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, as are all models, is a simplified representation of a
complex groundwater system. 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 1 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, and it is only
one component of the evaluations being conducted to choose an appropriate corrective action for
groundwater.
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 2015a, page 7). The primary natural attenuation processes for boron at the
Buck 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
13

2.2- bVbVDObnr02 9� V220CIV1E2' IMC'
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 percolated
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
100 million gallons per year. This recharge reduction will result in a nearly identical reduction of
the diffuse groundwater discharge from beneath the Buck facility to the Yadkin River. This
reduction in groundwater discharge to the Yadkin River will, by itself, result in a reduction in the
mass flux of ash -related constituents to the Yadkin 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 in a diffuse manner to the Yadkin River. The
decline in the water -table beneath the ash basins, and adjacent areas, will result in the groundwater
divide on the south moving northward. This will result in groundwater levels that demonstrate
more clearly than current groundwater levels, the northward components of groundwater now
beneath the ash basins.
The cessation of vertical water movement through the ash following capping is not
anticipated to lead to 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 at most locations, with a median Eh reading of -37.5 and ranging to as low as -205.
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
Yadkin River based on 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, and not toward areas with private wells, and water -
quality standards in the river will not be exceeded.
14

2.2- bVbVDObnr02 9� V220CIV1E2' JWC'
Section 7
Rebuttal of Plaintiffs' Experts
Robert Parette
Dr. Parette in his expert report states his major opinion as follows:
"Monitored natural attenuation is not an appropriate remedy for constituents of interest
(COIs) at the Buck site. " (Parette, 2016, page 8).
Dr. Parette's opinion is inconsistent with the extensive groundwater quality data collected
at the Buck 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 (MMA) will be less
favorable following capping as he believes capping will lead to more anoxic conditions. As
explained in Section 6, groundwater conditions are not likely to become more anoxic following
capping. The data show, however, significant retardation of antimony, chromium and cobalt
relative to boron under current conditions. 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.
Steven Campbell and Richard Spruill
Drs. Campbell and Spruill prepared an initial expert report and an addendum to the initial
expert report (2016a, 2016b). The primary opinions of Drs. Campbell and Spruill are stated on
page 8 of the Addendum (2016b):
• "...the most protective remediation option for coal ash at the Buck property is complete
excavation," and
•
"...coal ash -derived contamination impacting groundwater and surface water will require
additional assessment after coal ash is removed, and that the contamination will require
remediation using methods protective of human health and the environment, in particular
the potable groundwater resources used by many hundreds of people living near the Buck
Site."
The foundation for their rejection of a cap -in-place remedy is that with a cap -in-place remedy
"...water will continue to saturate considerable volumes of coal ash, resulting in the
delivery of ash -derived contaminants indefinitely to the groundwater system and the
Yadkin River" (Addendum, page 2), and
"... exceedances [of groundwater standards] will persist for decades to centuries under the
current site conditions and under Duke's recommendation to cap the coal ash, and that
15

2.2- bVbVDObnr02 9� V220CIV1E2' IMC'
ash -contaminated groundwater will continue to discharge to the Yadkin River for decades
to centuries (Addendum pages 1-2), and
"We conclude that Duke's own data and map indicate that groundwater has potential to
migrate toward the southeast and east, groundwater in the southeastern portions of the
Buckproperty will flow toward area residential properties and potable water supply wells,
and this indication exists even though the influence of dozens of pump water -supply wells
is not revealed by incorporating water -level data south of the Buck property. " (Addendum
page 10).
It is important to note the Drs. Campbell and Spruill did not evaluate, or opine, on the
impact of a continuing migration of the ash -derived constituents to the Yadkin River. As noted in
Section 6 above, the existing groundwater discharge does not result in an exceedance of surface -
quality standards in the river, and will not result in an exceedance in the future. Drs. Campbell
and Spruill note that: "...most residential water -supply wells in the area have been pumping for
decades in proximity to the coal ash pits... " and yet failed to note that sampling of approximately
77 of the private wells failed to detect migration of ash -related constituents to any of the sampled
wells despite such operation of the residential wells. Drs. Campbell and Spruill focus on
interpretation of existing groundwater levels but do not opine on future groundwater levels and
groundwater flow directions with a cap -in-place or source removal corrective action. As noted in
Section 6 above, a cap -in-place remedy will alter groundwater levels from existing conditions due
to a reduction of groundwater recharge. As a result, the groundwater mounding that currently exists
beneath the ash basins will cease to exist and groundwater flow directions will be more clearly
toward the river beneath the ash basins.
Drs. Campbell and Spruill have numerous opinions regarding what they perceive to be
flaws in the groundwater modeling analyses described in the CAP and CAP2 reports. As noted
in Section 6, the model is only a tool that has been used to assist in the evaluation of the
groundwater data collected at the Buck facility. The model is not intended to be an exact
representation of the actual groundwater. The simplifications of the real groundwater system that
have been made in developing the groundwater model do not alter the underlying groundwater
data that have been collected at the facility. It is these data that provide the foundation for
evaluating alternative corrective actions for groundwater.
Drs. Campbell and Spruill opine that existing monitoring wells cannot provide any
information about naturally -occurring constituents of interest and that no proper analyses have
been conducted to establish natural background concentrations (2016b, page 1). The deficiencies
that they note are in my opinion irrelevant to selecting an appropriate corrective action. In addition,
it is my opinion that there are abundant data available for estimating the ranges of background
concentrations of constituents of interest in the vicinity of the Buck facility and that existing
monitoring data provide significant information about naturally -occurring constituents of interest.
Drs. Campbell and Spruill also opine that the evaluations of on-site and off-site geology
and hydrogeology is simplistic, incomplete and inadequate (2016a, page 5). The primary
foundation for this opinion, based on my understanding of the report, is that groundwater flow in
the bedrock aquifer is through fractures and the fractures have not been appropriately
characterized. Groundwater flow in fractured bedrock at the fracture scale is complex, but at a
16

2.2- bVbVDObnr02 9� V220CIV1E2' IMC'
�S
larger scale groundwater flow in the bedrock is not complex. At the Buck facility, a large body of
information on bedrock conditions has been obtained from the bedrock wells and borings at the
facility and from private wells in the vicinity. As noted in Section 6, approximately 77 bedrock
wells used for water supply in the vicinity of the facility have been sampled. The water -quality
data from these wells clearly and unambiguously demonstrate that groundwater flow from the ash
basins has not affected water quality in these wells.
17

2.2- bVbVDObnr02 9� V220CIV1E2' IMC'
Section 8
References
Abney, M.A., J.J. Hall, and J.R. Quinn. 2011. Assessment of Balanced and Indigenous Populations
in the Yadkin River and High Rock Lake Near Buck Steam Station. NC0004774. Duke
Energy. March.
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/600/54-89/032. September.
Brookins, D.G. 1988. Eh pH Diagrams for Geochemistry: Springer -Verlag Berlin Heidelberg.
Campbell, S.K., and R.K. Spruill. 2016a. Expert Report Addendum #1 Buck Steam Station. May
12.
Campbell, S.K., and R.K. Spruill. 2016b. Expert Report Buck Steam Station. February 29.
Campbell, S.K., and R.K. Spruill. 2016c. Expert Report. Buck Steam Station (Federal). May 12.
Duke Energy. 2016a. Duke Energy Coal Plants and Ash Management. https://www.duke-
energy.com/pdfs/duke-energy-ash-metrics.pdf. June 2.
Duke Energy. 2016b. Emergency Action Plan (EAP), Duke Energy Buck Station Ash Basin Dam.
DUK-EAP-00-0001, Rev. 003, May 16.
Duke Energy Corporation. 2011. Duke Energy Carolinas LLC - NPDES Permit Application Buck
Steam Station - #NC0004774. February 28.
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. Buck
Steam Station Ash Basin. August 23.
HDR Engineering Inc of the Carolinas. 2015b. Corrective Action Plan Part 1. Buck Steam Station
Ash Basin. November 20.
HDR Engineering Inc of the Carolinas. 2016. Corrective Action Plan Part 2. Buck Steam Station
Ash Basin. February 19.
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 Environment and Natural Resources. 2011. Permit NC0004774 -
Permit for Duke Energy to Discharge Wastewater Under the National Pollutant Discharge
Elimination System. Buck Steam Station. December 2.

2.2- bVbVDObnr02 9� V220CIV1E2' JWC'
SSU
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_l_id=1169848&folderld=2688409
6&name=DLFE-125497.pdf, and
http://portal.ncdenr.org/c/document—library/get—file?p—l—id=l 169848&folderld=2688409
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., and Matson & Associates. 2016. Opinions on the Appropriateness of Monitored
Natural Attenuation in Conjunction with Cap -in -Place at the Buck 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. Use of Monitored Natural Attenuation
for Inorganic Contaminants in Groundwater at Superfund Sites. Directive 9283.1-36.
August.
U.S. Environmental Protection Agency (USEPA). 2015b. Hazardous and Solid Waste
Management Systems: Disposal of Coal Combustion Residuals from Electric Utilities.
Federal Register. Vol. 80 No. 74. April 17.
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.
19

FIGURES

2.2- bVbVDObnrO2 9 V220CIVlE2' jWC'
Yadkin River (High Rock Lake)
AB -7S
600 A AB-7SL
2000
AB -5S AB-5SL AB -8S
464- 800 1800
8800
AB -4S r
150
AB -2S
1830
A
AB-2SL
3920
AB -3S
2600
Grant Rd
j
s
at
��
ye
t
aures St
Boron Concentration
0
A 'a
Figure 1

Boron Concentration
0
A
Yadkin River (High Rock Lake)
GWA-9S
�r,�4M-2S
303
W
487
0
0
t
aures St
Figure 2
2.2- bVbVDObnrO2 9 V220CIVJ.E2' [MC'
A
GWA-3S
62.A
A MW -5S
259

Yadkin River (High Rock Lak
e p� GWA-9D
_ Jhfa t't 266
r
A
Boron Concentration
0
A
MW -1 D
593
GWA-10D
90
A
Figure 3
2.2- bVbVDObnrO2 9 V220CIV.LE2' [MC'
A
MW -5D
388
O
Grant Rd

Boron Concentration
D
IF
O
41jq-1
�9t
Yadkin River (High Rock Lake)
0
GWA-9BR
230
2.2- bVbVDObnrO2 9 V22OCIVIE2' IMC'
® Is
GWA-SBRU
350
A MW -11 D
0 0 AB-9BR 1320
420 A
AB-SBRU AB-8BRU
120 65.3
® A
63.6
63.6A 5 —
0
des St B
6�
O ;J•k � O
Figure 4
B
Grant Rd
O C
n

TABLES

2.2- bV6VD06nrO@ g br@20CiviE@' IVIG'
Table 1
Monitoring Wells with Boron Concentrations Greater than 50 ug/L and
Exccedances of Groundwater Criteria for Other Constituents of Interest
Well
B
Sb
As
Cr
Constituents of Interest (ug/L)
Co Fe Mn Se
Comment
TI v SO4 TDS
Criteria
700
1
10
10
1 300 50 20
0.2 20 250,000 500,000 2L Standard or IMAC
AB -10D
1900
17.4
27 130
A13-1 D
1500 J
AB-2BR
110
1.3 J
23.1
A13 -2D
630
3.2 360 130
AB-513RU
120
26.5 J+
27.6 J+
30.6
1.7 J+
42.8
A13-76RU
140
1.8
17.9
AB-8BRU
52
AB -8D
83
1.2
11.9
AB-9BR
420
12.3
26
A13-96RU
790
300
A13-913
1000
1
AS -1 D
360
AS -1 S
3000 J
356 4100 21
0.2 703000 1240000
GWA-3S
62
1.9 3000
GWA-41D
220
59
GWA-4S
260
1.1 50
GWA-513RU
350
310 180
GWA-913R
230
2.3
GWA-9D
220
1.4 683 120
GWA-9S
280
67.4 2100
GWA-18D
100
15.2
MW -11D
1100
MW -11S
410
1.8 280
MWAD
510
MWAS
730
22.3
MW -3D
640
60
MW -3D
630
MW -3S
860 J+
17.9 740 1200
MW -3S
920
18.4 720 1200
MW -4D
630
MW -4S
490
70
MW -5D
340
MW -5S
220
Notes: Maxium dissovled concentrations reported in CSA sampling. Only concentrations greater than groundwater critiera are listed for constituents others than boron.

APPENDIX A

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

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.
2'2' bV6VD06nr oe 8F b220CIb.LE2' INC'
• 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 226th 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 226th 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 --4 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.

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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.