2016-05-12 GMA, Expert Report-Addendum for Buck Steam Station

EXPERT REPORT
Addendum #1
BUCK STEAM STATION
1555 Dukeville Road
Salisbury, NC 28146
PREPARED FOR:
Southern Environmental Law Center
601 West Rosemary Street, Suite 220
Chapel Hill, NC 27516
Telephone [phone]
PREPARED BY:
Groundwater Management Associates, Inc.
4300 Sapphire Court, Suite 100
Greenville, North Carolina 27834
Telephone: [phone]
GMA
May 12, 2016
Steven K. Campbell, Ph.D, PG
Senior Hydrogeologist
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Richard K. Spruill, Ph.D, PG
Principal Hydrogeologist
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Executive Summary
Dr. Richard K. Spruill and Dr. Steven K. Campbell, both hydrogeologists at Groundwater
Management Associates, Inc. (GMA), produced an expert report dated February 29,
2016, that concerns known or potential hydrogeologic impacts of coal combustion
byproducts (i.e., coal ash) located at Duke Energy's Buck Steam Station facility, Rowan
County, North Carolina. Here we provide an addendum to the expert report focused on
Part 2 of Duke's Corrective Action Plan (CAP) for the Buck property. None of our
opinions expressed in the original expert report have changed. Our addendum opines
on a supplement that Duke produced for their Comprehensive Site Assessment (CSA), it
expands upon preliminary opinions regarding Part 2 of the Buck CAP expressed in the
expert report, and it provides additional opinions about the CAP, including computer
simulations of groundwater flow, contamination fate and transport simulations, and
Duke's proposal to'remediate'the Buck property by covering the coal ash in place and
monitoring water -quality conditions for an undefined period. Expert opinions provided in
this addendum to our original report include the following:
1) Duke continues to rely upon 'background' monitoring wells that are not proven to
be located hydraulically upgradient of the coal ash pits, and thus cannot provide
a� information about naturally -occurring concentrations of any "constituent of
interest' (COI).
2) Despite production of additional analytical data for background' monitoring wells
that reveal "fluctuations," Duke has not modified any "preliminary provisional
background concentration" (PPBC) that they claim occur naturally at a particular
concentration in groundwater present at all depths, and regardless of the type of
geologic material (e.g., stream alluvium versus fractured bedrock).
3) To date, Duke has not performed the evaluation required to establish any natural
background' concentration for any'COI' at or near the Buck property.
4) The CAP provides computerized contaminant fate and transport (F&T)
simulations that indicate that multiple groundwater contaminants located outside
and inside their coal ash "compliance boundary" exceed North Carolina
groundwater -quality standards, exceedances will persist for decades to centuries
under the current site conditions and under Duke's recommendation to cap the
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coal ash, and that ash -contaminated groundwater will continue to discharge to
the Yadkin River for decades to centuries.
5) Duke's computer model is contrived so that migrating groundwater can only exit
the modeled space (domain) through discharge at the Yadkin River and a
tributary. Other than along the Yadkin River, the model domain is enclosed by a
"ono -flow" boundary that prevents any groundwater flow across that boundary
under all circumstances (e.g., by pumping supply wells outside the boundary).
6) Duke's decision to employ a "no -flow" boundary explicitly excludes more than
120 Duke -identified residential water -supply wells located within 0.5 miles of the
Buck property from simulations involving the migration of groundwater and ash -
derived contamination. Nineteen of 58 Duke -identified residential supply wells
located inside the model domain were intentionally omitted from inclusion in the
computer simulations.
7) Duke made numerous hydrogeologically-unrealistic assumptions and
simplifications regarding the 39 water -supply wells that they included in their
computer model. For example, Duke simulates 'pumping' of these 39 wells at a
very low and constant rate, while real-world wells are pumped at much higher
withdrawal rates for shorter periods numerous times each day. Furthermore,
most residential water -supply wells in the area have been pumping for decades
in proximity to the coal ash pits, and not for 1 year as Duke chose to simulate.
8) Duke's computer modeling projects that the static level of groundwater beneath
the capped areas of coal ash will decrease by 33 to 35 feet, but no simulation
details are provided beyond elimination of all groundwater recharge above the
coal ash pits. It is our opinion that capping approximately 185 acres of the Buck
coal ash will result in much less real-world decline in the water level at the ash
pits than Duke's simulated 33 to 35 feet. Duke's over -estimation of groundwater
level decline is a result of how the computer model was constructed and is not
consistent with basic groundwater hydrogeology.
9) Duke's F&T model produces the appearance that groundwater contamination is
'remediated' by capping the coal ash, primarily because their computer model
was adjusted so that no additional contaminants are allowed to enter their model
domain at the capped coal ash locations. Even if dewatering of the capped ash
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occurs exactly as Duke simulated, water will continue to saturate considerable
volumes of coal ash, resulting in the delivery of ash -derived contaminants
indefinitely to the groundwater aquifer system and the Yadkin River.
10) We conclude that: (A) the most protective remediation option for coal ash
at the Buck property is complete excavation and transfer to a
engineered, encapsulating, water -free, properly -maintained and
monitored repository, and (B) 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.
I. Introduction and Scope
Groundwater Management Associates (GMA) has been retained by the Southern
Environmental Law Center (SELC) to provide expert geologic and hydrogeologic
consulting regarding coal combustion by-product (CCB) storage and disposal by Duke
Energy, Inc. (Duke). GMA's services have included producing an expert report focused
on the known or potential hydrogeologic impacts of CCBs located at Duke's Buck Steam
Station (BSS) facility within very large, unlined pits (aka, basins, ponds, or lagoons) and
a large, open pile of dry CCBs. The purpose of the report provided here is to act as
Addendum #1 to GMA's expert report dated February 29, 2016.
The general history of production and on-site storage of CCBs at the BSS is described in
our expert report, as well as our observations and expert opinions regarding Duke's
assessment documents released through early 2016. In the period since our expert
report was submitted, GMA has been provided, or has obtained from public sources,
additional documents and electronic files that supplement the more than 31,000 pages
of information that Duke made available to the North Carolina Department of
Environmental Quality (NCDEQ) and its predecessor (NCDENR) prior to our report.
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Additional documents that were supplied to GMA, or were obtained from public sources,
and were reviewed after our expert report was submitted to SELC, include: (1) NCDEQ
correspondence and reports that directly or indirectly reference risk to human health
and the environment and/or NCDEQ's "site risk" classification and remediation at the
BSS facility, (2) a report submitted to NCDEQ prepared by the SELC, the Yadkin
Riverkeeper, and the Waterkeeper Alliance, that responded to NCDEQ's classification of
the BSS as a "low risk" site, (3) a map prepared by Duke that identified the proposed
off-site location fora cluster' of monitoring wells. SELC provided GMA with a DVD
produced by Duke for the BSS site that contained 1,277 electronic computer
groundwater flow and contaminant fate and transport (F&T) modeling files totaling 28.1
gigabytes of data, and (4) Duke's electronic files of field and laboratory analytical results
for two quarters ('Round 4" and "Round 5'� of sampling of four pairs of background'
monitoring wells (BG-1S/D, BG-2S/D, BG-3S/D, and MW-6S/D) available through
NCDEQ's website http://edocs.deq.nc.gov/WaterResources/Browse.aspx?startid=221202&dbid=0.
GMA addresses aspects of some of these additional documents and information below.
II. Oualifications
Dr. Richard K. Spruill and Dr. Steven K. Campbell, both hydrogeologists at GMA, are
submitting this addendum to our expert report dated February 29, 2016. Our
qualifications and resumesare provided in the expert report. The descriptions,
interpretations, conclusions, and professional opinions described within this addendum
to the expert report are subject to revision, expansion, or retraction as additional
information becomes available.
III. Expert Opinions about Duke's Assessment and Remediation at Buck
Our review of new or previously -available information have not changed the opinions
provided in our expert report. We are aware that Duke is conducting additional
activities that may require expansion or revision of our addendum provided here.
Specifically, Duke began actively installing 22 additional groundwater monitoring wells
and two borings in January 2016, but we have not been provided with any information
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regarding installation, sampling, testing and/or interpretations regarding those wells or
borings. We have not seen any results from Duke's "First Quarter 2016 sampling event"
mentioned in Part 2 of the Corrective Action Plan (CAP), nor have we seen results from
any sampling and testing presumably conducted by Duke since August of 2015 for
surface water (including, seeps, springs, streams, ponds, and the Yadkin River).
A. The Comprehensive Site Assessment (CSA) for the BSS Property
A.I. General CSA Observations and Opinions in our Expert Report
Duke's CSA is massive (>9,400 pages), and it is only available through NCDEQ's
website. As of May 12, 2016, the downloadable CSA is still missing all but one
monitoring well construction record and at least three figures (11-1, 12-1, and 12-2),
including Duke's oft -cited "site conceptual model" (SCM), so we consider the CSA
incomplete.
Duke acknowledged in the CSA that contaminant concentrations in samples collected
from seeps and springs located inside and outside the BSS ash -pit "compliance
boundary" exceed applicable water -quality standards. A sample collected by GMA from
a seep on February 10, 2016 also documented contaminated groundwater from the BSS
site discharging at the surface (Appendix A).
We opine in our expert report that Duke's CSA: (1) is an incomplete and simplistic
evaluation of on-site and off-site geology and hydrogeology, (2) does not assess
adequately the fractured, crystalline, bedrock aquifer system that is the primary source
of water for all water consumers residing near the BSS property, and (3) failed to
consider or incorporate the construction, locations, pumping -induced influences, and
groundwater analytical data available for dozens of off-site, potable water -supply wells
used by people living near the Buck property.
A,2. Additional Observations and Opinions Regarding the CSA and the CSA
Addendum Provided in the BSS Corrective Action Plan (CAP) Part 2
It remains our opinion that Duke's CSA is seriously flawed, and it does not provide an
adequate basis for production and implementation of a CAP. Duke claimed that CSA
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"data gaps" (i.e., deficiencies) would be addressed within a "CSA Supplement" prior to
submitting a CAP to NCDEQ. However, no 'supplement' was produced prior to or within
Duke's CAP Part 1.
Appendix A of CAP Part 2 is referred to as a "CSA Addendum" or "CSA Supplement 1"
consisting of 3,384 pages dominated by a mass of raw data or tabulations. Some
components of Appendix A lack explanation, interpretation, and/or integration into the
CSA, the SCM, or the CAP. Duke's reported installation of at least two borings and 22
additional groundwater monitoring wells around the periphery of the ash -pits
"compliance boundary" that began in early 2016 is certainly a basic assessment activity
worthy of describing within a CSA 'supplement,' but it is not clear if Duke plans to
produce any 'supplements' even though Attachment 3 of Appendix A indicates that some
additional CSA -level assessment data will be supplied to NCDEQ in "Summer 2016."
Item 3 of the introductory memo to Appendix A states that "Responses to NCDEQ
comments obtained during in person meetings are included in the results [sic] are
included in Attachment 3 to this CSA Supplement 1." Attachment 3 is a short table that
briefly summarizes Duke's responses to 25 critiques, concerns, suggestions, or directives
provided by unidentified NCDEQ staff. Item 5 of Attachment 3 states that NCDEQ
"Specifically request that concentrations be declared background," to which Duke claims
that their proposed 'background' concentrations are "statistically derived." It might be
true that a few of Duke's self -identified "constituent ofinteresP' (COI; i.e., contaminant)
were produced via statistics, but we repeat here a statement on page 22 of our expert
report: Duke has failed to perform the evaluation required to establish Any
natural background' concentration for any TOY at or near the Buck property.
Item 5 of the Appendix A introduction states that "64 well construction records (that)
were inadvertently omitted (from the CSA) have been included in Attachment S' of
Appendix A. However, Duke yet again supplied dozens of copies of a single well
construction record for well A13 -1D, and we remain unable to evaluate the well records.
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Prior to the CSA, Duke and NCDEQ agreed to the use of "low -flow" sampling methods to
collect groundwater samples from monitoring wells, reportedly in order to minimize
sample turbidity, ostensively to produce more "reliable" analytical results. The potential
for turbid groundwater samples is reduced by withdrawing relatively little water at a
very slow rate from a single point in a well during purging.' Minimal withdrawal also
means that the samples collected can gRly represent groundwater quality changes in the
aquifer through time if the natural (non -pumping) groundwater flow through the well's
filter pack and screen is adequate to provide a time -representative sample of the
surrounding aquifer's groundwater. In the case of fractured crystalline rock, low -flow
sampling in even the very short (5 foot) screens that Duke used in their bedrock'
monitoring wells may be selectively sampling from a single fracture, even if multiple
fractures are potentially open to the well. Relying exclusively on "low -flow" sampling
methods may be skewing analytical results for some BSS monitoring wells to produce an
appearance of contaminant homogeneity through time, although most wells appear not
to have been sampled more than two or three times to date. This potential to miss
variations in groundwater quality at a monitoring well location bears on Duke's statistical
and empirical interpretations of COI spatial and temporal distributions, their claims
about 'background' concentrations, and computer F&T simulations and projections.
Ironically, Duke has stated that "No strong correlation can be made between turbidity
and the number of Cols exceeding the 2L Standards, IMA C5, or NCDHHS HSL. In some
cases, turbidity increased and the number of COls in a given well decreased." (CAP Part
2, Page 14)
B. The Corrective Action Plan (CAP) for the BSS Property
B.I. Genera/ CAP Part 1 Observations and Opinions in our Expert Report
Duke's CAP was produced in two parts, and the combined length of the two parts of the
CAP is 20,853 printable pages, plus 1,277 electronic files (28.1 gigabytes), and an
unknown number of datasets, electronic files, and iterations of computer simulations.
Our expert report focused on Part 1 of the CAP because Part 2 became available to GMA
only five days before our expert report was due. CAP Part 2 is the focus of Section B.2
of this addendum to our expert report. Some portions of CAP Part 1 appear to be
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supplemented or supplanted by some portions of CAP Part 2, although such an intent or
relationship is seldom identified explicitly by Duke.
Duke concludes that the following COIs are "...attributable to the (coal ash) source area
at Buck...": antimony, boron, chromium, hexavalent chromium, cobalt, iron, manganese,
nickel, selenium, sulfate, total dissolved solids (TDS), thallium, and vanadium. (CAP Part
1, pages 45-50) CAP Part 1 concluded that ash -derived groundwater contaminant
concentrations will exceed the 15A NCAC 2L or IMAC standards "...at the compliance
boundary and at the Yadkin River..." (page 64) for numerous COIs for decades or
centuries into the future. Duke acknowledged that multiple contaminants, both outside
and inside their coal ash "compliance boundary," exceed North Carolina groundwater -
quality standards, that those exceedances will persist for decades to centuries into the
future under the current site conditions and under their proposed cap -in-place
remediation' plan, and contaminated groundwater will continue to discharge to the
Yadkin River for decades or centuries.
We opined previously that Duke's CAP Part 1: (1) is built upon a simplistic, incomplete,
and inadequate CSA and SCM, (2) includes many unsupported and erroneous claims
about natural ly-occurring 'background' groundwater quality, including reliance upon data
obtained from several background' monitoring wells that Duke admits are not proven to
be located hydraulically upgradient of the BSS coal ash pits, and (3) includes
groundwater flow and contaminant F&T computer models that are built upon a seriously
flawed, and greatly simplified, hydrogeologic framework that does not consider the
complexities of groundwater migration in fractured bedrock, and the modeling ignores
the influence of pumping from many dozens of water -supply wells located near the Buck
property. We have not changed our opinions that CAP Part 1 is seriously flawed and
inadequate, Duke's computer modeling cannot evaluate the potential delivery of ash -
derived groundwater contaminants to the majority of known potable water -supply wells
located within 0.5 miles of the Buck facility, and Duke has failed to establish �Iny natural
background' concentration for any `COI' in groundwater at or near the Buck property.
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B,2 Observations and Opinions Regarding Duke's CAP Part 2
Section C of our original expert report provided preliminary opinions about CAP Part 2
(also see Section B.1. above). We opined in the original expert report that the 3,384
pages comprising the "CSA Addendum" of CAP Appendix A is predominantly raw data or
tabulations that often lack explanation, interpretation, and/or integration into the CSA,
the SCM, or the CAP. Appendix A is referenced exactly once in the CAP report (Part 2
hereafter, unless otherwise identified), so we conclude that many of the components of
the CSA Addendum are not integral to the CSA, the SCM, and/or the CAP.
CAP Appendix A includes 'revised' CSA Table 11-7 through 11-11 regarding critical
aquifer properties, but Duke provides no explanation of what was revised, why revisions
were necessary, or how those changes might impact �jny aspect of the SCM and/or the
groundwater -flow model and/or the F&T simulations. Our comparison of the CSA and
CSA Addendum versions of these tables reveals significant differences for many aquifer
parameters that directly impact rates and directions calculated (or simulated through
computer modeling) for groundwater flow and contaminant migration. However, the
groundwater flow and F&T computer modeling described in CAP Appendix B (discussed
below) g -al -y references the original CSA tables, and Duke's computer modeling
parameters are typically different from actual Buck -specific measurements (e.g.,
hydraulic conductivity).
In the CAP, Duke now defines any areas "...ofponded orf/owing water thatis not
attributable to stormwater runoff' as "areas of wetness (AOW)." (CAP, page 15)
Employing the creative term "AOW" allows Duke to avoid using more commonly
understood terms like spring and seep, thus obscuring the fact that an "AOW"
represents a place where groundwater discharges at the surface.
We opine below on five general topics addressed within the CAP; (1)
groundwater -quality data and violations, (2) the "refined" SCM, (3) additional analytical
data for'background' monitoring wells, (4) the "refined" groundwater flow computer
model, and (5) the "refined" contaminant F&T simulations and Duke's proposed
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"corrective action(s)" for the Buck facility. We discuss aspects of these five items below,
including reference to opinions that we provided in our original expert report.
B,2,1, Groundwater -Quality Data and Violations
The CAP contains a mass of raw analytical data and tabulations for "Round 2"
samples of "...groundwater, surface water, and areas of wetness..." (CAP, page 7)
However, "Round 2" (September 2015) analytical data are not evaluated in the context
of "Round 1" (June -July 2015) analyses because Duke claims that the combined dataset
consists of only two comprehensive sampling events and therefore does not consider
seasonal fluctuations or other temporal changes." (CAP, page 13) Duke does not
mention why five months elapsed between collecting samples in September 2015 and
releasing the data in CAP Part 2, nor do they explain how those "seasonal fluctuations or
other temporal changes" may impact naturally -occurring background' concentrations of
groundwater "constituents of interest (COI)."
Duke claims that "Round 2" groundwater -level measurements show patterns of
groundwater flow consistent with flow directions identified in Round 1..." (CAP, page
11) Provided below are contoured maps showing the distribution of hydraulic head
(water level) for Duke's "deep" monitoring wells in July 2015 (top) and September 2015
(middle). Comparison of these maps shows differences in hydraulic gradient, local flow
patterns, and orientation of arrows that Duke used to depict the horizontal component
of groundwater flow. We have added arrows illustrating the horizontal component of
groundwater flow to a portion of Duke's September 2015 map (bottom). 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 Buck
property will flow toward area residential properties and potable water -supply wells,
and this indication exists even though the influence of dozens of pumping water -supply
wells is not revealed by incorporating water -level data south of the Buck property. An
equally important issue revealed by this indicated easterly groundwater migration is that
Duke's critically important background' well MW -6D and BG -3D are located hydraulically
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downgradientof a coal ash pit. We address Duke's alleged background' monitoring
wells and naturally -occurring' PPBCs below in Section B.2.3.
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Duke downplays the widespread extent of ash -derived groundwater contamination at
and near the Buck property. Unsupported or outright false statements are common
within the CSA and CAP, and some of Duke's graphical depictions are inaccurate or
misleading (e.g., the vanadium example discussed above). Duke consistently ignores
the effects of pumping area residential wells, other than through their unrealistic
inclusion of only 39 of 179 Duke -identified potable water -supply wells within their
computer model simulations (addressed below in Section B.2.4.).
An example of downplaying the extent of groundwater contamination at Buck is
shown in Duke's most current map (CAP Figure 2-5, provided below) that employs
yellow shading to illustrate where Duke claims that coal ash -derived groundwater
contamination exists. However, Figure 2-5 does not show the distribution of individual
'COIs' (e.g., vanadium), it does not show spatial distributions or variations with depth
(e.g., bedrock aquifer), and it greatly understates the widespread groundwater
contamination that Duke acknowledged previously. In CAP Figure 2-5 (top), the yellow
shaded area should encompass all COI exceedances, as enclosed by the yellow line in
the map (CSA Figure 10-49, bottom) showing Duke's horizontal extents of vanadium.
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A second example of how Duke attempts to minimize the appearance of their
groundwater contamination is shown below in the CAP's hydrogeologic cross section for
their site conceptual model. (CAP, Figure 3-2) The image unrealistically depicts
horizontal groundwater flow directly along the surface of the fractured bedrock aquifer,
the only ash -derived groundwater contamination is located directly below the coal ash
pits, and the groundwater contaminant plume terminates inexplicitly at the AB -9 well
cluster; these are all basic components of the SCM that Duke has chosen to portray
incorrectly and unrealistically, and the resulting image is misleading, at best.
Page 14

B. 2 2 The "Refined"Site Conceptual Model (SCM)
Duke claims that one purpose of CAP Part 2 is to provide a 'refined" SCM. However,
Duke states explicitly that "...no revisions are warranted For the SCM at this time" (CAP,
page 33), and there is no "refinement" evident in their SCM (e.g., see our critique of
Figure 3-2 in the previous section). Despite Duke's claim that their underlying SCM
required no modifications in CAP Part 2, their refined' groundwater flow computer
model discussed below in section 13.2.4. indicates that major revisions were in fact made
to the "underlying" SCM. It is our opinion that the Buck SCM is ad hoc,
superficial, fundamentally flawed, and inadequate.
B,2,3, Additional Analytical Data for 'Background' Monitoring Wells
We reaffirm here our original opinion that Duke has failed to perform the evaluation
reauired to establish anv naturally-occurrina 'backaround' concentration for anv 'COI' at
or near the Buck property. Duke admits in CAP Part 1 that many of their 'background'
monitoring wells are apparently located hydraulically down_aradientof the BSS ash pits,
as detailed within our original expert report. However, Duke ignored this critical issue
Page I5
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B. 2 2 The "Refined"Site Conceptual Model (SCM)
Duke claims that one purpose of CAP Part 2 is to provide a 'refined" SCM. However,
Duke states explicitly that "...no revisions are warranted For the SCM at this time" (CAP,
page 33), and there is no "refinement" evident in their SCM (e.g., see our critique of
Figure 3-2 in the previous section). Despite Duke's claim that their underlying SCM
required no modifications in CAP Part 2, their refined' groundwater flow computer
model discussed below in section 13.2.4. indicates that major revisions were in fact made
to the "underlying" SCM. It is our opinion that the Buck SCM is ad hoc,
superficial, fundamentally flawed, and inadequate.
B,2,3, Additional Analytical Data for 'Background' Monitoring Wells
We reaffirm here our original opinion that Duke has failed to perform the evaluation
reauired to establish anv naturally-occurrina 'backaround' concentration for anv 'COI' at
or near the Buck property. Duke admits in CAP Part 1 that many of their 'background'
monitoring wells are apparently located hydraulically down_aradientof the BSS ash pits,
as detailed within our original expert report. However, Duke ignored this critical issue
Page I5

throughout CAP Part 2, even though their September 2015 equipotential map shows
clearly that several 'background' monitoring wells are located hydraulically downgradient
of the coal ash pits (also see our discussion above in Section 13.2.1.). The downgradient
position of these wells makes them unsuitable for evaluating the naturally -occurring
'background' concentrations of any COI.
CAP Part 1 revealed Duke's PPBCs for their COIs based on "Round 1" (June -July
2015) analytical data and limited older data for two alleged 'background' wells (MW -6S
and MW -6D). CAP Part 1 did not disclose analytical data for "Round 2" (and "Round T
sampling conducted prior to production of that report, although the Round 2 data were
available to Duke r[or to producing their PPBCs. Duke acknowledged in CAP Part 2 that
"Fluctuations in the total number of exceedances reported at individual (background)
wells were noted when comparing Round 1 to Round 2 results" (CAP, page 14)
However, Duke provides no evaluation of what such "fluctuations" might indicate
regarding their claims about naturally -occurring 'background' COI concentrations other
than to state noncommittally that "Background monitoring wells will continue to be
sampled and PPBCs recalculated as the data set increases with additional sampling
rounds " (CAP, page 14)
Our review of the analytical data reported for Duke's 'background' monitoring wells
through March 28, 2016 ("Round 5'� indicates that concentrations fluctuate substantially
for some analytes in some wells, although we cannot discern a clear pattern in Duke's
choice of which wells to sample and when, whether samples are pre -filtered in the field
or not, or which analytes are targeted for laboratory analysis. Unlike the June -July 2015
(Round 1) sampling reported in the CSA, Duke has elected not to provide their sampling
field records in the CAP, so we cannot review pertinent sampling field measurements
(e.g., static water level and purge volume). Duke's o lY robust 'background' data set is
for the MW-6S/D well pair, yet those two wells were omitted from Round 2 and Round 3
sampling and 5 months separate the sample collected on June 30/July 1 and December
10, 2015. Similarly, at least 4.5 months have elapsed since bedrock 'background' well
BG-lBR was reportedly last sampled on November 11, 2015 (Round 3) and at least
March 28, 2016, when the MW-6S/D well pair was sampled (Round 5). In contrast to
Page 16

this significant lapses between sampling some 'background' wells, only three weeks
separated the Round 3 and Round 4 sampling events, so those analytical data tend not
to vary noticeably, as one would expect from the fact that "low -flow" sampling would be
sampling essentially the same well water twice.
Duke obfuscates by seldom providing clear explanations for why certain analytical
data are emphasized in their report. For example, Table 2-8 in CAP Part 2 is a
"Constituents of Interest Evaluation" consisting of tabulated COI detections through
Round 4 for each well, and each concentration is color coded as greater than or less
than Duke's PPBCs. Although the applicable North Carolina groundwater -quality
"criteria" (e.g., a 15A NCAC 2L standard) is listed in the header of Table 2-8 beneath
each COI, concentrations exceeding those values are not identified. The table lists only
the concentration of the "total" constituent, not the "dissolved" concentration or the
higher of the two when both were measured for the same sample. Our review of Duke's
full dataset indicate that the "total" concentration is often roughly equal to, or greater
than, the "dissolved" concentration (when both are reported). However, there are also
cases where the "dissolved" concentration is greater than the "total" concentration.
Significantly, Duke's methods for establishing their PPBCs does not distinguish between
"total" and "dissolved" concentrations, as exemplified by their decision to declare their
hexavalent chromium PPBC using a single detection of dissolved Cr(VI) in 'background'
well BG-1BR. (see CAP Part 2, Table 2-5, page 1 of 8) Table 2-8 lists every Cr(VI)
detection as below their PPBC, including the 6.5 fag/L total Cr(VI) detected in well BG-
1BR. The table and related text in the CAP fail to acknowledge that every single
detection of Cr(VI) listed exceeds the applicable 0.07 pg/L "criteria." Nevertheless, the
CAP persists with the false claim that Cr(VI) occurs naturally at 78 pg/L throughout the
Buck property and the surrounding area in all aquifer materials and at all depths (e.g.,
CAP, Appendix B, page 21).
It is our opinion that Duke has failed to perform the evaluation required
to establish any natural 'background' concentration for Any COI' at or near
the Buck property.
Page 17

8,24, "Refined" Groundwater Flow and Contaminant Fate and Transport
(F& T) Computer Model
CAP Part 1 included a computer model of groundwater flow, and that model was the
basis for computer simulations of contaminant F&T under the scenarios of: (1) do
nothing, (2) leave the coal ash in place and install a low -permeability cover (e.g., clay)
over the pits, and (3) remove the ash from the pits for storage in an engineered and
fully lined repository. All coal ash pits in South Carolina are reportedly being remediated
by the third method. Between CAP Part 1 and CAP Part 2, Duke abandoned the option
to remediate the coal ash pits at Buck by removal and complete encapsulation in a lined
facility, and that method was not evaluated in CAP Part 2. Our expert report addressed
some key aspects and concerns regarding computer modeling included in CAP Part 1,
and we do not need to repeat or revise those opinions. We focus here on Duke's
"refined" groundwater flow computer model described in CAP Part 2, and as detailed in
CAP Appendix B. We address Duke's contaminant F&T computer model results below in
Section B.2.5.
Duke states that their refined' computer "...model domain extends beyond the
ash management areas to hydrologic boundaries such that groundwater flow and
COI transport through the area is accurately simulated without introducing
artificial boundary effects" (CAP, Appendix B, page 11, emphasis added) This
statement is false because most of Duke's model domain is enclosed by a 'ono -flow"
boundary that, by definition, is an intentionally artificial modeling boundary that has no
real-world equivalent at or anywhere near the Buck propertx. Duke's no -flow
boundaries reportedly coincide with land surface topographic divides so that they can
apply their hydrogeologically-unrealistic and completely unproven claims that
topographic divides define multiple, perfectly vertical divides in groundwater hydraulic
head, and that those presumed divides extend downward hundreds of feet through
multiple aquifers composed of a wide variety of geologic materials. No -flow boundaries
in groundwater flow computer models do not allow groundwater to migrate across the
boundary under gny circumstance, including seasonal changes in groundwater recharge
or discharge and under the influence of pumping by dozens, or even hundreds, of
water -supply wells located immediately outside the model domain. In fact,
Page 16

predominantly northward flow directed away from residential water -supply wells is
required by Duke's computer model because roughly three-fourths of the model domain
defining the west, south, and east sides is a no -flow boundary. The remainder of the
model's domain is enclosed by a specified head boundary (i.e., the Yadkin River) and
"drains" (e.g., minor streams) that constrain simulated groundwater discharge to
specific places, primarily along the northern edge of the model domain. Duke lacks
defendable field data from the area to support these assumptions about their model
domain. Surface topographic features may have no effect on groundwater flow patterns
in the subsurface, especially for deep aquifers with significant heterogeneity and
anisotropy such as the fractured crystalline bedrock aquifer beneath the Buck property
that is the source of water extracted from area residential water -supply wells.
Duke made numerous, fundamental changes to their computer model between the
original' and 'refined' versions, including the critical choice of number, size, and
placement of "drains," as shown for the refined' model (top) relative to the 'original'
model (bottom). Both versions simulate groundwater discharge in areas labeled "drain"
to represent "... unnamed streams east and west of the site and at selected low areas in
the model interior to limit the rise of the modeled water table above ground surface..."
(CAP, Appendix B, page 12) However, the refined' model eliminated a very large swath
of "drain" along the northern part of the model domain that presumably coincides with
Duke's so-called areas of wetness. These fundamental changes in the computer model
must be a reflection of significant modifications to Duke's underlying SCM, despite their
claim that "...no revisions are warranted for the SCM at this time" (CAP Part 2, page 33).
Page 15

Figure 4 Numerical Model Boundary Conditions
Figure 4. Numerical Model Boundary Conditions
Page 26

Duke states that their groundwater computer model is based on the SCM that is
"...primarily based on the CSA Report" and that their model "... was refined to
incorporate post -CSA data." (CAP, Appendix B, page 2) However, Duke states explicitly
that hydrostratigraphic units (i.e., aquifers) are assigned hydraulic "...properties
provided in CSA Report Tables 11-7 through 11-11." (CAP, Appendix B, page 9)
Nowhere in the CAP report or Appendix B does Duke reference their CSA Addendum
(Appendix A) or their revised' CSA tables (11-7 through 11-11) of aquifer properties.
Regardless of which CSA (or Addendum) aquifer parameters Duke initially employed to
setup their computer model, Appendix B indicates that the model employed values that
often deviate considerably from actual field -measured parameters. For example, the
CSA reported that the effective porosity of the saprolite-bedrock transition zone' and the
fractured bedrock is 5 to 10 percent and 2 to 5 percent, respectively. (CSA Table 11-11)
However, Table 4 in CAP Appendix B reports that Duke's model used effective porosity
values for the 'transition zone' and bedrock of only 0.1 percent and 0.005 percent,
respectively. One result of employing such tiny values within the computer modeling is
that the bedrock contains very little groundwater relative to the unconsolidated
materials (regolith and coal ash) that Duke assigns a surprisingly uniform 20 percent
effective porosity.
It is important to employ realistic values for groundwater recharge to build a realistic
groundwater flow model, but Duke admits that recharge "...has not been measured or
estimated..." for the Buck property (CAP, Appendix B, page 6, emphasis added). The
images provided below show that Duke made dramatic changes in the size, shape, and
rate of recharge areas between their'original' computer models (top) and their'refined'
model (bottom). For example, the refined' model assigns more than double the
recharge rate to northerly developed areas that contain an abundance of water -
impermeable surfaces (e.g., the BSS buildings) relative to adjacent areas that are
dominated by vegetative cover. Most of the coal ash pits in the'refined' model (bottom)
are assigned more than tri le the original recharge rate (top), and curiously the
predominantly dry "primary cell" (pit #1) has greater infiltration than the "secondary
cell" (pit #3) which contains abundant standing water. These differences bear no
obvious or verified relationship to hydrogeologic reality at the Buck property, they
Page 21

merely represent Duke's ad hoc manipulation "... through the model calibration process"
to get the results that they wanted to see (CAP, Appendix B, page 13)
Duke states that they performed "sensitivity analyses" of their'original' computer
model to evaluate how modifying certain input parameters such as groundwater
recharge influenced the response of their modeled water levels and flow patterns. Duke
claims that "... the flow model was most sensitive to horizontal hydraulic conductivity of
the shallow aquifer, followed by recharge to areas beyond the ash basin cells, and
hydraulic conductivity of the transition zone." (CAP, Appendix B, page 16, emphasis
added) Despite making huge changes to the rates of groundwater recharge across
much of their'refined' model domain, Duke admits that "Sensitivity analyses have not
been performed on the (refined) calibrated groundwater flow model..." (CAP, Appendix
B, page 16). Duke acknowledged that their sensitivity analysis of the original' model
showed that The elevation of the water table in the ash basin is particularly sensitive to
recharge..." (CAP, Appendix B, page 17), yet that model applied only about one third of
the recharge that was used in the refined' model. We are surprised that Duke's'refined'
model was able to maintain simulated water levels below the land surface in the face of
triple the groundwater recharge at the ash basins and double the recharge around and
north of the "active ash basin primary cell." Unfortunately, Duke provides very little
information in the CAP's text or graphics to demonstrate how hydraulic head appears in
their simulated "water table in the ash basin" for their refined' model.
Page 22

'�'�4fj�}�rt' �[j taownar,i.H
Recharge - 6 inly'N
I r{
t ALnveE
OLD P=Y
i CELL ASH BASIN`
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�90J�C} GC nC F'.ntfatl Cin.
sONfCC �1
Recharge = 6 mlyr
,f
I'
ACTIVE
ASH BASIN
PRIMA PV CELL
Recharge = 6 inlyr i `4
a sra is•-. f Recharge .
c tration :dam i8.5 1nlyr
AS- 't
' - ASH BASIN
.i PRIMARY CELL RE'C ildr
.22.7 inlyr
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4.5 in
Recharge •;�, :}, a
211 inlyr L
* s � a•.
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Figure 5 Model Recharge Areas and Contaminant Source Zones (Constant Concentration Cells)
Page 23
iOLIfLC
u "_• �i
Rach"arge =- 6 i year
0 500 1.000
,. _� y r.►
Feet
F. �', Yiµ mappine_
n
Figure 5. Model Recharge Areas and Contaminant Source Zones (Constant Concentration Cells)
LEGEND
OIJNE ENERGY
•
- _--
•r�
t�
PROPERTY BOUNDARY
ASH BASIN WASTE
BOUNDARY
ASH SASIN CCMPLIANCE
BONN GARY
- Rech r
ABH &SIN CCMPLIANCE
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` YWTH W NE ENERGY
PROPERTYSOl)xDARY
,'Recharge/
PRDVIS I4NJALASN BASHVg
_ DCNnLuxCE BOUNDARYACT�VF
:
AI
MODELOOMN
6 In JI�llQar. I
/ )/[
/--mnnaAa .N i
nr�lvv
a sra is•-. f Recharge .
c tration :dam i8.5 1nlyr
AS- 't
' - ASH BASIN
.i PRIMARY CELL RE'C ildr
.22.7 inlyr
i Constant
Rec @ Concentration. $TCpaGE
SOUrCC
4.5 in
Recharge •;�, :}, a
211 inlyr L
* s � a•.
I
Re �Karge N
9hty !!l1VV
4
o eaa 1.000
,'p fl P •=�L F
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Figure 5 Model Recharge Areas and Contaminant Source Zones (Constant Concentration Cells)
Page 23

Duke claims that their modeled bedrock aquifer was "...extended vertically in the
refined (computer) model to correlate to the deepest reported off-site private water
supply well..." (CAP, page 24) and that bedrock "Layer 9 is 100 feet thick ...and (bedrock)
layer 10 is 400 feet thick..." (CAP, Appendix B, page 15). Although Duke provides no
vertical scales on most of their figures, that bedrock thickness appears to be shown
below in Figure 14 of Appendix B (note: the caption should read "West -East" instead of
"North-South"). However, elsewhere in the CAP, Duke claims that the bottom of the
bedrock aquifer coincides with an assumed maximum depth of water yielding
fractures... assumed to be 80 feet below the base of the transition zone... based on a
review of boring logs contained in the CSA." (CAP, Appendix B, page 15, emphasis
added) Figure 3 of Appendix B shown below seems to show that the bedrock totals 80
feet in thickness. The two images showing hydrostratigraphic units in Duke's
refined' computer model are not compatible or internally consistent, making
it more difficult to accept other, less transparent aspects of their modeling.
C C'
Figure 14 Hydraulic Head in North-South Cross Section (C -C') through Primary and Secondary Ash Basinsl
Page 24

It is important to note that the simulated equipotential contours shown in Figure 14
provided above implies that groundwater flows from the coal ash pit in a dominantly
downward path all the way to the bottom bedrock layer of the model domain. That flow
pattern suggests that the primary path for contaminants eminating from the coal ash
pits would be directly downward into deep fractures of the bedrock aquifer that supplies
local residential water -supply wells.
Duke's model ignores the fundamentally inhomogeneous and hydraulically -
anisotropic character of the fractured bedrock aquifer (likewise for the overlying
"transition zone" and saprolite). Instead, "...fractured bedrock was simulated as an
equivalent porous medium." (CAP, Appendix B, page 7) This means that fracture
orientations, spatial distributions and densities, apertures, and connectivity were
ignored, and Duke assumed that groundwater flow in the fractured rock is essentially no
different than it would be in a simple porous material such as a sand. Assuming that
fractured rock aquifers act as an 'equivalent porous medium" (EPM) is model -friendly
and is essentially required by their choice of modeling software (MODFLOW). However,
it is a fundamentally -flawed computer construct that does not represent groundwater
Page 25

flow in the aquifers that occur beneath the Buck site. The EPM assumption inherent in
MODFLOW accounts for the fairly smooth distribution of modeled equipotential contours
shown crossing all of Duke's model layers illustrated above in Figure 14. We assert that
EPM does not represent the reality at and near the Buck property, and
groundwater hydraulics and flow around a pumping well in fractured bedrock is
completely non-equivalent to that of a pumping well in a sand aquifer. We address
implications of complex, pumping -induced groundwater -flow patterns below.
As a final example illustrating the ad hoc nature of Duke's groundwater model, the
two images provided below show the original (top) and 'refined' (bottom) distribution of
horizontal and vertical hydraulic conductivity values (KH and Kv, respectively) that Duke
assigned to model layers 5 through 7, which correspond to saprolite (highly weathered
bedrock). Values for K assigned to the zones shown in these two images are listed in
the underlying tables that correspond to the original' (left) and refined' (right)
computer models. The deepest real-world measure of KH in bedrock that Duke reported
for the Buck property was obtained from 94 feet below the top of rock (184 feet below
grade) at monitoring well GWA-9BR (CSA Table 11-3), which is less than 20 percent of
the bedrock thickness used in Duke's computer model. Neither map showing the
model's distribution of K has any basis in hydrogeologic reality for the Buck
property, not the assigned values and not the shape of any "zone."
During "calibration," the computer modeler will iteratively assign values for aquifer
parameters such as effective porosity and KH to try to make the model replicate water
levels measured in wells in July 2015. However, changing one value often requires
adjusting other values, which can easily result in unrealistic and/or inconsistent
"calibrated" values that do not match real-world parameters measured in the field.
Simple comparison of the two tables provided below indicates that the computer's
"calibrated model value" was seldom constrained by field measurements of KH for a
given material at Buck (e.g., coal ash). Duke's tables list a range of measured KH, which
requires even more effort to determine if end -member values are anomalous.
Page 26

N
S-1 A
i CDELBWNPARY 0 500 1,000
Feet
Figure 9. Hydraulic Conductivity Zonation in SIM11M2 Layers (Model Layers 5-7
LEGEND YIUlMNpNBp
DUNE ENERGY _
— ' PROPERTY BOUNI
PSN BASIN WASH
BOUN CARY �..y
ASNSASINCOMPLIANCE S/
BOUN GARY
ASN BASIN COMPLIANCE Z-�T
BOUNDARY COINCIDENT
WRN DUKE ENERGY
PROPERTYBDUNDARY
PR —IONALASNBABIN Z -Y
COMPLIANCE BOUNDARY
MODEL DOMAIN C
Z-8
6
ABR
I pi
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t , PRIMARY CELL �,)
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_%• Z'4 0 Soo 1.000
)J
iFeet
,e I .n , n. � Getmappn0.
Figure 9 Hydraulic Conductivity Zonation in Saprolite - MVM2 Layers (Model Layers 5-7)
Page 2;

Tables from CAP Part 1 Appendix C (below) and CAP Part 2, Appendix B (right)
Table 2. Hydraulic Conductivity in Model
'Range - geometric mean -1-ane standard deviation (see HDR Tables 11-7 to 11.11)
Table 2 Hydreullc Co d..trH, in Model
MmW
layers
Hytleoavee
��
Measured Value
��
Calibrated Model Value
ebrtonW
Hytlnutle
£enan®rxy
lJ
Range'
].45 -2&T9
S-xnnd1-h ry
Model
Hydrostratigraphic
Horizontal
Horizontal
Hydraulic
Vertical Hydraulic
Layers
Unit
Hydraulic
Z-1
Conductivity
Conductivity
22 4A
Z3
Conductivity
ZJ
(feetlday)
(feetlday)
1.3749 owl"
Z-6
lfecVdayl
Z-7
11.347 22601
Z -e
1-3
Ash
3.45
Z.10
0.341
0.341
2-4
Dike
--
Z.13
0.0028
0,0028
3.01 0.00325
z -t5
0.15482 QAQW1
S-1
11.366
1,1366
4.0267 0.98514
a
TZ
S-2
0.1137
0.0114
5-6
M1-Saprolite
0.72
S3
2.557
0,2557
7
M2-Saprolite
0.35
S-4
0.0284
0,0057
Z45
016 acm
Z -M
S-5
0,1421
0.01421
Zaa
CW a M
L28
S-6
0.1137
0.01137
8
TZ
0.98
Za1
2.842
0.5683
9-10
8R
0.025
0.025
0.02501
'Range - geometric mean -1-ane standard deviation (see HDR Tables 11-7 to 11.11)
Table 2 Hydreullc Co d..trH, in Model
MmW
layers
Hytleoavee
��
Ysecured VYue
Ren 1
��
Horlmnnl HYtl.wtic Ye.6cY4
£ontlucdNylaYrp Cantluctivay
]0 1.]
ebrtonW
Hytlnutle
£enan®rxy
lJ
Ace
].45 -2&T9
S-xnnd1-h ry
30 OA
24
M.
AZ
DAM DAM
56
]
M15epcao
cR S -ft
0,72-20.52
025-20.68
Z-1
154130 arias'&
Za
22 4A
Z3
3216® "12
ZJ
1 0.2
Zfi
1.3749 owl"
Z-6
a, 10977 052195
Z-7
11.347 22601
Z -e
9.30641 006129
2A
2x63 DAM
Z.10
9.3709 137412
Z-11
075 0.05
Z-12
9,@6473 9.13646
Z.13
15 3
L14
3.01 0.00325
z -t5
0.15482 QAQW1
z-19
0A orfs
Z.17
4.0267 0.98514
a
TZ
0.06-M92
Z-18
3299E 6.5075
Z-19
1 01
Za0
0.76 0.15
Z41
022476 0.04499
z-22
4&259 80970
2-23
24.25E 41606
Za4
0.01 0105
Z45
016 acm
Z -M
0.32139 0.06427
z4T
03275 0.113T5
Zaa
CW a M
L28
21994 4.7996
410
9R
0.026-220
P30
600079 am09e
Za1
0]233 011098
The net result of Duke's iterative manipulation of aquifer parameters assigned to
self -designated layers and "zones" is a groundwater model that Duke claims can
reproduce generally the "steady-state" July 2015 hydraulic heads used initially to create
the model. However, Duke's computer model does not simulate natural (e.g., drought)
or manmade (e.g., pumping) stressors that are known to perturbate the actual
hydrogeologic system. These "natural" stressors will also signifcantly impact the
"specified head" value used in the model to represent the Yadkin River. NCDEQ
required Duke to incorporate pumping residential water -supply wells located inside the
domain of their refined' model. The CAP states that 39 residential water -supply wells
are within the current model domain and have been included as active pumping wells
completed within the bedrock layer..." (CAP, Appendix B, page 13). Figure 3 of
Appendix B provided below shows black dots at the locations of the residential wells that
Duke selected to include within their model. However, we have found no description of
criteria used to choose those wells, and our image supplied below Duke's Figure 3
shows that 19 additional Duke -identified residential water -supply wells are located inside
the "no -flow" boundary and are part of the model domain. An additional 121 wells
identified previously by Duke are located outside the "no -flow" boundary, and thus the
computer model allows no interaction, influence, or impact on or from groundwater flow
patterns and contamination that is located anywhere inside the model domain.
Page 26

LE43END
• RECEPTOR YYELL4
DUKE ENERGY
` PROPP ER7Y BOUNDARY
A54 BASIN WASTE
BOUNDARY
I
_
AS4 BASIN COMPLIANCE
BOUNDARY
r,
A54 BASIN COMPLIANCE
BOUNDARY COINCIDENT
_
` WITH DUKE FOUNDA
PROPERTY BOUNDARY
PRCIVISIONALASHIN
�
' C-0M7LBOLNDA
1
MODEL DOMAIN
(
* S
A
0 Vii
One-year flaw paths intersect
complicance boundary
{ N
�E
© sao 1.000
SB`111Sy' Feel
`� ice E51 . �^,_nF�;P Gelmapping..
Jll
Figure 17 One -Year Reverse Particle Tracking from Residential Wells
�7 -
s vul' �46'
Page 25
LEGEND
canLnsN Ys�sTE aou�wRr
oB�GK �DM��N�E P�DNB.AY'
� 7DUI�I'ROPERTY EauNDARr
IDEMIFE:D AREVIDIIBLY BY
FROMTYIEDROlRE1LWTER
FLOWMOOEL
YAT uR'LYWELLS
• 9MUTATED IN NE
OROUNDNBTERFLOWN DEL
' BLGK MODELNO-FLOW
BOIJNMRY
BUCK MDDELBFEGIFIED HFA➢
�BJIINMRY
Feel
—VILEGED AND OONFID£—L
d U..TCOMIADHC0710R,
ATTORNEY WORK P -..
CRAFTWORK PRODUCT
DUKES COMPUTER MODEL
DOMXN AND AREA
WATER-SUPPY WELLS
BUCK FACILITY,
ROWAN COUNTY, NC
DATE: 516/2016

Duke's selection of the areal extents of the computer model domain, model
boundary types, and which area water -supply wells to include or exclude from
consideration in their model are all fundamental factors that dictate how closely their
computer simulations can mimic reality at and near the Buck property. Duke states that
the 39 wells are "...completed within the bedrock layer..." but the "...actual pumping
rates are not known..." (CAP, Appendix B, page 13) To overcome the inherent
complexity of intermittent real-world pumping of 39 water -supply wells tapping a
fractured bedrock aquifer, Duke chose to 'pump' each well simultaneously within the
model at a steady rate of 0.278 gallons per minute (i.e., 400 gallons per day). The
spidery black lines emanating from each well shown in Figure 17 illustrate the computer -
simulated paths that pumped groundwater would take toward each well over the course
of one year at a pumping rate of slightly over 1 quart per minute. Duke claims that the
extents of these lines delineate the area around a well that contributes water during
pumping, and only the two wells identified on Duke's image can withdraw groundwater
that will "...intersect the ash basin Compliance Boundary." (CAP, Appendix B, page 17)
There are numerous problems with Duke's methods and conclusions regarding the
simulation of residential water -supply wells included in their refined' computer model for
the Buck property, including the 13 issues listed below:
(1) Only 39 of the 58 Duke -identified wells are included in the computer simulations.
(2) The arbitrary use of a "no -flow" model boundary also excluded an additonal 121
residential water -supply wells near the Buck property, thus preventing any
simulation of the additive effect of pumping those wells.
(3) Omitting 140 Duke -identified residential supply wells from the model domain
equates to ignoring an additional 56,000 gallons pumped each day from the
bedrock aquifer (20.4 Million gallons per year).
(4) Duke's model simulates pumping the 39 wells for only 1 year, even though most
wells in the area have been pumping for decades in proximity to Duke's ash pits.
(5) No water -supply well is pumped in the way that Duke simulated, they are pumped
at much higher withdrawal rates for short periods numerous times each day.
(6) Well pumping volumes and patterns will vary greatly over time (e.g., gardening
during drought).
Page 36

(7) The relative proximity of the 39 wells to Duke's "no -flow" boundary produces
variations in flow patterns (shown as irregularities in many spidery lines in Figure
17) among the modeled supply wells.
(8) The model simulates incorrectly that the 39 wells have identical construction.
(9) Duke assumes that their groundwater flow model can simulate accurately the
hydrogeologic conditions in uninvestigated areas with water -supply wells located
1,000 feet away from any monitoring well used to construct the model.
(10) It is common knowledge that fractured rock aquifer hydraulics are very complex,
and groundwater flowing toward pumping bedrock wells will follow pathways
dictated by the orientations of fractures in the rock which often exhibit a
preferential regional orientation. Duke has not assessed the heterogeneity and
anisotropy of the bedrock aquifer to attempt to address preferential pathways of
groundwater flow associated with fracture orientations, and their computer
model incorporates nothing that accounts for this well-recognized complexity.
(11) Groundwater flow in fractured crystalline rocks cannot be simulated accurately by
EPM, especially in the presence of numerous, randomly -pumped residential
supply wells tapping a variety of depths within that inhomogeoneous and
anisotropic aquifer, as exists at and near the Buck facility
(12) Real-world pumping wells will often influence aquifer hydraulics at non -pumping
wells in the area.
(13) Pumping multiple wells simultaneously will cause complex vertical and horizontal
patterns of groundwater flow that are distinct from the patterns present in the
absence of active pumping
To summarize, we opine that Duke's groundwater flow model is a poor
representation of reality that appears to have been designed ad hoc to
validate a SCM conceived before the CSA investigation even began. We base
our opinion on (A) the weight of topics addressed in our expert report and elsewhere in
this report addendum, (B) Duke's selection of initial model conditions (e.g., limits and
boundary types of their model domain), (C) extensive manipulation of aquifer
parameters to produce a simulation that confirms Duke's pre -modeling claims regarding
the limited location and transport of ash -derived contamination in groundwater and
Page 31

surface water, and (D) Duke's claims that no area water -supply well has been impacted
by their coal ash pits and that residential wells are at no risk of becoming contaminated.
We contend that Duke's groundwater flow model provides no meaningful information
about past, present, or future risk to area residents that rely upon the groundwater
resource. In fact, we assert that the production of such a flawed model places the
public at increased risk if the simulations and related assertions are accepted by NCDEQ.
Decisions about future assessment, remediation, and monitoring at the Buck property
cannot be made based upon the flawed model results, and the real risk of contaminant
exposure to the public may be missed entirely if Duke's groundwater flow computer
model is accepted as it currently exists.
8,2,5, Contaminant Fate and Transport (F& T) and Duke's Proposed
"Corrective Action(s)"for the Buck Facility
Our expert report opined upon some aspects of Duke's'refined' F&T modeling, and
we expand that opinion to state that computer modeling of contaminant
migration and "attenuation," piggybacked onto the obviously flawed
groundwater flow model described above in Section B.2.4., cannot yield
meaningful results for the relative near term, let alone Duke's projections for
contaminant F&T 100 years (and previously 250 years) into the future. Our
expert report discussed the specific examples of Duke's F&T simulations for total
chromium and hexavalent chromium, and in particular the basic decision by Duke to use
unrealistic 'background' concentrations in their `refined' modeling, despite contradiction
by their own analytical data (e.g., Cr(VI) does not occur naturally at 78 fag/L).
We opine upon Duke's F&T modeling results here by examining one example, the
CAP's refined' computer model of the "initial" 2015 conditions showing vanadium in
shallow groundwater (Figure 93, top). Duke claims that the naturally -occurring
background' concentration of vanadium at the Buck site, and therefore within their
model domain, is 8.8 pg/L. If their'refined' simulation is correct, then all areas of the
map should be colored at least the blue corresponding to vanadium concentrations
between 8.8 and 10 pg/L. Instead, large swaths of the model domain are uncolored,
including areas where Duke has no nearby data, and those areas should all contain the
Page 32

alleged 8.8 pg/L'background' for vanadium. Conversely, numerous small patches of
blue in the southwestern corner of the model domain indicate the presence of 8.8 to 10
pg/L vanadium. No such contaminant distribution actually exists at that location, nor is
it clear how that could exist within Duke's F&T model. Comparison of the model
distribution in Figure 93 (top) with the map from Duke's CSA showing the area of
groundwater contaminated with vanadium (Figure 10-49, bottom) reveals obvious
disagreement between modeled and known concentrations (e.g., compare values for
northeastern monitoring wells GWA-3S and GWA-4S with the F&T model output).
LEGEND
- B 8 I6a=kgrauntl� - -
-11.14
®14-22
�22. d1
41-86
- 181 -444
DUKE ENERGY R
PROPERTYBDUKDARY d '-
AL TIJEI�{
ASH BASIN WASTE _ _ l5H 6hS N �vTiV E
BOUNDARY a OLC PRIMARY A5M 9d.51N
ASH BASIN COMPLIANCE `—_ .. CELL SECGAID►RY
BOUNDARY
ASH BASIN COMPLIANCE `
BOUNDARY COINODENT -
r'
WITH DUKE ENERGY
PROPERTY BOUNDARY
PROVIZIO14ALA54 SAWN _
COMPLIANCE BOUNDARY 1,K •+.
MODEL DOMAIN
Y1 I
WN
A CE
nau
PRIMAfitY GEL
fop
%. pldp� i
T 1
IN
1. NgIL = micrograms
per liter y+ _ 1
4 500 1.000
2- Vanadium IMAC L
value
.= 0. 3
.3 pglL * +'.
11� rGFiES1 e dE_•I�. +F.Ir1a�^FF'er,egl
3 Vaaim PPOC
8xJe
8 pg:L
.d
Figure 93 Initial (2015) Vanadium Concentrations in Shallow Groundwater Zone
Page 33

Duke's F&T modeling is used to claim that that gRly those areas located
"downgradient" of their ash pits are, or ever will be, impacted by ash -derived
contamination. Therefore, Duke's CAP recommends site remediation by simply placing
an "engineered cap" over the three ash pits as they currently exist, even though their
F&T modeling indicates that "... capping does not effectively address all COls
downgradient of the source area." (CAP, page 50) To address this persistent
groundwater contamination, Duke proposes to "remediate" the groundwater
contamination using monitored natural attenuation (MNA) "...fora 30 -year period..."
The CAP describes MNA as "...a strategy and set of procedures used to demonstrate that
physiochemical and/or biological processes in an aquifer will reduce concentrations of
COls to levels below regulatory standards or criteria." (CAP, page 45) The reality is that
MNA is essentially doing nothing to actively cleanup a problem, and Duke has done little
so far to demonstrate that MNA will actually "remediate" the contamination, although
they state that "...additional data collection is necessary..." (CAP, page 45)
Duke has long admitted that the bulk of their coal ash at Buck is saturated with
water and producing leachate, and they also admit that the water tends to migrate
Page 34

downward into underlying geologic materials. Duke claims that their refined'
groundwater flow model predicts that after the ash pits are capped, "The water table
within the active ash basin primary cell is reduced by approximately 35 feet, and within
the active ash basin old primary and secondary cell is reduced by approximately 33
feet." (CAP, Appendix B, page 18) This dramatic lowering of the water table is not
accomplished by active pumping or other engineering solutions, instead the
groundwater recharge values in the computer model "...at the ash basin and ash storage
area are set to zero at the beginning of the (computer) simulation. Groundwater flow is
affected by this scenario as the water table is lowered and groundwater velocities may
be reduced beneath the covered areas." (CAP, Appendix B, page 18, emphasis added)
In other words, lowering of the equipotential surface results only from how the
computer model was created and subsequently manipulated, and Duke must ignore
basic groundwater hydrogeology to accept the computer model's prediction that 33 to
35 feet of dewatered aquifer will occur across approximately 185 acres of the Buck
property below their coal ash solely because they install a cap.
Even if we accept that Duke's modeled dewatering occurs as claimed, water will
continue to saturate considerable volumes of coal ash in the pits, and that water will
continue to become contaminated. Duke's contaminant F&T model produced the
appearance that groundwater contaminants are being 'remediated' by capping the coal
ash, but that is primarily because their computer model was adjusted so that additional
contaminants are not allowed to enter their model domain at the capped locations. We
reiterate that water will continue to saturate considerable volumes of coal ash for the
foreseeable future under Duke's cap -in-place scenario, even if the unrealistically -
optimistic 33 to 35 feet of water level decline results from capping the coal ash, and
ash -derived contaminants will be delivered indefinitely to groundwater system.
Duke freely acknowledges that contaminated groundwater is actively discharging
to the Yadkin River, and it will continue to do so for decades or centuries into the future.
Duke concludes that "... modeling results indicate that no surface water quality criteria
are exceeded for COls modeled at the edge of the mixing zone in the Yadkin River."
(CAP, page 30) However, no permitted mixing zone has been established for the Yadkin
Page 35

River or other streams and ponds at the Buck facility. CAP Appendix E describes Duke's
surface water mixing calculations, which indicate that discharging contaminant dilution
requirements are being met within a Duke -designated mixing zone using a simple
volumetric dilution equation that inaccurately assumes uniform mixing and fails to
consider reduced surface water flow velocities along the river bank. Furthermore,
dilution calculations were only produced for mixing in the Yadkin River and not
tributaries or other surface water bodies, such as the unnamed tributaries to the west
and east of the BSS site. The dilution capacity of those smaller water bodies is
obviously lower than that of the Yadkin River. Regardless of mixing characteristics, an
exceedance of a 15A NCAC 2B surface water standard detected along the banks of the
Yadkin River, tributary streams, or other surface water bodies such as ponds still
constitutes an exceedance of a 15A NCAC 2B standard.
In our original expert report, we opined that removal of ash from the unlined pits
and placement of the ash in an engineered, fully -lined, and water -free repository is the
most certain and protective remedial option. We are more convinced than ever that
Duke should do for the Buck site what is being doing for seven of their 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.
Page 36

Appendix A: Analytical Report including Chain -of -Custody for Seep
Sample
Page 3;

P R I S M Full -Service Analytical &
Environmental Solutions
LABORATORIES, INC.
Groundwater Manage. Assoc.(GREE)
Steve Campbell
4300 Sapphire Court, Suite 100
Greenville, NC 27834
NC Certification No. 402
SC Certification No. 99012
NC Drinkinq Water Cert No. 37735
VA Certification No. 460211
DOD ELAP: L -A -B Accredited Certificate No. L2307
ISO/IEC 17025: L -A -B Accredited Certificate No. L2307
Project: 157201
Lab Submittal Date: 02/11/2016
Prism Work Order: 6020213
Case Narrative
03/14/2016
This data package contains the analytical results for the project identified above and includes a Case Narrative, Sample
Results and Chain of Custody. Unless otherwise noted, all samples were received in acceptable condition and processed
according to the referenced methods.
Data qualifiers are flagged individually on each sample. A key reference for the data qualifiers appears at the end of this case
narrative.
Narrative Notes:
Gross Alpha analysis was subcontracted to Florida Radiochemistry Services, Inc. TOC analysis
subcontracted to GCAL. Hexavalent Chromium analysis subcontracted to Pace/Florida. Laboratory
reports are attached.
This is a revised report and supercedes the original laboratory report dated 03/04/2016. Chromium for
sample ID number 6020213-01 was reanalyzed at the client's request.
Please call if you have any questions relating to this analytical report.
Respectfully,
PRISM LABORATORIES, INC.
a,j
Angela D. Overcash
VP Laboratory Services
Reviewed By Terri W. Cole For Angela D. Overcash
Project Manager
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone] Page 1 of 46

Data Qualifiers Key Reference:
BB Blank value is outside of the control limits. Validity of the data not affected.
M Matrix spike outside of the control limits.
Mc Sample concentration too high for recovery evaluation.
BRL Below Reporting Limit
MDL Method Detection Limit
RPD Relative Percent Difference
* Results reported to the reporting limit. All other results are reported to the MDL with values between MDL and
reporting limit indicated with a J.
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone] Page 2 of 46

PRISMSample Receipt Summary
Full -Service Analytical 8
Environmental Solutions 03/14/2016
X LABORATORIES, INC
Prism Work Order: 6020213
Client Sample ID Lab Sample ID Matrix Date Sampled Date Received
Thomas Seep 6020213-01 Water 02/10/16 02/11/16
Samples were received in good condition at 3.4 degrees C unless otherwise noted.
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone] Page 3 of 46

/Y P R ISM Full -Service Analytical
Environmental Solutions LABORATORIES, INC.
Summary of Detections
03/14/2016
Prism Work Order: 6020213
Prism ID
Client ID
Parameter
Method
Result
Units
6020213-01
Thomas Seep
Chloride
'9056A
11
mg/L
6020213-01
Thomas Seep
Nitrate as N
*9056A
0.23
mg/L
6020213-01
Thomas Seep
Sulfate
"9056A
23
mg/L
6020213-01
Thomas Seep
Barium
`6020A
28
ug/L
6020213-01
Thomas Seep
Boron
'6020A
270
ug/L
6020213-01
Thomas Seep
Calcium
*6020A
8900
ug/L
6020213-01
Thomas Seep
Magnesium
`6020A
7600
ug/L
6020213-01
Thomas Seep
Manganese
'6020A
73
ug/L
6020213-01
Thomas Seep
Potassium
*6020A
370
ug/L
6020213-01
Thomas Seep
Sodium
*6020A
9600
ug/L
6020213-01
Thomas Seep
Strontium
`6020A
86
ug/L
6020213-01
Thomas Seep
Ferric Iron
'Ferric Iron
6.9
mg/L
6020213-01
Thomas Seep
Total Alkalinity to pH 4.5
`SM2320 B
40
mg/L
6020213-01
Thomas Seep
Total Dissolved Solids
`SM2540 C
120
mg/L
6020213-01
Thomas Seep
Total Suspended Solids
'SM 2540 D
53
mg/L
6020213-01
Thomas Seep
Bicarbonate Alkalinity
*SM2320 B
40
mg/L
6020213-01
Thomas Seep
Aluminum
'6020A
5500
ug/L
6020213-01
Thomas Seep
Barium
'6020A
64
ug/L
6020213-01
Thomas Seep
Boron
*6020A
270
ug/L
6020213-01
Thomas Seep
Calcium
*6020A
8800
ug/L
6020213-01
Thomas Seep
Cobalt
'6020A
5.9
ug/L
6020213-01
Thomas Seep
Copper
'6020A
7.6
ug/L
6020213-01
Thomas Seep
Iron
"6010C
6.9
mg/L
6020213-01
Thomas Seep
Iron
*6020A
5900
ug/L
6020213-01
Thomas Seep
Lead
'6020A
4.1
ug/L
6020213-01
Thomas Seep
Magnesium
"6020A
7500
ug/L
6020213-01
Thomas Seep
Manganese
`6020A
170
ug/L
6020213-01
Thomas Seep
Nickel
`6020A
2.7
ug/L
6020213-01
Thomas Seep
Potassium
'6020A
520
ug/L
6020213-01
Thomas Seep
Sodium
`6020A
9200
ug/L
6020213-01
Thomas Seep
Strontium
`6020A
87
ug/L
6020213-01
Thomas Seep
Vanadium
'6020A
15
ug/L
6020213-01
Thomas Seep
Zinc
*6020A
14
ug/L
6020213-01R
Thomas Seep
Chromium
*6020A
4.6
ug/L
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone] Page 4 of 46

P R I S M Full -Service Analytical
Environmental Solutions
LABO-OFIE$ INC.
Groundwater Manage. Assoc.(GREE)
Attn: Steve Campbell
4300 Sapphire Court, Suite 100
Greenville, NC 27834
Laboratory Report
03/14/2016
Project: 157201 Client Sample ID: Thomas Seep
Prism Sample ID: 6020213-01
Prism Work Order: 6020213
Sample Matrix: Water Time Collected: 02/10/16 14:15
Time Submitted: 02/11/16 08:50
Parameter Result Units Report MDL Dilution Method Analysis Analyst Batch
Limit Factor Date/Time ID
Anions by Ion Chromatography
Chloride
11
mg/L
1.0
0.20
1
*9056A
2/11/16 15:18
CDE
P6B0227
Nitrate as N
0.23
mg/L
0.10
0.018
1
*9056A
2/11/16 15:18
CDE
P6B0227
Sulfate
23
mg/L
1.0
0.24
1
*9056A
2/11/16 15:18
CDE
P6B0227
Dissolved Metals
Aluminum
BRL
ug/L
50
0.93
1
*6020A
3/2/16 15:50
gmart
P6B0460
Mercury
BRL
mg/L
0.00020
0.000030
1
*7470A
2/18/16 12:35
JAB
P6B0268
Antimony
BRL
ug/L
1.0
0.069
1
*6020A
3/2/16 15:50
gmart
P6B0460
Arsenic
BRL
ug/L
1.0
0.29
1
*6020A
3/2/16 15:50
gmart
P6B0460
Barium
28
ug/L
5.0
0.041
1
*6020A
3/2/16 15:50
gmart
P6B0460
Beryllium
BRL
ug/L
1.0
0.047
1
*6020A
3/2/16 15:50
gmart
P6B0460
Boron
270
ug/L
100
2.7
1
*6020A
3/2/16 15:50
gmart
P6B0460
Cadmium
BRL
ug/L
1.0
0.019
1
*6020A
3/2/16 15:50
gmart
P6B0460
Calcium
8900
ug/L
100
10
1
*6020A
3/2/16 15:50
gmart
P6B0460
Chromium
BRL
ug/L
1.0
0.51
1
*6020A
3/2/16 15:50
gmart
P6B0460
Cobalt
BRL
ug/L
1.0
0.013
1
*6020A
3/2/16 15:50
gmart
P6B0460
Copper
BRL
ug/L
5.0
0.44
1
*6020A
3/2/16 15:50
gmart
P6B0460
Iron
BRL
ug/L
100
16
1
*6020A
3/2/16 15:50
gmart
P6B0460
Lead
BRL
ug/L
1.0
0.020
1
*6020A
3/2/16 15:50
gmart
P6B0460
Magnesium
7600
ug/L
100
0.25
1
*6020A
3/2/16 15:50
gmart
P6B0460
Manganese
73
ug/L
5.0
1.2
1
*6020A
3/2/16 15:50
gmart
P6B0460
Molybdenum
BRL
ug/L
2.0
0.64
1
*6020A
3/2/16 15:50
gmart
P6B0460
Nickel
BRL
ug/L
2.0
0.053
1
*6020A
3/2/16 15:50
gmart
P6B0460
Potassium
370
ug/L
100
4.5
1
*6020A
3/2/16 15:50
gmart
P6B0460
Selenium
BRL
ug/L
1.0
0.35
1
*6020A
3/2/16 15:50
gmart
P6B0460
Sodium
9600
ug/L
100
5.6
1
*6020A
3/2/16 15:50
gmart
P6B0460
Strontium
86
ug/L
1.0
0.057
1
*6020A
3/2/16 15:50
gmart
P6B0460
Thallium
BRL
ug/L
1.0
0.0093
1
*6020A
3/2/16 15:50
gmart
P6B0460
Vanadium
BRL
ug/L
5.0
2.5
1
*6020A
3/2/16 15:50
gmart
P6B0460
Zinc
BRL
ug/L
10
0.98
1
*6020A
3/2/16 15:50
gmart
P6130460
General Chemistry Parameters
Ferric Iron
6.9
mg/L
0.30
0.033
1
*Ferric Iron
2/15/16 17:08
bgm
[CALC]
Ferrous Iron
BRL
mg/L
0.20
0.022
1
*SM3500-Fe D
2/11/16 12:20
EGC
P6B0244
Sulfide
BRL
mg/L
2.0
0.83
1
*SM4500-S F
2/17/16 13:15
CDL
P6B0338
Total Alkalinity to pH 4.5
40
mg/L
5.0
0.77
1
*SM2320 B
2/12/16 10:30
CLB
P6B0234
Total Dissolved Solids
120
mg/L
50
1.4
1
*SM2540 C
2/15/16 12:05
EGC
P6B0283
Total Suspended Solids
53
mg/L
7.7
0.80
1
*SM 2540 D
2/12/16 13:10
EGC
P6B0260
Carbonate Alkalinity
BRL
mg/L
5.0
0.59
1
*SM2320 B
2/12/16 10:30
CLB
P6B0255
Bicarbonate Alkalinity
40
mg/L
5.0
0.59
1
*SM2320 B
2/12/16 10:30
CLB
P6B0255
Total Metals
Aluminum 5500 ug/L 50 0.93 1 *6020A 3/2/16 18:02 gmart P6B0437
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone] Page 5 of 46

P R S M Laboratory Report
Full -Service Analytical &
Environmental Solutions 03/14/2016
LABO-OFIE$ INC.
Groundwater Manage. Assoc.(GREE) Project: 157201 Client Sample ID: Thomas Seep
Attn: Steve Campbell Prism Sample ID: 6020213-01
4300 Sapphire Court, Suite 100 Prism Work Order: 6020213
Greenville, NC 27834 Sample Matrix: Water Time Collected: 02/10/16 14:15
Time Submitted: 02/11/16 08:50
Parameter
Result
Units
Report
Limit
MDL
Dilution
Factor
Method
Analysis
Date/Time
Analyst
Batch
ID
Mercury
BRL
mg/L
0.00020
0.000030
1
*7470A
2/18/16 12:16
JAB
P6130267
Antimony
BRL
ug/L
1.0
0.069
1
*6020A
3/2/16 18:02
gmart
P6130437
Arsenic
BRL
ug/L
1.0
0.29
1
*6020A
3/2/16 18:02
gmart
P660437
Barium
64
ug/L
5.0
0.041
1
*6020A
3/2/16 18:02
gmart
P6130437
Beryllium
BRL
ug/L
1.0
0.047
1
*6020A
3/2/16 18:02
gmart
P6130437
Boron
270
ug/L
100
2.7
1
*6020A
3/2/16 18:02
gmart
P6130437
Cadmium
BRL
ug/L
1.0
0.019
1
*6020A
3/2/16 18:02
gmart
P6130437
Calcium
8800
ug/L
100
10
1
*6020A
3/2/16 18:02
gmart
P6130437
Cobalt
5.9
ug/L
1.0
0.013
1
*6020A
3/2/16 18:02
gmart
P6B0437
Copper
7.6
ug/L
5.0
0.44
1
*6020A
3/2/16 18:02
gmart
P6B0437
Iron
5900
ug/L
100
16
1
*6020A
3/2/16 18:02
gmart
P6130437
Iron
6.9
mg/L
0.10
0.011
1
*6010C
2/15/16 17:08
bgm
P6130239
Lead
4.1
ug/L
1.0
0.020
1
*6020A
3/2/16 18:02
gmart
P6B0437
Magnesium
7500
ug/L
100
0.25
1
*6020A
3/2/16 18:02
gmart
P6B0437
Manganese
170
ug/L
5.0
1.2
1
*6020A
3/2/16 18:02
gmart
P660437
Molybdenum
BRL
ug/L
2.0
0.64
1
*6020A
3/2/16 18:02
gmart
P6130437
Nickel
2.7
ug/L
2.0
0.053
1
*6020A
312/16 18:02
gmart
P6130437
Potassium
520
ug/L
100
4.5
1
*6020A
312/16 18:02
gmart
P6B0437
Selenium
BRL
ug/L
1.0
0.35
1
*6020A
3/2/16 18:02
gmart
P6130437
Sodium
9200
ug/L
100
5.6
1
*6020A
3/2/16 18:02
gmart
P6B0437
Strontium
87
ug/L
1.0
0.057
1
*6020A
3/2/16 18:02
gmart
P6B0437
Thallium
BRL
ug/L
1.0
0.0093
1
*6020A
3/2/16 18:02
gmart
P6130437
Vanadium
15
ug/L
5.0
2.5
1
*6020A
3/2/16 18:02
gmart
P660437
Zinc
14
ug/L
10
0.98
1
*6020A
3/2/16 18:02
gmart
P6130437
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 6 of 46

This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 7 of 46
Laboratory Report
Full -Service Analytical &
P R S M Environmental Solutions
LABO-OFIE$ INC.
03/14/2016
Groundwater Manage. Assoc.(GREE)
Project: 157201
Client Sample ID: Thomas Seep
Attn: Steve Campbell
Prism Sample ID: 6020213-01 RE1
4300 Sapphire Court, Suite 100
Prism Work Order: 6020213
Greenville, NC 27834
Sample Matrix: Water
Time Collected: 02/10/16 14:15
Time Submitted: 02/11/16 08:50
Parameter Result
Units Report
MDL Dilution Method Analysis Analyst Batch
Limit
Factor Date/Time ID
Total Metals
Chromium 4.6
ug/L 1.0
0.51 1 '6020A 3/10/16 15:40 gmart P6C0170
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 7 of 46

P R I S M Full -Service Analytical &
Environmental Solutions
_.- LABORATORIES, INC.
Groundwater Manage. Assoc.(GREE) Project: 157201
Attn: Steve Campbell
4300 Sapphire Court, Suite 100
Greenville, NC 27834
Total Metals - Quality Control
Level II QC Report
3/14/16
Prism Work Order: 6020213
Time Submitted: 2/11/2016 8:50:OOAM
Reporting Spike Source %REC RPD
Analyte Result Limit Units Level Result %REC Limits RPD Limit Notes
Batch P6BO239 - 3010A
Blank (P6B0239-BLK1) Prepared: 02/12/16 Analyzed: 02/15/16
Iron BRL 0.10 mg/L
LCS (P6B0239-BS1) Prepared: 02/12/16 Analyzed: 02/15/16
Iron 5.12 0.10 mg/L 5.000 102 80-120
Batch P6130267 - 7470A
Blank (P6B0267-BLK1)
Prepared & Analyzed: 02/18/16
Mercury
BRL
0.00020
mg/L
LCS (P6B0267-BS1)
Prepared & Analyzed: 02/18/16
Mercury
0.00951
0.00020
mg/L
0.009375 101 80-120
Batch P6BO437 - 3005A
Blank (P6B0437-BLK1)
Prepared: 02/24/16 Analyzed: 03/02/16
Aluminum
BRL
50
ug/L
Antimony
BRL
1.0
ug/L
Arsenic
BRL
1.0
ug/L
Barium
BRL
5.0
ug/L
Beryllium
BRL
1.0
ug/L
Boron
BRL
100
ug/L
Cadmium
BRL
1.0
ug/L
Calcium
BRL
100
ug/L
Cobalt
BRL
1.0
ug/L
Copper
BRL
5.0
ug/L
Iron
BRL
100
ug/L
Lead
BRL
1.0
ug/L
Magnesium
BRL
100
ug/L
Manganese
BRL
5.0
ug/L
Molybdenum
BRL
2.0
ug/L
Nickel
BRL
2.0
ug/L
Potassium
BRL
100
ug/L
Selenium
BRL
1.0
ug/L
Sodium
BRL
100
ug/L
Strontium
BRL
1.0
ug/L
Thallium
BRL
1.0
ug/L
Vanadium
BRL
5.0
ug/L
Zinc
BRL
10
ug/L
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 8 of 46

Full -Service Analytical
P R I S M
Environmental Solutions
LABORATORIES, INC.
Level II QC Report
3/14/16
Groundwater Manage. Assoc.(GREE) Project: 157201 Prism Work Order: 6020213
Attn: Steve Campbell Time Submitted: 2/11/2016 8:50:OOAM
4300 Sapphire Court, Suite 100
Greenville, NC 27834
Total Metals - Quality Control
Reporting Spike Source %REC RPD
Analyte Result Limit Units Level Result %REC Limits RPD Limit Notes
Batch P6B0437 - 3005A
LCS (P6B0437-BS1)
Prepared: 02/24/16 Analyzed: 03/02/16
Aluminum
979
50
ug/L
1000
98
80-120
Antimony
103
1.0
ug/L
100.0
103
80-120
Arsenic
98.1
1.0
ug/L
100.0
98
80-120
Barium
116
5.0
ug/L
100.0
116
80-120
Beryllium
104
1.0
ug/L
100.0
104
80-120
Boron
1060
100
ug/L
1000
106
80-120
Cadmium
100
1.0
ug/L
100.0
100
80-120
Calcium
1050
100
ug/L
1000
105
80-120
Cobalt
97.9
1.0
ug/L
100.0
98
80-120
Copper
102
5.0
ug/L
100.0
102
80-120
Iron
1010
100
ug/L
1000
101
80-120
Lead
102
1.0
ug/L
100.0
102
80-120
Magnesium
991
100
ug/L
1000
99
80-120
Manganese
98.5
5.0
ug/L
100.0
98
80-120
Molybdenum
102
2.0
ug/L
100.0
102
80-120
Nickel
100
2.0
ug/L
100.0
100
80-120
Potassium
1000
100
ug/L
1000
100
80-120
Selenium
97.7
1.0
ug/L
100.0
98
80-120
Sodium
968
100
ug/L
1000
97
80-120
Strontium
100
1.0
ug/L
100.0
100
80-120
Thallium
99.0
1.0
ug/L
100.0
99
80-120
Vanadium
98.7
5.0
ug/L
100.0
99
80-120
Zinc
100
10
ug/L
100.0
100
80-120
Batch P6C0170 - 3005A
Blank (P6C0170-BLK1)
Prepared & Analyzed: 03/10/16
Chromium
BRL
1.0
ug/L
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 9 of 46

Full -Service Analytical
P R I S M
Environmental Solutions
LABORATORIES, INC.
Groundwater Manage. Assoc.(GREE) Project: 157201
Attn: Steve Campbell
4300 Sapphire Court, Suite 100
Greenville, NC 27834
Total Metals - Quality Control
Level II QC Report
3/14/16
Prism Work Order: 6020213
Time Submitted: 2/11/2016 8:50:OOAM
Reporting Spike Source %REC RPD
Analyte Result Limit Units Level Result %REC Limits RPD Limit Notes
Batch P6CO170 - 3005A
LCS (P6C0170-BS1) Prepared & Analyzed: 03/10/16
Chromium 96.7 1.0 ug/L 100.0 97 80-120
Post Spike (P6C0170-PS1) Source: 6020213-01RE1 Prepared & Analyzed: 03/10/16
Chromium 96.1 ug/L 100.0 4.62 92 80-120
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 10 of 46

Full -Service Analytical
P R I S M
Environmental Solutions
LABORATORIES, INC.
Groundwater Manage. Assoc.(GREE)
Attn: Steve Campbell
4300 Sapphire Court, Suite 100
Greenville, NC 27834
Dissolved Metals - Quality Control
Analyte
Batch P6130268 - 7470A
Project: 157201
Reporting
Result Limit Units
Level II QC Report
3/14/16
Prism Work Order: 6020213
Time Submitted: 2/11/2016 8:50:OOAM
Spike Source %REC RPD
Level Result %REC Limits RPD Limit Notes
Blank (P6130268-13LK1) Prepared & Analyzed: 02/18/16
Mercury BRL 0.00020 mg/L
LCS (P6B0268-BS1) Prepared & Analyzed: 02/18/16
Mercury 0.00945 0.00020 mg/L 0.009375 101 80-120
Matrix Spike (P6130268-MS1) Source: 6020213-01 Prepared & Analyzed: 02/18/16
Mercury 0.00944 0.00020 mg/L 0.009375 BRL 101 80-120
Matrix Spike Dup (P6B0268-MSD1) Source: 6020213-01 Prepared & Analyzed: 02/18/16
Mercury 0.00942 0.00020 mg/L 0.009375 BRL 100 80-120 0.2 20
Batch P660460 - 3005A
Blank (P660460-BLK1)
Prepared: 02/25/16 Analyzed: 03/02/16
Aluminum
BRL
50
ug/L
Antimony
BRL
1.0
ug/L
Arsenic
BRL
1.0
ug/L
Barium
BRL
5.0
ug/L
Beryllium
BRL
1.0
ug/L
Boron
BRL
100
ug/L
Cadmium
BRL
1.0
ug/L
Calcium
BRL
100
ug/L
Chromium
BRL
1.0
ug/L
Cobalt
BRL
1.0
ug/L
Copper
BRL
5.0
ug/L
Iron
BRL
100
ug/L
Lead
BRL
1.0
ug/L
Magnesium
BRL
100
ug/L
Manganese
BRL
5.0
ug/L
Molybdenum
BRL
2.0
ug/L
Nickel
BRL
2.0
ug/L
Potassium
BRL
100
ug/L
Selenium
BRL
1.0
ug/L
Sodium
BRL
100
ug/L
Strontium
BRL
1.0
ug/L
Thallium
BRL
1.0
ug/L
Vanadium
BRL
5.0
ug/L
Zinc
BRL
10
ug/L
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone] Page 11 of 46

Full -Service Analytical
P R I S M
Environmental Solutions
LABORATORIES, INC.
Groundwater Manage. Assoc.(GREE)
Attn: Steve Campbell
4300 Sapphire Court, Suite 100
Greenville, NC 27834
Dissolved Metals - Quality Control
Analyte
Batch P6BO460 - 3005A
Project: 157201
Reporting
Result Limit Units
Level II QC Report
3/14/16
Prism Work Order: 6020213
Time Submitted: 2/11/2016 8:50:OOAM
Spike Source %REC RPD
Level Result %REC Limits RPD Limit Notes
LCS (P6B0460-BS1)
Prepared: 02/25/16 Analyzed: 03/02/16
Aluminum
992
50
ug/L
1000
99
80-120
Antimony
99.3
1.0
ug/L
100.0
99
80-120
Arsenic
97.1
1.0
ug/L
100.0
97
80-120
Barium
100
5.0
ug/L
100.0
100
80-120
Beryllium
101
1.0
ug/L
100.0
101
80-120
Boron
1020
100
ug/L
1000
102
80-120
Cadmium
98.0
1.0
ug/L
100.0
98
80-120
Calcium
1040
100
ug/L
1000
104
80-120
Chromium
102
1.0
ug/L
100.0
102
80-120
Cobalt
98.1
1.0
ug/L
100.0
98
80-120
Copper
101
5.0
ug/L
100.0
101
80-120
Iron
994
100
ug/L
1000
99
80-120
Lead
99.7
1.0
ug/L
100.0
100
80-120
Magnesium
1010
100
ug/L
1000
101
80-120
Manganese
98.2
5.0
ug/L
100.0
98
80-120
Molybdenum
98.9
2.0
ug/L
100.0
99
80-120
Nickel
99.9
2.0
ug/L
100.0
100
80-120
Potassium
1020
100
ug/L
1000
102
80-120
Selenium
98.2
1.0
ug/L
100.0
98
80-120
Sodium
992
100
ug/L
1000
99
80-120
Strontium
98.8
1.0
ug/L
100.0
99
80-120
Thallium
97.0
1.0
ug/L
100.0
97
80-120
Vanadium
102
5.0
ug/L
100.0
102
80-120
Zinc
99.5
10
ug/L
100.0
100
80-120
Matrix Spike (P6B0460-MS1)
Source: 6020213-01
Prepared:
02/25/16
Analyzed: 03/02/16
Aluminum
969
50
ug/L
1000
7.02
96
75-125
Antimony
99.2
1.0
ug/L
100.0
0.128
99
75-125
Arsenic
99.0
1.0
ug/L
100.0
BRL
99
75-125
Barium
125
5.0
ug/L
100.0
27.8
97
75-125
Beryllium
99.5
1.0
ug/L
100.0
BRL
99
75-125
Boron
1270
100
ug/L
1000
270
100
75-125
Cadmium
96.1
1.0
ug/L
100.0
BRL
96
75-125
Calcium
9650
100
ug/L
1000
8860
80
75-125
Chromium
99.8
1.0
ug/L
100.0
0.722
99
75-125
Cobalt
95.7
1.0
ug/L
100.0
0.797
95
75-125
Copper
98.9
5.0
ug/L
100.0
BRL
99
75-125
Iron
983
100
ug/L
1000
25.7
96
75-125
Lead
98.1
1.0
ug/L
100.0
0.157
98
75-125
Magnesium
8330
100
ug/L
1000
7580
75
75-125
Manganese
165
5.0
ug/L
100.0
72.5
93
75-125
Molybdenum
98.7
2.0
ug/L
100.0
BRL
99
75-125
Nickel
96.4
2.0
ug/L
100.0
0.210
96
75-125
Potassium
1340
100
ug/L
1000
370
97
75-125
Selenium
105
1.0
ug/L
100.0
0.389
105
75-125
Sodium
1.00E9
100
ug/L
1000
9640
NR
75-125 MC
Strontium
182
1.0
ug/L
100.0
86.0
96
75-125
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone] Page 12 of 46

Full -Service Analytical
P R I S M
Environmental Solutions
LABORATORIES, INC.
Groundwater Manage. Assoc.(GREE) Project: 157201
Attn: Steve Campbell
4300 Sapphire Court, Suite 100
Greenville, NC 27834
Dissolved Metals - Quality Control
Analyte
Batch P6BO460 - 3005A
Reporting
Result Limit Units
Level II QC Report
3/14/16
Prism Work Order: 6020213
Time Submitted: 2/11/2016 8:50:OOAM
Spike Source %REC RPD
Level Result %REC Limits RPD Limit Notes
Matrix Spike (P6B0460-MS1)
Source: 6020213-01
Prepared: 02/25/16 Analyzed: 03/02/16
Thallium
96.3
1.0
ug/L
100.0
0.0997
96
75-125
Vanadium
99.1
5.0
ug/L
100.0
BRL
99
75-125
Zinc
96.6
10
ug/L
100.0
4.84
92
75-125
Matrix Spike Dup (P6B0460-MSD1)
Source: 6020213-01
Prepared:
02/25/16 Analyzed: 03/02/16
Aluminum
951
50
ug/L
1000
7.02
94
75-125
2
20
Antimony
96.8
1.0
ug/L
100.0
0.128
97
75-125
2
20
Arsenic
95.8
1.0
ug/L
100.0
BRL
96
75-125
3
20
Barium
123
5.0
ug/L
100.0
27.8
95
75-125
2
20
Beryllium
96.9
1.0
ug/L
100.0
BRL
97
75-125
3
20
Boron
1240
100
ug/L
1000
270
97
75-125
2
20
Cadmium
93.9
1.0
ug/L
100.0
BRL
94
75-125
2
20
Calcium
9590
100
ug/L
1000
8860
73
75-125
0.6
20 M
Chromium
96.6
1.0
ug/L
100.0
0.722
96
75-125
3
20
Cobalt
93.4
1.0
ug/L
100.0
0.797
93
75-125
2
20
Copper
95.9
5.0
ug/L
100.0
BRL
96
75-125
3
20
Iron
951
100
ug/L
1000
25.7
93
75-125
3
20
Lead
95.9
1.0
ug/L
100.0
0.157
96
75-125
2
20
Magnesium
8260
100
ug/L
1000
7580
68
75-125
0.8
20 M
Manganese
162
5.0
ug/L
100.0
72.5
90
75-125
2
20
Molybdenum
96.8
2.0
ug/L
100.0
BRL
97
75-125
2
20
Nickel
93.5
2.0
ug/L
100.0
0.210
93
75-125
3
20
Potassium
1310
100
ug/L
1000
370
94
75-125
2
20
Selenium
102
1.0
ug/L
100.0
0.389
102
75-125
3
20
Sodium
1.00E9
100
ug/L
1000
9640
NR
75-125
0
20 MC
Strontium
179
1.0
ug/L
100.0
86.0
93
75-125
2
20
Thallium
94.2
1.0
ug/L
100.0
0.0997
94
75-125
2
20
Vanadium
96.3
5.0
ug/L
100.0
BRL
96
75-125
3
20
Zinc
95.1
10
ug/L
100.0
4.84
90
75-125
2
20
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 13 of 46

Full -Service Analytical
P R I S M
Environmental Solutions
LABORATORIES, INC.
Level II QC Report
3/14/16
Groundwater Manage. Assoc.(GREE) Project: 157201 Prism Work Order: 6020213
Attn: Steve Campbell Time Submitted: 2/11/2016 8:50:OOAM
4300 Sapphire Court, Suite 100
Greenville, NC 27834
Dissolved Metals - Quality Control
Reporting Spike Source %REC RPD
Analyte Result Limit Units Level Result %REC Limits RPD Limit Notes
Batch P61130460 - 3005A
Post Spike (P6130460-PS1)
Source: 6020213-01
Prepared:
02/25/16 Analyzed: 03/02/16
Aluminum
928
ug/L
1000
7.02
92
80-120
Antimony
94.7
ug/L
100.0
0.128
95
80-120
Arsenic
95.8
ug/L
100.0
0.153
96
80-120
Barium
121
ug/L
100.0
27.8
93
80-120
Beryllium
94.9
ug/L
100.0
0.0343
95
80-120
Boron
1230
ug/L
1000
270
96
80-120
Cadmium
93.2
ug/L
100.0
0.0123
93
80-120
Calcium
9640
ug/L
1000
8860
78
80-120 MC
Chromium
95.2
ug/L
100.0
0.722
94
80-120
Cobalt
91.4
ug/L
100.0
0.797
91
80-120
Copper
94.0
ug/L
100.0
0.268
94
80-120
Iron
937
ug/L
1000
25.7
91
80-120
Lead
94.8
ug/L
100.0
0.157
95
80-120
Magnesium
8220
ug/L
1000
7580
64
80-120 MC
Manganese
161
ug/L
100.0
72.5
89
80-120
Molybdenum
93.7
ug/L
100.0
0.0580
94
80-120
Nickel
92.2
ug/L
100.0
0.210
92
80-120
Potassium
1310
ug/L
1000
370
94
80-120
Selenium
103
ug/L
100.0
0.389
103
80-120
Sodium
1.00E9
ug/L
1000
9640
NR
80-120 MC
Strontium
178
ug/L
100.0
86.0
92
80-120
Thallium
93.2
ug/L
100.0
0.0997
93
80-120
Vanadium
94.6
ug/L
100.0
0.407
94
80-120
Zinc
96.7
ug/L
100.0
4.84
92
80-120
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 14 of 46

Full -Service Analytical
P R I S M
Environmental Solutions
LABORATORIES, INC.
Level II QC Report
3/14/16
Groundwater Manage. Assoc.(GREE) Project: 157201 Prism Work Order: 6020213
Attn: Steve Campbell Time Submitted: 2/11/2016 8:50:OOAM
4300 Sapphire Court, Suite 100
Greenville, NC 27834
Anions by Ion Chromatography - Quality Control
Reporting Spike Source %REC RPD
Analyte Result Limit Units Level Result %REC Limits RPD Limit Notes
Batch P61130227 - NO PREP
Blank (P6B0227-BLK1)
Prepared & Analyzed: 02/11/16
Chloride
BRL
1.0
mg/L
Nitrate as N
BRL
0.10
mg/L
Sulfate
BRL
1.0
mg/L
LCS (P6B0227-BSI)
Prepared & Analyzed: 02/11/16
Chloride
43.9
1.0
mg/L
40.00 110
80-120
Nitrate as N
4.12
0.10
mg/L
4.000 103
80-120
Sulfate
43.8
1.0
mg/L
40.20 109
80-120
Matrix Spike (P660227-MS1)
Source: 6020213-01
Prepared & Analyzed: 02/11/16
Chloride
56.5
1.0
mg/L
40.00 11.3 113
80-120
Nitrate as N
4.44
0.10
mg/L
4.000 0.233 105
80-120
Sulfate
67.2
1.0
mg/L
40.20 22.5 111
80-120
Matrix Spike Dup (P6130227-MSD1)
Source: 6020213-01
Prepared & Analyzed: 02/11/16
Chloride
56.6
1.0
mg/L
40.00 11.3 113
80-120 0.3 15
Nitrate as N
4.39
0.10
mg/L
4.000 0.233 104
80-120 1 15
Sulfate
66.8
1.0
mg/L
40.20 22.5 110
80-120 0.6 15
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 15 of 46

Full -Service Analytical
P R I S M
Environmental Solutions
LABORATORIES, INC.
Groundwater Manage. Assoc.(GREE)
Attn: Steve Campbell
4300 Sapphire Court, Suite 100
Greenville, NC 27834
General Chemistry Parameters - Quality Control
Analyte
Batch P6BO234 - NO PREP
Project: 157201
Reporting
Result Limit Units
Level II QC Report
3/14/16
Prism Work Order: 6020213
Time Submitted: 2/11/2016 8:50:OOAM
Spike Source %REC RPD
Level Result %REC Limits RPD Limit Notes
Blank (P6130234-13LK1)
Prepared & Analyzed: 02/12/16
Total Alkalinity to pH 4.5
BRL 5.0 mg/L
BB
Blank (P6130234-131_11(2)
Prepared & Analyzed: 02/12/16
Total Alkalinity to pH 4.5
BRL 5.0 mg/L
BB
LCS (P6130234-BS1)
Prepared & Analyzed: 02/12/16
Total Alkalinity to pH 4.5
238 5.0 mg/L
250.0 95 90-110
Duplicate (P6B0234-DUP2)
Source: 6020213-01
Prepared & Analyzed: 02/12/16
Total Alkalinity to pH 4.5
39.3 5.0 mg/L
39.7 1 20
Batch P6BO244 - NO PREP
Blank (P660244-BLK1)
Prepared & Analyzed: 02/11/16
Ferrous Iron
BRL 0.20 mg/L
LCS (P61130244-13SI)
Prepared & Analyzed: 02/11/16
Ferrous Iron
1.87 0.20 mg/L
2.000 94 90-110
Matrix Spike (P6B0244-MS1)
Source: 6020213-01
Prepared & Analyzed: 02/11/16
Ferrous Iron
1.80 0.20 mg/L
2.000 BRL 90 80-120
Matrix Spike Dup (P6B0244-MSD1)
Source: 6020213-01
Prepared & Analyzed: 02/11/16
Ferrous Iron
1.78 0.20 mg/L
2.000 BRL 89 80-120 1 20
Batch P6BO255 - NO PREP
Blank (P6130255-BLK1) Prepared & Analyzed: 02/12/16
Carbonate Alkalinity BRL 5.0 mg/L
Bicarbonate Alkalinity BRL 5.0 mg/L
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone] Page 16 of 46

Full -Service Analytical
P R I S M
Environmental Solutions
LABORATORIES, INC.
Level II QC Report
3/14/16
Groundwater Manage. Assoc.(GREE) Project: 157201 Prism Work Order: 6020213
Attn: Steve Campbell Time Submitted: 2/11/2016 8:50:OOAM
4300 Sapphire Court, Suite 100
Greenville, NC 27834
General Chemistry Parameters - Quality Control
Reporting Spike Source %REC RPD
Analyte Result Limit Units Level Result %REC Limits RPD Limit Notes
Batch P6BO255 - NO PREP
LCS (P6B0255-BS1)
Prepared & Analyzed: 02/12/16
Bicarbonate Alkalinity
Batch P6BO260 - NO PREP
238
5.0
mg/L
250.0 95 90-110
Blank (P6130260-13ILK1)
Prepared & Analyzed: 02/12/16
Total Suspended Solids
LCS (P6B0260-BS1)
BRL
5.0
mg/L
Prepared & Analyzed: 02/12/16
Total Suspended Solids
Batch P6BO283 - NO PREP
470
5.0
mg/L
477.0 98 90-110
Blank (P6B0283-BLK1)
Prepared & Analyzed: 02/15/16
Total Dissolved Solids
LCS (P6B0283-BSI)
BRL
50
mg/L
Prepared & Analyzed: 02/15/16
Total Dissolved Solids
Batch P6BO338 - SM4500-S C
1000
50
mg/L
1000 100 90-110
Blank (P660338-BLK1) Prepared & Analyzed: 02/17/16
Sulfide BRL 2.0 mg/L
LCS (P6B0338-BS1) Prepared & Analyzed: 02/17/16
Sulfide 9.80 2.0 mg/L 10.00 98 70-130
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 17 of 46

Level II QC Report
Full -Service Analytical 3/14/16
P R I S M
Environmental Solutions
LABORATORIES, INC.
Groundwater Manage. Assoc.(GREE) Project: 157201 Prism Work Order: 6020213
Attn: Steve Campbell Time Submitted: 2/11/2016 8:50:OOAM
4300 Sapphire Court, Suite 100
Greenville, NC 27834
General Chemistry Parameters - Quality Control
Reporting Spike Source %REC RPD
Analyte Result Limit Units Level Result %REC Limits RPD Limit Notes
Batch P61130338 - SM4500-S C
Matrix Spike (P6B0338-MS1)
Source: 6020213-01
Prepared & Analyzed: 02/17/16
Sulfide
19.6
2.0 mg/L
20.00 1.00 93 70-130
Matrix Spike Dup (P6B0338-MSD1)
Source: 6020213-01
Prepared & Analyzed: 02/17/16
Sulfide
20.4
2.0 mg/L
20.00 1.00 97 70-130 4
20
Sample Extraction
Data
Prep Method: 3005A
Lab Number
Batch
Initial
Final
Date/Time
6020213-01
P6130460
50 mL
50 mL
02/25/16 10:00
Prep Method: 7470A
Lab Number
Batch
Initial
Final
DatelTime
6020213-01
P6130268
20 mL
30 mL
02/18/16 8:45
Prep Method: SM4500-S C
Lab Number
Batch
Initial
Final
Date/Time
6020213-01
13660338
200 mL
200 mL
02/17/16 13:15
Prep Method: 3005A
Lab Number
Batch
Initial
Final
DatelTime
6020213-01
P6130437
50 mL
50 mL
02/24/16 8:15
6020213-01 RE1
P6C0170
45 mL
45 mL
03/10/16 9:45
Prep Method: 3010A
Lab Number
Batch
Initial
Final
DatelTime
6020213-01
P6130239
50 mL
50 mL
02/12/16 8:15
Prep Method: 7470A
Lab Number
Batch
Initial
Final
Date/Time
6020213-01
136130267
20 mL
30 mL
02/18/16 8:45
This report should
not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543
- Charlotte, NC 28224-0543
Phone: [phone]
- Toll Free Number:
1-800/529-6364 - Fax: [phone]
Page 18 of 46

Subcontracted Analyses
The following analyses were subcontracted to Florida Radiochemistry Services, Inc.
Lab Number
6020213-01
Analysis
Radiological (Sub)
The following analyses were subcontracted to Gulf Coast Analytical Labs, Inc.
Lab Number
6020213-01
Analysis
TOC (Sub)
The following analyses were subcontracted to Pace Analytical Services, Inc.(FL)
Lab Number
6020213-01
Analysis
Hexavalent Chromium (Sub)
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone] Page 19 of 46

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Page 20 of 46

Radiochemistry S,
Contact: Michael J. Naumann
5456 Hoffner Ave., Suite 201 Orlando, FL 32812
Phone: [phone] Fax: [phone]
Certification I. D. # 12709
Work Ord , 16 02111
Report 02/23/16
Prism Laboratories, Inc.
449 Springbrook R
PO Box 240543
Charlotte, NC 28217
Attention: Angela D. Overcash
1 do hereby affirm that this record contains no willful misrepresentations and that this information given by
me is true to the best of my knowledge and belief. i further certify that the methods and quality control
measures used to produce these laboratory results were implemented in accordance with the requirements of
this laboratory's certification and NELAC Standards. The test results in this report relate only to the
samples received.
Signed `ti / ;,4 Date :
ichael J. umann -President
Page 1 of 3
Page 21 of 46

Florida Radiochemistry Services, Inc.
Sample Login
Client: Prism Laboratories
Client Contact:
Client P.O.
Project I.D.
Lab Sample I.D.
1602111-01
Gross Alpha
Error +/-
MDL
EPA Method
Prep Date
Prep Time
Analysis Date
Analysis Time
Analyst
Units
Client Sample I.D.
6020213-01
Analysis Results
<0.S
0.5
0.8
900.0
02/16/16
08:08
02/17/16
13:26
MJN
LU
A U next to a result indicates analyte not detected at the MDL level
Date /'Time
Received
02/15/16 13:32
Sample
Date/'Time
02/10/16 14:15
Work order #
1602111
Analysis
Requested
Gross Alpha
Page 2 of 3
Page 22 of 46

BFlorida Radiochernistry Services, Inc.
Analyte Sample # Date Sample Amount Spike Spike /Dup Spike Spike ®up
Analyzed Result Spiked Result Result % Ree. % Rpd
Gross Alpha 1602110-01 02/17/16 <0.9 11.7 00.1 10.6 86 4.8
% RPD % Rec.
Gross Alpha 25.0 60-125
Page 3 of 3
Page 23 of 46

SUBCONTRACT ORDER
Prism Laboratories, Inc.
6020213
SENDING LABORATORY: RECEIVING LABORATORY:
Prism Laboratories. Inc. Florida Radiochemistry Services, Inc.
P. O. Box 240543 5456 Noffner Avenue, Suite 201
Charlotte, NC 28224-0543 Orlando, FL 32812
Phone: [phone] Phone :[phone]
Fax: [phone] Fax: -
Project Manager. Angela D. Overcash
Analysis Due Expires Laboratory ID Comments
Sample ID: 6020213-01 Nater Sample(1:02/10/16 14:15 ®ate Gs S 1f `-_L'
Radiological (Sub) 08/08/16 14:1 j Gross Alpha only
rrr�riner.r Supplied:
UN
IM
IWased By Date `
d-�1'!IV
Received By
�L
'1 Date
-A)� IIS
i �-�D_
Released By Date
Received By
Date
Page I of I
Page 24 of 46

ANALYTICAL, INC.
CLIENT
Prism Laboratories, Inc.
PO BOX 240543
Charlotte, NC 28224
ATTENTION
Angie Overcash
PROJECTID
6020213
LABORATORY REPORT NUMBER
216021218
DATE
02/17/2016
Primary Data Review By
K,r4l�,�g Data el
Authorized Signature
6712F --F1-2 V, Eel I
Secondary Data Review By
Ashley B. Amick
Project Manager, Access Analytical, Inc.
[e-mail]
- Unless otherwise noted, all analysis on this report performed at Gulf Coast Analytical Labs (GCAL),
7979 Innovation Park Dr., Baton Rouge, LA 70820.
- GCAL is SCDHEC certified laboratory # 73006, NCDENR certified lab # 618, GA certified lab # LA -01955,
NELAP certified laboratory # 01955
- Local support services for this project are provided by Access Analytical, Inc.. Access Analytical is a
representative of GCAL serving clients in the SC/NC/GA areas. All questions regarding this report should be
directed to your local Access Analytical representative at 803.781.4243 or toll free at 888.315.4243.
Lab Report#: 216021218
Page 25 of 46

3 SJU-11 WON;
st 1-4 1, OCR
Baton Rouge, LA 70820
KIM
Deliver To Additional Recipients
Angie Overcash NONE
Prism Laboratories, Inc.
PO BOX 240543
Charlotte, NC 28224
706-529-6364
Lab Report#: 216021218 pAn. 9 n
Page 26 of 46

Report#: 216021218
Project ID: 6020213 Report Date: 02/17/2016
Sample analysis was performed in accordance with approved methodologies provided by the Environmental Protection Agency or other recognized
agencies. The samples and their corresponding extracts will be maintained for a period of 30 days unless otherwise arranged. Following this
retention period the samples will be disposed in accordance with GCAL's Standard Operating Procedures.
Common Abbreviations that may be Utilized in this Report
ND Indicates the result was Not Detected at the specified reporting limit
DO Indicates the result was Diluted Out
MI Indicates the result was subject to Matrix Interference
TNTC Indicates the result was Too Numerous To Count
SUBC Indicates the analysis was Sub -Contracted
FLD Indicates the analysis was performed in the Field
DL Detection Limit
DL Diluted analysis — when appended to Client Sample ID
LOD Limit of Detection
LOQ Limit of Quantitation
RE Re -analysis
00:01 Reported as a time equivalent to 12:00 AM
Reporting Flags that may be Utilized in this Report
J or I Indicates the result is between the MDL and LOQ
J DOD flag on analyte in the parent sample for MS/MSD outside acceptance criteria
U Indicates the compound was analyzed for but not detected
B or V Indicates the analyte was detected in the associated Method Blank
Q Indicates a non-compliant QC Result (See Q Flag Application Report)
* Indicates a non-compliant or not applicable QC recovery or RPD — see narrative
E The result is estimated because it exceeded the instrument calibration range
E Metals - % diference for the serial dilution is > 10%
P RPD between primary and confirmation result is greater than 40
Sample receipt at GCAL is documented through the attached chain of custody. In accordance with NELAC, this report shall be reproduced only in
full and with the written permission of GCAL. The results contained within this report relate only to the samples reported. The documented results
are presented within this report.
This report pertains only to the samples listed in the Report Sample Summary and should be retained as a permanent record thereof. The results
contained within this report are intended for the use of the client. Any unauthorized use of the information contained in this report is prohibited.
I certify that this data package is in compliance with The NELAC Institute (TNI) Standard 2009 and terms and conditions of the contract and
Statement of Work both technically and for completeness, for other than the conditions in the case narrative. Release of the data contained in this
hardcopy data package and in the computer readable data submitted has been authorized by the Quality Assurance Manager or his/her designee,
as verified by the following signature.
Estimated uncertainty of measurement is available upon request. This report is in compliance with the DOD QSM as specified in the contract if
applicable.
Karen M.We Mng la oel
Authorized Signature
GCAL Report 216021218
Lab Report#: 216021218 Pacie 3 of 11
Page 27 of 46

Lab Report#: 216021218
Report#: 216021218
Project ID: 6020213
Certifications
10/02/2015
Report Date: 02/17/2016
Certification
Certification Number
DOD FLAP
L14-243
Alabama
01955
Arkansas
12-060-0
Colorado
01955
Delaware
01955
Florida
E87854
Georgia
01955
Hawaii
01955
Idaho
01955
Illinois
200048
Indiana
01955
E-10354
-Kansas
Kentucky
95
Louisiana
01955
Maryland
01955
Massachusetts
01955
Michigan
01955
Mississippi
01955
Missouri
01955
Montana
N/A
Nebraska
01955
New Mexico
01955
North Carolina
618
North Dakota—
R-195
Oklahoma
9403
South Carolina
73006001
South Dakota
01955
Tennessee
01955
7104704178
-Texas
Vermont
01955
Virginia
460215
USDA Soil Permit
P330-10-00117
Paae 4 of
Page 28 of 46

Report#: 216021218
Project ID: 6020213
,•.�i� K,
Report Date: 02/17/2016
Gulf Coast Analytical Laboratories received and analyzed the sample(s) listed
on the Report Sample Summary page of this report. Receipt of the sample(s) is documente"i,
by the attached chain of custody. This applies only to the sample(s) listed in this report.
No sample integrity or quality control exceptions were identified unless noted below.
Lab Report#: 216021218
Page 29 of 46

KOU a I
Report#: 216021218
Project ID: 6020213
Report Date: 02/17/2016
Client ID Matrix Collect Date/Time Receive Date/Time
21602121801 THOMAS SEEP Water 02/10/2016 14:15 02/12/2016 10:05
Lab Report#: 216021218 pqnp R nf
Page 30 of 46

Report#: 216021218
n.
IsB.1411111s. ILI project ID: 6020213
Summary of Compounds Detected
Report Date: 02/17/2016
Collect Date 02/10/2016 14:15 GCAL ID 21602121801
THOMAS SEEP Receive Date 02112/2016 10:05 Matrix Water
SM 5310 B-2011
CAS# Parameter Result DL LOQ Units
C-612 Total Organic Carbon 0.591 0.30 2.0 mg/L
Lab Report#: 216021218 Pqnp 7 nf 11
Page 31 of 46

Report#: 216021218
ANALYTICAL t &q0RATQRf'-'S. LLC Project ID: 6020213
Sample Results
Report Date: 02/17/2016
Collect Date 0211012016 14:15 GOAL ID 21602121801
THOMAS SEEP Receive Date 02/1212016 10:05 Matrix Water
SM 5310 B-20 I
Prep Date Prep Batch Prep Method Dilution Analysis Date By Analytical Batch
NA NA NA 1 02/12/2016 22:27 JEM 579274
CAS# Parameter
C-012 Total Organic Carbon
Lab Report#: 216021218
Result DL LOQ Units
0.591 0.30 2.0 mg/L
Pnnp A nf 11
Page 32 of 46

Rep®rt#: 216021218
Project ID: 6020213
Report Date: 02/17/2016
Analytical Batch Client ID
MB579274
LCS579274
LCSD579274
579274GCALID
1540208
1540209
1540716
Sample Type
MB <
LCS
LCSD
Prep Date
NA
NA
NA
Analysis Date
02/12/201617:46
02/12/2016 16:23
02/12/2016 22:45
Matrix
Water
Water
Water
S 5310 ®2011
Units
mg/L
Spike
Result
%R
Control
Spike
Result
%R
RPD
RPD
Result
DL
Added
Total Organic Carbon I C-012 1.4
0.30
Limits R
Added
94
1 80 - 120
1 50.01
Limit
Total Organic Carbon C-012
0.30U
0.301
50.01
47.2
194
1 90 - 110
1 50.01
48.21961
2
1 20
Analytical Batch Client ID MW9
1539669MS'
1539669MSD
579274 GCALID 21602113607
1540210
1540211
Sample Type SAMPLE
MS
MSD
Prep Date NA '
NA
NA
Analysis Date 02/12/2016 18:10
02/12/2016 18:35
02/12/2016 19:06
Matrix Water
Water
Water
S 5310 -2011 Units
; mg/L
Spike
Result
%R
Control
Spike
Result
%R
I
RPD
I
RPD
I
Result
DL
Added
Limits%R
Added
Limit
Total Organic Carbon I C-012 1.4
0.30
50.01
48.41
94
1 80 - 120
1 50.01
49.61961
2
120
Lab Report#:216021218
Page 33 of 46

r
v
6
X
CD
O
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it
N
W
SUBCONTRACT ORDER
Prism Laboratories, Inc.
6020213
SENDING LABORATORY-
RECEIVING LABORATORY.
Prism; Laboratories, Inc.
GulfCoast Analytical Labs, Inc.
P. 0. Bax 240543
7979 GSRI Avenue
Charlotte, NC 28224-0543
Baton Rouge, LA 70820
Phone: [phone]
Phone :[phone],
Fax: [phone]
Fax: [phone],717
Project Manager: Angela D. Overeash
ii
Analysis
Due
Expires Laboratory ID Comments
2
Sample -1D:6020213 -6I
hater Sarapled:02/10/1614:15
TOC (Sub)
03/09/16 14:15
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Page I of
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Page 34 of 46

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I
e Analytical
—pacelabs.cam
February 16, 2016
Angela Overcash
Prism Laboratories
449 Springbrook Rd.
Charlotte, NC 28217
RE: Project: Thomas Seep
Pace Project No.: 35229104
Pace Analytical Services, Inc.
8 East Tower Circle
Ormond Beach, FL 32174
[phone]
Dear Angela Overcash:
Enclosed are the analytical results for sample(s) received by the laboratory on February 11, 2016.
The results relate only to the samples included in this report. Results reported herein conform to the
most current TNI standards and the laboratory's Quality Assurance Manual, where applicable, unless
otherwise noted in the body of the report.
If you have any questions concerning this report, please feel free to contact me.
Sincerely,
Bo Garcia
[e-mail]
Project Manager
Enclosures
0
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 1 of 11
Page 36 of 46

ace real cal®
www.pacelabs.com
Project: Thomas Seep
Pace Project No.: 35229104
Ormond Beach Certification lDs
8 East Tower Circle, Ormond Beach, FL 32174
Alabama Certification #: 41320
Connecticut Certification #: PH -0216
Delaware Certification: FL NELAC Reciprocity
Florida Certification #: E83079
Georgia Certification #: 955
Guam Certification: FL NELAC Reciprocity
Hawaii Certification: FL NELAC Reciprocity
Illinois Certification #: 200068
Indiana Certification: FL NELAC Reciprocity
Kansas Certification #: E-10383
Kentucky Certification #: 90050
Louisiana Certification #: FL NELAC Reciprocity
Louisiana Environmental Certificate #: 05007
Maryland Certification: #346
Michigan Certification #: 9911
Mississippi Certification: FL NELAC Reciprocity
Missouri Certification #: 236
Montana Certification #: Cert 0074
Pace Analytical Services, Inc.
8 East Tower Circle
Ormond Beach, FL 32174
[phone]
Nebraska Certification: NE -OS -28-14
Nevada Certification: FL NELAC Reciprocity
New Hampshire Certification #: 2958
New York Certification #: 11608
North Carolina Environmental Certificate #: 667
North Carolina Certification #: 12710
North Dakota Certification #: R-216
Oklahoma Certification #: D9947
Pennsylvania Certification #: 68-00547
Puerto Rico Certification #: FL01264
South Carolina Certification: #96042001
Tennessee Certification #: TN02974
Texas Certification: FL NELAC Reciprocity
US Virgin Islands Certification: FL NELAC Reciprocity
Virginia Environmental Certification #: 460165
West Virginia Certification #: 9962C
Wisconsin Certification #: 399079670
Wyoming (EPA Region 8): FL NELAC Reciprocity
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 2 of 11
Page 37 of 46

ace Analytical
www.pecolabs.com
Pace Analytical Services, Inc.
8 East Tower Circle
Ormond Beach, FL 32174
[phone]
Project: Thomas Seep
Pace Project No.: 35229104
Lab ID Sample ID Matrix Date Collected Date Received
35229104001 Thomas Seep Water 02/10/16 14:15 02/11/16 09:11
[W-USIZ-4 111M a 11IF-111191 OV -11% 1101 wh—ITMAMW
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.. Page 3 of 11
Page 38 of 46

(�Iacl eAnalXkal'
www.pacelabs.com
V
Pace Analytical Services, Inc.
8 East Tower Circle
Ormond Beach, FL 32174
[phone]
Project: Thomas Seep
Pace Project No.: 35229104
Analytes
Lab ID Sample ID Method Analysts Reported Laboratory
35229104001 Thomas Seep EPA 218.7 TK1 1 PAST -0
EPA 218.7 TKI 1 PASI-0
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.. Page 4 of 11
Page 39 of 46

C eAnal yticaI8
www.pacelabs.com
Project: Thomas Seep
Pace Project No.: 35229104
Pace Analytical Services, Inc.
8 East Tower Circle
Ormond Beach, FL 32174
[phone]
Sample: Thomas Seep
Lab ID: 35229104001 Collected:
02/10/16 14:15
Received: 02/11/16 09:11 Matrix: Water
Parameters
Results Units PQL
MDL DF
Prepared Analyzed CAS No. Qual
Hexavalent Chromium by IC
Analytical Method: EPA 218.7
Chromium, Hexavalent
0.054 ug/L 0.030
0.010 1
02/11/16 13:59 18540-29-9 M1,R1
Hexavalent Chromium Lab Filter
Analytical Method: EPA 218.7
Hexavalent Chromium (unfilter)
0.041 ug/L 0.030
0,010 1
02/11/16 13:46 18540-29-9 N2
Date: 02/16/2016 02:50 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 5 of 11
Page 40 of 46
lv I i

ace nal l
www.pacelabs.com
Project: Thomas Seep
Pace Project No.: 35229104
QC Batch: WETA/54968
QC Batch Method: EPA 218.7
Associated Lab Samples: 35229104001
METHOD BLANK: 1478236
Associated Lab Samples: 35229104001
Parameter Units
Chromium, Hexavalent ug/L
LABORATORY CONTROL SAMPLE: 1478237
Parameter Units
Chromium, Hexavalent ug/L
Pace Analytical Services, Inc.
8 East Tower Circle
Ormond Beach, FL 32174
[phone]
Analysis Method: EPA 218.7
Analysis Description: Chromium, Hexavalent IC
Matrix: Water
Blank Reporting
Result Limit MDL Analyzed Qualifiers
ND 0.030 0.010 02/12/1610:23
Spike LCS LCS % Rec
Conc. Result % Rec Limits Qualifiers
.075 0.076 101 85-115
MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 1478238 1478239
MS MSD
35229104001 Spike Spike MS MSD MS MSD % Rec Max
Parameter Units Result Conc. Conc. Result Result % Rec % Rec Limits RPD RPD Qual
Chromium, Hexavalent ug/L 0.054 .075 .075 0.18 0.14 170 108 85-115 29 20 M1,R1
Results presented on this page are in the units indicated by the "Units" column except where an alternate unit is presented to the right of the result.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 02/16/2016 02:50 PM without the written consent of Pace Analytical Services, Inc..
Page 6 of 11
Page 41 of 46

IeAnalytical
www.pacelabs.com
Project: Thomas Seep
Pace Project No.: 35229104
QC Batch: WETA/54967
QC Batch Method: EPA 218.7
Associated Lab Samples: 35229104001
METHOD BLANK: 1478228
Associated Lab Samples: 35229104001
Parameter Units
Hexavalent Chromium (unfilter) ug/L
Pace Analytical Services, Inc.
8 East Tower Circle
Ormond Beach, FL 32174
[phone],
1 0111:z.1,111111111111irr=l
Analysis Method: EPA 218.7
Analysis Description: Chromium, Hexavalent IC Lab Filtered
Matrix: Water
Blank Reporting
Result Limit MDL Analyzed Qualifiers
ND 0.030 0.010 02/12/1610:49 N2
LABORATORY CONTROL SAMPLE: 1478229
Spike LCS LCS % Rec
Parameter Units Conc. Result % Rec Limits Qualifiers
Hexavalent Chromium (unfilter) ug/L .075 0.073 97 85-115 N2
MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 1478230 1478231
MS MSD
35229104001 Spike Spike MS MSD MS MSD % Rec Max
Parameter Units Result Conc. Conc. Result Result % Rec % Rec Limits RPD RPD Qual
Hexavalent Chromium ug/L 0.041 .075 .075 0.13 0.12 114 101 85-115 8 20 N2
(unfilter)
Results presented on this page are in the units indicated by the "Units" column except where an alternate unit is presented to the right of the result.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 02/16/2016 02:50 PM without the written consent of Pace Analytical Services, Inc..
Page 7 of 11
Page 42 of 46

acmnalyfical"
wuw.pacelabs.com
I
Project: Thomas Seep
Pace Project No.: 35229104
Pace Analytical Services, Inc.
8 East Tower Circle
Ormond Beach, FL 32174
[phone]
DF - Dilution Factor, if reported, represents the factor applied to the reported data due to dilution of the sample aliquot.
ND - Not Detected at or above adjusted reporting limit.
J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit.
MDL -Adjusted Method Detection Limit.
PQL - Practical Quantitation Limit.
RL - Reporting Limit,
S - Surrogate
1,2-Diphenylhydrazine decomposes to and cannot be separated from Azobenzene using Method 8270. The result for each analyte is
a combined concentration.
Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values.
LCS(D) - Laboratory Control Sample (Duplicate)
MS(D) - Matrix Spike (Duplicate)
DUP - Sample Duplicate
RPD - Relative Percent Difference
NC - Not Calculable.
SG - Silica Gel - Clean -Up
U - Indicates the compound was analyzed for, but not detected.
N-Nitrosodiphenylamine decomposes and cannot be separated from Diphenylamine using Method 8270. The result reported for
each analyte is a combined concentration.
Pace Analytical is TNI accredited. Contact your Pace PM for the current list of accredited analytes.
TNI - The NELAC Institute.
WA-= •13_L•13N61
PASI-O Pace Analytical Services - Ormond Beach
ANALYTE QUALIFIERS
M1 Matrix spike recovery exceeded QC limits. Batch accepted based on laboratory control sample (LCS) recovery.
N2 The lab does not hold TNI accreditation for this parameter.
R1 RPD value was outside control limits.
Date: 02/16/2016 02:50 PM
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 8 of 11
Page 43 of 46

acaceeAnalytical@
I www.pacelabs.com
Project: Thomas Seep
Pace Project No.: 35229104
Lab ID
35229104001
35229104001
Sample ID
Thomas Seep
Thomas Seep
Date: 02/16/2016 02:50 PM
QC Batch Method QC Batch
EPA 218.7 WETA154968
EPA 218.7 WETA/54967
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Pace Analytical Services, Inc.
8 East Tower Circle
Ormond Beach, IFIL 32174
[phone]
Analytical
Analytical Method Batch
Page 9 of 11
Page 44 of 46

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Project
o-. t
Courier: ❑ Fed Ex ❑ UPS ❑ USPS ❑ Client ❑ Commercial L
Date and Initials of person exarninjn
contents.
Deliver:
pH: w%
Other ❑
Shipping Method: ❑ First Overnight ❑ Priority Overnight ❑ Standard Overnight ❑ Ground
Silting: ❑Recipient 11 Sender 11 Third Party 11Unkown Cooler Size if Applicable
Tracking # f f 5 J e) eo 6r, j� 7
Custody Seal on Cooler/Box Present: Dyes ❑ no Seals intact: ❑ yes❑ no
Packing Material: ❑Bubble Wrap ubble Bags ❑None ❑Other Biological Tissue is Frozen: Yes No NIA
Thermometer Used - Type of Ice: of )Blue None El Samples on ice, cooling Process has begun
Cooler 1%1 Temperature°C_a1 (Visual) {Correction Factor) r (Actual)
Cooler#2 Temperature°C (Visual) (Correction Factor) (Actual)
Cooler #3 Temperature°C (Visual) (Correction Factor) (Actual) Temp should be above freezing
Cooler #4Temperature°C (Viisual) (Correction Factor) (Actual) to 6°C
Cooler #5 Temperature°C (Visual) (Correction Factor) (Actual)
Cooler#6 Temperature°C (Visual) (Correction Factor) (Actual)
t`nmmantc'
Chain of Custody Present
DocumentName:
ocument Revised:
4ilafyticaf
Sample Condition Upon Receipt Form
December 28, 2015
ace u 4.a f
ocument o.;
F -FL -0-007 rev. 07
Issuing ut only:
Pace Florida Quality Office
Project
o-. t
Courier: ❑ Fed Ex ❑ UPS ❑ USPS ❑ Client ❑ Commercial L
Date and Initials of person exarninjn
contents.
Deliver:
pH: w%
Other ❑
Shipping Method: ❑ First Overnight ❑ Priority Overnight ❑ Standard Overnight ❑ Ground
Silting: ❑Recipient 11 Sender 11 Third Party 11Unkown Cooler Size if Applicable
Tracking # f f 5 J e) eo 6r, j� 7
Custody Seal on Cooler/Box Present: Dyes ❑ no Seals intact: ❑ yes❑ no
Packing Material: ❑Bubble Wrap ubble Bags ❑None ❑Other Biological Tissue is Frozen: Yes No NIA
Thermometer Used - Type of Ice: of )Blue None El Samples on ice, cooling Process has begun
Cooler 1%1 Temperature°C_a1 (Visual) {Correction Factor) r (Actual)
Cooler#2 Temperature°C (Visual) (Correction Factor) (Actual)
Cooler #3 Temperature°C (Visual) (Correction Factor) (Actual) Temp should be above freezing
Cooler #4Temperature°C (Viisual) (Correction Factor) (Actual) to 6°C
Cooler #5 Temperature°C (Visual) (Correction Factor) (Actual)
Cooler#6 Temperature°C (Visual) (Correction Factor) (Actual)
t`nmmantc'
Chain of Custody Present
Q es
t7 No ❑N/A
Chain of Custody Filled Out
es
❑ No ❑NIA
Relinquished Signature & Sampler Name COC
Yes
❑ No ❑NIA
Samples Arrived within Hold Time
fes
❑ No ❑NIA
Rush TAT requested on COC
i
❑Yes
❑ No /A
Sufficient Volume
es
❑ N ❑NIA
Correct Containers Used
Yes
❑ No ❑NIA
Pace Containers Used
U7 es
❑ No ❑NIA
Containers Intact
Yes
❑ No ❑N/A
Sample Labels match COC (sample IDs & date/time of
collection)
Vyes
❑ No El NIA
All containers needing acid/base preservation have been
! /
HNO3 pH<2
checked.
(AF
❑ No ❑NIA
HCI pH -2
All Containers needing preservation are found to be in
H2SO4 pH<2
compliance with EPA recommendation:
Yes
❑ No ❑NIA
NaOH pH>12
Exceptions: VOR, Col form, TOC,'O&G
NaOH/ZnOAc pH>9
No Headspace in VOA Vials (>6mm):
❑Yes
❑ No NIA.
Trip Blank Present:
❑Yes
❑ N NIA
Client Notification( Resolution:
Person Contacted:
Comments/ Resolution (use back for additional comments):
i✓
Date1Time:
Project Manager Review: Date:
Page 11 of 11
Page 46 of 46

CERTIFICATE OF SERVICE
I hereby certify that the foregoing Supplemental Expert Report for the Buck Steam
Station was served on all parties by depositing a true and correct copy in the U.S. Mail, first-
class postage prepaid, addressed as follows:
Anita LeVeaux
Frank E. Emory
Amy Bircher
Brent Rosser
Carolyn McLain
Nash Long
Francisco Benzoni
Melissa Romanzo
T. Hill Davis
Emma C. Merritt
N.C. Department of Justice
Hunton & Williams, LLP
P.O. Box 629
Bank 6fAmerica Plaza
Raleigh, NC 27602-0629
101 South Tryon Street, Suite 3500
[e-mail]
Charlotte, NC 28280
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Charles D. Case
McGuire Woods, LLP
James P. Cooney, III
434 Fayetteville Street
Womble Carlyle Sandridge
Suite 2600
& Rice, LLP
Raleigh, NC 27601
One Wells Fargo Center,
[e-mail]
Suite 3500
301 South College Street
Charlotte, NC 28202
[e-mail]
This the 13th day of May, 2016.
Myra Blake