20160226 GHI Mayo Report_Final

GEO-HYDRO, INC
Consulting in Geology and Hydrogeology
1928 E. 14th Avenue
Denver, Colorado 80206
[phone]
EXPERT REPORT OF
MARK A. HUTSON, PG
Mayo Steam Electric Plant
Roxboro, NC
Prepared for:
Southern Environmental Law Center
601 West Rosemary Street
Suite 220
Chapel Hill, NC 27516-2356
February 2016

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

GEO-HYDRO, INC
2. Introduction
Duke Energy currently stores approximately 6,900,000 tons of coal ash in an unlined, water -filled
lagoon at the Mayo facility in Persons County NC. Pollution caused by the coal ash at this site is
currently the subject of an enforcement action brought by the NCDEQ. Organizations represented
by the Southern Environmental Law Center are also parties to this litigation.
North Carolina General Assembly Session Law 2014-122, the Coal Ash Management Act (CAMA)
of 2014, required the owner of coal combustion waste surface impoundments to conduct
groundwater monitoring, assessment and remedial activities at coal ash basins across the state, as
necessary. The owner of coal ash surface impoundments were required to submit a Groundwater
Assessment Plan (GAP) to NCDEQ by December 31, 2014. Comprehensive Site Assessment (CSA)
reports that reported the results of site characterization activities were required to be submitted
within 180 days of approval of the GAP. Information developed under the CSA provided the data to
be used to prepare Corrective Action Plans (CAP) that were to be submitted to NCDEQ within 90
days of submittal of the CSA. An agreement between Duke Energy and NCDEQ resulted in
breaking the CAP into Parts 1 and 2. As of this date only the CAP Part 1 has been produced for the
Mayo site.
Further, CAMA specifies that any impoundments classified by NCDEQ as high-risk be closed no
later than December 31, 2019 by dewatering the waste and either, a) excavating the ash and
converting the impoundment to an industrial landfill, or b) excavating and transporting the waste off-
site for disposal in an appropriately licensed landfill. Intermediate -risk impoundments are required
to be closed similarly to high-risk impoundments, but under a relaxed closure deadline of December
31, 2024. Impoundments classified as low-risk by NCDEQ must be closed by December 31, 2029
either similarly to the high and intermediate -risk sites, or by dewatering to the extent practicable and
capping the waste in place.
In January 2016 the NCDEQ issued Draft Proposed Risk Classifications (NCDEQ, 2016) for 10 ash
impoundment sites, including Mayo. The draft proposed risk classification assigned to Mayo is low
risk, thus allowing for closure of the impoundment by capping waste in place. On behalf of the
Southern Environmental Law Center, I have reviewed the Groundwater Assessment Plan (SynTerra,
2015a), Comprehensive Site Assessment (SynTerra, 2015b), the Corrective Action Plan Part 1
(SynTerra, 2015c), the Draft Proposed Risk Classifications (NCDEQ, 2016), and the National
Pollutant Discharge Elimination System (NPDES) permit for Mayo (North Carolina Department of
Environment and Natural Resources (NCDENR, 2009).
2

GEO-HYDRO, INC
This report details my opinions regarding: the source of groundwater and surface water pollution at
Mayo, potential remedies for that pollution discussed in the Corrective Action Plan, and the
proposed risk classification for the Mayo site.

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

GEO-HYDRO, INC
4. Site Background
The Mayo plant is a coal-fired electricity -generating facility located in north -central North Carolina in
the northeastern corner of Person County, North Carolina, north of the City of Roxboro. The northern
Plant property line extends to the North Carolina/Virginia state line. Mayo Lake borders the entire
eastern portion of this part of the Site. The Mayo Plant began coal-fired power production in 1983.
The 144 acre Mayo ash basin was formed by construction of a dam across the upper reaches of
Crutchfield Branch, a perennial' stream that once flowed in the valley immediately northwest of the
Mayo Steam Power Plant (Figure 1). The basin is impounded by an earthen dam approximately 2,300
feet long, with a dam height of 110 feet, and a crest height elevation of 479.8 feet above mean sea level
(msl). The ash basin contains approximately 6,900,000 tons of Coal Combustion Residuals2. Coal ash
and ash -impacted water have buried Crutchfield Branch behind the dam. The ash basin acts as an
elongated bowl -like feature with groundwater flowing to the basin from all sides, except from the
northeast, which is the discharge side from the basin. Groundwater flows north-northeast from the ash
basin into the small valley formed by Crutchfield Branch. Crutchfield Branch flows north off of Mayo
Plant property into Virginia3.
Constituents leached from ash into ash basin pore water at concentrations greater than North Carolina
Groundwater Quality Standards (2L) or Interim Maximum Allowable Concentrations (IMAC) include
antimony, arsenic, barium, boron, cobalt, iron, manganese, pH, thallium, total dissolved solids (TDS),
and vanadium 4. Ash -impacted water exits the impoundment by seeping through and around the dam
and discharging to the surface to reform the buried Crutchfield Branch, by migrating downgradient
from the impoundment as groundwater, and through NPDES discharge 0025 that discharges water
from the coal ash impoundment directly to Mayo Lake. Two engineered toe drains are located on the
downstream side of the dam and flow either directly into or eventually into Crutchfield Branch. Some
of the ash -contaminated impoundment water that infiltrates through the dam discharges to the surface
through the toe drains and other unplanned seeps below the dam to reform Crutchfield Branch.
The CSA determined that leaching from waste impounded within the ash basins impacts groundwater
in the vicinity of the ash basin 6. That document describes three hydrogeologic units or zones of
groundwater flow at the Mayo Plant. The zone closest to the surface is the shallow or surficial flow
1 The USGS Cluster Springs, VA -NC 7.5 minute topographic map shows Crutchfield Branch as a perennial stream across
most of the impounded area with intermittent reaches in the upper arms of the impoundment.
2 SynTerra, 2015a, p.6.
3 SynTerra, 2015 b, 1-7.
4 SynTerra, 2015a, p.129.
s NCDENR, 2009
6 SynTerra, 2015b,p. 1-7.
5

GEO-HYDRO, INC
zone encompassing saturated conditions, where present, in the residual soil, saprolite, or alluvium
beneath the Site. A transition zone is encountered below the surficial zone and the bedrock is
characterized primarily by partially weathered rock of variable thickness. The bedrock flow zone
occurs below the transition zone and is characterized by the storage and transmission of groundwater
in water -bearing fractures.
Available potentiometric data generally confirm that groundwater flow in the vicinity of the
impoundment is toward the north-northeast towards the reformed Crutchfield Branch. An exception to
this statement exists in the area of the Flue Gas Desulfurization (FGD) ponds located on the southeast
side of the impoundment where geology and groundwater flow direction are inadequately defined.
Site Layout and Water Level Mapss included with the CSA Report each show the FGD ponds located
inside the waste boundary, apparently indicating that the FGD ponds were constructed over disposed
ash. Review of the USGS topographic map (Figure 1) corroborates this interpretation. Contradicting
this information are cross-sections9 included with the CSA that each show the FGD ponds located
above soil/fill. The location of the waste boundary must be confirmed in order to determine the extent
of waste that must be remediated, either by excavation or capping.
The direction of groundwater flow is also poorly defined in the area of the FGD ponds. The CSA
report describes Mayo Lake as acting as a groundwater discharge area on the east side of the Plant.
Each of the C -C' cross-sections (see footnote) show the water table declining to the east between the
ash basin and wells CW -1/1D with flow toward the east beneath the area of the FGD ponds. The
Water Level Map shows the hydraulic gradient flowing toward the north from a high beneath the
electric plant toward the ash basin in this same location. An additional well cluster located between
the FGD ponds and discharge canal is needed to provide additional control on geology and
groundwater flow direction, velocity and chemistry in the area of the FGD ponds.
The groundwater flow and transport model of the site was constructed and used in the CAP to evaluate
groundwater flow and investigate three remedial scenarios. The scenarios investigated included the
No Action scenario, a Capping Ash in Place scenario, and a Complete Ash Removal scenario. The
model was used to predict contaminant distributions for the next 5, 15 and 30 years, under each
scenario.
The Existing Conditions scenario 10 relies on natural attenuation processes to reduce contaminant
concentrations over time. The ash basin remains in place without modification and "the assumption is
made that current recharge and contaminant loading rates from the ash to the underlying formations are
7 Figure 2-1
8 Figure 6-9
9 C -C' Sections included presented in Figures 6-3, 6-6, 8-3, 11-1b, 11-2b. 11-3b, 11-4b, 11-5b, 11-6b, 11-7b, 11-8b, 11-9b,
and 11-10b
10 The entire description of this scenario is presented in the CAP, Appendix E, Section 6.1.
M

GEO-HYDRO, INC
held constant". "The flow system is assumed to be at steady state with respect to the conditions in
2015." "Concentrations in the ash were held constant at the measured concentrations." Using these
assumptions the model predicts that the boron and arsenic plumes will continue to expand and the
leading edge of the boron plume is predicted to move north of the compliance boundary over the next
30 years.
The Capping Ash Basin scenario' 1 involves placing a low permeability liner over the ash basin to
prevent infiltration. The description of this scenario assumes that there is no recharge within the basin,
that the dam was removed and that contaminant concentrations in the ash were allowed to vary
(concentrations were fixed in the Existing Conditions scenario). Other changes to the model included
modified boundary conditions to remove constant head conditions representing the impoundment and
the grid was modified to represent grading of the ash. Results of this modified model predict that the
leading edge of the boron plume would recede by 100 to 200 feet in the vicinity of the compliance
boundary. Arsenic concentrations are predicted to increase in the saprolite, but the increase is smaller
than that predicted under the Existing Conditions scenario.
Concerns with the Capping Ash Basin scenario include the assumption of no recharge within the basin
and changing the way that contaminant concentrations in the source material are handled. The
hydrogeologic setting of the impoundment 12 describes groundwater discharges into the impoundment
form the east, west and south sides. Capping of the ash in the basin will not control discharging
groundwater. The discharges of groundwater into the ash are likely significant as groundwater
discharges into the basin were sufficient to support a perennial reach of Crutchfield Branch prior to
burying the stream with coal waste.
The concentration of contaminants in the ash were held constant in the Existing Conditions simulation
but were allowed to vary in the Capping Ash Basin scenario. This change in assumptions allowed the
concentration in the ash to decrease more rapidly in the Capping Ash Basin scenario than in the
Existing Conditions simulation. The rationale for changing the method of handling source
concentrations between simulations was not discussed. Comparison of the No Action scenario and
Capping Ash Basin scenario simulations show the leading edge of the boron plume receding by 100 to
200 feet by 2045. It is unclear if this reduction is a result of cap installation, or if it is an artifact of the
change in assumptions.
The Removal of Ash 13 scenario represents complete removal of the ash by applying zero concentration
levels and regional recharge within the ash basin. Even if one ignores the defects with the first two
simulations, the Removal of Ash scenario predicts, by far, the largest reduction in ash -related
11 The entire description of this scenario is presented in the CAP, Appendix E, Section 6.2
12 SynTerra 2015b, p. 1-7 and 1-11.
13 The entire description of this scenario is presented in the CAP, Appendix E, Section 6.3
7

GEO-HYDRO, INC
contaminant concentrations. Figures 2, 3 and 4 show predicted 2045 boron concentrations within the
saprolite layer (Layer 5) for all three of the simulated options.
N.

GEO-HYDRO, INC
5. Opinion 1: Coal Ash Stored in the Mayo Ash Basin is the Source
of Contamination Detected in Surface Water and Groundwater
Coal ash is the source of contaminants detected in surface water and groundwater at concentrations
above applicable standards in the vicinity and downgradient of the ash basin. Data collected during
the CSA show that that ash basin pore water contains antimony, arsenic, barium, boron, cobalt, iron,
manganese, pH thallium, TDS and vanadium at concentrations greater than 2L or IMAC standards 14
The contaminated pore water migrates into groundwater and is discharged into impoundment water,
each of which subsequently discharge to Crutchfield Branch. This interpretation is consistent with
the conclusions of the CSA which states that "The CSA found that leaching of CCR accumulated in
the ash basin is a source of COIs detected in groundwater and surface water downgradient of the
basin"ls
14 SynTerra 2015b, p. 1-7
15 Synterra 2015a, p.127, Constituent of Interest (COI)
0

GEO-HYDRO, INC
6. Opinion 2: Capping Coal Ash Located Within the Mayo Ash
Basin Will Not Protect Groundwater Quality Downgradient of the
Basin
Capping the waste within the footprint of the ash basin will not be protective of groundwater quality
downgradient of the basin. Further, the CAMA process proposed designation of the Mayo Site as
low-risk creates the possibility that Duke Energy (Duke) could pursue closure of the Mayo
impoundment by capping the disposed ash in place.
Environmental contaminants contained in coal ash are leached into groundwater when precipitation
infiltrates through the waste or, when groundwater flows through waste that has been placed below
the water table. In the case of the Mayo ash basin, both of these processes are currently acting to
create the contaminated ash porewater, groundwater, and surface water that discharge into
Crutchfield Branch and contaminate surface water downstream of the impoundment. The cap -in-
place remedy would likely reduce the amount of water that enters the waste from precipitation. This
remedy would however do nothing to reduce the amount of water that flows laterally into the basin
from surrounding geologic materials, through the capped waste, and eventually into Crutchfield
Branch.
The CAP and its included modeling results show that much of the coal ash in the Mayo ash basin
will remain submerged below the water table under a cap -in-place remedy. The thickness of
saturated waste that would remain saturated can be estimated by comparing the pre -impoundment
topographic map of the basin (Figure 1) with the calculated hydraulic head map for the cap in place
option (Figure 5). The topographic map of the buried valley shows that natural land surface below
the impoundment is located at approximately 400 feet above mean sea level (msl) near the center of
the basin. The calculated hydraulic head in the basin after ash is capped in place is predicted by the
model to be approximately 460 to 470 feet msl near the center of the basin. Therefore, the model of
the cap -in-place scenario predicts 60 to 70 feet of saturated ash would remain in portions of the
basin. The data presented in these figures is consistent with the known hydrogeology of the site.
Groundwater will continue to flow into the ash basin from adjacent areas and some infiltration
through the cap would continue to occur. Groundwater that flows through the ash will continue to
leach metals from the ash and transport those metals down -gradient before discharging into
Crutchfield Branch.
Further, the results of the groundwater modeling exercise undertaken as part of this program indicate
that removal of the Mayo coal ash is by far the most effective option for improving groundwater
quality and preventing future discharges to Crutchfield Branch. The modeling results indicate that
10

GEO-HYDRO, INC
removal of the ash significantly reduces the size and concentration of the boron plume in the
saprolite and transition zones, something that capping -in-place does not achieve.
11

GEO-HYDRO, INC
7. Opinion 3: Monitored Natural Attenuation Is Not An Acceptable
Groundwater Remediation Strategy at Mayo
The CAP 16 indicates that Duke may evaluate Monitored Natural attenuation as a potential
groundwater remedy for certain area of the Mayo site. The CAP attempts to make it appear that
Monitored Natural Attenuation (MNA) is a viable remedial option for impacted groundwater and
surface water downgradient of the Mayo ash basin. However, MNA is not a viable closure option
for this site for several reasons including the following North Carolina requirements for
implementing MNA:
1.0 NCAC 02L.0106 (1)(1) requires a demonstration that all sources of
contamination have been removed or controlled. So far, Duke Energy has not proposed
removal of the waste for disposal in a secure location. Modeling presented in this
document shows that most of the ash would remain saturated after capping. Saturated
ash will continue to leach metals into groundwater that will flow toward and eventually
discharge into Crutchfield Branch. As a practical matter, in the absence of removal all
sources of contamination cannot be controlled
2.0 NCAC 02L .0106 (1)(2) requires a demonstration that the contaminant has the
capacity to degrade or attenuate under site-specific conditions. Many of the ash -related
constituents in groundwater at this site neither degrade nor attenuate. The Geochemical
Site Conceptual Modell? states that boron best represents the extent of impact to
groundwater because it "does not sorb or precipitate within the ash or on aquifer
materials." Because of this, the Mayo site would not be eligible for NINA.
3.0 NCAC 02L.0106 (1)(6) requires a demonstration that groundwater discharge
will not possess contaminant concentrations that would result in violations of surface
water standards. Crutchfield Branch, which receives the contaminated groundwater
discharge at Mayo, currently exceeds surface water standards for several parameters.
Sampling has detected ash -related metals at concentrations above background and
relevant NCAC 2B and/or 2L standards, including boron, cobalt, copper, iron,
manganese, thallium, vanadium, and zinc 18. These surface water exceedances are likely
to continue since the majority of flow in Crutchfield Branch is associated with drainage
from the ash basin19 and the groundwater model shows that a substantial amount of ash
will continue to be saturated with groundwater that eventually flows to Crutchfield
Branch, even if the basin is capped.
16 SynTerra, 2015b, p.5-1
17 SynTerra, 2015b, Section 3.2
18 SynTerra, 2015b, Table 2-14
19 SynTerra, 2015b, Page 4-13, Section 4.4.1
12

GEO-HYDRO, INC
8. Opinion 4: Capping Coal Ash Located Within the Mayo Ash
Basin Will Not Be Protective of Surface Water Quality in
Crutchfield Branch
Prior to construction of the Mayo plant Crutchfield Branch was a free-flowing perennial stream that
occupied the valley through which it flowed. The coal ash basin was constructed by damming the
stream and used to segregate and store coal combustion wastes that were allowed to settle in the
basin. If coal ash located within the Mayo ash basin is capped in place, the surface water in
Crutchfield Branch will continue to be polluted and a significant portion of Crutchfield Branch will
remain buried by waste.
Crutchfield Branch, which receives the contaminated groundwater discharge at Mayo, currently
exceeds surface water standards for several parameters. Sampling has detected ash -related metals at
concentrations above background and relevant NCAC 2B and/or 2L standards, including boron,
cobalt, copper, iron, manganese, thallium, vanadium, and zinc 20. These surface water exceedances
will continue since the majority of flow in Crutchfield Branch is associated with drainage from the
ash basin 21 and the groundwater model shows that a substantial amount of ash will continue to be
saturated with groundwater that eventually flows to Crutchfield Branch, even if the basin is capped
(See Opinion #2). Coal ash must be separated from the groundwater and surface water flow
systems if further contamination of these resources is to be avoided
The surface water quality discussion in the CAP 22 indicates that concentrations of ash -related
constituents in Crutchfield Branch decrease with distance downstream from the ash basin due to
"attenuation by dilution." This is problematic because, of course, there is so such process as
attenuation by dilution. Attenuation and dilution are two different processes. Attenuation occurs
when contaminants interact with the soil or sediments, and contaminants are removed from the
water. Dilution does not remove or treat any contaminants; instead, the concentration, but not the
amount, of a pollutant is reduced by diluting the polluted plume with water containing a lower
concentration of the contaminant. Thus, dilution and attenuation are distinctly different processes.
The made-up process referred to as "Attenuation by Dilution" appears to have been invented in an
effort to make discharges of contaminated groundwater and subsequent exceedances of surface water
quality standards appear acceptable.
North Carolina regulations covering corrective action plans based on natural processes (NCAC 02L
.0106 (1)(2)) require that a corrective action plan that proposes to utilize monitored natural
20 SynTerra, 2015b, Table 2-14
21 SynTerra, 2015b, Page 4-13, Section 4.4.1
22 SynTerra, 2015b, Section 4.4.2
13

GEO-HYDRO, INC
attenuation as a remedy demonstrate that the contaminant has the capacity to degrade or attenuate
under site-specific conditions. The Geochemical Site Conceptual Mode123 states that boron best
represents the extent of impact to groundwater because it "does not sorb or precipitate within the ash
or on aquifer materials." The properties of the contaminants at Mayo would therefore render the site
ineligible for remediation by MNA, even if attenuation by dilution were a real process. In addition,
capping the coal ash in the in place would leave a significant portion of Crutchfield Branch buried in
waste. Now that the Mayo waste handling system is no longer going to be used there is no
justification for leaving the existing stream covered in coal ash.
13 SynTerra, 2015b, Section 3.2
14

GEO-HYDRO, INC
9. Opinion 5: Removal of the Coal Ash Will Remove the Source and
Reduce the Concentration and Extent of Groundwater and
Surface Water Contaminants
Removal (excavation) of the coal ash from the Mayo ash basin will remove the source, and reduce
the concentration and extent of groundwater and surface water contaminants. The groundwater flow
and transport model of the site was used in the CAP to evaluate groundwater flow and investigate
three remedial scenarios. The scenarios investigated included the No Action scenario, a Capping
Ash in Place scenario, and a Complete Ash Removal scenario. The model was used to predict
contaminant distributions for the next 5, 15 and 30 years, under each scenario.
The extent of boron in groundwater for each scenario at the end of 30 years are shown in Figures 2,
3 and 4. The model shows that the Removal of Ash scenario results in, by far, the largest reduction
in ash -related contaminant concentrations.
15

GEO-HYDRO, INC
10. Opinion 6: The Coal Combustion Residual Impoundment Risk
Classification Proposed by NCDEQ Improperly Minimizes
Protection of Environmental Quality
A risk ranking process was specified in CAMA to determine the type of closure permitted at each
facility. The law specifically requires NCDEQ to classify each impoundment as either high-risk,
intermediate -risk, or low-risk, based on consideration, at a minimum, of all of the following criteria.
(1) Any hazards to public health, safety, or welfare resulting from the impoundment.
(2) The structural condition and hazard potential of the impoundment.
(3) The proximity of surface waters to the impoundment and whether any surface waters are
contaminated or threatened by contamination as a result of the impoundment.
(4) Information concerning the horizontal and vertical extent of soil and groundwater
contamination for all contaminants confirmed to be present in groundwater in exceedance of
groundwater quality standards and all significant factors affecting contaminant transport.
(5) The location and nature of all receptors and significant exposure pathways.
(6) The geological and hydrogeological features influencing the movement and chemical and
physical character of the contaminants.
(7) The amount and characteristics of coal combustion residuals in the impoundment.
(8) Whether the impoundment is located within an area subject to a 100 -year flood.
(9) Any other factor the Department deems relevant to establishment of risk.
In order to evaluate each impoundment on the nine criteria the NCDEW established a risk
classification group24. The Risk Classification Group was broken into three sub -groups of people
based on areas of expertise (Groundwater, Surface Water, and Dam Safety) to develop a set of risk
factors to address each of the nine required criteria. Each subgroup reportedly placed a primary
emphasis on risk as it relates to the public from a groundwater, surface water, and dam safety
perspective and established one key factor that "plays a significant role in assigning an overall
classification" for that group. Other factors not identified as Key Factors were supposedly used to
"refine the risk classification and address the actual or potential risk to the environment and natural
resources."
The result of the risk classification methodology utilized by NCDEQ is that environmental and
ecologic risks posed by the Mayo site were not fully considered by NCDEQ when establishing the
overall site risk and clean-up priority. This resulted in an overall Low Risk rating, a rating that
essentially ignores the known environmental impacts of the Mayo Ash Basin. For example, Table
24 NDEQ, 2016, p. 13, Classification Methodology
16

GEO-HYDRO, INC
provides a listing of the groundwater risk classification factors and associated ratings for Mayo. Ten
groundwater risk factors were established and received ratings by NDEQ. Of the 10 rated factors, 6
received High or Intermediate Ratings, one factor was rated as Low/Intermediate, and only 3
received ratings of Low Risk. Only 30% of the rated groundwater risk classification factors were
rated Low Risk, yet NCDEQ gave Mayo an overall Low Risk Rating for Groundwater.
Table 1
Groundwater Risk Classification
Groundwater Factors
Mayo Rating
Number of downgradient receptors within 1500 feet of compliance boundary that
are potentially or currently known to be exposed to impacted water. (Key Factor)
Low Risk
Amount of stored CCR reported in an impoundment
Intermediate Risk
Depth of CCR with respect to the water table
High Risk
Exceedance of 2L or IMAC standards at or beyond the established CCR
compliance boundary
High Risk
Population served by water supply wells within 1,500 feet upgradient or side
gradient of the compliance boundary
Low /Intermediate Risk
Population served by water supply wells within 1,500 feet downgradient of the
compliance boundary
Low Risk
Proximity of 2L or IMAC exceedances beyond the compliance boundary with
respect to water supply wells
High Risk
Groundwater emanating from the impoundment exceeds 2L or IMAC and that
discharges to a surface water body
High Risk
Ingestion of contaminated soil or fugitive emissions
Low Risk
Data Gaps and Uncertainty
Intermediate Risk
Table 2 provides a listing of the surface water risk classification factors and associated ratings for
Mayo. A total of eight surface water risk factors were rated by NCDEQ. Of the 8 rated factors, 3
were High or Intermediate Risk, and additional 3 factors were rated as Low/Intermediate Risk, and
only 2 of 8 factors are rated Low Risk. Only 25% of the rated surface water risk classification
factors were rated Low Risk, yet NCDEQ gave Mayo an overall Low Risk Rating for Surface Water.
The preceding analysis uses the risk ratings applied by NCDEQ with no evaluation or judgment
about whether they were or were not appropriately applied. The risk ratings given to the Mayo ash
basin point out that protection of environmental and natural resources are not being treated as
priority issues by the North Carolina agency entrusted with the responsibility to do just that. The
approach utilized by NCDEQ effectively ignores impacts to the natural environmental and natural
resources, and even ignores future human users of the groundwater and surface water resources. It
appears that in the view of NCDEQ the only way that a site can be rated as Intermediate or High
Risk is if a facility is located within a 100 -year floodplain or if 11 or more people within 1,500 feet
of the compliance boundary are potentially or currently known to be exposed to ash -impacted
17

GEO-HYDRO, INC
groundwater25. It is hard to imagine that exposed persons 1 through 10 would agree with this rating
scheme.
Table 2
Surface Water Risk Factors
Surface Water Factors
Mayo Rating
Landscape Position and Floodplain (Key Factor)
Low Risk
NPDES Wastewater and Ash Disposal Methods
Low/ Intermediate Risk
Impoundments Footprint Siting in Natural Drainage Way or
Stream
Low/ Intermediate Risk
Potential to Impact Surface Water Based on Total Ash Amount at
Facility
High Risk
Potential to Impact Surface Water Based on Dilution
High Risk
Development Density of Single -Family Residences along
Lake/Reservoir Shoreline
Low Risk
Classification of the Receiving Waters
Low/ Intermediate Risk
Proximity to Water Supply Intake
Intermediate Risk
15 NCDEQ, 2016, page 15, Key Factors

GEO-HYDRO, INC
References
NCDEQ, 2016, Coal Combustion Residual Impoundment Risk Classifications, January 2016.
NCDENR, 2009, Permit to Discharge Wastewater Under the National Pollutant Discharge
Elimination System, Permit NC0038377, October, 2009
SynTerra, 2014, Groundwater Assessment Work Plan for Mayo Steam Electric Plant, September
2014
SynTerra, 2015a, Comprehensive Site Assessment Report, Mayo Steam Electric Plant, Roxboro,
NC, September 2015.
SynTerra , 2015b, Corrective Action Plan, Part 1, Mayo Steam Electric Plant, Roxboro, NC,
December 2015.
United States Geological Survey, Cluster Springs VA. — N.C., 7.5 Minute Topographic Map, 1968,
photorevised 1987.
19

GEO-HYDRO, INC
Figures

ti
`!!i!■rii■ II ^S
■rrl. •!■■■ iNiYi !!■Ik �4
j ■4■■■i+• • >r ■i}■1.. 1. ski• - i
�r� ■■f!■!■a■kkk••l}i�rlrV
■ !t -. r ■i .F ■
■ ■ lig. •!■e■ 1 ■ .• ■■ i ♦ r}�,
I�f •#t..+.. R• Vi a �, ffa .1� rr� Yiaf �
•rfrr .■ ■. Y..• . F +
i i4 ani
t■iiN. R aV'V. / ■ _
f Y.,.. f•
f iR • .
iii!!!"' ■ #•##s
■■.q L
e
■+ it � /■ k .■..+
iii ■ YY� aj1■ ■ ■ 'r# !-•#Rir•i■■ - a■■aa -
f�■##RVV .• ■q r•r■■Pili •! ■ if■ a' ■i! #i ■ i ••w YM� ■ M#■A 1 • • ■R• r N
iiiil■i#f af■ f!■ kr.a ! ! R#f###a# N N 1 t .t ■ rN i
a.. •i• r■ �ffr fi r Y.■ s •
! ■ N.
■if!■ r! ■i■ • ■ • F .wri a
` iNiY R 11. f. , ea N■ . ■
■r +■ ■■ a •■ .i _a N
•• !# a • R
f+■ .l�.r+ y i■ :ef
• • '.• r it - ■■u■■N
• r##
•V• ■ a 10
f
OVr
Figure 1
GEO-HYDRO INC Image taken from
� USGS Cluster Springs VA —NC
Ash Pond Topography
Consulting in Geology and Hydrogeology 1968
Mayo Steam Electric Plant
Photorevised 1987

Figure 32. Simulated October, 2045 boron concentrations (pg -I) in the model laver of the
saprolite (layer 5) for CAP I,
Images from Mayo CAP Part 1,
Appendix E
Figure 2
GEO-HYDRO, INC Predicted 2045 Layer 5
Consulting in Geology and Hydrogeology Boron Concentration
No Action Scenario
Mayo Steam Electric Plant

E=igurc 50. Simulated October, 2045 boron concentrations (jigFL.) in the mode) layer of the
saprolite (layer 5) ror CAP2.
Images from Mayo CAP Part 1,
Appendix E
Figure 3
GEO-HYDRO, INC Predicted 2045 Layer 5
Consulting in Geology and Hydrogeology Boron Concentrations
Capping Ash Basin Scenario
Mayo Steam Electric Plant

Figure Vii . Simulated October, 2045 Moron concentrations; (pg/L) in the model layer of tete
:iproliw (layer 5) ruT CAPS.
Images from Mayo CAP Part 1,
Appendix E
Figure 4
GEO-HYDRO, INC Predicted 2045 Layer 5
Consulting in Geology and Hydrogeology Boron Concentration
Removal of Ash Scenario
Mayo Steam Electric Plant

Images from Mayo CAP Part 1,
Appendix E
GEO-HYDRO, INC
Consulting in Geology and Hydrogeology
f4�
Remove ash
Figure 5
Calculated Head Maps
Mayo Steam Electric Plant

Mark A. Hutson, P.G.
Summary of Qualifications
Over 30 years professional experience performing and managing site characterization, RI/FS's, RFI's, treatability
studies, and soil and groundwater remediation projects. Management experience includes all aspects of projects
for both industrial and government clients. Provided technical review, comments, and oversight on numerous
permit applications and projects for a large variety of projects.
Professional Experience
Geo -Hydro, Inc., 2006 -Present, Principal/Senior Scientist
Weston Solutions, Inc., 2002-2006, Senior Project Manager/Business Line Operations Manager
Ellis Environmental Group, LLC, 2001-2002, Senior Project Manager
Foothill Engineering Consultants, 1997-2001, Senior Project Manager
Burns & McDonnell Waste Consultants, Inc., 1996-1997, Senior Project Manager
Hydro -Search, Inc., 1990-1996, Senior Project Manager/Operations Manager
Roy F. Weston, Inc., 1984-1990, Senior Geologist/ Project Manager
University of Illinois at Chicago, 1982-1984, Teaching Assistant
Ecology and Environment, Inc., 1980-1982, Hydrogeologist
Illinois Environmental Protection Agency, 1978-1980, Environmental Protection Specialist
Professional Registrations, Memberships, and Affiliation
Professional Geologist - Wisconsin (No. 889), Indiana (No. 754), Kansas (No.709), Nebraska (No. G-0329)
American Institute of Professional Geologists - Certified Professional Geologist (No. 7302)
Colorado Ground Water Association - (President 2014-2015, Vice President 2013-2014, Education Committee
Chair, 2011-2013)
Education
M.S., Geology, University of Illinois at Chicago, 1989
B.S., Geology, Northern Illinois University, 1978
Graduate Studies in Business, Northern Illinois University, 1979-81
Various courses on computer software and geographic information systems, Red Rocks Community College,
2000-2010

Project Experience
Technical Oversight and Consulting
• Consultant to tasked with reviewing closure plan information and monitoring reports from the Santee
Cooper Grainger Generating Station ash pond closure. The site is located near Conway, SC. Documents
were reviewed to evaluate the effectiveness of the proposed closure plan and comments were provided to
counsel for use in negotiations with the company.
• Technical Consultant tasked with reviewing and preparing comments on the Draft Environmental Impact
Statement (DEIS) for the Four Corners power plant (FCPP) and Navajo Mine Energy Project in New
Mexico. Reviewed documentation from Office of Surface Mining Reclamation and Enforcement sources
and prepared comments covering the effects of current and previous mining and coal ash disposal practices
and identifying proposed activities likely to adversely impact environmental quality.
• Consultant providing support to counsel by reviewing and providing comments on Groundwater Assessment
Work Plans and Drinking Water Supply Well and Receptor Surveys at 14 coal ash disposal facilities located
in the southeast. The document reviews were conducted in order to evaluate the appropriateness of
proposed characterization, make recommendations to improve characterization, and identify any sites that
showed a particularly high risk to off-site receptors.
• Consultant tasked with reviewing and preparing comments on the 2012 reports covering the Plant Area,
Stage One and Stage Two Evaporation Ponds Area, and Units 3 & 4 Evaporation Holding Ponds Area of the
Colstrip Steam Electric Station located at Colstrip, MT. Reviewed documents and prepared comments and
talking points that were submitted subsequently submitted to regulators.
• Consultant on the Pines Groundwater Plume Site through a USEPA Technical Assistance Program (TAP)
grant from PRPs to local citizens' group. The Pines site is a coal combustion waste landfill with significant
spread of contaminants. Provide assistance to the citizens through grant to provide assessment and feedback
on site work products as they are developed and implemented, explain the remediation processes and
activities to the citizens, and serve as technical liaison between citizens and remediation team.
• Technical Consultant tasked by with reviewing a variety of documents and monitoring data from the
Rosebud Mine located near Colstrip, MT. Document and data reviews included groundwater monitoring
data, MPDES permits and discharge monitoring reports, and permit renewal documents. In each case,
documentation and data were reviewed and comments were prepared and submitted to counsel.
• Technical Consultant providing support at the Massachusetts Military Reservation (MMR) on Cape Cod,
MA. Under contract to the Corps of Engineers, provided third -party technical support services for the
Selectmen of four towns surrounding MMR from 1998 thm 2011. The project involved oversight of impact
area characterization and remediation activities including UXO location and disposal, and characterization
of explosive impacted soil and groundwater, volatile organics, and perchlorate. Provided technical review
of remediation data as well as comments and advice to the Selectmen on technical issues.
• Environmental Consultant to the City of Afton, MN to review and provide comments on an application to
develop a coal combustion waste landfill on the site of a former sand and gravel mining operation. On
behalf of the City of Afton, GHI reviewed the available materials, identified data gaps and potential
concerns, and submitted detailed comments on the plan. Major concerns included the susceptibility of the
local water supply to contamination from the facility, the unacceptable geologic characteristics of the site
for construction of a waste disposal facility, poor characterization of wastes to be placed in the facility,
improper modeling of the site conducted in support of the EIS, and the location of many potential receptors
downgradient of the facility.
• Project Manger and Consultant tasked with reviewing and providing technical comments on the Faulkner,
Westland and Brandywine coal combustion waste disposal facilities in rural Maryland. Provided comments
on the adequacy of characterization of the nature and extent of contaminants released from these facilities.
Subsequently supported the legal team in negotiating the details of necessary actions to be taken during
-2-

Mark Hutson
(Continued)
closure of these facilities to protect human health and the environment.
• Consultant tasked with reviewing and preparing comments on a permit amendment application for the
Savage Mine located in eastern Montana. Comments submitted to counsel primarily concerned the
adequacy of the site characterization, the hydrologic balance and probable hydrologic consequences of
proposed application.
• Project Manager and Consultant on the review and preparation of technical comments on an application by a
major utility to develop an unlined coal combustion waste (CCW) disposal facility in western Kansas.
Major issues included the leachability of CCW in the landfill environment, inadequacy of the proposed
groundwater monitoring plan and the lack of necessary groundwater protection systems in the design.
Comments were provided to counsel for inclusion in the public review process.
• Environmental Consultant tasked with reviewing and preparing comments on a permit application for a
proposed lignite mine located near South Heart, North Dakota. Comments submitted to counsel included
identification of inadequacies in the site characterization, the monitoring plan, the Probable Hydrologic
Consequences, and the evaluation of potential alluvial valley floors. Comments were submitted to counsel.
• Project Manger and Consultant for Robinson Township and Environmental Integrity Project on a review of
a permit application submitted to the State of Pennsylvania to mine coal refuse, generate electricity and
dispose of coal combustion waste at the location of a large coal refuse pile. Services included permit
application review and preparation of comments. Review identified deficiencies in the characterization of
geologic materials, groundwater, surface water, and the hydrologic balance provided in the permit
application.
• Geologist on a geologic and hydrogeologic assessment of a proposed regional landfill in Kendall County, Il.
Research documented problems with the geologic and hydrogeologic characterization, including karst
features in the area that had not been noted or anticipated in the permit application materials.
Site Characterization and Remediation
• Lead author on a Groundwater Impact Assessment at a coal combustion waste disposal facility in Illinois.
This project was conducted to assist an electric generating station investigate the nature and extent of
contaminants that had been released to the groundwater and to investigate remedial options necessary to
minimize future releases. Results of this study are currently being implemented by the company and are
projected to adequately contain contamination and avoid exposures to surrounding residents.
• PCP Contaminated Soil Remediation, Beaver Wood Products, Columbia Falls, MT, Project Manager.
Manager of a project to investigate, excavate and bio -remediate PCP impacted soils at a former pole
treatment site. Soil treatment was conducted via an on-site Land Treatment Unit (LTU). At the time of
project completion over 20,000 cubic yards of impacted soil had been excavated, treated, and returned to the
site. Responsible for project planning and execution, budget and schedule tracking, and cost control.
Project Manager of a project to remediate and remove an oil interceptor pond containing PCB -contaminated
sediment at a generating facility in North Dakota. Oily sludge in the pond contained PCB's in sufficient
concentrations to require special handling and disposal. Responsible for all aspects of the project including
evaluating remedial action alternatives, preparing construction plans, representing the client with regulatory
agencies, and implementation of the approved site closure. Pond closure consisted of dewatering and water
management, sediment stabilization, confirmation sampling, transportation and disposal of waste, and site
restoration. The occurrence of extremely high groundwater conditions during construction required
constant dewatering to control inflow without mobilizing pond -bottom sediment. Fly ash was added as a
stabilizing agent to solidify the sediment within the pond. Stabilized and characterized sediment was
shipped to a permitted TSCA facility for disposal.
• Remediation of hydrocarbon contaminated soils at natural gas collection and pumping Stations, KN Energy,
-3-

Mark Hutson
(Continued)
Project Manager. The project consisted of identification of areas of visually impacted soils, excavation of
soils to visually clean, screening soils with field instrumentation, collecting verification samples for
laboratory analysis, directing contaminated soil excavation, and replacing excavated soil with clean backfill.
Impacted soil was transported to pre-existing landfarm areas for treatment by the client.
Project Manager and Principal Investigator on a mixed waste treatability study performed for Kerr-McGee
Corporation to investigate methods of making radiologically impacted hydrocarbon sludge acceptable for
disposal without increasing the total volume. The project included characterization of the physical,
chemical, and radiologic composition of the available waste materials, and evaluating the feasibility of
combining wastes to produce an acceptable material. Pilot scale testing was conducted on the most
promising materials to identify the proportions necessary to produce an optimum mixture.
• Project Manager on a groundwater remedial design project at a Phillips Petroleum facility in Beatrice,
Nebraska. Project tasks included a general site characterization, geophysical surveys, soil borings and
chemical analysis, pump testing, and design of ground water remediation system. Remedial technologies
selected utilized air stripping and carbon absorption.
• Project Geologist involved in the installation of a petroleum hydrocarbon recovery system at the Hess Oil
refinery on St. Croix US Virgin Islands. Activities included daily coordination with refinery personnel and
drilling contractors, logging and installing recovery wells, and performing recovery tests on completed
installations.
• Project Manager of a program to investigate, design and construct ground water remediation systems at
three Chevron facilities in Puerto Rico. Project included ground water characterization, pump testing and
conceptual and detailed designs of remediation systems. Systems were constructed, operated for a period of
approximately 2 years and have now been removed.
• Prepared Detailed Plans and Specifications for construction and operation of a land treatment unit to remove
hydrocarbon and volatile organics from soil in North Dakota, Project Manager. Managed a team of people
involved in preparation of a complete design and specifications package for construction and operation of a
land treatment unit to treat soils impacted with petroleum hydrocarbon and chlorinated solvents. This
project was completed on schedule, has been built and was successfully completed.
• Project Manager and author of a revised and updated Site Decommissioning Plan for the Kerr-McGee
facility in Cushing, OK. Plan preparation included summarizing site conditions, establishing clean-up
criteria, specifying remedial actions for each of 16 radioactive materials areas (RMAs) including
measurement and sorting of materials, and planning final survey procedures. The scope of the remediation
was negotiated with Nuclear Regulatory Commission headquarters and regional personnel as the document
was being drafted to attempt to minimize the time for subsequent review and approval.
• Project Manager of a multi-million dollar U.S. Army program to identify and properly abandon wells
located on Rocky Mountain Arsenal (RMA) that could possibly be conduits for downward migration of
contamination. This work was conducted in accordance with an Administrative Order ceasing remedial
activities at RMA. Over 350 wells were identified and abandoned under this program.
Project Manager on the characterization of Bombing Target 5 for the Pueblo of Laguna, NM. Portions of
the Laguna Pueblo were used during WWII as a bombing practice area. Munitions used were
predominantly M-51 practice bombs with black powder spotting charges. The project consisted of
preparation of detailed UXO planning documents, surface clearance of the area around the target, and
excavation of the target to a depth of 5 -feet below the surface. Material found to potentially present and
explosive hazard were collected on-site and detonated on-site at the end of the project. The Pueblo of
Laguna and the Corps of Engineers approved all procedures and field activities.
Multi -phase AFCEE Soil And Groundwater Investigation And Monitoring Program at the Former
Bergstrom Air Force Base in Austin, Texas, Project Manager. Investigation areas included an oil -water
-4-

Mark Hutson
(Continued)
separator at an engine test facility, a former maintenance facility, and the base landfills. Soils were
contaminated with heavy metals including lead and solvents. Contaminated soils were excavated and
disposed at an off-site facility. Closure reports for all three areas were submitted and approved by TNRCC.
• Proj ect Manager on a contract to the Department of Energy to perform a surface clearance for UXO at three
former bombing targets at the Tonopah Test Site in Nevada. Materials encountered included practice bombs
and rockets that had been fired several decades ago. UXO technicians inspected each piece of material for
potential explosive hazards. Materials that potentially contained explosive hazards were blown -in-place by
Tonopah personnel. Scrap material was secured on-site and disposed appropriately at the end of the project.
• Project Manager for the investigation of subsurface contamination at several high priority SWMU's at
Rocky Flats Plant. Work included identification and characterization of surface and subsurface soil
contamination, source characterization, and evaluation of ground water quality and movement.
Project Manager under contract to Rockwell International to develop usable and defendable background
geochemical data sets for various media at the Rocky Flats Plant. The occurrence of low-level radioactive
material contamination from many years of plant operations, surrounding land uses, and atomic test fallout
necessitated an extensive program to develop data and apply statistical analysis to describe background
conditions. Additional statistical testing was performed to identify investigative results that showed results
above defensible background values.
• Project Manager on a multi -phase soil and groundwater investigation and monitoring program at the former
Bergstrom Air Force Base in Austin, Texas. Investigation areas included an oil -water separator at an engine
test facility, a former maintenance facility, and the base landfills. Closure reports for all three areas are
currently being prepared.
• Project Manager on a geophysical survey program at the Rocky Flats Plant designed to identify sources of
chemical and radiological contamination at high priority SWMU's. Surveys included electromagnetic,
magnetic, and electrical resistivity methods used in conjunction with aerial photographs to identify possible
source areas.
• Project Manager on a contract for USEPA Region 5 to plan and execute an investigation of the Federal
Marine Terminals site near Detroit, Michigan. The investigation included a detailed review of historical
aerial photographs, geophysical surveys of potential burial sites, soil sampling, monitoring well construction
and sampling, and preparation of a site investigation report. Documentation and depositions on findings
were provided to Region 5 enforcement.
• Project Geologist on a preliminary investigation of possible JP -4 impacts to soil and groundwater from the
fueling system at Forbes Field Air National Guard base in Topeka, KS. The investigation included drilling
through runway and ramp areas, around fuel storage facilities, and evaluation of possible migration
pathways.
• Project Geologist on a project to use electromagnetic geophysical techniques to trace the lateral migration of
shallow, high TDS groundwater plumes associated with three DOE uranium mill tailings sites located in
different parts of the western U.S. Results of these surveys showed that electromagnetics was useful for
tracing the plumes and allowed a minimal number of subsequent monitoring wells to be installed to quantify
leading edge impacts.
Remedial Investigations/Feasibility Studies
• Project Manager for the Remedial Investigation at a former Atlas Missile site located near Holton, Kansas,
Responsible for completion of a site investigation and risk assessment for the Kansas City District. Direct
push soil sampling, sonic drilling and well installation, and indoor air, surface water, sediment, and
groundwater sampling have been conducted in and around the former facility to determine the level and
-5-

Mark Hutson
(Continued)
extent of contamination that may be present. An ecological and human health risk assessment was
conducted to evaluate the potential health risks associated with the site.
Project Manager on a Remedial Investigation and Focused Feasibility Study of JP -4 contaminated soils at
the Fire Protection Training Area at Minot Air Force Base. Performed under contract to the U.S. Corp of
Engineers, this project utilized Laser Induced Fluorescence, an innovative investigation technique, to
characterize the extent of subsurface contamination. The Focused Feasibility Study examined eight
potential remedial actions and was successful in gaining State acceptance of on-site land treatment as the
chosen remedial alternative.
Project Manager for the Remedial Investigation/Feasibility Study (RI/FS) of the Landfill Solids and Gases
Operable Units at the Lowry Landfill CERCLA site. This project involves the characterization and
assessment of the extent of potential contamination within the unsaturated solid and gaseous phases of the
materials at this high profile site. Responsible for coordinating the activities of up to 30 project staff
assigned to multiple concurrent tasks. Responsibilities also included extensive coordination and interaction
with multiple clients and PRP groups as well as the Colorado Department of Health and Environment and
USEPA Region 8 personnel.
• Technical Advisor under contract to EPA Region V on the Remedial Investigation at the Marion Bragg
Landfill CERCLA site. Provided technical assistance to the project team related to investigation techniques
to be used in characterizing the landfill and surrounding areas, including evaluating and providing remedies
to difficult well installation encountered during the remedial investigation.
• Project Manager on a Feasibility Study/Risk Assessment program at a former Rocketdyne fuel test facility
located near Spanish Springs, NV. This program included performing a risk assessment on an impacted
groundwater plume, performing a feasibility study to evaluate appropriate remedial options, and performing
treatability studies on two alternatives to verify and quantify effectiveness and estimate costs.
• Project Geologist and Site Manager on contract to USEPA Region V on the Remedial Investigation of the
Skinner Landfill CERCLA site located near Cincinnati, OH. Prepared planning documents including the
Sampling and Analysis Plan, Quality Assurance Project Plan, and Health and Safety Plan. Managed
implementation of the remedial investigation that included geophysical surveys, aquatic biology surveys,
well installation, and soil and groundwater sampling.
Publications and Presentations
Hutson, M.A., " Oil Interceptor Pond Closure, Sediment, PCB's and Groundwater on a Budget", presented at the
2005 Air Force Environmental Symposium, Louisville, KY, March 2005.
Holliway, K.D., Witt, M.E., and M.A. Hutson, "Abandoned Well Closure Program at a Hazardous Waste Facility,
Rocky Mountain Arsenal, Denver, Colorado" Hazardous Materials Control, vol. 5, no. 1, January 1992.
Karnauskas, R.J., Deigan, G.J., Schoenberger, R.J., and M. A. Hutson, "Closure of Lead Contaminated Glass
Manufacturing Waste Lagoons" Proceedings of HAZMACON 87, April 1987.
Hutson, M.A., and R. J. Karnauskas, "Groundwater Contamination Study, Forbes Field Air National Guard Based,
Shawnee County Kansas, Defense Technical Information Center, 1985.
-6-