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HomeMy WebLinkAbout2016-05-13 Parette Expert Report- Mayo Site - 05-13-160 MATSON ASSOCIATES Opinions on the Appropriateness of Monitored Natural Attenuation in Conjunction with Cap -in -Place at the Mayo Steam Station, Roxboro, NC Prepared for: Southern Environmental Law Center 22 South Pack Square, Suite 700 Asheville, NC 28801 Prepared by: Robert Parette, Ph.D., P.E. May 13, 2016 Table of Contents I. Qualifications...................................................................................................................................1 11. Scope of Wo k.................................................................................................................................1 III. Basis of Opinion...........................................................................................................................1 IV. Methodology...............................................................................................................................1 V. Backg ound.....................................................................................................................................3 A. Coal Ash and the Mayo Site.......................................................................................................... 3 B. Monito ed Natu al Attenuation (MNA)........................................................................................4 VI. Opinion: Monito ed Natu al Attenuation is not an app op iate emedy at the Mayo site ............. 7 A. Evidence indicates that constituents in the g oundwate a e not being attenuated by adso ption uncle cu ent conditions at the Mayo site...........................................................................................7 B. Kd values dete mined in the labo ato y cannot be eliably utilized as a means to demonst ate site-specific attenuation fo the Mayo site...........................................................................................8 C. When MNA is based upon adso ption of COls onto i on and manganese oxides, the utilization of MNA in combination with capping is p oblematic as conditions fo MNA a e less favo able following capping................................................................................................................................................ 9 D. MNA based upon adso ption is not an app op iate emedy fo a senic at the Mayo site ............ 10 VII. Refe ences.................................................................................................................................12 I. Qual f cat ons I am an Envi onmental Enginee (P.E.) at Matson & Associates, Inc. (M&A). My academic backg ound includes a B.S. in Chemical Enginee ing f om Wo ceste Polytechnic Institute and a M.S. and a Ph.D. in Envi onmental Enginee ing f om The Pennsylvania State Unive sity. I have ove 10 yea s of expe ience in the emoval of va ious contaminants f om envi onmental media. I have co-autho ed seve al pee - eviewed pape s pe taining to the emoval of a senic f om g oundwate utilizing i on o i on-tailo ed adso bents. I have also p eviously evaluated emedies fo a senic contaminated g oundwate (including MNA) at coal ash disposal sites, as well as the use of va ious technologies to t eat effluent impacted by metals and othe constituents at a coal mining site. My CV is attached in Appendix A. II. Scope of Work I was etained by the Southe n Envi onmental Law Cente (SELC) to evaluate whethe Monito ed Natu al Attenuation (MNA), in conjunction with Cap -in -Place, is an app op iate emedy fo Duke's Mayo Steam Station (Mayo site) nea Roxbo o, NC. III. Bas s of Op n on My opinion is based on site specific documents, as well as scientific lite atu e, and my education and expe ience. My opinion is based on a easonable deg ee of enginee ing and scientific ce tainty. I ese ve the ight to supplement my opinions should additional info mation become available. IV. Methodology My ole in this matte was to evaluate whethe MNA, in conjunction with Cap -in -Place, is an app op iate emedy fo the Mayo site. An evaluation of the app op iateness of MNA at a site equi es an in-depth uncle standing of the p ocesses that constitute natu al attenuation at the site and how the site specific envi onmental conditions impact these p ocesses. Fo the Mayo site, knowing the constituents of inte est (COls) and that the emedial st ategy p oposed by Duke Ene gy was based in -pa t on co -p ecipitation and adso ption, I evaluated whethe these p ocesses we a occu ing uncle the specific conditions found at the Mayo site. My evaluation utilized the c ite is established by the U.S. EPA fo MNA of ino ganic contaminants in g oundwate ; the same c ite is identified by Duke's consultants in thei analysis. My opinions a e based on conside ation of data and info mation p ovided in the Comp ehensive Site Assessment Repo t, the Co ective Action Plan Pa t 1, and the Co ective Action Plan Pa t 2 fo the Mayo site; and on methods that I have used in othe scientific o enginee ing inqui ies conce ning envi onmental p ocesses, which a e based upon methods and analysis widely accepted in the published, pee - eviewed lite atu a in the fields of envi onmental science and enginee ing. Fi st, I examine the data available to dete mine whethe a p ocess is wo king, and 1 if not I then conduct esea ch to dete mine why. This esea ch gene ally involves a eview of the elevant pee - eviewed lite atu e followed by an analysis of the applicability of the lite atu e to the p ocess being evaluated. In this matte I examined all of the available data fo the coal ash, the g oundwate , and the solid-wate pai analyses to gain an uncle standing as to whethe COls we e natu ally attenuating and to gain an uncle standing of the site conditions influencing natu al attenuation. I then conducted a lite atu a sea ch fo studies on simila MNA applications. Since the application of MNA as a t eatment fo COls in g oundwate at coal ash sites is new, published lite atu a on sites whe e it has been implemented fo such pu pose is not yet available fo assessment of MNA's pe fo mance in this capacity. The efo e, I eviewed a numbe of studies in the pee - eviewed lite atu a that had examined the effectiveness of t eating coal ash leachate o individual COls in othe systems with i on o manganese oxides in active o enginee ed t eatment systems. These studies included my own publications investigating how i on and a senic behave in g oundwate t eatment ope ations in o de to design effective t eatment systems fo a senic emoval. Based on my knowledge, t aining, education, and yea s of expe ience esea ching emoval by adso ption onto i on oxides, I knew that a numbe of facto s can influence the adso ption of COls to metal oxides so I conducted an investigation to dete mine whethe the Mayo site conditions we a impacting MNA. My ole also involved evaluating the effectiveness of MNA uncle Duke's p oposed plan of capping the Mayo site. The efo e, I conducted a simila analysis of MNA uncle alte ed site conditions based on this p oposed scena io. My analysis focused on a numbe of COls as identified in my opinion below in Section VI. Fo the COls not discussed, I am not making a dete mination on whethe MNA is an app op iate emedy. K V. Background A. Coal Ash and the Mayo Site • Coal ash is the waste mate ial p oduced f om the bu ning of coal in coal-fi ed powe plants. It is comp ised of a numbe of byp oducts. Fo example, fly ash is "a ve y fine powde y mate ial comp ised mostly of silica made f om the bu ning of finely g ound coal in a boile ." (U.S. EPA 2016). Bottom ash, is aptly named fo the ash pa ticles that a e too la ge to be ca ied into the smoke stacks and thus collect in the bottom of the boile (U.S. EPA 2016). Both p oducts a e commonly efe ed to as coal ash. • Coal ash in gene al is comp ised mainly of oxides of silica, aluminum, i on and calcium, and also contains nume ous othe elements such as a senic, bo on, ch omium, cobalt, and vanadium. Exposu a of coal ash to wate is known to cause the leaching and elease of coal ash constituents to g oundwate and su face wate (Elect is Powe Resea ch Institute 2009, Liu et al. 2004, Lokeshappa et al. 2014, Abe nethy et al. 1969). • The Mayo Steam Station (Mayo site) is located nea the weste n bank of the Mayo Lake, nea Roxbo o, No th Ca olina. Beginning in 1983 coal was bu ned at the site to p oduce elect icity. (Co ective Action Plan Pa t 1, Appendix Q. • At the Mayo site coal combustion esiduals we a disposed into an ash basin occupying app oximately 144 ac es. The basin was c eated by impounding C utchfield B anch, a small st eam that flows to the no th, th ough the const uction of a 2,300 foot long ea then dam with a height of 110 feet. The ash basin (the fo me st eam valley of C utchfield B anch), is app oximately half open wate and half ash (as shown in Figu a ES -2 of the Co ective Action Plan Pa t 2). (Co ective Action Plan Pa t 1, Appendix Q. Acco ding to Duke's website, the "total volume of ash" at the Mayo site is 6.51 million tons (Duke Ene gy Ash Met ics). • A small st eam flows into the Mayo site ash basin. Based on the wate elevation in the ash basin (in compa ison to the elevation in wells along C utchfield B anch (no th of the basin), Duke indicated that g oundwate gene ally flows no th- no theast f om the ash basin, but also that site g oundwate f om the easte n side of the site discha ges to Mayo Lake (Comp ehensive Site Assessment Repo t, Co ective Action Plan Pa t 1 Appendix Q. • Coal ash disposal at the Mayo site has led to a numbe of constituents in site g oundwate that exceed applicable standa ds. Based on the Co ective Action Plan Pa t 1, these constituents a e antimony, a senic, ba ium, bo on, ch omium, cobalt, i on, manganese, thallium, total dissolved solids (TDS), and vanadium. These g oundwate constituents, he ein efe ed to as constituents of inte est (COls), will 3 t avel with the g oundwate unless they a e emoved (adso bed, p ecipitated, etc.) along the g oundwate flow path. • Duke has p oposed to utilize cap -in-place in combination with monito ed natu al attenuation at the Mayo site. Duke indicates that cap -in-place at the Mayo site will place "a low pe meable line ove the ash basin to contain the ash and p event ainwate infilt ation" (Co ective Action Plan Pa t 1 Appendix Q. B. Monito ed Natu al Attenuation (MNA) • MNA elies solely on natu al envi onmental geochemical p ocesses to mitigate concent ations of contaminants (no active emediation) with egula ly scheduled monito ing to assess whethe MNA is wo king. Acco ding to the USEPA (2012): "Monito ing typically involves collecting soil and g oundwate samples to analyze them" fo the contaminants of conce n and othe site pa amete s. The " ight conditions must exist uncle g ound to clean sites p ope ly and quickly enough." • COls at the Mayo site a e elements (ino ganics), and the efo a cannot be dest oyed. Natu al p ocesses to immobilize ino ganics include adso ption, p ecipitation/co- p ecipitation, and/o oxidation- eduction eactions (U.S. EPA 2007a). Duke indicated that at the Mayo site, that "attenuation is in the fo m of dilution as constituents flow th ough the system; so ption whe eby aqueous ions a e emoved by chemical inte actions with a su face [adso ption]; and chemical p ecipitation which includes homogeneous mine al p ecipitation and co -p ecipitation" (Co ective Action Plan Pa t 2). P ocesses such as adso ption and co -p ecipitation can potentially immobilize a COI, and evaluating the effectiveness of natu al attenuation via these p ocesses is the focus of this epo t. While concent ations of COls can be educed via dilution, dilution does not p event the movement o discha ge of a COI f om a site. • Duke is elying in -pa t upon adso ption/co-p ecipitation of COls onto hyd ous metal oxides, such as i on and manganese in its selection of MNA as a emedy. In educed fo ms (i on and manganese in the +2 oxidation state), i on and manganese (also components of coal ash) have highe solubility and mobility. As these species mig ate f om thei sou ce and encounte mo a oxidized conditions, p ecipitation (pa ticula ly fo i on) as insoluble species (i on in the +3 oxidation state and manganese in the +4 oxidation state) occu s c eating su faces onto which COls can be adso bed. MNA based on these p ocesses is successful only uncle the ight conditions, which will be discussed in mo a detail below. • In gene al, many g oundwate constituents a e known to adso b onto i on oxide su faces. In gene al, adso ption of g oundwate constituents onto manganese oxide 4 su faces is not as well studied, though it is known that manganese oxide is not an effective adso bent fo a senic, but has been epo ted to have high affinity fo cobaltuncle the ight conditions (Hoffman et al. 2006, Salminen 2005). • In gene al, the e a e a numbe of facto s that influence the effectiveness of natu al attenuation fo ino ganics at a site. These facto s include (but a e not limited to) the oxidation- eduction potential of the g oundwate , the pH, competition fo adso ption sites, complexation, the elative ates of oxidation between a COI and a potential adso bent such as i on, the amount of COls in the coal ash sou ce, and atios of COls to adso bents. o The speciation of a COI is dependent upon pH and the oxidation- eduction potential of the g oundwate . Potential emoval mechanisms fo a constituent can change depending upon the speciation of the constituent. o In addition to COls having to compete against each othe fo adso ption sites, othe constituents p esent in the g oundwate can also significantly impact the adso ption of COls onto hyd ous metal oxide su faces. Fo example, silica, phosphate, bica bonate, and dissolved o ganic ca bon can p esent competition p oblems (Meng et al. 2002, Meng et al. 2000, Holm et al. 2008, Su and Puls 2003, Holm 2002, Mille 2001, Swedlund and Webste 1999, Chen et al. 2007, Sa ka et al. 2014, Ma iussen et al. 2015, U.S. EPA 2007b). Based on my eview of site data, to my knowledge, concent ations of silica and phosphate in Mayo site g ound g oundwate have not been monito ed. ■ G oundwate typically contains silica in the ange of 3.3 to 21 mg/L (as Si) (Holm et al. 2008, Davis et al. 2001). Silica is known to limit the adso ption of COls onto i on oxides (Meng et al. 2000, Davis et al. 2001, Swedlund and Webste 1999). Dissolved silica at concent ations below the typical ange found in g oundwate has been shown to limit adso ption of the COls (Mille 2001). Silica comp ises a majo f action of coal ash by weight (Elect is Powe Resea ch Institute 2009), and has been found in the g oundwate between 180 and 650 mg/L as Si at a coal ash site in the mid- Atlantic egion. ■ Concent ations of phosphate below 1 mg/L have been shown to limit adso ption of COls. The p esence of silica is known to magnify the impact of phosphate. Phospho us pentaoxide (which fo ms phosphate in wate ) is a known constituent of coal ash (Meng et al. 2002, Meng et al. 2000, Holm et al. 2008, Su and Puls 2003, Holm 2002, Blackmo a et al. 1996, Liu et al. 2004). ■ With ega d to cobalt adso ption onto manganese oxide, othe metals such as coppe , nickel, and zinc may outcompete it fo adso ption sites L (Mukhe jee et al. 2013). The p esence of bo ate (bo on is a site COI) can also significantly educe the adso ption of cobalt onto manganese oxides (Hasany and Qu eshi 1981). o Othe constituents in g oundwate can fo m complexes with metals which can dec ease COI adso ption/co-p ecipitation. Fo example, vanadium, a site COI, can fo m complexes with sulfate (Salminen 2005, U.S. EPA 2007a). o When utilizing i on to emove COls such as a senic and vanadium, oxidation of these ino ganics should occu simultaneously with the oxidation of i on to achieve optimal emoval (Hoffman et al. 2006, Rocca o and Vagliasindi 2015). • Due to the numbe of va iables that can impact MNA of ino ganics, the feasibility of utilizing natu al attenuation fo ino ganics must be assessed on a site -by -site basis because the effectiveness is highly site specific (Reisinge et al. 2005, Mille 2011). • Acco ding to the U.S. EPA, dete mining the feasibility of using MNA at a site fo an ino ganic constituent at a site is a fou -tie ed evaluation (U.S. EPA 2007a). • The envi onmental geochemical p ocesses that constitute natu al attenuation fo COls at the Mayo site a e ongoing, and have been ongoing since coal ash disposal began; these p ocesses do not begin at the time MNA is app oved as a emedy fo a site. The efo e, a Tie I evaluation establishes whethe natu al attenuation is cu ently occu ing at the site, and if so is the fi st step in demonst ating the long to m app op iateness of MNA as a site emedy. • In the Tie I evaluation p ocess, concent ations of COls we a measu ed in Mayo site wate and soil (solid) f om the same location and depth. If attenuation is occu ing via adso ption onto aquife solids, the concent ation of the COI on the solid mate ial should inc ease with the concent ation of the COI in the g oundwate . An example of this type of analysis is shown below in Figu e 1 (U.S. EPA 2007a). A st ong positive co elation between the COI concent ation in wate and solid pai s indicates attenuation. Conve sely, acco ding to the U.S. EPA, sites whe e COI attenuation is not obse ved "would be eliminated f om fu the conside ation of MNA as pa t of the cleanup emedy" (U.S. EPA 2007a). 11 F gure 1. Example of a sol d -water pa r analys s to demonstrate attenuat on (adapted from U.S. EPA 2007a) Site -Specific Sorption Trend (A) AttenuationAttenuation (B) NoNo Attenuation Arpuaos (Ppm) • Simila to the elationship analysis shown in Figu e 1, a p opo tionality constant (Kd) can be dete mined in the labo ato y by allowing site soil samples to equilib ate with wate . Kd is defined as the concent ation of the COI in the solid divided by the concent ation of the COI dissolved in the wate . In a solid-wate pai analysis with a positive linea t end, Kd would be the slope of the t end line. Kd values can give an indication of the potential fo dissolved COIs in g oundwate to adso b onto soil, which then can be elated to the ate at which a COI moves in elation to the ate of g oundwate movement (Co ective Action Plan Pa t 1 Appendix D). • With ega d to the Mayo site, Duke also pe fo med geochemical modeling (Co ective Action Plan Pa t 2). The U.S. EPA ecommended that modeling esults be "used as seconda y lines of evidence in suppo t of site-specific measu ements that demonst ate active so ption of the contaminant onto aquife solids" and not be elied upon independently (U.S. EPA 2007a). VI. Op n on: Mon tored Natural Attenuat on s not an appropr ate remedy at the Mayo s te. A. Evidence indicates that constituents in the g oundwate a e not being attenuated by adso ption uncle cu ent conditions at the Mavo site • Duke pe fo med a solid-wate pai analysis fo five COls that have been measu ed in Mayo site wells at concent ations that have exceeded applicable standa ds. These COls we e a senic, bo on, ch omium, i on, and manganese. 7 • In its analysis, Duke stated that examination of the solid-wate pai s " eveals that little so ption appea s to be occu ing at Mayo", "likely because g oundwate flow is la gely th ough the t ansition zone and uppe bed ock units, whe e thei physical p ope ties limit the amount of adso ption." • The t end line fo the solid-wate pai analysis fo each of these COls has a negative slope. Adso ption onto solids is not inc easing as a function of the g oundwate concent ation, as would be the case if attenuation was occu ing via adso ption (as shown in Figu e 1 above f om U.S. EPA 2007a). • Fu the mo e, g oundwate will continue to flow th ough the t ansition zone and uppe bed ock units (as shown in Figu a ES -2 of the Co ective Action Plan Pa t 1), (even if the ash is capped in place). The efo e, the "physical p ope ties that limit the amount of adso ption" in the t ansition zone and uppe bed ock is a pe manent p oblem. • In gene al, it is uncle stood that bo on is poo ly adso bed. o Results of the labo ato y soil so ption expe iments indicate that "bo on so ption is ve y low in Mayo site soil samples" (Co ective Action Plan Pa t 1 Appendix D). o With ega d to coal combustion p oduct leachate, MNA pathways do not exist fo bo on (Mille 2011). o Bo on was not effectively emoved f om coal ash leachate by adso ption/co- p ecipitation with i on in a settling basin at a site in Pennsylvania (Rightnou and Hoove 1998). B. Kd values dete mined in the labo ato v cannot be eliably utilized as a means to demonst ate site-specific attenuation fo the Mayo site. • Kd values dete mined in the labo ato y a e not ep esentative of site-specific Kd values fo the Mayo site. As stated above, Kd is a pa amete to estimate the potential fo the adso ption of the COls in the g oundwate onto soil. Fo the Mayo site, Kd values we a dete mined expe imentally in the labo ato y using "synthetic g oundwate ", which was ve y limited in to ms of the numbe of constituents and in many cases the concent ation of these constituents, and the efo a was not ep esentative of g oundwate impacted by coal ash at the Mayo site. o Duke, in the Co ective Action Plan Pa t 1 (Appendix D) states that "a solution intended to ep esent ae� ne is g oundwate is used as the backg ound to which [contaminants of conce n] we a added" and that "this solution diffe s f om the actual solution in g oundwate f om which the soil sample was sample[d]". N • The Kd expe iments we a conducted uncle oxic (high oxygen) conditions. In Co ective Action Plan Pa t 2 epo is fo othe sites (Allen, Belews C eek, Buck, Cliffside, Ma shall), Duke stated that "typically Kd expe iments a e also conducted uncle oxic [high oxygen] conditions, which may not eflect actual site conditions. Consequently, Kd values f om labo ato y expe iments should be inte p eted and used with caution because they may not account fo the full ange of so ption conditions that occu in hete ogeneous, natu al soils." • Additionally, the "synthetic g oundwate " did not include a numbe of competing constituents that a e known to limit adso ption of COls. These include silica and phosphate, which can significantly impact adso ption. Silica, in pa ticula , can be p esent at ve y high concent ations at coal ash disposal sites. • The efo e, the Kd values dete mined in the labo ato y we e likely biased high because the "synthetic g oundwate " did not have othe constituents competing fo the same adso ption sites. C. When MNA is based upon adso ption of COls onto i on and manganese oxides, the utilization of MNA in combination with capping is p oblematic as conditions fo MNA a e less favo able following capping. • Even if the site is capped, much of the coal ash at the Mayo site will emain in contact with g oundwate (Co ective Action Plan Pa t 1 Appendix E, Figu es 16 and 17a). This means that Cols can continue to leach f om the coal ash. • Reducing infilt ation will educe the echa ge of oxygen into site g oundwate and likely c eate mo a anoxic (less oxygen) conditions in the site g oundwate , which can impact the mobility of constituents in the g oundwate (Schwa tz et al. 2016). • The solubility of i on and manganese is st ongly influenced by oxidation- eduction potential conditions, with solubility inc easing as the oxidation- eduction potential is dec eased. Both a e eadily mobilized o esolubilized uncle anoxic conditions. COls that had p eviously adso bed to i on o manganese will be emobilized and potentially lead to a slug of COls ente ing the g oundwate . When i on and manganese a e in the dissolved phase, COls cannot adso b to them. (Salminen 2005, Masscheleyn et al. 1991, Ha to et al. 2012, Schwa tz et al. 2016, U.S. EPA 2007b, Ta utis and Unz 1995). • Though i on is eadily oxidized when it comes into contact with oxygen, ae ation (oxygen) is not effective fo oxidizing dissolved manganese (manganese in the +2 oxidation state) to the elatively insoluble +4 oxidation state. The efo e d inking wate t eatment plants utilize a st ong oxidant such as ozone, chlo ine dioxide, o potassium pe manganate when manganese emoval is equi ed. Additionally, the p esence of dissolved i on in the g oundwate inhibits the fo mation of manganese O7 oxides. Only 14% manganese emoval was obse ved in a settling basin following ae ation used to t eat coal ash leachate at a site in Pennsylvania (Hoffman et al. 2006, Ta utis and Unz 1995, Robinson -Lo a and B ennan 2011, Rightnou and Hoove 1998). This is impo tant because the fo mation of manganese oxides has been identified as a COI at the Mayo site. • Infilt ation (and thus oxygen echa ge) would be educed ove the a ea of the Mayo site uncle the cap, and thus i on and manganese mobility will be enhanced (less i on and manganese oxide p ecipitation/COI adso ption occu ing within the a ea that is capped). This inhe ently sho tens the distance to the site bounda y ove which these MNA p ocesses can potentially occu . D. MNA based upon adso ption is not an app op iate emedy fo a senic at the Mayo site. • MNA fo a senic was not obse ved in the soil-wate pai analysis conducted by Duke fo the Mayo site. The t end line had a dec easing slope. If attenuation was obse ved, a positive co elation (positive slope) between a senic concent ation in the wate phase and the solid phase (as shown in Figu e 1 above) should have been obse ved. • A senic in wate is typically p esent in the +3 oxidation state [As(III)] o the +5 oxidation state depending the oxidation- eduction potential (oxygen concent ation) of the g oundwate . As(III) is favo ed uncle educed (low oxygen) conditions and As(V) is favo ed uncle oxidized conditions. Compa ed to As(V), As(III) is mo a toxic, mo a soluble, and mo e difficult to adso b (e.g. mo a mobile). The efo e the leaching and mobility of a senic gene ally inc eases as edox potential dec eases (Schwa tz et al. 2016, Ha to et al. 2012, Masscheleyn et al. 1991). Duke uncle stands that a senic is gene ally less mobile uncle oxidizing conditions (Co ective Action Plan Pa t 2 Appendix C). • Fo a senic in g oundwate at the Mayo site, As(III) is the p edominant species of a senic measu ed in site g oundwate samples (Co ective Action Plan Pa t 2 Appendix C). • Capping the site will make conditions less favo able fo MNA of a senic. Capping of the site will lead to mo a anoxic conditions in the site g oundwate (Schwa tz et al. 2016), which would likely lead to an inc ease in the atio of As(III) to As(V); thus the addition of a cap would likely inc ease the mobility of a senic at the Mayo site. • Conce n ove a eduction in site g oundwate oxidation- eduction potential and enhancement of a senic solubility as a esult of closu a plans fo coal ash impoundments that include capping, led a g oup of scientists to ecently state that "even if no p evious g oundwate contamination issues have been epo ted, 10 capping methods that might induce anae obic conditions should be avoided in the closu a of unlined impoundments" (Schwa tz et al. 2016). 11 VII. References Abe nethy, RF; MJ Pete son and FH Gibson (1969). Spect ochemical analyses of coal ash fo t ace elements. United States Depa tment of the Inte io , Repo t of Investigations 7281. Blackmo e, DPT; J Ellis and PJ Riley (1996). T eatment of a vanadium -containing effluent by adso ption/cop ecipitation with i on oxyhyd oxide. Wate Resea ch 30(10): 2512-6. Chen, W; R Pa ette, J Zou, FS Cannon and BA Dempsey (2007). A senic emoval by i on modified activated ca bon. Wate Resea ch 41: 1851-8. Comp ehensive Site Assessment Repo t. Mayo Steam Elect is Plant. Fo Duke Ene gy P og ess, p epa ed by SynTe a. Septembe 2, 2015. Co ective Action Plan Pa t 2. Mayo Steam Elect is Plant. Fo Duke Ene gy P og ess, p epa ed by SynTe a. Feb ua y 29, 2016. Co ective Action Plan Pa t 1. Mayo Steam Elect is Plant. Fo Duke Ene gy P og ess, p epa ed by SynTe a. Decembe 1, 2015. Davis, CC; WR Knocke and M Edwa ds (2001). Implications of aqueous silica so ption to i on hyd oxide: mobilization of i on colloids and inte fe ence with so ption of a senate and humic substances. Envi onmental Science & Technology 35: 3158-62. Duke Ene gy (2015). Duke Ene gy Ash Met ics. https://www.duke-ene gy.com/pdfs/duke-ene gy- ash-met ics.pdf Elect is Powe Resea ch Institute (2009). Coal Ash: Cha acte istics, Management, and Envi onmental Issues. www.whitehouse.gov/sites/default/files/omb/assets/oi a_2050/2050_meeting_101609- 2.pdf Ha te, PT; JD Ayotte, A Hoffman, KM Revesz, S Lamb and JK Bohlke (2012). Hete ogeneous edox conditions, a senic mobility, and g oundwate flow in a f actu ed- ock aquife nea a waste eposito y site in New Hampshi e, USA. Hyd ogeology Jou nal 20(6): 1189-1201. Hasany, QM and MA Qu eshi (1981). Adso ption studies of cobalt (II) on manganese dioxide f om aqueous solutions. Inte national Jou nal of Applied Radiation and Isotopes 32: 747-52. Hoffman, GL; DA Lytle, TJ So g, ASC Chen and L Wang (2006). Design Manual: Removal of A senic f om D inking Wate Supplies by I on Removal P ocess. Ap it 2006. EPA/600/R-06/030. Holm, TR; WR Kelly, SD Wilson and JL Talbott (2008). A senic emoval at Illinois i on emoval plants. Jou nal AWWA 100(9): 139-150. 12 Holm, TR (2002). Effects of C032-/bica bonate, Si, and PO43-on a senic so ption to HFO. Jou nal AWWA 94(4):174-81. Liu, G; H Zhang, L Gao, L Zheng and Z Peng (2004). Pet ological and mine alogical cha acte izations and chemical compositions of coal ashes f om powe plants in Yanzhou mining dist ict, China. Fuel P ocessing Technology 85: 1635-46. Lokeshappa, B; AK Dikshit, Y Luo, TJ Hutchinson and DE Giamma (2014). Assessing bioaccessible f actions of a senic, ch omium, lead, selenium, and zinc in coal fly ashes. Inte national Jou nal of Envi onmental Science and Technology 11: 1601-10. Ma iussen, E: IV Johnsen and AE St omseng (2015). Selective adso ption of lead, coppe , and antimony in unoff wate f om a small a ms shooting nage with a combination of cha coal and i on hyd oxide. Jou nal of Envi onmental Management 150: 281-7. Masscheleyn, PH; RD Delaune and WH Pat ick J . (1991). A senic and selenium chemist y as affected by sediment edox potential and pH. Jou nal of Envi onmental Quality 20: 522-7. Meng, X; GP Ko fiatis, S Bang and KW Bang (2002). Combined effects of anions on a senic emoval by i on hyd oxides. Toxicology Lette s 133: 103-11. Meng, X; S Bang and GP Ko fiatis (2000). Effects of silicate, sulfate, and ca bonate on a senic emoval by fe is chlo ide. Wate Resea ch 34(4): 1255-61. Mille , GP (2011). Monito ed natu al attenuation: a emediation st ategy fo g oundwate impacted by coal combustion p oduct leachate. 2011 Wo Id of Coal Ash Confe ence. May 9-12, 2011. Denve , CO. Mille , GP (2001). Su face complexation modeling of a senic in natu al wate and sediment systems. Ph.D. disse tation, New Mexico Institute of Mining and Technology. Mukhe jee, J; J Ramkuma , S Chand amoukeeswa an, R Shukla and AK Tyagi (2013). So ption cha acte istics of nano manganese oxide: efficient so bent fo emoval of metal ions f om aqueous st earns. Jou nal of Radioanalytical and Nuclea Chemist y 297: 49-57. Rightnou , TA and KL Hoove (1998). The Sp ingdale P oject: Applying Const ucted Wetland T eatment to Coal Combustion By -P oduct Leachate. EPRI epo t TR -111473. Robinson -Lo a, MA and RA B ennan (2011). Anae obic p ecipitation of manganese and co -existing metals in mine impacted wate t eated with c ab shell -associated mine als. Applied Geochemist y 26: 853-62. 13 Rocca o, P and FGA Vagliasindi (2015). Cop ecipitation of vanadium with i on(III) in d inking wate : a pilot -scale study. Desalination and Wate T eatment 55: 799-809. Salminen, R (2005). Geochemical Atlas of Eu ope, Pa t 1— Backg ound Info mation, Methodology, and Maps. weppi.gtk.fi/publ/fo egsatlas/text. Sa ka , D; DK De, R Das and B Mandal (2014). Removal of o ganic matte and oxides of i on and manganese f om soil influences bo on adso ption in soil. Geode ma 214-5: 213-6. Schwa tz, GE; N Rive a, SW Lee, JM Ha ington, JC Howe , KE Levine, A Vengosh and H Hsu -Kim (2016). Leaching potential and edox t ansfo mations of a senic and selenium in sediment mic ocosms with fly ash. Applied Geochemist y 67: 177-85. Swedlund, PJ and JG Webste (1999). Adso ption and polyme ization of silicic acid on fe ihyd ide, and its effect on a senic adso ption. Wate Resea ch 33(16): 3413-22. Ta utis, WJ and RF Unz (1995). 1 on and manganese elease in coal mine d ainage wetland mic ocosms. Wate Science & Technology 32(3): 187-92. U.S. EPA (2007a). Monito ed Natu al Attenuation of Ino ganic Contaminants in G ound Wate , Volume 1, Technical Basis of Assessment. EPA/600/R-03/139. U.S. EPA (2007b). Monito ed Natu al Attenuation of Ino ganic Contaminants in G ound Wate , Volume 2, Assessment fo Non -Radionuclides Including A senic, Cadmium, Ch omium, Coppe , Lead, Nickel, Nit ate, Pe chlo ate, and Selenium. EPA/600/R-03/140. USEPA (2012, Septembe ). A Citizens Guide to Monito ed Natu al Attenuation. Ret ieved f om https://clu-in.o g/ U.S. EPA (2016). Coal Ash Basics. Janua y 15, 2016. https://www.epa.gov/coalash/coal-ash- basics#02 14 APPENDIX A D . Robe t Pa ette CV 15 ROBERT PARETTE Matson & Assoc ates, Inc. 331 East Foster Avenue, State College, PA 16801 Phone: (814) 231-5253 Ema I: bparette@matson-assoc ates.com EDUCATIO Doctor of Philosophy August 2005 Env ronmental Eng neer ng The Pennsylvan a State Un vers ty, Un vers ty Park, PA D ssertat on: The Removal of Perchlorate from Groundwater v a Quaternary Ammon um Cat on c Surfactant Pre -Loaded GAC Master of Science May 2004 Env ronmental Eng neer ng The Pennsylvan a State Un vers ty, Un vers ty Park, PA Thes s: GAC Ta lored w th Organ c Cat ons for the Removal of Perchlorate from Groundwater and Base/Ac d Chem cal Regenerat on of the GAC Bachelor of Science February 1999 Chem cal Eng neer ng Worcester Polytechn c Inst tute, Worcester, MA WORK EXPERIE CE Matson and Associates, Inc., State College, PA Env ronmental Eng neer (P.E.)/Env ronmental Chem st (2009-2014) V ce Pres dent of Eng neer ng/Project Manager for Matson B ofuels (2009-2011) The Pennsylvania State University, Dept. of Civil and Environmental Engineering Post -Doctoral Research Assoc ate (2005-2009) Graduate Research Ass stant (2000-2005) Environmental Consultant Ass stant to Penn State professor sery ng as an expert w tness (2007) Hercules Incorporated Research Center, Wilmington, DE Research Ass stant (1998) REPRESE TATIVE PROJECT EXPERIE CE • Rev ewed closure plan alternat ves for a coal ash mpoundment located n Conway, South Carol na. Prepared wr tten comments address ng the lack of groundwater treatment (as part of these closure plan alternat ves) and the feas b I ty of remed at ng the arsen c contam nated groundwater. A-1 • Evaluated the d sposal pract ces of waste salt conta n ng arsen c at a fac I ty along the Menom nee R ver n W scons n n relat on to waste d sposal standards and the alternat ve d sposal opt ons ava fable. Invest gated the spec at on of arsen c n the waste salts, the propert es of the var ous arsen c spec es, and the transformat ons these arsen c spec es would undergo n the env ronment. • At Penn State, 9% years of R&D on technolog es to remed ate ground water. Th s R&D resulted n numerous publ cat ons (I sted below) on the removal of arsen c and perchlorate from water. Des gned and produced custom adsorbents for the removal of arsen c from groundwater. Des gned and fabr cated a p lot plant w th a capac ty n excess of one m II on gallons per year to study the removal of arsen c by a comb nat on of act vated carbon and ron from a var ety of d fferent sources. Respons ble for develop ng exper mental and sampl ng plans for a number of p lot and laboratory stud es. • Evaluated treatment technolog es, and the feas b I ty of employ ng such technolog es, n connect on w th remed at ng a large lake contam nated w th selen um. Prepared a report to be ut I zed for publ c comments and negot at ons w th the power company. • Evaluated the potent al mplementat on of var ous technolog es for a number of outfalls at a coal m n ng operat on n western Pennsylvan a. Prepared wr tten comments address ng shortcom ngs of a consent decree perta n ng to the s te. • Evaluated wastewater treatment pract ces of a paper m II along the Fox R ver n W scons n n relat on to the treatment opt ons ava fable (chronolog cally) to the pulp and paper ndustry and the removal eff c enc es ach eved by var ous treatment technolog es across the ndustry. • Des gned and conducted laboratory exper ments to test the mpact of MTBE on the removal of other organ c contam nants from groundwater for a case nvolv ng MTBE n Suffolk County, NY. Ut I zed mult ple f eld data sets to assess the ab I ty of act vated carbon to remove MTBE, ass sted n the preparat on of expert w tness reports, and performed an extens ve I terature rev ew pert nent to the case. • Correlated s to act v t es at an abandoned chem cal manufactur ng plant n NJ w th contam nants found n the near offshore areas of the s te; determ ned the or g n and chem cal react ons beh nd the presence of 2,4,6,8-tetrachlorod benzoth ophene (2,4,6,8-TCDT), a contam nant whose source was prev ously unknown. • Evaluated the s ngle phase eff c ency for the str pp ng of CO2 n a cool ng tower model for an nternat onal company that spec al zes n gases. Mod f ed the model's source code to reflect the determ ned s ngle stage eff c ency, evaluated the I qu d to gas rat o ut I zed by the model, and compared results from the model aga nst the exper mental data. • Invest gated groundwater qual ty and consulted w th a forester at a res dent al s to n Centre County, PA, mpacted by a nearby hous ng development. • D rected the R&D efforts for Matson B ofuels from 2009 through 2011. Respons ble for the management of three b od esel projects, w th grant fund ng n excess of $250K. Developed sol d A-2 catalysts capable of convert ng low qual ty o I feedstocks to b od esel w th no feedstock pretreatment and no soap format on. Des gned a p lot plant, w th a capac ty to produce more than 1 m II on gallons of b od esel annually. PUBLICATIO 5 R Parette, R McCr ndle, KS McMahon, M Pena-Abaurrea, E Re ner, B Ch tt m, N R ddell, G Voss, FL Dorman, WN Pearson and M Robson (2016). Response to the comment on "Halogenated nd go dyes I kely source of 1,3,6,8-tetrabromocarbazole and some other halogenated carbazoles n the env ronment". Chemosphere 150: 414-5. N R ddell, UH J n, S Safe, Y Cheng, B Ch tt m, A Konstant nov, R Parette, M Pena-Abaurrea, EJ Re ner, D Po r er, T Stefanac, AJ McAlees and R McCr ndle (2015). Character zat on and b olog cal potency of mono- to tetra -halogenated carbazoles. Env ronmental Sc ence & Technology 49 (17): 10658-66. R Parette, R McCr ndle, KS McMahon, M Pena-Abaurrea, E Re ner, B Ch tt m, N R ddell, G Voss, FL Dorman and WN Pearson (2015). Halogenated nd go dyes: a I kely source of 1,3,6,8- tetrabromocarbazole and some other halogenated carbazoles n the env ronment. Chemosphere 127: 18-26. R Parette and WN Pearson (2014). 2,4,6,8-Tetrachlorod benzoth ophene n the Newark Bay Estuary: the I kely source and react on pathways. Chemosphere 111: 157-63. W Chen, R Parette and FS Cannon (2012). P lot -scale stud es of arsen c removal w th granular act vated carbon and zero -valent ron. Env ronmental Eng neer ng Sc ence 29(9): 897-901. K Gombotz, R Parette, G Aust c, D Kannan and J Matson (2012). MnO and T O sol d catalysts w th low- grade feedstocks for b od esel product on. Fuel 92(1): 9-15. MK Sel em, S Komarnen, R Parette, H Katsuk, FS Cannon, MG Shah en, AA Khal I and IM Abdel -Ga d (2011). Perchlorate uptake by organos I cas, organo -clay m nerals and compos tes of r ce husk w th MCM-48. Appl ed Clay Sc ence 53: 621-6. JP Patterson, R Parette and FS Cannon (2011). Compet t on of an ons w th perchlorate for exchange s tes on cat on c surfactant-ta lored GAC. Env ronmental Eng neer ng Sc ence 28(4): 249-56. JY K m, S Komarnen , R Parette and FS Cannon (2011). Perchlorate uptake by synthet c layered double hydrox des and organoclays. Appl ed Clay Sc ence 51(1-2): 158-64. JP Patterson, R Parette and FS Cannon (2010). Ox dat on of ntermed ate sulfur spec es (th osulfate) by free chlor ne to ncrease the bed I fe of to lored GAC to remove perchlorate. Env ronmental Eng neer ng Sc ence 27(10): 835-43. MK Sel em, S Komarnen, R Parette, H Katsuk, FS Cannon, MG Shah en, AA Khal I and IM Abdel -Ga d (2010). Compos tes of MCM-41 s I ca w th r ce husk: Hydrothermal Synthes s, character zat on and appl cat on for perchlorate separat on. Mater als Research Innovat ons 14(5): 351-4. A-3 S Komarnen , J Y K m, R Parette and FS Cannon (2010). As -Synthes zed MCM-41 s I ca: New adsorbent for perchlorate. Journal of Porous Mater als 17: 651-6. MJ Jang, FS Cannon, R Parette, S Yoon and W Chen (2009). Comb ned hydrous ferr c ox de and quaternary ammon um surfactant to for ng of granular act vated carbon for concurrent arsen c and perchlorate removal. Water Research 43(12): 3133-43. W Chen, R Parette and FS Cannon FS (2008). Arsen c adsorpt on v a ron preloaded act vated carbon and zero -valent ron. Journal of Amer can Water Works Assoc at on 100(8): 96-105. W Chen, R Parette, J Zou, FS Cannon and BA Dempsey (2007). Arsen c removal by ron-mod f ed act vated carbon. Water Research 41(9): 1851-8. R Parette and FS Cannon (2006). Perchlorate removal by mod f ed act vated carbon. In Perchlorate Env ronmental Occurrence, Chem stry, Tox cology, and Remed at on Technolog es. Spr nger Publ sh ng Company, New York. R Parette and FS Cannon (2005). The removal of perchlorate from groundwater by act vated carbon to lored w th cat on c surfactants. Water Research 39(16): 4020-28. R Parette, FS Cannon and K Weeks (2005). Remov ng low ppb level perchlorate, RDX, and HMX from groundwater w th cetyltr methylammon um chlor de (CTAC) pre -loaded act vated carbon. Water Research 39(19): 4683-92. A-4