Attachments

Expert Report of Douglas Cosler, Ph.D., P.E.

Amended Expert Report of Douglas J. Cosler, Ph.D., P.E.

Chemical Hydrogeologist Adaptive Groundwater Solutions LLC

Charlotte, North Carolina

Cliffside Steam Station Ash Basins Mooresboro, North Carolina

April 13, 2016

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Introduction

Site Background

The Cliffside Steam Station (CSS) is a coal-fired generating station owned by Duke Energy and located

on a 1,000-acre site in Mooresboro, Rutherford and Cleveland Counties, North Carolina, adjacent to the

Broad River. CSS began operations 1940 with Units 1-4, followed later by Unit 5 (1972) and Unit 6

(2013). Units 5 and 6 are currently operating, but Units 1-4 were retired from service in 2011. An ash

basin system has been historically used to dispose of coal combustion residuals ("coal ash") and other

liquid discharges from the CSS coal combustion process. The ash basin system consists of an active ash

basin (constructed in 1975 and expanded in 1980; used by Units 5 and 6), the Units 1-4 inactive ash

basin (retired in 1977 upon reaching its capacity), and the Unit 5 inactive ash basin (retired at capacity in

1980, but local stormwater collects and infiltrates within its footprint). The active ash basin also contains

an unlined dry ash storage area. Duke Energy performed voluntary groundwater monitoring around the active ash basin from August 2008

to August 2010 using wells installed in 1995/1996, 2005, and 2007. Compliance groundwater monitoring,

required by a NPDES permit, has been performed by Duke starting in April 2011. Recent groundwater

sampling results at Cliffside have indicated exceedances of 15A NCAC 02L.0202 Groundwater Quality

Standards (2L Standards). In response to this, the North Carolina Department of Environmental Quality

(NC DEQ) required Duke Energy to perform a groundwater assessment at the site and prepare a

Comprehensive Site Assessment (CSA) report. The Coal Ash Management Act of 2014 (CAMA) also

required owners of surface impoundments containing coal combustion residuals (CCR) to conduct

groundwater monitoring and assessment and prepare a CSA report. The recently-completed CSA

(August 2015) prepared by HDR Engineering, Inc. of the Carolinas (HDR) determined that the source and

cause of certain constituent regulatory exceedances at the CSS site is leaching from coal ash contained

in the active and inactive ash basins and the ash storage area into underlying soil and groundwater. The

Cliffside CSA report defined Constituents of Interest (COI) in soil, groundwater, and seeps that are

attributable to coal ash handling and storage.

CAMA also requires the submittal of a Corrective Action Plan (CAP); the CAP for the Cliffside site

consists of two parts. CAP Part 1 (submitted to DEQ in November 2015) provides a summary of CSA

findings, further evaluation and selection of COI, a site conceptual model (SCM), the development of

groundwater flow and chemical transport models of the site, presentation and analysis of the results of

the modeling, and a quantitative analysis of groundwater and surface water interactions. The CAP Part 2

contains proposed remedial methods for achieving groundwater quality restoration, conceptual plans for

recommended corrective action, proposed future monitoring plans, and a risk assessment.

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Information Reviewed

My opinions are based upon an analysis and technical review of (i) hydrogeologic and chemical data

collected at the Cliffside site; (ii) the analyses, interpretations, and conclusions presented in site-related

technical documents and reports; (iii) the groundwater flow and chemical transport models constructed

for the site (including model development, calibration, and simulations of remedial alternatives); (iv) the

effectiveness of proposed remedial alternatives to achieve groundwater quality restoration; and (v)

proposed future site monitoring. This amended report contains additional opinions based on my review of

the recently-issued CAP Part 2 report. These opinions are subject to change as new information

becomes available.

As a basis for forming my opinions I reviewed the following documents and associated appendices:

(1) Comprehensive Site Assessment Report, Cliffside Steam Station Ash Basin (August 18, 2015);

(2) Corrective Action Plan, Part 1, Cliffside Steam Station Ash Basin (November 16, 2015);

(3) Corrective Action Plan, Part 2, Cliffside Steam Station Ash Basin (February 12, 2016);

(4) Miscellaneous historical groundwater and soil concentration data for the Cliffside site collected

prior to the CSA; and

(5) Specific references cited in and listed at the end of this report.

Professional Qualifications

I have advanced graduate degrees in Hydrogeology (Ph.D. Degree from The Ohio State University) and

Civil and Environmental Engineering (Civil Engineer Degree from the Massachusetts Institute of

Technology), and M.S. and B.S. degrees from Ohio State in Civil and Environmental Engineering. I have

36 years of experience as a chemical hydrogeologist and environmental engineer investigating and

performing data analyses and computer modeling for a wide variety of projects. These projects include:

investigation, remediation, and regulation of Superfund, RCRA, and other hazardous waste sites involving

overburden and bedrock aquifers; ground water flow and chemical transport model development; natural

attenuation/biodegradation assessments for chlorinated solvent and petroleum contamination sites;

volatile organic compound vapor migration and exposure assessment; exposure modeling for health risk

assessments; hydrologic impact assessment for minerals and coal mining; leachate collection system

modeling and design for mine tailings disposal impoundments; and expert witness testimony and

litigation support. I also develop commercial groundwater flow and chemical transport modeling software

for the environmental industry.

The types of sites I have investigated include: landfills, mining operations, manufactured gas plants,

wood-treating facilities, chemical plants, water supply well fields, gasoline and fuel oil storage/delivery

facilities, nuclear waste disposal sites, hazardous waste incinerators, and various industrial facilities. I

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have investigated the following dissolved, nonaqueous-phase (LNAPL/DNAPL), and vapor-phase

contaminants: chlorinated solvents, various metals, gasoline and fuel oil constituents, wood-treating

products, coal tars, polychlorinated biphenyls, pesticides, dioxins and furans, phenolic compounds, flame

retardants (PBDE), phthalates, radionuclides, and biological constituents.

Summary of Opinions

The following is a brief summary of the opinions developed in my report:

• A total of 62 Compliance Boundary groundwater samples exceeded North Carolina groundwater

standards for these COI: antimony, boron, chromium, cobalt, iron, manganese, sulfate, total

dissolved solids, and vanadium. Of these 62 exceedances, 36 were greater than the proposed

provisional background concentrations by HDR;

• The statistical analyses of shallow background groundwater concentrations at the Cliffside site

(well MW-24D) are invalid due to the characteristically slow rate of COI migration in groundwater;

• There is a significant risk of chemical migration from the ash basin to neighboring private water

supply wells in fractured bedrock;

• Major limitations of the CAP groundwater flow and chemical transport models prevent simulation

and analysis of off-site migration;

• The CAP Closure Scenario simulations greatly underestimate (by factors of 10 or more) the time

frames required to achieve meaningful groundwater concentration reductions in response to

remedial actions;

• For either the Existing Condition or Cap-in-Place Model Scenario groundwater concentrations of

coal-ash constituents much higher than background levels will continue to exceed North Carolina

groundwater standards at the Compliance Boundary because saturated coal-ash material and

secondary sources will remain in place;

• Source-area mass removal included in the Excavation Scenario results in COI concentration

reductions at the Compliance Boundary that are generally two to ten (2 - 10x) times greater

compared to Cap-in-Place, best reduces impacts to surface water, and reduces cleanup times by

factors of two to five (2 - 5x). Additional excavation of secondary sources would further

accelerate concentration reductions;

• The CAP simulations show that source excavation reduces groundwater concentrations for many

COI below North Carolina groundwater standards (antimony, arsenic, chromium, hexavalent

chromium, cobalt, nickel, thallium, vanadium), but cap-in-place closure does not;

• CSA data show multiple exceedances of groundwater standards in bedrock not only at the

compliance boundary but also inside the CB. However, the CAP Closure Scenarios do not

address either concentration reduction or off-site chemical migration control in the fractured

bedrock aquifer;

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• Due to an incorrect boundary-condition representation of the active ash basin, the CAP models

underestimate by a factor of two or more both the mass loading of COI into the Broad River and

the corresponding Broad River water concentrations (attributable to coal ash ponds) estimated by

the groundwater/surface-water mixing model;

• The CAP Part 2 geochemical modeling and monitored natural attenuation (MNA) evaluations do

not provide the required quantitative analyses of COI attenuation rates necessary to support MNA

as a viable corrective action. The CAP 2 chemical transport modeling, which included attenuation

by sorption, demonstrated that MNA is not an effective remedial option for several COI (e.g.,

antimony, arsenic, beryllium, boron, chromium, hexavalent chromium, cobalt, lead, sulfate,

thallium, and vanadium);

• Future Compliance Monitoring at the Cliffside site should include much more closely-spaced

Compliance Wells to provide more accurate detection, and groundwater sampling frequency

should be re-evaluated to allow valid statistical analyses of concentration variations.

Hydrogeology of the Cliffside Site

Introduction

The groundwater system at the Cliffside site is an unconfined, connected system consisting of three basic

flow layers: shallow, deep, and fractured bedrock. The shallow and deep layers consist of residual soil,

saprolite (clay and coarser granular material formed by chemical weathering of bedrock), and weathered

fractured rock (regolith). A transition zone at the base of the regolith is also present and consists of

partially-weathered/fractured bedrock and lesser amounts of saprolite. The ash basin system overlies

native soil and was constructed in historical drainage features formed from tributaries that flowed toward

the Broad River using earthen embankment dams and dikes. As described in the CSA report, the active

ash basin was formed by construction of two dams across natural drainages. At the upstream dam, Suck

Creek was diverted through a canal and away from the ash basin to the Broad River, at its present-day

configuration. The active ash basin downstream dam is located near the historical discharge point of

Suck Creek into the Broad River. A large percentage of the coal ash lies below the groundwater table

and is saturated. Groundwater flow through saturated coal ash and downward infiltration of rainwater

through unsaturated coal ash leach COI into the subsurface beneath the basin and via seeps through the

embankments.

As described by HDR, groundwater flow in all three layers within the site boundary is generally from south

to north toward the Broad River. Vertical groundwater flow between the three layers also occurs, and

surface water ponding in the active ash basin effects flow directions locally. The CSA and CAP

investigations assumed that all groundwater north of the ash basin system (overburden and bedrock

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aquifers) discharges into the Broad River. However, these studies did not collect hydrogeologic data or

perform data analyses or groundwater flow modeling to support this assumption. The CSA and CAP

Parts 1 and 2 also did not analyze potential changes to site groundwater flow directions, or the risk of off-

site migration of COI in the overburden or bedrock aquifers, caused by groundwater extraction from

numerous private and public water supply wells located close to the site boundaries and near the Broad

River.

My report begins with a discussion of significant errors in CSA data analysis and conceptual model

development that contradict HDR's interpretation of three-dimensional groundwater flow patterns at the

Cliffside site. This is followed by a presentation and discussion of measured exceedances of North

Carolina groundwater standards at multiple locations on the ash basin compliance boundary. I then

address several limitations of the CAP Parts 1 and 2 groundwater flow and chemical transport models

and identify various model input data errors. Finally, I present my evaluations of the CAP Closure

Scenario simulations and provide my opinions regarding the effectiveness of various remedial alternatives

for restoring groundwater quality to North Carolina standards.

Errors in Hydraulic Conductivity Test Analyses

Background

Throughout the CSA and CAP reports HDR provides interpretations and conclusions regarding the

horizontal and vertical variations of groundwater flow directions and rates, and the fate and transport of

COI dissolved in groundwater. The most important site-specific parameter that controls these time-

dependent flow and transport mechanisms is the hydraulic conductivity (also referred to as "permeability")

of the underlying soils and fractured bedrock (Bear, 1979). Hydraulic conductivity (length/time) is a

media-specific measure of the rate at which water can flow through a porous (soil) or fractured (bedrock)

porous medium. Groundwater flow and chemical transport rates are directly proportional to the product of

hydraulic conductivity and the hydraulic gradient (hydraulic head difference between two points divided by

the separation distance; e.g., the water table elevation slope at the Cliffside site). Therefore, accurate

measurement of hydraulic conductivity is critical for understanding the current and future distributions of

COI in soil and groundwater and for evaluating the effectiveness (e.g., cleanup times) of alternative

remedial measures.

In addition, the contrast in hydraulic conductivity between adjacent hydrogeologic units is the key factor in

determining three-dimensional groundwater flow directions and the ultimate fate of dissolved COI. For

example, at the Cliffside site accurate measurement of hydraulic conductivity is critical in evaluating the

potential for: downward chemical migration into the fractured bedrock unit, off-site COI migration in the

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overburden (soil) or fractured bedrock aquifers, groundwater flow and COI transport into or beneath the

Broad River.

A slug test is one of the standard field methods for measuring hydraulic conductivity (K) using a soil

boring or installed monitoring well. Slug tests were performed in most of the overburden and bedrock

wells at the Cliffside site. In this test the static water level in the open hole (boring) or well casing is

suddenly increased or decreased and the resulting transient change in water level is recorded. Two

commonly-used techniques for quickly changing the water level are the introduction (increases the water

level) and removal (decreases the water level) of a solid rod, or "slug" into the boring or well casing.

These tests are called "falling-head" and "rising-head" tests, respectively. Higher rates of water-level

recovery correspond to higher values of K. The measurements of water level versus time are analyzed

using mathematical models of the groundwater flow hydraulics and information regarding the well

installation (e.g., length of the slotted monitoring well screen and well casing diameter) to compute an

estimate of K.

As discussed below, HDR made significant errors in all of their analyses of field slug test data. Their

analysis errors caused the reported (CSA report) slug test hydraulic conductivity values to be as large as

a factor of two (almost 100 percent) smaller than the correct K values. I discuss the impacts of these

analysis errors on HDR's groundwater flow and chemical transport assessments and the CAP modeling

later in my report.

Overburden Slug Tests

HDR analyzed all of the CSA overburden slug tests in shallow and deep wells with the Bouwer-Rice

(1976) method using a vertical anisotropy, Av = Khorizontal / Kvertical , that is as large as a factor of 100 lower

than the values presented in the CSA report (e.g., compare geometric mean values in CSA Tables 11-10

and 11-11) and used in the CAP modeling (e.g., CAP 1 report Appendix C, Table 2), where K is hydraulic

conductivity. Comparing CSA Tables 11-10 and 11-11, the measured Av for overburden soil units ranges

from 4 to 50. In the calibrated CAP flow model Av is on the order of 100 for overburden soil. However,

the Bouwer-Rice slug test analyses assumed Av = 1 for every monitoring well (CSA Appendix H). If the

CAP 1 flow model results (Av ~ 100) are used in the Bouwer-Rice analyses all of the measured

overburden hydraulic conductivity values increase by about 70 percent (factor of 1.7), depending on how

the slug-test radius of influence was computed. Using the Tables 11-10/11-11 measured vertical

anisotropies (Av = 4 to 50) increases all of the measured overburden hydraulic conductivity values (CSA

Table 11-4) by about 20-60 percent.

Since every reported overburden K value in the CSA report (at least for new shallow and deep wells) is

up to 70 percent too low, the actual average chemical transport rates in overburden soils are up to 70

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percent greater than reported. This site-wide data reduction error also affects the CAP flow and transport

model calibrations. For example, the transport model developers significantly reduced laboratory

measurements of the soil-water partition coefficient, Kd, for various COI during the transport model

calibration based on comparisons of observed and simulated chemical migration rates. However, if the

correct (i.e., higher) overburden K values had been used in the model calibration the Kd values would not

have been reduced as much (compared to laboratory values). The reason for this is, assuming linear

equilibrium partitioning of COI with soil, the chemical migration rate is proportional to K / Kd (except for Kd

<< 1). The CAP 1 and 2 transport model history matching indicated that the simulated transport rate was

too low, so the model developers reduced the model Kd. In other words, the reductions in calibrated Kd

values would not have been as great if the correct (higher) K values were used in the first place. As

discussed below, the CAP Part 2 transport modeling used Kd values that are generally a factor of about

10 larger than the CAP 1 values; however, the CAP 2 Kd 's are still on the order of 10 times smaller than

the measured site-specific Kd 's reported in CAP 1 Appendix D and CAP 2 Appendix C. COI sorption to

soil is important because, as discussed below, aquifer cleanup times (i.e., chemical flushing rates) are

generally proportional to the chemical retardation factor, which is directly proportional to Kd , except when

Kd << 1 (Zheng et al., 1991).

Groundwater Flow

Throughout the CSA and CAP reports HDR made several critical assumptions, not supported by data,

regarding the horizontal and vertical groundwater flow directions near the boundaries of the Cliffside site

which impacted their conclusions regarding the ultimate discharge locations for site groundwater and

dissolved COI. Two examples discussed in this section are (i) the relationship between site groundwater

and the Broad River and (ii) groundwater flow directions and the potential for offsite migration of COI.

Broad River and the LeGrand Conceptual Model

Most of the groundwater at the Cliffside site was apparently assumed to discharge into the Broad River

(other than groundwater discharges to small streams such as Suck Creek) according to a generalized

conceptual model (LeGrand, 2004) before actual site-specific hydrogeologic data were analyzed.

Statements to this effect were made at numerous points in the CSA and CAP reports. However, HDR did

not present any site-specific data analyses or groundwater flow modeling that would support this

assumption in either report. In fact, as discussed below, the boundary conditions for the CAP Parts 1 and

2 flow models effectively forced site groundwater to discharge into the river at the downgradient model

boundary.

HDR continued to state this assumption in the CAP 2 report (e.g., Section 3.3.2) even though strong

measured downward groundwater flow components exist next to the Broad River. In CAP 2 Section

3.3.2, HDR also states that "The Broad River serves as a hydrologic boundary for groundwater within the

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shallow, deep, and bedrock flow layers at the site." However, the river cannot be a "hydrologic boundary"

for the deep and bedrock layers when the measured vertical flow direction in these layers is consistently

downward at many locations next to the river (see discussion below), which demonstrates that HDR has

not delineated this inferred "lower boundary" used in the CAP models. HDR further states in CAP 2

Section 3.3.2 that "the approximate vertical extent of the groundwater impacts is generally limited to the

shallow and deep flow layers, and vertical migration of COIs is limited by the underlying bedrock." This

statement ignores that fact that groundwater flow across the site is consistently downward from the

impacted deep flow layer to the highly-fractured bedrock aquifer at many locations and that, as discussed

below, 35 exceedances of North Carolina 2L and/or IMAC groundwater standards (and greater than

background concentrations) were measured in samples collected from bedrock wells located inside the

Compliance Boundary.

The LeGrand (2004) guidance document presents a general discussion of groundwater flow patterns that

may occur near streams in the Piedmont and Mountain Region of North Carolina based on ground

surface elevations (i.e., site topography and surface watershed boundaries). However, surface water and

groundwater watersheds commonly do not coincide (Winter et al., 2003). Further, groundwater flow

patterns and rates in bedrock have been found to be poorly related to topographic characteristics (Yin

and Brook, 1992). LeGrand does not present or derive any mathematical equations or quantitative

relationships for groundwater flow near rivers or streams. The author emphasizes that site-specific data

must be collected in order to correctly evaluate river inflow or outflow. In strong contrast to the LeGrand

generalizations, numerous detailed and sophisticated mathematical (analytical and numerical) river-

aquifer models and highly-monitored field studies have been published in the scientific and engineering

literature in the past several decades. What these investigations and applied hydraulic models show is

that the water flow rate into or out of a river or stream and the depth of hydraulic influence within an

underlying aquifer are highly sensitive to several factors, including: the transient river water surface

elevation and slope; river bed topography; bed permeability and thickness; horizontal and vertical

permeability (and thickness) of the different hydrogeologic units underlying the river; transient horizontal

and vertical hydraulic head variations in groundwater beneath and near the river; and groundwater

extraction rates and screen elevations for neighboring pumping wells (e.g., Simon et al. 2015; McDonald

and Harbaugh, 1988; Bear, 1979; Hantush, 1964).

The CSA investigation did not: measure river bed permeability or thickness; characterize the river

bathymetry; monitor transient water surface elevation variations at more than one location (one average

value was used); collect river bed hydraulic gradient data; measure horizontal or vertical overburden or

bedrock permeability beneath or on the northern side of the river; characterize the geology beneath or

north of the river; measure hydraulic heads in the overburden or bedrock beneath or north of the river; or

consider the hydraulic effects of groundwater extraction from nearby private water supply wells, as

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discussed in the following section. With regard to the Cliffside site, much of the data that were collected

in the CSA contradict the LeGrand hypothesis. A strong downward flow component (~ 10 feet head

difference) from deep overburden to bedrock was measured at the following locations next to the Broad

River: GWA-21 (near several private bedrock supply wells), GWA-29, IB-3D/GWA-11BRU, MW-

38D/MW-36BRU, and the entire area between the river and northern portion of the Active Ash Basin as

generally bounded by the 650- to 725-foot bedrock head contours (compare CSA Figures 6-6 and 6-7).

The vertical flow direction from shallow to deep overburden is also downward in this area located

between the Broad River and the Active Ash Basin (compare CSA Figures 6-5 and 6-6). In addition,

downward groundwater flow was measured at several other locations across the site (CSA Table 11-13).

A similar trend of downward groundwater flow from deep overburden to bedrock in these areas next to

the river was measured in the CAP 2 investigation. Contour maps of vertical hydraulic gradient variations

were not generated for the CSA or CAP Part 2, and HDR did not discuss the significance of downward

hydraulic gradients next to the Broad River and at many other deep/bedrock monitoring well clusters.

These downward groundwater flow measurements are consistent with the hydraulic conductivities of the

bedrock and overburden being of similar magnitude, as discussed above.

The strong and consistent measured downward groundwater flow components immediately adjacent to

the Broad River and at other well clusters indicate that site groundwater is entering the deep fractured

bedrock unit in these areas and that not all of the site groundwater discharges into the river as the site

Conceptual Model and the CAP flow and transport models assume. The downward flow into bedrock

may also be due in part to groundwater extraction from private bedrock water supply wells located near

the eastern property boundary, but in the CSA and CAP investigations HDR assumed these factors

related to the potential for off-site COI migration beneath the river were not important and did not evaluate

them.

Groundwater Flow Directions

The CSA assumptions and analysis errors discussed above have had a strong effect on: the Conceptual

Model development; the site hydrogeologic and COI transport assessment; the construction/calibration

of the CAP flow and transport models; and the simulations of CAP Close Scenarios. The hydrogeologic

assumptions should have been carefully evaluated and tested during the performance of the CSA and as

part of the CAP groundwater flow model construction and calibration to determine whether they were

valid. Instead, the hypotheses appear to have effectively guided the model development and led to

inaccurate interpretations.

As an illustration, because the permeability of the weathered bedrock is similar to the overlying soils at

the Cliffside site the CSA and CAP interpretation that the bedrock acts as a lower confining layer for

groundwater flow and chemical transport is incorrect. In addition, the similarity of the overburden and

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bedrock aquifer permeability values increases the potential for off-site COI migration toward private water

supply wells. Therefore, the CSA and CAP conclusions that (i) all site groundwater discharges into the

Broad River and (ii) groundwater and dissolved coal-ash constituents are restricted from migrating to

residential water supply wells are not consistent with the data.

The CSA and CAP reports also did not adequately evaluate the three-dimensional groundwater flow field

near and beneath the Broad River. Numerous private water supply wells are located in the following

areas (CSA Figure 4-2): a few hundred feet north of the Broad River and immediately east of the

Compliance Boundary for the Active Ash Basin, less than 1,500 feet from the Active and Unit 5 Inactive

Ash Basins, and less than 1,500 feet from the Active Ash Basin and on the southern shore of the Broad

River (close to the northeastern portion of the Compliance Boundary). Bedrock hydraulic head

measurements (CSA Figure 6-8) for monitoring wells located next to the river (e.g., Wells GWA-32BR,

GWA-11BRU, GWA-29BR, and GWA-21BR) indicate a strong easterly bedrock aquifer flow component

from downgradient areas of the site toward these private wells on the southern shoreline. However, CSA

Figure 6-8 does not show these head contours, and the CAP flow model boundary conditions artificially

prevent groundwater from either flowing east or northeast beneath the Broad River (as underflow), or

flowing toward the private wells near the northeast Compliance Boundary. The CSA and CAP reports

also do not address the large measured downward hydraulic gradients in the northern portion of the

Active Ash Basin and near the river, and their potential relationship to offsite groundwater extraction from

the bedrock aquifer. The CAP flow models were not properly constructed to allow evaluation of these

observed three-dimensional flow patterns due to: the model no-flow boundary condition on the eastern

and western sides of the grid; the uniform specified head boundary condition in grid cells underlying the

river (i.e., the sloping, west-to-east water surface elevation in the river was not represented in the model);

and the fact that the CAP flow models did not include the effects of groundwater extraction from off-site

water supply wells.

Exceedances of Groundwater Standards

In this section I compare measured groundwater concentrations in shallow, deep, and bedrock

groundwater samples to North Carolina 2L and IMAC standards and show the following: (i) 60 measured

exceedances for several COI at multiple locations on the Compliance Boundary (CB); (ii) an additional

two CB exceedances based on chemical transport modeling I performed; (iii) 36 of the 62 Compliance

Boundary exceedances were greater than the proposed provisional background concentrations (PPBC)

by HDR; (iv) 37 of the 62 Compliance Boundary exceedances were greater than the maximum

concentration at any background well from the same hydrogeologic unit (e.g., shallow, deep, or bedrock)

for a particular constituent; (v) 12 more exceedances were measured in wells located on the Broad River;

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(vi) 54 additional exceedances were observed in wells screened in the highly-permeable fractured

bedrock unit underlying the ash basin system and located inside the CB; and (vii) the statistical analyses

of groundwater concentrations at shallow monitoring well MW-24D for purposes of defining background

levels were performed incorrectly.

Throughout this report I reference the ash basin compliance boundary and the Duke Energy property

boundary for the Cliffside site as drawn on maps developed by HDR (e.g., CSA Figure 6-2). My reference

to the "compliance boundary" is only for identification purposes and not an opinion that this boundary as

drawn by HDR is accurate or legally correct.

Summary of Exceedances

Table 1 summarizes exceedances of 2L or IMAC standards in shallow, deep, and bedrock groundwater

samples obtained from monitoring wells located: (i) on the Ash Basin Compliance Boundary (CB) as

drawn by HDR; (ii) on the southern shore of the Broad River (RV), which is the downgradient boundary of

the CAP groundwater flow and chemical transport models; (iii) bedrock wells (BR) located inside the CB;

and (iv) modeled Compliance Boundary concentrations (CBM), using modeling techniques described

below. The proposed provisional background concentrations (PPBC) by HDR are also listed in Table 1.

A total of 33 Compliance Boundary groundwater samples exceeded North Carolina 2L standards, and

IMAC standards were exceeded in an additional 27 samples for these COI: antimony, boron, chromium,

cobalt, iron, manganese, sulfate, total dissolved solids, and vanadium. I estimated an additional two CB

exceedances dowgradient from wells MW-11S and GWA-27D for boron based on chemical transport

modeling and measured upgradient concentrations (designated CBM in Table 1). In addition, 39

exceedances of 2L regulatory limits were observed in wells screened in the highly fractured bedrock unit

located inside the CB. An additional 15 bedrock sample concentrations were greater than IMAC limits.

Ten more 2L (plus two IMAC) exceedances were measured in wells located on the Broad River.

A total of 29 of the 35 Compliance Boundary 2L (and 9 of 25 IMAC) exceedances were greater than the

maximum concentration at any background well (from the same hydrogeologic unit; e.g., shallow or

deep) for a particular constituent. All of the Broad River shoreline "RV" exceedances were greater than

background levels. A total of 27 of the 39 bedrock 2L (and 8 of 15 IMAC) exceedances were greater than

the maximum background concentration.

A total of 36 of the 62 Compliance Boundary exceedances were greater than the proposed provisional

background concentrations (PPBC) by HDR.

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Note that the iso-concentration contours in all of the CSA Section 10 figures are not consistent, and are in

many cases misleading, with regard to chemical transport mechanisms in the subsurface. For example,

the iso-concentration contours in Section 10 generally closely encircle a monitoring well and infer no

subsequent transport downgradient from the well location. This contouring problem is especially

prevalent near the southern shore of the Broad River. Figure 10-65 (cobalt) is a good example of this

practice. These closed contours at the downgradient property boundary suggest that COI transport

beyond the farthest downgradient line of monitoring wells does not occur and that no COI migrate north of

the southern shore of the river. However, the simulated (CAP model) "existing conditions" cobalt

concentration contours in CAP Appendix C are "open" at the Broad River, indicating transport beneath the

river.

Modeled Compliance Boundary Exceedances

I computed Compliance Boundary (CB) concentrations labeled "CBM" with footnote "e" in Table 1 (MW-

11S and GWA-27D) using a calibrated one-dimensional, analytical chemical transport model (van

Genuchten and Alves, 1982; Equation C5) because the CB at these locations was up to 400 feet

downgradient from the wells and boron is highly mobile in the subsurface. I calibrated the analytical

model to chemical-specific site conditions (i.e., determined model input parameter values) using CAP

transport model simulated concentration versus time curves for "Existing Conditions" (CAP report

Appendix C). The analytical model input parameters in my model were: groundwater pore velocity,

chemical retardation factor, and longitudinal dispersivity. For each constituent, I used the calibrated

analytical model to compute the concentration versus time curve immediately downgradient at the

Compliance Boundary.

Exceedances of Groundwater and Surface Water Standards in Seep Samples

Concentrations in seeps discharging from the active ash basin (upstream toe, adjacent to Suck Creek)

have exceeded North Carolina surface water standards (2B) and 2L and/or IMAC groundwater standards

(e.g., arsenic, chromium, iron, lead, manganese, nickel, selenium, and vanadium; CAP Figures 2-2 and

2-3, CSA Table 7-9). Groundwater discharges to Suck Creek were confirmed by the CAP flow modeling.

Elevated concentrations of boron, calcium, chloride, sulfate, and total dissolved solids were detected in a

surface water sample from Suck Creek (SW-3) collected downgradient from the toe of the active ash

basin upstream dam (page 90 of the CSA report).

The CSA also identified other continuously-flowing seeps as tributaries of the Broad River [e.g., S-1, S-3,

S-6, and S-8; refer to Table 1 in the Topographic Map and Discharge Assessment Plan(DAP)]. Seep S-3

is apparently part of a stream discharging to the Broad River north of inactive units 1-4 (DAP Figure 2).

Seep S-6 is located downgradient from the downstream dam of the active ash basin and coincides with

historical Suck Creek discharge (CSA Appendix I, Figure 1). Concentrations in samples from seep S-6

14

have exceeded relevant surface water 2B standards, and 2L and/or IMAC groundwater standards for

boron, cobalt, iron, manganese, and vanadium. Concentrations in samples from seep S-3 have

exceeded relevant surface water 2B standards for cobalt, iron, manganese, sulfate, thallium and total

dissolved solids. For the CAP 2 sampling round (September 2015) the 2B standard for mercury was also

exceeded at Seep S-1.

Referring to my Table 1, 122 of the seep samples exceeded North Carolina groundwater standards (84

2L exceedances and 38 IMAC exceedances; CSA Table 7-11) for these COI: arsenic, barium, beryllium,

boron, chromium, cobalt, iron, lead, manganese, nickel, sulfate, total dissolved solids, thallium, and

vanadium. These samples were collected at the active ash basin; inactive ash basins 1-4 and 5; and

the ash storage area.

Statistical Analyses of Background Concentrations

Appendix G of the CSA report presents statistical analyses of historical concentrations from Monitoring

Wells MW-24D and MW-24DR, which HDR described as following methods specified by the U.S.

Environmental Protection Agency (EPA, 2009), in an attempt to establish background groundwater

concentrations for the Cliffside site. As outlined in Sections 3.2.1 and 5.5.2 of the EPA guidance

document these data must be checked to ensure that they are statistically independent and exhibit no

pairwise correlation. Groundwater sampling data can be non-independent (i.e., autocorrelated) if the

sampling frequency is too high (i.e., time interval between sampling events is too small) compared to the

chemical migration rate in the aquifer (groundwater pore velocity divided by chemical retardation factor).

Section 14 of the EPA guidance presents methods for ensuring that the Wells MW-24D and MW-24DR

background data are not autocorrelated, but the analyses in CSA Appendix G did not include evaluations

for statistical independence.

As an illustration, "slow-moving" groundwater combined with high chemical retardation (i.e., large soil-

water partition coefficients, Kd), which is the case at the Cliffside site, can lead to the same general

volume of the chemical plume being repeatedly sampled when the monitoring events are closely spaced.

Examining shallow wells at the Cliffside site, the shallow groundwater pore velocity (Vp) is in the order of

70 ft/yr (CSA Table 11-14), which is representative of the pore velocity near well MW-24D. Note that

shallow pore velocities are as much as a factor of 100 greater in many areas downgradient of the ash

basin system (e.g., the active ash basin) due to much greater hydraulic gradients (~ 10x larger) and larger

hydraulic conductivity (~ 10x greater) in these areas. In addition, groundwater pore velocities in deep

overburden and in fractured bedrock are generally more than a factor of 1,000 greater than velocities in

the shallow overburden (CSA Table 11-14).

15

The retardation factors, Rd, based on laboratory Kd measurements (Kd ~ 10 cm3/g, or greater) are on the

order of 100 (or greater) for many of the COI (except conservative parameters such as sulfate and

boron). Therefore, the average shallow chemical migration rate at Cliffside (Vp / Rd) is on the order of 0.7

ft/yr many of the non-conservative COI near well MW-24D, assuming linear equilibrium sorption (refer to

discussion below). For quarterly sampling, the chemical migration distance between sampling rounds is

about 0.2 feet for several COI, which is smaller than the sand pack diameter for the monitoring wells.

Therefore, based on either quarterly or annual monitoring the shallow groundwater samples at Cliffside

are basically representative of the same volume of the plume (i.e., the sandpack, depending on the well

purge volume) for many COI, and any measured sample concentration changes are not due to real

chemical transport effects in the aquifer. In this case, this means that the groundwater samples are non-

independent and that the statistical analyses of background concentrations at Wells MW-24D do not

satisfy the key requirements of the analysis method.

CAP Groundwater Flow Model Underestimates Potential for Off-Site Chemical Migration

My discussions in this section focus on limitations of the CAP groundwater flow model. I focus specifically

on model boundary conditions representing the Broad River; the overall size of the model grid and no-

flow boundary conditions on the western, southern, and eastern grid boundaries; groundwater flow in the

fractured bedrock aquifer; and the potential for off-site groundwater flow in relation to groundwater

extraction from numerous private and public water supply wells located close to the model boundaries,

but not incorporated into the flow model

Broad River Boundary Condition

The CAP Parts 1 and 2 groundwater flow models force all Cliffside site groundwater along the northern

model boundary to discharge directly into the Broad River and underestimate the potential for off-site flow

and chemical migration in fractured bedrock. No-flow boundary conditions defined along the entire

western, eastern, and southern model boundaries prevent any off-site groundwater flow and chemical

transport in these areas (refer to Figures 1 and 5 in Appendix C of the CAP 1 Report). The bottom

surface (bedrock) of the flow model is also assumed to be a no-flow boundary even though the hydraulic

conductivity data and measured downward hydraulic gradients at several monitoring well clusters do not

support this assumption. The only locations where groundwater and dissolved constituents are allowed

to leave the CAP models are streams (e.g., Suck Creek and unnamed tributaries to the west), top-layer

flood plain cells next to the Broad River, and the vertical array of cells underlying Broad River along the

northern grid boundary; these cells are specified as constant-head boundary conditions in which the

head is uniform with depth.

16

This hydraulic representation of the Broad River in the flow model is inaccurate for several reasons. First,

the river bottom is assumed to extend all the way through the unconsolidated deposits and the fractured

bedrock unit, which is not the case. Second, groundwater flow beneath and adjacent to the river is

assumed to be horizontal with zero vertical flow component. Because this boundary condition does not

allow groundwater to flow vertically in areas that underlie the river, the CAP models do not represent

actual site hydrologic conditions. Further, groundwater flow at the Cliffside site is not strictly horizontal

and, as discussed above, many of the vertical hydraulic gradient measurements (including next to the

river) are downward. Third, as represented in the CAP models, neither the lower-permeability river bed

sediments nor the smaller vertically hydraulic conductivity of underlying soils restricts the potential flow

rate into or out of the river (i.e., a perfect hydraulic connection exists between the aquifer and the Broad

River). The actual degree of aquifer-river hydraulic connection was not evaluated in the CSA. In

summary, due to all of these factors the potential for site groundwater and dissolved constituents to

migrate off-site northward beyond the Broad River or eastward as underflow beneath the river cannot be

evaluated with the model.

The CAP models should have represented the Broad River using a "leaky-type" (i.e., river) boundary

condition in the top model layer (McDonald and Harbaugh, 1988), and the model grid should have

extended farther north so that the above factors could have been evaluated during model calibration and

sensitivity analyses. In their reviews of both the CAP 1 and 2 models (submitted with the CAP modeling

appendices), the Electric Power Research Institute third-party peer review team also concluded that the

Broad River should be modeled as a leaky boundary condition instead of using constant heads. The

models also should have included groundwater extraction from the private water supply wells installed at

many points close to the river bank. A river boundary condition incorporates the bed permeability and

thickness, the river water surface elevation, and the simulated hydraulic head in the aquifer (at the base

of the river bed) to dynamically specify a flux (flow rate per unit bed area) into or out of the groundwater

model depending on the head difference between the river and aquifer. Typically, permeability and

vertical hydraulic gradient measurements for the river bed (not collected in the CSA) and flow model

calibration (three-dimensional matching of simulated and measured hydraulic head measurements in the

aquifer) are used to determine a best-fit estimate of river bed conductance (permeability divided by

thickness) in the model. HDR did not perform this routine analysis.

Limitations of No-Flow Boundary Conditions and Small Model Domain Size

The limited areal extent and depth of the CAP Parts 1 and 2 flow and transport model grids prevent the

use of the models as unbiased computational tools that can be used to evaluate off-site migration of coal-

ash constituents. For example, the model grids should have extended farther north and east to

incorporate groundwater extraction from off-site private water-supply wells and allow three-dimensional

17

groundwater flow patterns to naturally develop. The eastern and western no-flow boundaries in the

current CAP models artificially prevent any off-site flow or transport in either the bedrock or overburden

aquifers. The same is true for the entire northern and southern model boundaries despite the fact that

several private homes are located north and east of the Active Ash Basin, and the bedrock hydraulic head

map (CSA Figure 6-7) exhibits a strong easterly flow component in this area. Some additional private

water supply wells are also located close to the northern shore of the Broad River (CSA Figure 4-2).

Artificial limitations created by the northern Broad River boundary condition are outlined above.

The bottom boundaries of the CAP models should extend much deeper because the hydraulic

conductivity of the fractured bedrock zone is of the same order of magnitude as the overburden soils

based on slug test results. In the present configuration the lower boundaries of the CAP Parts 1 and 2

model grids are only about 50 feet below the bedrock surface (Figure 2 in both the CAP 1 & 2 modeling

appendices). Because several bedrock wells were screened to this depth the bedrock hydraulic

conductivity data collected for the CSA demonstrate that imposing an impermeable model boundary at

this depth is incorrect (compare similarities of mean overburden and bedrock aquifer permeabilities in

CSA Table 11-10). As discussed above, the strong downward hydraulic gradients between deep and

bedrock wells in the northern portion of the Active Ash Basin also demonstrate that vertical and horizontal

groundwater flow in bedrock is important, and these transport mechanisms need to be accurately

simulated in the CAP models in order to accurately assess the potential for off-site chemical migration.

Off-Site Groundwater Extraction Ignored

The CSA and CAP Parts 1 and 2 failed to examine the strong potential for coal-ash constituents from the

Cliffside site to migrate with groundwater to private water supply wells located immediately east and

northeast of the Active Ash Basin. COI may also potentially migrate to private wells located close to the

northern Duke Energy property boundary on the northern side of the Broad River. CSA Figure 4-2 shows

the locations of water supply wells near the site. The basis of my opinion includes the following:

hydraulic conductivity measurements for the overburden and bedrock formations; three-dimensional

variations in measured hydraulic head in the bedrock and overburden units; groundwater concentration

data; and calculations of potential hydraulic head reductions (i.e., drawdown) that could be caused by off-

site groundwater extraction. As discussed throughout my report, neither the CSA nor CAP Parts 1 or 2

investigations addressed the potential for off-site migration.

COI's were detected in several water supply well samples (CSA Appendix B), but the CSA report did not

plot these detections on a map and did not discuss their possible relationship to the Cliffside site.

Appendix B also did not present the well construction details (e.g., well diameter and elevation range of

the well screen or open bedrock interval) so that well dilution effects and potential chemical transport

pathways in the bedrock unit could be evaluated. In addition, the CSA investigations and CAP Part 1

18

modeling did not include these areas east and north of the Cliffside site. The CAP Part 2 flow model did

include a small number of residential wells (13 of the 100 neighboring private wells) located inside the

undersized model domain (east of the active ash basin), but the CAP 2 modeling report (CAP 2, Appendix

B) did not show simulated hydraulic head maps with these residential wells pumping and did not provide

any discussion or analyses of the potential for these wells to capture COI dissolved in groundwater. The

CAP Part 2 also did not increase the model grid size to incorporate the large number of residential water

supply wells located immediately north of the Broad River and downgradient from the active ash basin in

the northeastern portion of the site (CAP 2 Figure 3-3); fix the boundary condition problems; or correct

the model input data errors I have outlined so that the flow and transport models could be used to more

accurately analyze the potential for off-site chemical transport.

Another important model input data error is the bedrock hydraulic conductivity, which is assumed in the

CAP 1 and 2 flow models to be about a factor of ten (10x) lower than the overburden aquifer in different

areas (Tables 2 in CAP 1 Appendix C and CAP 2 Appendix B). The bedrock slug test results show that

the mean bedrock permeability is approximately the same as the overburden permeability. Also, in the

CAP 1 model HDR assumed that the vertical bedrock permeability [ (KBR)vert ] was the same as the

horizontal value (i.e., vertical anisotropy, Av = 1). Without justification or any field measurement of

(KBR)vert the CAP 2 model assumed Av = 10-1,000 in bedrock; at several locations the model assumes

the vertical bedrock permeability is 100 to 1,000 times smaller than the horizontal permeability. These

vertical anisotropy values are extremely large, are highly variable across the site, and do not appear to be

supported by data. By comparison, HDR assumed Av = 2 in their hydraulic modeling of bedrock slug

tests (CSA Appendix H). In an extensive hydrogeologic study and groundwater model of the Indian

Creek Basin in the southwestern Piedmont of North Carolina by the U.S. Geological Survey (Daniel et al.,

1989) a value of Av = 1 in bedrock was used by the USGS. This study is especially relevant because the

146-square-mile Indian Creek model area lies in parts of Catawba, Lincoln, and Gaston Counties, North

Carolina and is located in the general vicinity of the Cliffside site. Therefore, the CAP 1 and 2 flow

models significantly restrict (incorrectly) groundwater from flowing from the overburden aquifer into the

fractured bedrock unit, which causes the CAP transport models to underestimate the potential for off-site

chemical migration.

Model Significantly Underestimates Leakage Rate from Active Ash Basin

The CAP Part 2 flow model underestimates leachate discharge from the active ash basin by as much as

a factor of 180 in areas of ponded surface water (e.g., refer to CSA Figures 4-5 and 8-2). The CAP 1

model underestimates active basin leakage by as much as a factor of 330. As shown in Figure 5 of CAP

1, Appendix C, the CAP 1 flow model assumes a constant groundwater recharge rate (i.e., leakage rate)

equal to 6.0 inches/year in the active ash basin and all other unlined areas of the site. In the CAP 2 flow

model the active basin leakage rate is assumed to be 11 inches/year (Figure 5 of CAP 2, Appendix B).

19

However, CSA Figure 8-2 (cross-section A-A') shows that the vertical hydraulic gradient through the coal

ash in the downgradient portion of the active ash basin is on the order of unity. Using Darcy's law and the

mean vertical coal-ash permeability of 1.6E-4 cm/sec in CSA Table 11-11, the approximate vertical

leakage rate out of the active basin is about 2,000 inches/year near the Broad River (i.e., ~ 180 times

greater than the specified CAP 2 recharge rate of 11 inches/year; and ~ 330 times greater than the

specified CAP 1 recharge rate of 6 inches/year).

The CAP flow models should have represented ponded areas of the active ash basin as either constant-

head or leaky-type boundary conditions, which would have allowed the model to simulate a realistic

leakage rate for the active ash basin. The major discrepancies between the measured shallow hydraulic

head maps (CSA Figure 6-5 and CAP 2 Figure 2-2) and the CAP 1 and 2 simulated shallow head maps

(Figure 14 in CAP 1, Appendix C; Figure 15 in CAP 2, Appendix B) clearly show that the CAP flow

models significantly underestimate the hydraulic head beneath the active ash basin due to the fact that

the modeled leakage rate from the active basin is much too low.

Three related impacts of this incorrect active basin boundary condition are that the CAP models

significantly underestimate: (i) vertical groundwater flow rates (by on the order of a factor of 200) through

coal-ash source material in the vicinity of the downgradient portion of the active ash basin; (ii) horizontal

groundwater flow and chemical transport rates downgradient from the active ash basin; and (iii) vertical

flow rates from the overburden aquifer into the fractured bedrock unit beneath ponded areas. This

incorrect boundary condition representation of the active ash basin also causes the CAP models to

significantly underestimate (by on the order of a factor of two or more) both the mass loading of COI into

the Broad River and the corresponding Broad River surface water concentrations (attributable to coal ash

ponds) that HDR estimated with their mixing model (e.g., CAP 2 report Table 4-2 and Appendix D).

CAP Chemical Transport Modeling

Due to model calibration, model construction, and boundary-condition and input-data errors the CAP

models significantly underestimate remediation time frames. As discussed in this section, reasons for this

include significant underestimation of the chemical mass sorbed to soil, failure to account for slow

chemical desorption rates, inaccurate analyses of water-table lowering due to capping, and flaws in the

transport model calibration.

Soil-Water Partition Coefficients and Model Calibration

The fraction of chemical mass sorbed to soil can be represented by the soil-water partition coefficient, Kd

(Lyman et al., 1982). Kd is an especially important parameter at the Cliffside site because for most of the

20

COI the bulk of the chemical mass in the soil is associated with the solid phase (i.e., sorbed to soil grains

rather than dissolved in pore water). In effect, the solid fraction of the soil matrix acts as a large "storage

reservoir" for chemical mass when Kd is large [e.g., metals, many chlorinated solvents, and highly-

chlorinated polycyclic aromatic hydrocarbon (PAH) compounds associated with coal tars and wood-

treating fluids]. Kd is also a very important chemical transport parameter which is used to compute the

chemical retardation factor, Rd, assuming linear equilibrium partitioning of mass between the soil (solid)

and pore-water phases (Hemond and Fechner, 1994):

1 /d b d eR K nρ= +

where bρ is the soil matrix bulk dry density and ne is the effective soil porosity. For example, the

chemical migration rate is directly proportional to hydraulic conductivity and inversely proportional to Rd .

The total contaminant mass in an aquifer is also directly proportional to Rd , as well as aquifer cleanup

times once the source is removed (e.g., Zheng et al., 1991).

Accordingly, it is very important to use accurate Kd values in the CAP Closure Scenario modeling.

Specifically, the CAP Part 1 transport modeling used Kd values that were typically factors of 10 - 100 (i.e.,

one to two orders of magnitude) smaller than the measured site-specific Kd 's reported in CAP Appendix

D. In contrast, the CAP Part 2 transport modeling used Kd values that are generally a factor of about 10

larger than the CAP 1 values; however, the CAP 2 Kd 's are still on the order of 10 times smaller than the

measured site-specific Kd 's reported in CAP 1 Appendix D and CAP 2 Appendix C. Further, soil-water

partition coefficients for the CAP Parts 1 and 2 models are much smaller than most values presented in

the literature for the COI (e.g., EPRI, 1984; Baes and Sharp, 1983). This means that, using the actual

measured Kd 's for the Cliffside site, the times required to reach North Carolina water quality standards at

the Compliance Boundary are at least a factor of 10 longer (see additional discussion below) than

cleanup times predicted by the CAP Parts 1 and 2 transport models for many COI.

The CAP 1 modeling report (CAP 1 Appendix C; Section 4.8) argues that the major Kd reductions were

needed due to the following:

"The conceptual transport model specifies that COis enter the model from the shallow saturated source zones in the ash basins. When the measured Kd values are applied in the numerical model to COIs migrating from the source zones, some COIs do not reach the downgradient observation wells where they were observed in June/July 2015 at the end of the simulation period. The most appropriate method to calibrate the transport model in this case is to lower the Kd values until an acceptable agreement between measured and modeled concentrations is achieved. Thus, an effective Kd value results that likely represents the combined result of intermittent activities over the service life of the ash basin. These may include pond dredging, dewatering for dike construction, and ash grading and placement. This approach is expected to produce conservative results, as sorbed constituent mass is released and transported downgradient."

21

First, considering the approach that was used to develop the chemical transport model (history matching),

it is not true that "the most appropriate method to calibrate the transport model is to lower the Kd values."

The CAP Parts 1 and 2 transport models used an incorrect value (2.65 g/cm3) for the bulk density of

overburden materials; this value is the density of a solid mass of mineral (e.g., quartz) with zero porosity.

The bulk density should have been computed using the total porosity (n) values in CSA Table 11-1 using

the following formula (e.g., Baes and Sharp, 1983):

2.65(1 )b nρ = −

Based on the Table 11-1 values bρ ~ 1.0 - 1.9 g/cm3, which means that the Rd values for the CAP 1 and

2 models were as much as a factor of 2.65 (2.65/1.0) too high before HDR adjusted the Kd values during

calibration. Also, as discussed earlier, the overburden slug test values were about 70 percent too low

due to HDR's data analysis errors. Both of these errors (sorption rate and hydraulic conductivity) resulted

in a modeled transport rate that was up to five times (5x) too low before calibration simply due to data

input errors.

At least two other important factors were not considered during the transport model calibration. At least

two other important factors were not considered during the CAP 1 and 2 transport model calibrations.

First, the groundwater flow models are based on average hydraulic conductivity (K) values within a

material zone, but K distributions in aquifers are highly variable (e.g., varying by factors of 3-10, or more,

over distances as small as a few feet: Gelhar, 1984, 1986, 1987; Gelhar and Axness, 1983; Rehfeldt et

al., 1992; Rehfeldt and Gelhar, 1992; Molz, 2015). The Cliffside site hydrogeology certainly qualifies as

"heterogeneous". This is very important to consider for the CAP transport model calibrations because it is

the high-permeability zones and/or layers that control the time required (Ttravel ) for a constituent to reach

a downgradient observation point, and HDR used differences in observed versus simulated Ttravel (i.e.,

time to travel from sources zones to downgradient monitoring wells) as the justification for lowering

measured Kd values.

Second, the history matching that HDR performed is very sensitive to the assumed time at which the

source (i.e., coal ash) is "turned on" and to the assumed distribution of source concentrations (fixed pore

water concentrations) in source area cells. Section 5.3 of CAP 1 Appendix C explains that the source

was activated 58 years ago in the model:

"The model assumed an initial concentration of 0 within the groundwater system for all COIs at the beginning of operations approximately 58 years ago. A source term matching the pore water concentrations for each COI was applied within the Units 1-4 inactive ash basin, Unit 5 inactive ash basin, active ash basin and the ash storage area at the start of the calibration period. The source concentrations

22

were adjusted to match measured values in the downgradient monitoring wells that had exceedances of the 2L Standard for each COI in June 2015."

For several reasons it is a major simplification (and generally inaccurate) to use 2015 ash pore water

concentrations to define year-1957 source zone (fixed concentration) boundary conditions. These

reasons include: coal ash was gradually and nonuniformly distributed (spatially and temporally) in ash

basins throughout the 58-year simulation period (not instantaneously in 1957); it is very difficult (or not

possible) to accurately extrapolate geochemical or ash-water leaching conditions (i.e., predict COI pore-

water concentrations) that existed during the 2015 sampling round to conditions that may have existed in

1957 and thereafter; the actual source-area concentration distributions are highly nonuniform, but it is not

clear from the CAP modeling reports how "... source concentrations were adjusted to match measured

values ... ", or if the source area concentrations were nonuniform. All of these uncertainties are further

magnified when using history matching to calibrate a chemical transport model.

Based on the above model input errors and major uncertainties in hydraulic-conductivity variations and

source-term modeling, it is incorrect to simply reduce Kd values by factors of 10 to 100 below site

measurements (and the large database of literature Kd values) based only on the transport model "history

matching" exercises that HDR performed. My additional comments on the CAP Parts 1 and 2 transport

modeling of Closure Scenarios are listed in the following section.

Geochemical Modeling and Evaluation of Monitored Natural Attenuation

The CAP Part 2 geochemical modeling results do not include quantitative analyses of COI attenuation

rates at the Cliffside site and are only qualitative in nature. In addition, HDR did not incorporate any

source/sink (e.g., precipitation/dissolution) terms representing geochemical reaction mechanisms in the

CAP 2 chemical transport model to evaluate whether such reactions are important compared to

groundwater concentration changes caused by advection, dispersion, and soil-water partitioning. In this

regard, HDR states in Section 2.10 of CAP 2 Appendix B : "A physical-type modeling approach was

used, as site-specific geochemical conditions are not understood or characterized at the scale and extent

required for inclusion in the model." Indeed, the Electric Power Research Institute (e.g., EPRI, 1984;

page S-8) has extensively reviewed subsurface chemical attenuation mechanisms applicable to the "utility

waste environment" and concluded: (i) precipitation/dissolution has not been adequately studied; and (ii)

"Quantitative predictions of chemical attenuation rates based upon mineralogy and groundwater

composition cannot be made because only descriptive and qualitative information are available for

adsorption/desorption mechanisms."

Nonetheless, HDR performed the geochemical modeling to evaluate the technical basis for its MNA

analysis; however, any quantitative MNA analysis must compare mass transport rates and changes (e.g.,

23

grams/year per unit area normal to a groundwater pathline) in the aquifer for the various active transport

mechanisms in order to determine whether MNA is a viable alternative (e.g., produces meaningful

groundwater concentration reductions) at the Cliffside site. In Section 6.3.2 of the CAP 2 report HDR

acknowledges that these quantitative evaluations were not performed in CAP 2 and indicated that they

would need to be completed as part of a Tier III MNA assessment. Nevertheless, HDR suggested in the

CAP 2 report that COI concentrations "will" or "may" attenuate over time without completing the

necessary evaluations to reach these conclusions. HDR also states in CAP 2 Section 6.3.4 that "MNA is

an effective correction action because COIs will attenuate over time to restore groundwater quality at the

CSS site...." and in CAP 2 Section 6.3.3 that "the groundwater model did not allow for removal of COI via

co-precipitation with iron oxides, which likely resulted in an over-prediction of COI transport. Completion

of the Tier II assessment described in Appendix H has addressed this issue." I saw no quantitative

analysis or evidence in the CAP 2 report or related appendices to support these claims. In fact, the CAP

2 Appendix H emphasizes that much more geochemical data need to be collected and chemical transport

modeling with a source/sink term must be performed in a Tier III assessment to further assess whether

MNA is a viable remedial alternative.

Therefore, the CAP 2 report fails to provide any quantitative evidence supporting COI attenuation due to

co-precipitation with iron or manganese. The second component of COI attenuation evaluated in

Appendix H is chemical sorption to soil. It is important to note that, although the CAP models did not

incorporate a mechanism for co-precipitation with iron or manganese (or any COI sink term), the CAP

models did simulate attenuation due to sorption. Even with the sorption attenuation mechanism included,

CAP 2 Table 4-1 shows that for both the "existing conditions" and "cap-in-place" scenarios the following

COI will exceed North Carolina groundwater standards at the Compliance Boundary 100 years into the

future: antimony, arsenic, beryllium, boron, chromium, hexavalent chromium, cobalt, lead, sulfate,

thallium, and vanadium. Further, my Table 1 shows that groundwater standards are currently exceeded

at the Compliance Boundary for barium, cobalt, iron, manganese, nickel, and total dissolved solids (i.e.,

barium, cobalt, iron, manganese, nickel, and TDS contaminant plumes originating in the source areas

have already reached the Compliance Boundary). The conclusions of the MNA Tier I analyses (CAP 2

Appendix H, page 18) were that arsenic, barium, beryllium, boron, chromium, cobalt, lead, thallium, and

vanadium showed some evidence of attenuation and should be evaluated further in a Tier II evaluation.

However, the CAP 2 modeling results in Table 4-1 (which included a significant amount of sorption

attenuation) show that all of these COI currently exceed North Carolina groundwater standards at the

Compliance Boundary and are expected to exceed those standard 100 years into the future. All of these

data and CAP 2 modeling results strongly contradict the CAP 2 conclusion that MNA is a viable corrective

action at the Cliffside site.

24

Simulation of Closure Scenarios

As discussed below, CAP 1 Closure Scenario simulations greatly underestimate (by factors of 10 or

more) the time frames required to achieve meaningful groundwater concentration reductions in response

to remedial actions. Compared to the Cap-in-Place (CIP) remedial alternative evaluated in the CAP Part

1, the Excavation Scenario results in COI concentration reductions at the Compliance Boundary that are

generally two to ten times greater compared to Cap-in-Place and best reduces impacts to surface water.

In addition, the time frames to achieve equivalent concentration reductions are at least factors of 2 to 5 (2

- 5x) shorter for excavation compared to cap-in-place for most of the COI; further, several COI

concentrations reduce below 2L or IMAC standards with excavation but remain significantly higher than

the groundwater standards with cap-in-place.

Although the CAP 1 modeling showed that Source Excavation outperforms CIP, the CAP 2 modeling did

not simulate an Excavation closure scenario. Nonetheless, the following comparisons between CIP and

Excavation impacts on groundwater concentrations are valid for both the CAP 1 and 2 model results.

This is because the main difference with the CAP 2 transport model (compared to CAP 1) is that

concentration changes resulting from either CIP or Excavation (if it was evaluated in CAP 2) occur much

more slowly (i.e., ~ 10x slower) in the CAP 2 model due to the much larger Kd (and Rd ) values. The CAP

2 transport model also assumed uniform initial COI concentrations equal to HDR's proposed provisional

background concentrations (PPBC), even though the PPBC exaggerate background levels (see above

discussion) and there are no data to suggest that background concentrations should be spatially uniform.

Despite these changes in the CAP 1 and 2 models, the relative differences in groundwater concentrations

between the two closure scenarios remain about the same if the uniform starting (PPBC) COI

concentrations are subtracted from the simulated concentration versus time curves. For these reasons

the following discussions focus on the CAP 1 modeling results.

Source Concentrations for Cap-in-Place Scenario

In this scenario the CAP 1 flow model predicts cap-induced water-table declines equal to approximately 5

feet (relative to the Existing Conditions simulation) within the Units 1-4 inactive ash basins, 12 feet within

the Unit 5 inactive ash basin (11 feet in the CAP 2 flow modeling), and 10 feet within the active ash basin

(10 feet in CAP 2). However, the geologic cross-sections presented in the CSA show that the saturated

coal ash thickness at several borings is as great as 30-60 feet. This means that under the simulated

Cap-In-Place Scenario most of the coal ash, which is the source of dissolved COI, would remain

saturated and continue to leach constituents into groundwater in several parts of the ash basin system.

The CAP 1 simulations ignored this fact and set all source concentrations equal to zero (i.e., assumed all

coal ash was dewatered). Therefore, the simulated Cap-in-Place concentrations should be much higher

than the values presented in the CAP Part 1.

25

The groundwater flow model simulations also exaggerate the hydraulic effects of the cap (i.e., overstates

water table lowering) because the no-flow boundary conditions along the entire western, southern, and

eastern grid boundaries prevent flow into the Ash Basin System when the laterally inward hydraulic

gradients are created by capping. In addition, the base of the flow model is assumed to be impervious

even though the bedrock aquifer hydraulic conductivity is about the same as the overburden aquifer; this

artificially restricts upward flow from bedrock into the capped area and exaggerates predicted water table

lowering.

In addition, a site-specific distribution of groundwater recharge values should have been developed for

this and the other simulation scenarios to take into account site-specific topography and soil types (e.g.,

runoff estimation) and climate data (precipitation, evapotranspiration, etc.; e.g., using the U.S. Army

Corps of Engineers HELP Model; Schroeder et al., 1994). The CAP 1 flow model uses an assumed

value of 6 inches year uniformly throughout the model domain even though the actual value is highly

variable across the Ash Basin System and site land surface. Further, as discussed above, HDR should

have used a leaky-type boundary condition to model ponded areas of the active ash basin. The predicted

water table lowering due to capping is very sensitive to the model recharge value, so more effort should

have been made to develop a site-specific recharge-rate distribution.

Slow and Multirate Nonequilibrium Desorption of COI

Since the 1980's the groundwater industry has learned how difficult it is to achieve water quality

standards at remediation sites without using robust corrective actions such as source removal (Hadley

and Newell, 2012, 2014; Siegel, 2014). Two of the key reasons for this in aqueous-phase contaminated

soil are inherently low groundwater or remediation fluid flushing rates in low-permeability zones and slow,

nonequilibrium chemical desorption from the soil matrix (Culver et al., 1997, 2000; Zheng et al., 2010). A

good example of this is the "tailing effect" (i.e., very slow concentration reduction with time) that is

commonly observed with pump-and-treat, hydraulic containment systems. These factors are also related

to the "rebound effect" in which groundwater concentrations sometimes increase shortly after a

remediation system is turned off (Sudicky and Illman, 2011; Hadley and Newell, 2014; Culver et al.,

1997).

The CAP 1 and 2 flow models use different permeability (K) zones, but the scale of these zones is very

large and within each zone K is homogeneous even though large hydraulic conductivity variations (e.g.,

lognormal distribution) are known to exist at any field site over relatively small length scales (Molz, 2015).

Moreover, the CAP transport models assume linear, equilibrium soil-water partitioning which corresponds

to instantaneous COI release into flowing groundwater. The transport code (MT3D) has the capability of

simulating single-rate nonequilibrium sorption, but the Close Scenario simulations did not utilize this

modeling feature. Slow desorption of COI can also be expected at the Allen site because sorption rates

26

are generally highly variable, and multi-rate (Culver et al., 1997, 2000; Zheng et al., 2010), and Kd

values are nonuniform spatially (Baes and Sharp, 1983; EPRI, 1984; De Wit et al., 1995). The CAP flow

and transport models can be expected to significantly underestimate cleanup times required to meet

groundwater standards at the compliance boundary because they do not incorporate these important

physical mechanisms.

Adequacy of the Kd Model for Transport Simulation

The laboratory column experiment effluent data (e.g., CAP 1 Appendix D) generally gave very poor

matches with the analytical (one-dimensional) transport model used to compute Kd values. Since the

CAP transport model solves the same governing equations in three dimensions, the adequacy of the Kd

modeling approach for long-term remedial simulations should have been evaluated in much more detail in

the modeling appendix.

The transport modeling also did not evaluate alternative nonlinear sorption models such as the Freundlich

and Langmuir isotherms (Hemond and Fechner, 1994), which are input options in the MT3D transport

code. Several of the batch equilibrium sorption experiments (CAP 1 Appendix D) exhibited nonlinear

behavior, and such behavior is commonly observed in other studies (e.g., EPRI, 1984). However, HDR

only computed linear sorption coefficients (i.e., Kd) for the Cliffside site in CAP Part 1. In CAP Part 2 HDR

did fit Freundlich isotherms to the batch sorption data for selected COI (CAP 2 Appendix C, Tables 1-8)

but did not use these Freundlich isotherm results in the CAP 2 transport modeling. De Wit et al. (1995)

showed that the nonlinear sorption mechanism is similar in importance to aquifer heterogeneities in

extending remediation time frames.

Closure Scenario Time Frames

As outlined in my report, the CAP Part 1 chemical transport model underestimates the time intervals

required to achieve groundwater concentration reductions (i.e., achieve groundwater quality restoration)

by factors that are at least on the order of 10 to 100. In other words, the CAP 1 transport model

significantly overestimates the rate at which concentrations may reduce in response to remedial actions

such as capping or source removal. This is due to several factors, including major errors in model input

data, model calibration mistakes, field data analysis errors, and oversimplified model representation of

field conditions (e.g., hydraulic conductivity) and transport mechanisms (e.g., chemical

sorption/desorption). These limitations of transport models for realistically predicting cleanup times have

been recognized by the groundwater industry for the past few decades based on hands-on experience at

hundreds of extensively-monitored remediation sites.

Even if we ignore the factors of 10 or more errors in cleanup time predictions with the CAP 1 model, the

remediation time frames for the Excavation Scenarios are still more than two centuries for several

27

constituents due to slow groundwater flushing rates from secondary sources (surrounding residual soil)

left in place after excavation and due to high chemical retardation factors for most of the COI. However,

excavation of secondary-source material would further accelerate cleanup rates under this alternative.

The CAP 1 simulated Cap-In-Place concentration reduction rates are much slower, compared to

excavation, but are also incorrect (i.e., overestimated) because the cap-induced water-table lowering is

insufficient to dewater all of the source-area coal ash, as discussed above, and the CAP 1 and 2 flow

models overestimate cap-induced water-table lowering due to boundary condition errors. Furthermore,

these simulation times are well beyond the prediction capabilities of any chemical transport model for a

complex field site (especially one that is as geochemically complex as the Cliffside site). The historical

model-calibration dataset (1957-2015) is also significantly smaller than the predictive (remediation) time

frames. In addition, the "history matching" technique used to calibrate the transport model (e.g., major

reduction in measured Kd values) was not performed correctly by HDR.

Cap-In-Place versus Excavation Closure Scenarios

Although the the CAP 1 model underestimates remediation time frames, the CAP 1 Closure Scenario

simulations demonstrate several significant advantages of excavation for restoring site groundwater

quality versus cap-in-place. First, predicted COI concentration reductions in groundwater downgradient

from the ash basin system are generally factors of 2-10 greater with excavation compared to cap-in-place

(e.g., refer to most of the simulated concentration versus time curves in CAP 1 Appendix C). Further, if

HDR had correctly performed the CAP 1 cap-in-place simulations the predicted CIP concentrations would

be much higher because predicted water-table lowering due to the cap would be insufficient to dewater all

of the coal ash. Second, North Carolina 2L or IMAC standards for many COI (antimony, arsenic,

chromium, hexavalent chromium, cobalt, nickel, thallium, vanadium) are not achieved by cap-in-place but

are achieved by excavation (e.g., CAP 1 Appendix C Figures 13, 20, 21, 26, 27, 28, 29, 30, 31, 33, 34,

36, 37, and 39). Third, the time frames to achieve equivalent concentration reductions are at least factors

of 2 to 5 shorter for excavation compared to cap-in-place; further, several COI concentrations reduce

below 2L or IMAC standards with excavation but remain significantly higher than the groundwater

standards with cap-in-place.

Even though the CAP 1 modeling demonstrated that the CIP closure alternative would be much less

effective than excavation, and that CIP would only dewater about 20-40 percent of the saturated coal-ash

thickness in many areas, HDR eliminated excavation from consideration in CAP 2. In Section 7.1 of the

CAP 2 report HDR assumes that "Evaluation of the geochemical modeling indicated COIs are attenuated

by a combination of sorption and/or precipitation" and that "Based on review of the groundwater modeling

results, COIs with sorption coefficients similar to or greater than arsenic are immobilized by sorption

and/or precipitation .....". As discussed above, HDR provided no quantitative analysis or evidence in the

CAP 2 report or related appendices to support this claim. Further, sorption is not a mechanism that

28

"immobilizes" a dissolved consituent; sorption only slows down the rate of transport proportional the

chemical retardation factor. Considering that up to 80 percent of the coal-ash source material would

remain saturated with CIP and that multiple exceedances of groundwater standards at the Compliance

Boundary currently exist (with no historical data to indicate that these Compliance Boundary

concentrations are decreasing with time), it is not reasonable to make sweeping assumptions about future

concentration changes. Tier III MNA analyses require rigorous quantitative evaluations using the CAP

transport model with a source/sink term that incorporates geochemical reactions to support MNA as a

viable corrective action. CAP 2 did not provide this information.

As discussed above, the CAP Part 2 flow model did include a small number of residential wells (13 of the

100 neighboring private wells), but the CAP 2 modeling report (CAP 2, Appendix B) did not show

simulated hydraulic head maps with these residential wells pumping and did not provide any discussion

or analyses of the long-term potential for these wells to capture COI dissolved in groundwater. Further,

the private bedrock wells that HDR chose to include in the CAP 2 model appear to be located upgradient

from the active ash basin; HDR should have included all of the private wells located near the northern

bank of the Broad River (in a downgradient direction from the ash basin system) and near the

northeastern site boundary which is downgradient from the active ash basin, as I describe above. In CAP

2 section 4.1.5 HDR discusses that fact that the CAP 2 flow model was used to compute 1-year, reverse

particle pathlines for these bedrock residential wells (Figure 18 in CAP 2 Appendix B) to determine their

short-term groundwater capture zones. However, the residential well reverse pathline tracing should

have been performed for a much longer time period (e.g., from the beginning of coal ash disposal to the

present) to evaluate whether COI may have migrated from source areas to these wells. In addition, if

HDR had extended the CAP 2 model grid much farther to the north and east the capture zones for the

remaining 87 private water supply wells could have been determined, as I discuss earlier in my report.

The CAP Closure Scenarios do not include hydraulic containment remedial alternatives (e.g., gradient

reversal) for the bedrock aquifer that would address the risk of off-site COI transport. As discussed

above, the CSA data show many exceedances of groundwater standards in bedrock not only at the

compliance boundary but also inside the CB. In addition, strong downward groundwater flow components

from the deep overburden to bedrock aquifers were measured during the CSA at multiple locations

across the site, including the southern shoreline of the Broad River. The cap-in-place alternative does not

address either concentration reduction or off-site chemical migration control in the fractured bedrock

aquifer.

The CAP Parts 1 and 2 do not assess whether water quality standards will be achieved in the tributaries

and wetlands between the ash basins and the Broad River [e.g., seep locations S-3 or S-6 (Broad River

tributaries) or the wetland located along Suck Creek downgradient from the upstream dam of the active

29

ash basin] under any closure scenario. As discussed above, for the cap-in-place scenario a significant

fraction of the source material will remain saturated and dissolved COI will continue to migrate with

groundwater toward these seep locations. Although unaddressed by the model, COI concentration

decreases in groundwater and unsaturated zone pore water due to source removal would also reduce

impacts to tributaries and wetlands that are influenced by the ash basins.

Conclusions

Based on my technical review and analyses of the referenced information for the Cliffside site I have

reached the following conclusions:

• A total of 62 Compliance Boundary groundwater samples exceeded North Carolina groundwater

standards for these COI: antimony, boron, chromium, cobalt, iron, manganese, sulfate, total

dissolved solids, and vanadium. Of these 62 exceedances, 36 were greater than the proposed

provisional background concentrations by HDR;

• The statistical analyses of shallow background groundwater concentrations at the Cliffside site

(well MW-24D) are invalid. The time periods between groundwater sample collection from this

well are too small and the concentration data are not independent;

• There is a significant risk of chemical migration from the ash basin to neighboring private water

supply wells in fractured bedrock. The design of the CAP flow and transport models prevents the

potential for off-site migration from being evaluated;

• The limited CAP model domain size; the no-flow boundary conditions along the western,

southern, and eastern boundaries; and incorrect hydraulic boundary condition representations of

the Broad River and the active ash basin prevent simulation and analysis of off-site COI

migration;

• The CAP Closure Scenario simulations greatly underestimate (by factors of 10 or more) the time

frames required to achieve meaningful groundwater concentration reductions in response to

remedial actions. This is due to oversimplification of field fate and transport mechanisms in the

CAP model and several model input errors;

• The simulated water table lowering for the Cap-in-Place Scenario is more than a factor of five too

small at several locations in the ash basin system in order to dewater all source material; and the

actual cap-induced water table elevation reduction would be much less than predicted due to the

incorrect no-flow boundary conditions. Therefore, the remediation time frames for this scenario

would be much greater because a large percentage of the source zone would still be active with

the cap installed;

30

• For either the Existing Condition or Cap-in-Place Model Scenario groundwater concentrations of

coal-ash constituents much higher than background levels will continue to exceed North Carolina

groundwater standards at the Compliance Boundary because saturated coal-ash material and

secondary sources will remain in place;

• Due to an incorrect boundary-condition representation of the active ash basin, the CAP models

underestimate by a factor of two or more both the mass loading of COI into the Broad River and

the corresponding Broad River water concentrations (attributable to coal ash ponds) estimated by

the groundwater/surface-water mixing model;

• Source-area mass removal included in the Excavation Scenario results in COI concentration

reductions at the Compliance Boundary that are generally two to ten (2 - 10x) times greater

compared to Cap-in-Place and best reduces impacts to surface water. In addition, the time

frames to achieve equivalent concentration reductions are factors of two to five (2 - 5x) shorter for

excavation compared to cap-in-place, and source removal reduces the number of COI that will

exceed North Carolina groundwater standards in the future. Additional excavation of secondary

sources would further accelerate concentration reductions;

• The CAP simulations show that source excavation reduces groundwater concentrations for many

COI below North Carolina groundwater standards (antimony, arsenic, chromium, hexavalent

chromium, cobalt, nickel, thallium, vanadium), but cap-in-place closure does not;

• The CAP Part 2 geochemical modeling and monitored natural attenuation (MNA) evaluations do

not provide the required quantitative analyses (e.g., numerical transport modeling) of COI

attenuation rates necessary to support MNA as a viable corrective action and are only qualitative

in nature. The CAP 2 chemical transport modeling, which included attenuation by sorption,

demonstrated that MNA is not an effective remedial option for several COI (e.g., antimony,

arsenic, beryllium, boron, chromium, hexavalent chromium, cobalt, lead, sulfate, thallium, and

vanadium);

• The CAP Closure Scenarios do not include hydraulic containment remedial alternatives for the

bedrock aquifer and do not address the risk of off-site COI transport. CSA data show multiple

exceedances of groundwater standards in bedrock not only at the compliance boundary but also

inside the CB. The cap-in-place alternative does not address either concentration reduction or

off-site chemical migration control in the fractured bedrock aquifer; and

• Future Compliance Monitoring at the site should include much more closely-spaced Compliance

Wells to provide more accurate detection, and the time intervals between sample collection

should be large enough to ensure that the groundwater sample data are statistically independent

to allow accurate interpretation of concentration trends.

31

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DOUGLAS J. COSLER, Ph.D., P.E. 10240 Stonemede Lane 704-246-7702 Matthews, NC 28105 dcosler@adaptivegroundwater.com EDUCATION

Ph.D. Chemical Hydrogeology The Ohio State University 2006 C.E.D. Civil Engineer Degree Massachusetts Institute of Technology 1987 M.S. Civil & Environmental Engineering The Ohio State University 1979

B.S. Civil & Environmental Engineering The Ohio State University 1977 Summa Cum Laude

PROFESSIONAL HISTORY

2009- Principal Hydrogeologist and Commercial Software Developer,

Adaptive Groundwater Solutions LLC, Charlotte, NC 2007-2009 Environmental Consultant, Hart Crowser, Portland, OR 2006-2007 Research Scientist and Instructor, School of Earth Sciences, The Ohio State University,

Columbus, OH 2003-2006 Research Assistant, School of Earth Sciences, The Ohio State University, Columbus, OH 1987-2003 Environmental Consultant, MACTEC (now AMEC), Nashua, NH 1984-1987 Research Assistant, Department of Civil & Environmental Engineering,

Massachusetts Institute of Technology, Cambridge, MA 1979-1984 Environmental Consultant, D'Appolonia Consulting Engineers, Pittsburgh, PA 1977-1979 Research Assistant, Department of Civil & Environmental Engineering,

The Ohio State University, Columbus, OH

REGISTRATION Registered Professional Engineer: Pennsylvania and Vermont HONORS AND AWARDS

Member of Tau Beta Pi University Graduate Fellowship, The Ohio State University, 1979 The Brown Scholarship (top undergraduate in Civil Engineering), The Ohio State University, 1977

PROFESSIONAL EXPERIENCE

Environmental Consulting 1979-1984, 1987-2003, 2007-present • Areas of Specialization: Groundwater flow and chemical transport analyses and computer modeling,

contaminant fate and transport in the environment, numerical code development, ground water and surface water hydraulics and hydrology, contaminant fate and transport, expert witness testimony and litigation support, hydrogeologic investigation, nonaqueous phase liquid (LNAPL/DNAPL)

Douglas J. Cosler, Ph.D., P.E. - Page 2 of 15

investigation, subsurface remediation and remedial design, natural attenuation and risk assessment, and hydrologic and wetlands impact evaluation.

• Responsibilities: Principal Hydrogeologist/Hydrologist responsible for technical aspects of a wide

variety of projects, including: investigation, remediation, and regulation of Superfund, RCRA, and other hazardous waste sites; ground water flow and chemical transport model development for numerous projects; expert witness testimony and litigation support for several clients and hazardous waste sites; natural attenuation/biodegradation assessments for chlorinated solvent and petroleum contamination sites; volatile organic compound vapor (soil gas) migration and exposure assessment; exposure modeling for health risk assessments; hydraulic and hydrologic modeling of impoundments and spillways for U.S. Army Corps of Engineers dam safety assessments; stream hydraulics and solute transport modeling; hydrologic impact assessment for minerals and coal mining; leachate collection system modeling and design for waste disposal impoundments; and design of runoff, sedimentation, and erosion control plans.

• Types of Sites and Contaminants: Sites investigated include: landfills, manufactured gas plants, wood-

treating facilities, chemical plants, water supply well fields, gasoline and fuel oil storage/delivery facilities, nuclear waste disposal sites, hazardous waste incinerators, mining operations, and various industrial facilities. Investigated dissolved, nonaqueous-phase (LNAPL/DNAPL), and vapor-phase contaminants: chlorinated solvents, gasoline and fuel oil constituents, wood-treating products (e.g., creosote and pentachlorophenol), coal tars, polychlorinated biphenyls, pesticides, dioxins and furans, phenolic compounds, flame retardants (PBDE), phthalates, radionuclides, biological constituents, and various metals.

• Representative Project Experience:

Expert Witness Testimony and Litigation Support

Litigation and Expert Witness Support, Wells G&H Superfund Site, Woburn, MA (MACTEC). Doug provided technical support for property owners involved in litigation related to economic damages associated with groundwater contamination in a fractured bedrock aquifer resulting from upgradient sources of chlorinated solvents (DNAPL and aqueous-phase). He completed a thorough review of RI/FS technical reports (including groundwater pumping tests) and performed modeling of chemical transport in the fractured bedrock aquifer that accounted for the effects of horizontal anisotropy on transport directions. Based on the evaluations, Doug developed an alternative site conceptual model that incorporated the effects of bedrock fractures on solute transport in order to define probable contaminant migration pathways in overburden and bedrock aquifers that were not identified in historical documents. He demonstrated the existence of these pathways using two-dimensional models of groundwater flow and contaminant advection (particle pathlines) that established a connection between DNAPL sources areas and groundwater contamination beneath the subject properties.

Expert Witness Testimony and Litigation Support, Gasoline Remediation Site and Sewer/House Explosion Case, Winneconne, WI (MACTEC). Doug provided expert witness testimony and investigated the potential causes of and chemical fate and transport mechanisms responsible for a house explosion case. Plaintiffs alleged that vadose and saturated zone petroleum remediation activities at a service station located a few blocks from the residence and subsequent transport of gasoline vapors through a sewer line/backfill were the fuel source for the explosion. He analyzed gasoline vapor transport rates and concentrations in the

Douglas J. Cosler, Ph.D., P.E. - Page 3 of 15

subsurface at the service station site, in the 12-inch sewer pipe, and within the sewer backfill. Doug demonstrated that gasoline vapors could not have migrated to the residence between the time that remediation stopped and the house exploded. He also demonstrated that gasoline vapors at explosive levels could not have migrated up the sewer lateral and into the house. His analyses showed that sewer gas (methane) was the likely cause of the explosion because a methane source was present in the sewer line near the residence (sewage blockage due to tree root growth through pipe joints) and lighter-than-air methane naturally migrates upslope along sewer lines and laterals.

Remedial Investigation and Feasibility Study (RI/FS) and Expert Witness Testimony for the Old Southington Landfill Superfund Project, Southington, CT (MACTEC). Doug developed a three-dimensional groundwater flow model (MODFLOW) to evaluate source control alternatives for a municipal landfill that received solid and semi-solid waste materials (primarily VOC). In the vicinity of the landfill, high-permeability deposits in the bottom portion of the aquifer and the presence of a neighboring pond caused large downward groundwater flow components that complicated contaminant transport analysis. He directed the site investigation that focused on the landfill and underlying and downgradient portions of the regional aquifer. He prepared an expert report and provided expert witness testimony for insurance litigation regarding the nature and timing of waste disposal in the landfill.

Expert Witness Testimony, Hydrogeologic Investigations of a Gasoline Station, CT (MACTEC). Doug provided expert witness testimony regarding the results of a hydrogeologic investigation to determine the source of petroleum contamination within a telephone company utility conduit. He provided opinions concerning groundwater flow and chemical transport rates in the surrounding aquifer, age dating of petroleum products, and the potential relationship of gasoline-related contaminants in a utility manhole to historical petroleum releases at an upgradient gasoline station.

Remedial Investigation, Site Remediation and Expert Witness Testimony, Former MGP Site, Concord, NH (MACTEC). Historical discharges of carburetted water gas tar contaminated a 10-acre pond and the underlying groundwater with aqueous-phase constituents and NAPL. Contaminants included PAHs and BTEX compounds. Doug designed the hydrogeologic investigation to determine the nature and extent of groundwater and NAPL contamination. He performed data evaluations to assess the potential for vertical and horizontal migration of NAPL and the potential for contamination of a river adjacent to the site. He also prepared two expert reports and provided expert witness testimony for two related insurance litigation actions regarding the timing and ongoing nature of pond contamination and contamination from the former MGP, located upgradient from the pond.

Remedial Design Evaluation and Expert Witness Support, Chlorinated Solvent and Petroleum Contamination Site, MO (MACTEC). Doug served as a company expert for litigation involving a groundwater extraction system designed to control LNAPL and aqueous-phase contaminants. Plaintiffs (downgradient property) claimed that the extraction system was not controlling contamination. Doug developed a hydraulic model of the site, analyzed in detail the groundwater capture zone, and demonstrated that the system was very effective in controlling LNAPL and aqueous-phase contaminant migration.

Douglas J. Cosler, Ph.D., P.E. - Page 4 of 15

Expert Witness Testimony, Petroleum Contamination Site, Concord, NH (MACTEC). Doug served as a hydrogeology, coal tar, and petroleum fate and transport expert for property damage litigation involving a fuel oil distributor and former MGP site. The plaintiff claimed that coal tar contamination from the former MGP caused environmental damage and increased construction costs for a new hotel being built at the site. Doug performed petroleum transport and fingerprinting analyses and demonstrated that the fuel oil distributor located immediately upgradient from the subject property was the likely source of contamination - not coal tar.

Remedial Investigation, Design, and Expert Witness Testimony, Former MGP Site, Laconia, NH (MACTEC). Doug reviewed site investigation reports and evaluated hydrogeologic conditions, contaminant sources, and NAPL mobility at a former MGP site. Historical MGP waste releases (coal tar) had contaminated soil and groundwater and dissolved-phase constituents, and NAPL had migrated into adjacent surface water bodies. He developed conceptual remedial alternatives for the site and evaluated NAPL containment and collection designs. He prepared an expert report and provided expert witness testimony for insurance litigation regarding the timing and ongoing nature of pond contamination.

Expert Witness Report, Former MGP Site, Goshen, IN (MACTEC). Provided litigation support and expert report preparation for a case involving a former MGP site. Technical aspects of the project involved hydrogeology, coal tar, and petroleum fate and transport.

Remedial Alternatives Evaluation and Expert Witness Report Preparation, Former Electronics Manufacturing Facility, Manchester, NH (MACTEC). Historical releases of tetrachloroethene (PCE) and PCE dissolved in fuel oil caused soil and groundwater contamination at the site. Contaminants were present as dissolved-phase constituents and DNAPL. Doug evaluated data regarding site hydrogeology and contaminant fate and transport to assess the relative contributions of the PCE sources. He evaluated the feasibility and costs of potential remedial alternatives and prepared an expert report assessing the relative contributions of the two different sources of contamination.

Groundwater Flow and Aqueous-Phase Chemical Fate and Transport

Developed Adaptive Groundwater, a Three-Dimensional Groundwater Flow and Chemical Transport Code based on the Adaptive Mesh Refinement Method (Adaptive Groundwater Solutions LLC). Adaptive Groundwater is a highly-scalable, three-dimensional numerical code for high-resolution simulation of groundwater flow and solute transport problems. Dynamic adaptive mesh refinement (AMR) and multi-threading are used to automatically generate unstructured grids to handle multiple scales of flow and transport processes. This is done by translating and adding/ removing telescoping levels of progressively finer subgrids during simulation (https://www.rockware.com/product/overview.php?id=329).

Groundwater Flow, Contaminant Transport, and Biodegradation Model, Feasibility Study and Natural Attenuation Assessment, Estes Landfill Site, Phoenix, AZ (MACTEC). Doug developed three-dimensional groundwater flow and contaminant transport models to simulate current and future, long-term TCE, cis 1,2-DCE, and vinyl chloride (VC) concentrations in the sand and gravel, overburden aquifer at the Estes Landfill site. He used MODFLOW and MT3D99 to simulate chemical transport and fate mechanisms,

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including advection, dispersion, dilution by surface water, sorption to soil, and TCE>DCE>VC biotransformation modeled as a sequential, first-order decay-chain process. He computed site biotransformation rates from historical chemical data and transport model calibration. He demonstrated that natural attenuation was a viable remedial alternative, primarily due to significant source-area VOC depletion and high biodegradation rates (reductive dechlorination and direct oxidation of DCE and VC).

Combined MTCA RI/FS and RCRA RFI/CMS Plus Independent Cleanup Actions, Confidential Metals Manufacturing Facility, WA (Hart Crowser). As the Hydrogeologist and Technical Lead for PCB fate and transport issues during work on this large metals manufacturing facility, Doug developed a three-dimensional transport model of the PCB plume that incorporated the variation in mobility and mass fraction of each of the 209 congeners in the PCB mixture. He constructed a three-dimensional groundwater flow/transport model (MODFLOW/MT3D99) to analyze the capture zones and effluent concentration variations for multiple extraction wells with various screened-interval depths. He investigated PCB contamination sources at the site, including industrial wastewater transfer line leaks and unsaturated/saturated zone water contact with contaminated soils.

Doug also developed an innovative two-dimensional, rate-limited PCB congener and colloid transport model to evaluate fate and transport mechanisms at the site. The model simulates the transport of all 209 PCB congeners simultaneously, both as aqueous-phase (i.e., dissolved in groundwater) and colloidal (sorbed to mobile colloids flowing with the groundwater) fractions. Colloid filtration due to interactions with the porous media is included. Because of the high groundwater velocities at the site, the model also incorporates rate-limited soil to groundwater chemical partitioning (nonequilibrium chemical sorption) and nonequilibrium groundwater to colloid PCB sorption mechanisms.

Remedial Design and Natural Attenuation Modeling, Savage Municipal Water Supply Superfund Site, Milford, NH (MACTEC). Doug developed three-dimensional groundwater flow and solute transport models of this extensive drinking water aquifer using MODFLOW and MT3D. DNAPL releases (PCE and TCA) caused groundwater contamination. Doug directed evaluation of data collected during field permeability testing, monitoring well sampling, and extensive vertical groundwater profiling using microwells. He modeled the effectiveness of various remedial design alternatives that included soil excavation and hydraulic containment in the source area, hydraulic control of downgradient portions of the PCE and TCA plumes, and natural attenuation due to biodegradation, natural groundwater flushing, and dilution by rainwater and river recharge. Doug estimated biodegradation rates using 1) long-term measurements of VOC concentration reductions along the plume centerline, 2) comparisons of parent to daughter compound concentrations, and 3) computations of total VOC mass reductions in the aquifer. In addition, the natural attenuation evaluation used other analytical parameters (e.g., electron acceptor concentrations) to assess the strength of the biodegradation evidence based on the Technical Protocol for Natural Attenuation of Chlorinated Aliphatic Hydrocarbons in Ground Water. He used the MODFLOW model and the AQTESOLV software to analyze the pumping test data. He used AQTESOLV and the Hantush solution for partially-penetrating wells to analyze the single-well tests.

Natural Attenuation Software Development, Risk-Based Correction Action (RBCA) Tier 2 Analyzer (MACTEC). Doug authored the commercial software package RBCA Tier 2 Analyzer, a two-dimensional

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groundwater flow and biodegradation (transport) model. The software provides five different transport simulation capabilities: 1) single constituent; 2) the PCE>TCE>DCE>VC sequential-decay sequence that occurs during reductive dechlorination; 3) instantaneous BTEX biodegradation with a single electron acceptor (oxygen); 4) instantaneous BTEX biodegradation with multiple electron acceptors (oxygen, nitrate, iron(III), sulfate, carbon dioxide); and 5) kinetics-limited BTEX biodegradation with multiple electron acceptors. The transport model can simulate either equilibrium or non-equilibrium (one-, two-, or multi-site sorption) partitioning between water and soil. The software provides a design tool that can be used for a wide variety of problems, including the analysis of remedial alternatives such as groundwater pump and treat systems (including extraction well concentration “tailing” effects caused by slow contaminant desorption from soil), natural attenuation evaluation, and source remediation level determination.

Remedial Investigation and Feasibility Study (RI/FS) for the Gallups Quarry Superfund Site, Plainfield, CT (MACTEC). Designed investigations of this former waste disposal site to evaluate the nature and extent of groundwater and residual soil (source area) contamination. The initial field program included geophysical surveys, a source-area soil vapor survey, installation and sampling of 50 microwells, wetlands delineation, and surface water/sediment sampling. Doug performed three-dimensional computer visualization of the contaminant plume based on microwell results to direct monitoring well installation. He performed two-dimensional flow modeling to identify an off-site source of groundwater contamination and developed a three-dimensional groundwater flow and chemical transport model (MODFLOW/MT3D) of the site to facilitate the evaluation of remedial alternatives during the FS process.

Darling Hill Superfund Site Remedial Investigation and Feasibility Study (RI/FS), Lyndonville, VT (MACTEC). As Technical Leader during the RI/FS for a municipal well field contaminated with VOCs, Doug directed the site investigation, which focused on a disposal area upgradient of the well field and a highly permeable sand and gravel aquifer. The investigation included geophysical investigations, a soil gas survey, boring and well installations, groundwater sampling and analysis, air sampling, surface water and sediment sampling, and pumping and slug tests. Doug developed a three-dimensional analytical groundwater flow model to evaluate potential plume control at the disposal area and the municipal well field. He also constructed a one-dimensional, numerical contaminant transport model, coupled with a chemical leaching model of the waste disposal area, to estimate cleanup times in the regional aquifer in response to various source control alternatives.

Evaluation of New Monitoring Well Design and Sampling Techniques to Determine Vertical Concentration Variations in an Aquifer, Independent Research Project (MACTEC). Performed independent research to determine new monitoring well designs and sampling techniques that can provide the necessary data to evaluate vertical concentration variations in an aquifer. Doug developed two-dimensional, numerical axisymmetric groundwater flow and chemical transport models to analyze time-dependent monitoring well concentrations during sampling as a function of various vertical concentration distributions in the aquifer and different well designs. The results of this research demonstrated that discrete intervals of monitoring wells with long screens (e.g., 10 to 20 feet or more) can be sampled in a manner that allows both the vertical plume location and concentration variation in the aquifer to be determined. The research also showed that the time vs. concentration responses of a well during a sampling event lasting a few days

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exhibit characteristic shapes that can be directly related to aquifer properties and well design parameters and the vertical concentration distribution. He computed a series of concentration vs. time "type curves," analogous to time-drawdown type curves for aquifer permeability tests, that can be matched with measured time-concentration responses.

Evaluation and Recommendation of Hydrologic Models for the Department of Natural Resources, Commonwealth of Kentucky (D’Appolonia). Doug performed an extensive analysis of hydraulic/hydrologic simulation models for the Department of Natural Resources, Commonwealth of Kentucky. He evaluated more than 60 hydrologic (i.e., watershed), surface water, and groundwater computer models for simulating flow and contaminant transport that could be used in determining the potential hydrologic and environmental impacts of coal mining operations at various locations in Kentucky. He made several code modifications to the USACE’s STORM, Stream Hydraulics Package (SHP), and Water Quality for River/Reservoir Systems (WQRRS) models.

Mine Inflow Evaluation for the Shell Minerals Company, IN (D’Appolonia). To evaluate groundwater inflow rates into a 30-square mile underground coal mine in southwestern Indiana during a 30-year mine life, Doug developed a three-dimensional computer model to simulate groundwater flow into various mine panels from an overlying sandstone aquifer by three processes: (1) artesian flow from portions of the aquifer outside of the mine plan area, (2) gravity drainage of water from the voids in the overlying sandstone, and (3) infiltration through a shale layer separating the aquifer and coal seam.

Site Investigation and Hydrogeologic Study, Massachusetts Contingency Plan (MCP), Manufacturing Facility (MACTEC). Designed an investigation to characterize the nature and extent of VOC contamination in a shallow overburden-bedrock aquifer system underlying a manufacturing facility. The investigation included soil vapor analysis, overburden and bedrock monitoring well installation, and permeability testing. Doug designed an interim pump and treat system to control contaminant migration from a source area containing PCE in the form of a NAPL.

Hydrogeologic Study and Groundwater Remediation for an Industrial Facility, NH (MACTEC). Served as the Technical Leader during the Phase I investigation and performed data evaluation for this 70-acre salvage yard site. The investigation included evaluation of VOC contamination in the groundwater and the design, installation, and operation of a pump and treat system. Doug developed a two-dimensional, axisymmetric groundwater flow model to evaluate the data from a pumping test involving a large-diameter, partially penetrating water supply well. He performed groundwater flow modeling for the final engineering design of the pump and treat system.

Design of Waste Disposal Facility for the U.S. Department of Energy, WV (D’Appolonia). Doug designed the leachate collection system for a waste disposal facility that contained process waste from a proposed solvent-refined coal preparation plant near Morgantown, West Virginia. The 800-acre-foot impoundment consisted of two embankments approximately 60 feet in height constructed from coarse refuse, a primary spillway system, a 5-foot clay liner beneath the impoundment, and an underdrain system directly above the liner to reduce the liquid content of the waste and thereby decrease seepage of contaminants through the clay blanket. He performed a detailed computer simulation of the underdrain system performance to

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determine the hydrostatic pressure reduction above the clay liner as a function of waste permeability, drain spacing, ground slope, saturated waste depth, and drain dimensions.

Remedial Investigation/Feasibility Study (RI/FS) for Allied Chemical Company, OH (D’Appolonia). Doug performed a groundwater contamination evaluation and remedial design study for a chemical plant bordering the Ohio River. He developed two-dimensional groundwater flow and chemical transport models to evaluate migration beneath a stream to a local municipal well field and computed a groundwater mass balance to determine the percentage of site groundwater flow reaching the well field, the Ohio River, a neighboring stream, and an adjacent property. He used the calibrated model to screen remedial alternatives and determine cleanup levels.

Vadose Zone Flow and Transport

Vadose Zone and Hydrogeologic Modeling of Storm Water Detention Facilities, Vancouver, WA (Hart Crowser). Doug developed a three-dimensional saturated/unsaturated groundwater flow model of a storm water detention facility using the USGS computer program SUTRA (Saturated-Unsaturated Transport). He dynamically linked the SUTRA code with watershed hydrology (i.e., runoff hydrograph) and detention basin (storage and discharge rate vs. elevation) models. He modified the SUTRA code to incorporate the hydrologic and hydraulic models as subroutines, which provided storm water runoff inflow rates and time-dependent water elevations in the detention basins. Water elevations were converted to time-dependent specified pressure node values in SUTRA. He added transient discharge rates through the porous boundaries of the detention facilities (computed by SUTRA) to the outflow hydrographs. Doug used the models to evaluate the impacts of several factors on the storm water detention facility performance and design, including groundwater table mounding, hydraulic conductivity (K) heterogeneity, the ratio of vertical to horizontal K, detention basin storage capacity, and storm event recurrence interval.

Hydrologic Impact Assessment at a Waste Isolation Pilot Plant for the U.S. Department of Energy, NM (D’Appolonia). Evaluated potential salt removal from beneath a radioactive waste disposal facility enclosed in a 2,000-foot-thick salt formation in southeastern New Mexico. The objective was to determine the size and geometry of a dissolution cavity that could form beneath the facility in the next 10,000 years due to hydraulic interaction with a water-bearing unit located 1,000 feet below. Doug evaluated potential mechanisms for salt dissolution and migration to the underlying unit (e.g., diffusion or advection currents produced by density differences), derived analytical equations to quantify the salt removal rate and cavity geometries, and developed a computer model of salt transport in the water-bearing unit.

Hydrologic Impact Assessment and Vadose Zone Modeling for the Exxon Minerals Company, WI (D’Appolonia). Evaluated potential hydrologic impacts on the groundwater and surface water regimes due to minerals mining and the related disposal of inorganic wastes at a 400-acre site. Doug developed site-specific computer models of saturated/unsaturated flow and transport to predict changes in groundwater flow rates, water quality, and water levels in hydraulically-connected lakes. He used predictions encompassing an estimated 100-year mine life to negotiate a work plan with the Wisconsin DNR.

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Remedial Investigation/Feasibility Study, Vadose Zone Modeling, and Remedial Design for a Former Wood-Treating Facility, Olympia, WA (MACTEC). Doug directed the hydrogeologic investigation and remedial design for this wood-treating site. The site involved tidally influenced groundwater contaminated with polynuclear aromatic hydrocarbons (PAH), chlorinated dibenzo-p-dioxins, pentachlorophenol (PCP), LNAPL (PCP carrier oil), and DNAPL (creosote). The investigation consisted of installation of monitoring wells specifically designed to detect LNAPL and DNAPL, aquifer tests, long-term tidal monitoring, salt water intrusion evaluation, aquifer water budget (infiltration) modeling, and treatability studies for bioremediation of soil and groundwater. Doug designed a NAPL and groundwater extraction system and developed a two-dimensional, numerical groundwater flow model as part of the groundwater extraction system design. He performed one-dimensional unsaturated zone vapor transport modeling to estimate leachate and soil gas flux loadings to groundwater. He used the AquiferTest software to analyze the pumping test data and analyzed tidal variations in water-level amplitude and phase lag to evaluate hydraulic conductivity variations.

Vapor-Phase Transport Modeling, Lipari Landfill Superfund Site, NJ (MACTEC). Doug constructed a vertical, one-dimensional vapor (soil gas) flux model to calculate VOC emission rates from contaminated soil downgradient of the landfill. He used the emission estimates as source terms in an atmospheric dispersion model to compute air concentrations in the immediate vicinity of the contaminated soil and at several downgradient receptors and used the results to estimate health risks caused by inhalation exposure. These modeling results and health risk estimates provided the necessary data to determine excavation depths for contaminated soil and the thickness of a soil cap that would reduce future exposures to acceptable levels.

Health Risk Assessment, Massachusetts Contingency Plan (MCP), Auto Auction Facility (MACTEC). Doug performed the exposure assessment for potential exposure to VOC contamination resulting from a leaking underground fuel tank. He developed a one-dimensional, unsaturated zone, soil gas flux model for estimating indoor air concentrations in domestic buildings overlying subsurface areas contaminated by the spill. He also developed a two-dimensional groundwater transport model for estimating downgradient concentrations beyond the existing monitoring network.

Development of Performance Goals for Remedial Measures, a Risk-Based Approach for a Manufacturing Facility, OH (MACTEC). Computed exposure point concentrations for a health risk assessment to determine performance goals for soil and groundwater remediation at a 2-acre site contaminated with several organic chemicals. Doug was responsible for the exposure assessment that involved the development of a groundwater transport model to perform two basic calculations: 1) rate of chemical removal from the contaminated areas of the unsaturated zone soil, and 2) two-dimensional chemical advection and dispersion in the shallow groundwater unit downgradient from the source area. The computation of contaminant removal from the unsaturated zone involved a one-dimensional (vertical) analysis of advection due to infiltration and molecular diffusion through the water and air phases of the soil. He also calculated contaminant dilution in the sand layer using a calibrated two-dimensional (horizontal) transport model.

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NAPL Characterization and Modeling

Petroleum Extraction System Optimization, Former Manufacturing Facility, MA (MACTEC). Developed and calibrated a two-dimensional fuel oil flow model using the SPILLCAD software to evaluate historical free product recovery volumes and optimize extraction well locations and oil and groundwater pumping rates. He used the calibrated oil flow model to (i) demonstrate the effectiveness of the recovery system in minimizing the future risk of off-site free product transport and (ii) estimate the time period required to obtain the remedial goals for the site.

Remedial Design and Investigation, Former Manufactured Gas Plant (MGP) Site, Fort Wayne, IN (MACTEC). Doug designed a groundwater and NAPL (coal tar) containment and collection system for this former MGP site adjacent to a river. A sheet pile wall provided containment along the perimeter of the site, and a trench system with collection pipes and wells collected groundwater and NAPL. Doug developed a three-dimensional groundwater model (MODFLOW) to determine the required water levels in the various collection trench segments to provide hydraulic control of the groundwater plume and optimize NAPL recovery.

Remedial Design and Investigation, Former MGP Site, Hammond, IN (MACTEC). Doug designed a NAPL (coal tar) containment system at this former MGP site to prevent NAPL migration into a river that formed the downgradient site boundary. Doug evaluated slurry wall and sheet piling designs. He developed a three-dimensional groundwater model (MODFLOW) of the site to evaluate optimal containment wall designs (e.g., wing wall orientation and length) for minimizing off-site groundwater transport of contaminants. In addition, he used the model to evaluate water level increases on the upgradient side of the wall and potential design options (e.g., gates) to mitigate this effect.

Surface Water Modeling

Evaporation Prediction for Heated Water Bodies, Research Project for the Electric Power Research Institute, GA (Massachusetts Institute of Technology). Evaluated the evaporative heat loss from a series of heated (70 degrees Celsius) cooling ponds (1 to 5 acres) and canals. Doug developed a one-dimensional hydrothermal model to evaluate the temperature distribution and the energy budgets for the system of water bodies. He performed a literature review of evaporation prediction methods, emphasizing methods capable of predicting combined free (thermally induced) and forced (wind) evaporative heat loss. The research resulted in the formulation of a new evaporation equation that more accurately predicts heat loss from water bodies for conditions, such as high water temperature, where both free and forced evaporation are important.

Site Evaluation of Two Nuclear Power Plants for Northeast Utilities, New England (Massachusetts Institute of Technology). Doug evaluated waste heat transport from two nuclear power generation facilities located along the coast of New England. He developed two-dimensional numerical tidal hydrodynamic and

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thermal transport models to evaluate temperature increases in adjacent estuaries. He used the temperature simulations to locate new water intakes and to determine heat effects on sediment biota.

Sewage Disposal Outfall Siting Study for the Massachusetts Water Resources Authority, Boston, MA (Massachusetts Institute of Technology). Doug evaluated tidal hydrodynamics and contaminant transport in Boston Harbor as part of the design of the new Deer Island sewage treatment plant. He used mass loading data at the existing Deer and Nut Island treatment plants in conjunction with measured concentration distributions for six chlorinated VOCs to calibrate dispersion coefficients and first order surface volatilization rates for the compounds. He used current meter measurements for calibration of the two-dimensional, harmonic hydrodynamic model. He simulated harbor concentrations for several planned diffuser outfall locations using a two-dimensional, transient contaminant transport model that was linked with the hydrodynamic model.

Estimate of Toxic Chemical Loadings to Puget Sound, Washington State Department of Ecology Toxics Cleanup Program, WA (Hart Crowser). Doug was the Technical Director assisting Ecology with a multi-year effort to develop strategies, remedial actions, and performance measures to protect and restore the overall health of the Puget Sound ecosystem. He identified toxic chemicals of concern and characterized contaminant sources and pathways (e.g., stormwater runoff, municipal/industrial wastewater effluents, groundwater discharge, chemical spills, and atmospheric deposition). For each of the 17 chemicals of concern, Doug estimated average annual rates of mass loading (runoff rates and stormwater concentrations) to Puget Sound via each pathway. He developed a probabilistic approach to characterizing data uncertainty that involved computing cumulative probability distributions for each mass loading pathway.

Surface Water Quality Impact of Treatment System Effluent, Industri-Plex Trust, Superfund Site, Woburn, MA (MACTEC). Developed two-dimensional hydrodynamic and contaminant transport models of a 10-acre impoundment to evaluate water quality impacts of the treatment system effluent from a series of groundwater extraction wells. Both organic (VOC) and inorganic contaminants were present in the waste stream. Steady-state hydrodynamic simulations, qualitatively verified by field observations, provided an understanding of the velocity distribution in the impoundment that was a function of both tributary and treatment system inflows and large water depth variations of 5 to 20 feet. Doug incorporated depth-averaged contaminant concentration distributions computed using the transport model in an aquatic impact assessment designed to determine preferred effluent discharge locations and rates.

Surface Water Quality Impact of Dam Breach, Bangor Hydroelectric, ME (MACTEC). Doug developed a numerical, one-dimensional dissolved oxygen transport model to evaluate receiving water quality impacts from hydrodynamic changes caused by the breaching of a dam in a large river system. He used the USACE’s stream hydraulics model HEC-1 to simulate river stage and velocity for a range of breach elevations and stream flow rates. For each flow field the transport model provided estimates of dissolved oxygen changes in the river system. These results demonstrated the beneficial effects of leaving the dam in place.

Sedimentation and Erosion Control Plan Design for DuPont, SC (D’Appolonia). Designed the sedimentation and erosion control plan for a 200-acre site disturbed during construction of a waste

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processing facility. Evaluations included calculation of storm runoff hydrographs, the design of three sedimentation basins with heights ranging from 10 to 20 feet and storage capacities of 3 to 5 acre-feet, hydraulic design of primary and emergency spillways for the basins, specification of diversion ditch locations and sizes, and design of various other erosion control measures.

Research Research Assistant, School of Earth Sciences, The Ohio State University, Columbus, OH, 2003 – 2006. • Dissertation: Numerical Investigation of Field-Scale Convective Mixing Processes in Heterogeneous,

Variable-Density Flow Systems Using High-Resolution Adaptive Mesh Refinement Methods. Advisor: Motomu Ibaraki.

• Ph.D. Research: Developed new adaptive simulation software for high-resolution, field-scale modeling of non-linear, variable-density ground water flow systems. Examined practical problems such as in situ chemical oxidation of contaminants by dense treatment fluids, water supply applications such as freshwater storage and recovery in coastal aquifers, and saltwater intrusion assessments. The software automatically adjusts to multiple scales of convective mixing processes by translating and adding/removing telescoping levels of progressively finer subgrids to maintain a specified numerical accuracy throughout the global simulation domain. Adaptive mesh refinement methods and higher-order Eulerian-Lagrangian discretization schemes were used to construct a three-dimensional flow and transport code capable of simulating fine-scale (~1-10 cm) instability development and resulting convective mixing in field-scale variable-density ground water flow systems. Because the flow and transport solutions for each subgrid are computed independently, field-scale simulations are broken into multiple smaller problems that can be modeled more efficiently and with finer detail.

Convective mixing in heterogeneous porous media is shown to be more amenable to prediction than previously concluded. Convective mixing rates are related to the geostatistical properties of the aquifer (variance and mean of the log permeability distribution, horizontal and vertical correlation scales), the fluid density difference, the magnitude of local small-scale dispersion, the effects of different permeability field realizations, the injection well size and orientation, hydraulic parameters such as injection rate and regional hydraulic gradient, and the spatial resolution. Further, three-dimensional fluid mixing rates are related to mathematical expressions for density-dependent macrodispersivity that are based on stochastic flow and solute transport theory.

• Colloid transport modeling: Simulated colloid and radionuclide injection experiments for fractured-

rock test site in Switzerland. Used two-dimensional finite element code COLFRAC (flow and transport of colloids and contaminants in discretely-fractured porous media) to perform sensitivity analyses involving: fracture aperture, spacing, connectivity; secondary permeability and diffusion rate in rock matrix; equilibrium and kinetic radionuclide sorption parameters for colloids and fracture walls; longitudinal dispersivity; colloid filtration coefficient; and radionuclide decay rate.

Research Assistant, Department of Civil & Environmental Engineering, Massachusetts Institute of

Technology, Cambridge, MA, 1984 – 1987. • Areas of Specialization: Hydraulics/hydrology, surface water heat transport mechanisms, heat transfer

in unstable atmospheric boundary layers, tidally- and density-driven flow/transport, chemical fate/transport, numerical methods (finite element, finite difference, Eulerian-Lagrangian).

• Thesis: Evaporation from Heated Water Bodies, Predicting Combined Forced Plus Free Convection. Advisor: Eric Adams. Constructed hydrothermal model to compute evaporative heat loss from 70o C cooling ponds and canals based on simulated temperature distributions and energy budgets.

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Formulated new evaporation equation that more accurately predicts heat loss from heated water bodies for conditions where both free and forced evaporation are important.

• Surface water modeling: Analyzed tidal hydrodynamics and contaminant transport in Boston Harbor and Massachusetts Bay for design of new Deer Island sewage treatment plant. Constructed two-dimensional, finite element hydrodynamic (harmonic) flow and Eulerian-Lagrangian transport models to evaluate mixing of treatment plant effluent for alternative multi-port diffuser designs and locations.

• Hydrothermal modeling: Developed two-dimensional finite element, tidal hydrodynamic and thermal transport models to evaluate waste heat transport in estuaries for two nuclear power generation facilities.

Research Assistant, Department of Civil & Environmental Engineering, The Ohio State University, Columbus, OH, 1977 – 1979. • Areas of Specialization: Turbulent transport processes, hydraulics/hydrology, numerical methods. • Thesis: Numerical Simulation of Turbulence in a Wind-Driven, Shallow Water Lake. Advisor: Keith

Bedford. Developed three-dimensional hydrodynamics code (finite difference) using large-eddy simulation techniques. Evaluated energy cascade process for turbulent flows in lakes through spectral analysis of velocity fluctuation time series.

Independent Research, 1990 – 2002. • Effects of Rate-Limited Mass Transfer, Vertical Concentration Distribution, and Well Design on

Ground-Water Sampling and Remediation: Constructed numerical axisymmetric flow and nonequilibrium (multi-rate) transport models to simulate monitoring/extraction well concentrations as a function of plume shape and well design. Showed how sample concentration variations with time can be used to determine vertical concentration distributions in plumes and aquifer properties such as vertical anisotropy ratio, porosity, retardation factor, and soil-water mass transfer parameters.

• Commercial Contaminant Transport and Biodegradation Modeling Software: Author of the Risk-Based Correction Action (RBCA) Tier 2 Analyzer, a two-dimensional ground water flow, nonequilibrium (multi-rate) transport, and biodegradation model. Software is based on Eulerian-Lagrangian solution of transport equation with alternating direction implict (ADI) technique for dispersion, and fourth-order Runge-Kutta scheme for PCE decay chain and BTEX biodegradation terms.

Teaching Instructor, School of Earth Sciences, The Ohio State University, Columbus, OH, 2006. • Instructor for graduate-level courses in hydrogeology and environmental risk assessment, and

undergraduate courses in hydrology and water resources. Teaching Assistant, School of Earth Sciences, The Ohio State University, Columbus, OH, 2003-2006. • Taught several class sessions of graduate-level courses in hydrogeology and environmental risk

assessment, and an undergraduate course in water resources. Assisted in the preparation of lecture materials and homework assignments, developed class projects involving field applications, and guided group discussions among students during classes.

• Instructor for laboratory sessions of class in earth sciences and water resources. Prepared review materials and lectured on fundamental concepts, and directed students during laboratory exercises.

Mathematics Tutor, Boston Partners in Education, Boston, MA, 2001.

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• Served as volunteer tutor for high school students in Boston Public School system. Taught individual studies mathematics course in preparation for Massachusetts Comprehensive Assessment System (MCAS) proficiency tests.

Teaching Assistant, Department of Civil & Environmental Engineering, Massachusetts Institute of

Technology, Cambridge, MA, 1984 – 1987. • Instructed laboratory sessions of undergraduate fluid mechanics course. Conducted laboratory

demonstrations and directed students during experiments using various fluid mechanics apparatus. Led field trip to conduct a stream tracer study and evaluate stream hydraulics and dispersion characteristics.

Engineering Tutor and Coordinator, College of Engineering, The Ohio State University, 1974 – 1977. • Tutored undergraduate engineering students in mathematics, physics, chemistry, and engineering

mechanics. Served as student program coordinator responsible for evaluating undergraduate educational requirements, and tutor assignments and schedules.

PUBLICATIONS

Cosler, D.J. 2006. Numerical Investigation of Field-Scale Convective Mixing Processes in

Heterogeneous, Variable-Density Flow Systems Using High-Resolution Adaptive Mesh Refinement Methods. Ph.D. Dissertation, The Ohio State University, School of Earth Sciences, Columbus, Ohio.

Cosler, D.J. 2004*. Effects of Rate-Limited Mass Transfer on Water Sampling with Partially Penetrating Wells. Ground Water 42, no. 2: 203-222.

Cosler, D.J. 2000. Risk-Based Correction Action (RBCA) Tier 2 Analyzer, Two-Dimensional Groundwater Flow and Biodegradation Model, Ref. Manual. Waterloo Hydrogeologic, Inc., Waterloo, Ontario, Canada.

Cosler, D.J. 1997*. Ground-Water Sampling and Time-Series Evaluation Techniques to Determine Vertical Concentration Distributions. Ground Water 35, no. 5: 825-841.

Adams, E.E. and Cosler, D.J. 1990*. Evaporation from Heated Water Bodies: Predicting Combined Forced Plus Free Convection. Water Resources Research 26, no. 3: 425-435.

Adams, E., Kossik, R., Cosler, D., MacFarlane, J., and Gschwend, P. 1990. Calibration of a Transport Model Using Halocarbons. Estuarine and Coastal Modeling, M.L. Spaulding, ed., ASCE, New York, N.Y., pp. 380-389.

Andrews, D.E. and Cosler, D.J. 1989*. Preventing and Coping with Water Pollution. Journal of Testing and Evaluation, ASTM 17, no. 2: 95-105.

Walton, R., Kossik, R., Adams, E., and Cosler, D. 1989. Far-Field Numerical Model Studies for Boston's New Secondary Treatment Plant Outfall Siting. Third National Conference on Hydraulic Engineering, New Orleans, Louisiana, August 14-18.

Adams, E.E. and Cosler, D.J. 1988*. Density Exchange Flow Through a Slotted Curtain. Journal of Hydraulic Research 26, no. 3: 261-273.

Adams, E.E. and Cosler, D.J. 1987. Predicting Circulation and Dispersion Near Coastal Power Plants: Applications Using Models TEA and ELA. Massachusetts Institute of Technology Energy Laboratory Report No. MIT-EL 87-008, 113.

Adams, E.E., Cosler, D.J., and Helfrich, K.R. 1987. Evaporation from Heated Water Bodies: Analysis of Data from the East Mesa and Savannah River Sites. Civil Engineer Degree Thesis, Massachusetts Institute of Technology, Cambridge, Massachusetts.

Cosler, D.J. and Snow, R.E. 1984*. Leachate Collection System Performance Analysis. Journal of Geotechnical Engineering, ASCE 110, no. 8: 1025-1041.

Snow, R.E. and Cosler, D.J. 1983. Computer Simulation of Ground Water Inflow to an Underground Mine. In Proceedings of the First Conference on Use of Computers in the Coal Industry, AIME, (Y.J. Wang and R.L. Sanford editors), pp. 587-593. W. Virginia University, August 1-3.

Douglas J. Cosler, Ph.D., P.E. - Page 15 of 15

Cosler, D.J. 1979. Numerical Simulation of Turbulence in a Wind-Driven, Shallow Water Lake. M.S. Thesis, The Ohio State University, Columbus, Ohio.

* Denotes peer-reviewed journal.

PRESENTATIONS Cosler, D.J. 2015. An Intelligent Graphical User Interface for MODFLOW and MT3D based on

Dynamic Adaptive Mesh Refinement Methods. MODFLOW and More 2015 Conference. Colorado School of Mines, Golden, Colorado, May 31 - June 3.

Cosler, D.J. 2013. Numerical Simulation of Multiscale Transport Processes in Variable-Density Flow

Systems Using High-Resolution Adaptive Mesh Refinement Methods. MODFLOW and More 2013 Conference. Colorado School of Mines, Golden, Colorado, June 2-5.

Cosler, D.J. 2006. Numerical Investigation of Field-Scale Convective Mixing Processes in Heterogeneous,

Variable-Density Flow Systems Using High-Resolution Adaptive Mesh Refinement Methods. Geological Society of America Annual Meeting, October 22-25, Philadelphia, Pennsylvania.

Cosler, D.J. and Ibaraki, M. 2006. Numerical Investigation of Multiple-, Interacting-Scale Variable-

Density Ground Water Flow Systems. American Geophysical Union, Western Pacific Geophysics Meeting, July 24-27, Beijing, China.

Cosler, D.J. and Ibaraki, M. 2005. Numerical Investigation of Multiple-, Interacting-Scale Variable-

Density Ground Water Flow Systems. Geological Society of America Annual Meeting, October 16-19, Salt Lake City, Utah.

Cosler, D.J. 2003. Modeling the Effects of Multirate Mass Transfer on Water Sampling with Partially-

Penetrating Wells. Geological Society of America Annual Meeting, November 2-5, Seattle, Washington.

Expert Report of Philip Bedient, Ph.D., P.E.

REMEDIATION OF SOIL AND GROUNDWATER AT THE

CLIFFSIDE STEAM STATION OPERATED BY DUKE ENERGY CAROLINAS, LLC

MOORESBORO, NORTH CAROLINA

Expert Opinion of:

Philip B. Bedient, Ph.D., P.E. P.B. Bedient and Associates, Inc.

P.O. Box 1892 Houston, Texas 77251

713-303-0266

Amended 13 April 2016

13 April 2016

REMEDIATION OF SOIL AND GROUNDWATER AT THE

CLIFFSIDE STEAM STATION OPERATED BY DUKE ENERGY CAROLINAS, LLC

MOORESBORO, NORTH CAROLINA

TABLE OF CONTENTS

Remediation of Soil and Groundwater Expert Opinion of Cliffside Steam Station, Belmont, NC i Philip B. Bedient, Ph.D., P.E.

1.0 Introduction ........................................................................................................................ 1

1.1 Summary of Opinions ......................................................................................................... 1 1.2 Qualifications ...................................................................................................................... 2

2.0 Summary of the HDR CSA ............................................................................................... 2

2.1 Physical Setting ................................................................................................................... 2 2.2 Hydrogeology ..................................................................................................................... 3 2.3 Cliffside Coal Ash Basins and Coal Combustion Products (CCP) Landfill ....................... 3 2.4 Contamination ..................................................................................................................... 4

3.0 Efficacy of Remedial Options for Coal Ash Contaminants Evaluated by HDR .......... 4

3.1 Excavation and Removal .................................................................................................... 5 3.2 Cap-In-place ........................................................................................................................ 5

4.0 Opinions .............................................................................................................................. 5

4.1 The groundwater flow and transport model developed by HDR to evaluate remediation scenarios at the site is fundamentally flawed. ................................................. 5

4.2 The remediation scenarios evaluated by HDR will not prevent coal ash contaminants from migrating across the compliance boundary and into the Broad River for the foreseeable future. ......................................................................................... 6

4.3 Successful remediation of groundwater will require excavation and removal coupled with hydraulic groundwater containment. ............................................................. 7

5.0 References ........................................................................................................................... 7

13 April 2016

Remediation of Soil and Groundwater Expert Opinion of Cliffside Steam Station, Mooresboro, NC 1 Philip B. Bedient, Ph.D., P.E.

REMEDIATION OF SOIL AND GROUNDWATER AT THE

CLIFFSIDE STEAM STATION OPERATED BY DUKE ENERGY CAROLINAS, LLC

BELMONT, NORTH CAROLINA

1.0 Introduction

I was retained on this project for the purpose of evaluating remediation of soil and groundwater at the Duke Energy Carolinas, LLC (Duke) Cliffside Steam Station (the “site”) coal ash disposal facilities. In particular, I have focused my analysis on different methods of preventing continued transport of coal ash contaminants across the compliance boundary in groundwater at concentrations that exceed relevant groundwater standards. The compliance boundary1 is the regulatory boundary established for measuring compliance with applicable water quality standards by the North Carolina Department of Environmental Quality (NCDEQ). The relevant standards are:

• 15A NCAC 02L.0202 Groundwater Quality Standards (2L Standards); and,

• 15A NCAC 2L.0202(c) Interim Maximum Allowable Concentrations (IMACs) established by the NCDEQ, which apply to groundwater locations beyond the limits of the ash basins.

My opinions are based on my professional experience in hydrogeology, environmental engineering, hydrology and hydraulics, and review of relevant data, maps, aerials, documentation to date, and are subject to change if and when additional information becomes available. 1.1 Summary of Opinions

It is my opinion that:

• The groundwater flow and transport model developed by HDR to evaluate remediation scenarios at the site is fundamentally flawed.

• The cap-in-place remediation scenario evaluated by HDR will not cause groundwater standards to be met inside the compliance boundary, cause groundwater standards to be met beyond the compliance boundary, prevent coal ash contaminants from migrating across the compliance boundary, or prevent migration into Suck Creek and the Broad River for the foreseeable future.

• Successful remediation of groundwater will require excavation and removal coupled with additional measures, such as hydraulic groundwater containment.

1 My references to the compliance boundary mean the compliance boundary as drawn by HDR in the CSA (HDR, 2015a). My references do not imply that I believe that the compliance boundary drawn by HDR is correct.

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Remediation of Soil and Groundwater Expert Opinion of Cliffside Steam Station, Mooresboro, NC 2 Philip B. Bedient, Ph.D., P.E.

1.2 Qualifications

My educational background, research and professional experience, and the review of documents and models provided are the basis of my opinions. I hold the Ph.D. degree from the University of Florida in Environmental Engineering Sciences, and I have attached a curriculum vita including a list of peer-reviewed publications. I am the professor of Civil and Environmental Engineering at Rice University, where I have been on faculty since 1975, and teach courses in hydrology, floodplain analysis and modeling, and courses in groundwater hydrology, contaminant transport, and transport modeling. My textbook entitled “Hydrology and Floodplain Analysis” is one of the top texts used at over 75 universities in the U.S. I have also written a textbook entitled “Ground Water Contamination Transport and Remediation.” I am currently the Herman Brown Professor of Engineering, a Fellow of ASCE, and a Diplomat of the American Academy of Water Resources Engineers. I am a registered professional engineer in Texas. Groundwater Contamination and Remediation I have been actively involved in groundwater contamination and remediation studies for many years. I was principle investigator (PI) on a major EPA-funded study of Hill Air Force base in the late 1990s where comparison tests for various remediation of Dense Non-Aqueous Phase Liquids (DNAPLs) were performed. In the 1990s, I was a member of the EPA National Center for Groundwater Research, and I held the Shell Distinguished Chair in Environmental Science for my efforts in developing biodegradation models in the subsurface. Between 1999 and 2002, I had the opportunity to work on the remediation of MTBE spills sites in Texas and California. From 2000-2003, I worked on chlorinated solvent impacts and remediation strategies through a study funded by EPA. More recently, I evaluated the impact of ethanol on groundwater and various remediation methods on an API-funded study from 2003-2007. I have worked on groundwater contamination and remediation litigation at more than 30 waste sites nationwide. These sites include DOW Chemical and Vista Chemical in Louisiana; Conroe Creosote, Brio, Texas Instruments and San Jacinto Waste Pits in Texas; Raytheon in Florida; coal ash sites in North Carolina; BF Goodrich in California; and an Amoco site in Missouri. My experience with groundwater contamination and remediation at military sites include Coast Guard facility in Michigan, Eglin, Hill and Kelly Air Force Bases. 2.0 Summary of the HDR CSA

The information related in this summary is derived from the HDR Comprehensive Site Assessment report and CAP Part 1 and Part 2 report (CSA; HDR, 2015a; HDR, 2016). I have noted in this section where my interpretation of the CSA data differs from HDR’s, and the basis for those differing interpretations are provided in my technical opinions. 2.1 Physical Setting

Duke Energy owns and operates the Cliffside Steam Station (CSS) which is located in Moorseboro, North Carolina. Operation as a coal-fired generating station began at CSS in 1940

13 April 2016

Remediation of Soil and Groundwater Expert Opinion of Cliffside Steam Station, Mooresboro, NC 3 Philip B. Bedient, Ph.D., P.E.

(HDR, 2015). CSS was once a 6-unit operating station. In 2011, Units 1 through 4 were retired while Units 5 and 6 continue to operate. 2.2 Hydrogeology

The CSS site is located in the Inner Piedmont within the Cat Square terrane, which is one of a number of tectonostratigraphic terranes that have been defined in the southern and central Appalachians (HDR, 2015). According to the Corrective Action Plan (CAP) Part I, the Cat Square Terrane is bounded by the younger-over-older Brindle Creek fault to the west that places the terrane over the Tugaloo terrane of the Inner Piedmont and the Central Piedmont suture to the east. The terrane is characterized by gentle dipping structures and low-angle thrust faulting and sillimanite and higher amphibolite grade metamorphism (HDR, 2015). The fractured bedrock is overlain by a mantle of unconsolidated material known as regolith (HDR, 2015). According to the CAP Part I, the regolith includes residual soil and saprolite zones, and where present, alluvial deposits. Saprolite, the product of chemical weathering of the underlying bedrock, is typically composed of clay and coarser granular materials (HDR, 2015). According to the CAP Part I, the groundwater system is a two medium system generally restricted to the local drainage basin. The groundwater occurs in a system composed of two interconnected layers: residual soil/saprolite and weather rock overlying fractured metamorphic rock separated by a transition zone (TZ). Typically, the residual soil/saprolite is partially saturated and the water table fluctuates within it; water movement is generally preferential through the weathered/fractured bedrock of the TZ (i.e., zone of higher horizontal permeability) (HDR, 2015). According to HDR, the character of the system results from the combined effects of the rock type, fracture system, topography, and weathering. Topography exerts an influence on both weathering and the opening of fractures, while the weathering of the crystalline rock modifies both transmissive and storage characteristics (HDR, 2015). The geologic and hydrogeological features influencing the migration, chemical, and physical characteristics of contaminants are related to the Piedmont hydrogeologic system present at the site (HDR, 2015). According to the CSA, the direction of the migration of the contaminants is towards Suck Creek and the Broad River. According to HDR, groundwater under CSS site flows horizontally generally toward the north and discharges to the Broad River. Groundwater flow that is to the west of the active ash basin and east of Unit 6 flows toward Suck Creek which discharges to the Broad River (HDR, 2015). 2.3 Cliffside Coal Ash Basins and Coal Combustion Products (CCP) Landfill

According to HDR, coal ash residue and other liquid discharges from CSS’s coal combustion process have been disposed of in the ash basin system located both west and east-southeast from the station and adjacent to the Broad River. As referenced in the CAP Part I, coal ash residue is conveyed to the active ash basin system at the plant and is used to settle and retain ash generated from coal combustion at CSS. The ash basin system is located adjacent to the Broad River and consists of the active ash basin, the Units

13 April 2016

Remediation of Soil and Groundwater Expert Opinion of Cliffside Steam Station, Mooresboro, NC 4 Philip B. Bedient, Ph.D., P.E.

1-4 inactive ash basin, and the Unit 5 inactive ash basin, all of which are unlined (HDR, 2015). According to HDR, the Units 1-4 inactive ash basin was converted into holding cells for storm and plant process water. Two unlined ash storage areas are also located north and adjacent to the active ash basin (HDR, 2015). During operation of the coal-fired units, the active ash basin receives variable inflows from the ash removal system and other permitted discharges. Currently, the active ash basin is permitted to receive variable inflows from the Unit 5 fly ash handling system, Unit 5 bottom ash handling system, cooling tower blowdown, stormwater runoff from yard drainage, coal pile runoff, gypsum pile runoff, limestone pile runoff, landfill leachate, and wastewater streams generated from emission monitoring equipment (HDR, 2015). Duke Energy also owns and operates the Cliffside Steam Station Coal Combustion Products (CCP) Landfill (HDR, 2015). The CCP landfill is located nearly a mile southwest of the CSS on Duke Energy property entirely within Rutherford County (HDR, 2015). According to the CAP Part I, the CCP landfill is permitted to receive fly ash, bottom ash, boiler slag, mill rejects, flue gas desulfurization sludge, gypsum, leachate basin sludge, nob-hazardous sandblast material, limestone, ball mill rejects, coal, carbon, sulfur pellets, cation and anion resins, sediment from sumps, and cooling tower sludge generated by Duke Energy North Carolina coal-fired facilities, including from CSS. 2.4 Contamination

The CAP Part I assembled by HDR uses the term COI to describe any parameter that exceeded its applicable regulatory standard or criteria. Review of laboratory analytical results within the CAP Part I identified eight COIs including arsenic, barium, boron, cobalt, iron, manganese, selenium, and vanadium. COIs identified in pore water in the ash basins and ash storage area included antimony, arsenic, boron, cobalt, iron manganese, pH, sulfate, thallium, vanadium, and TDS (HDR, 2015). According to the CAP Part I, upgradient, background monitoring wells contain naturally occurring metals and other constituents at concentrations that exceeded their respective 2L Standards or Interim Maximum Allowable Concentration (IMACs). The CAP Part I explains the that some naturally occurring metals and constituents, including antimony, chromium, cobalt, iron, manganese, and vanadium were all detected in background groundwater samples at concentrations greater than 2L Standards or IMACs however, groundwater monitoring data shows concentrations of several other constituents exceeding their respective 2L Standards or IMACS in groundwater across the site (HDR, 2015). These specific constituents with exceedances include arsenic, barium, beryllium, boron, chromium, cobalt, lead, manganese, nickel, sulfate, TDS, thallium, and vanadium (HDR, 2015). 3.0 Efficacy of Remedial Options for Coal Ash Contaminants Evaluated by

HDR

In its CAP Part I, HDR evaluates the effects of two remedial options on groundwater concentrations at the compliance boundary: (1) excavation of the coal ash material, and (2) the use of a cap to reduce leaching of contaminants to groundwater. The efficacy of these two

13 April 2016

Remediation of Soil and Groundwater Expert Opinion of Cliffside Steam Station, Mooresboro, NC 5 Philip B. Bedient, Ph.D., P.E.

remediation options for the COIs present in groundwater at the Cliffside Station site is discussed below. 3.1 Excavation and Removal

Excavation and removal would remove the source of the contamination (coal ash in all of the basins) entirely in order to end the contamination of underlying groundwater. This process would entail excavating coal ash from the site, loading it onto trucks or rail cars, and disposing of in a secure landfill that is equipped with a proper liner and leachate collection system. This remediation technique is underway at other contaminated coal ash sites in North Carolina. While there is precedent for complete removal of the coal ash, additional, temporary protective measures, such as the construction of sheet piles and coffer dams, would be necessary on this site to prevent influx of groundwater and river water during excavation. Ultimately, this remedial approach is feasible and the most effective remediation measure due to permanent source removal. Even with coal ash removal, however, the current impacted groundwater will exist as a constant source of contamination within the transmissive zones beneath and adjacent to the site and to the Broad River. Additional measures will be needed to address this residual contamination at the site. Nevertheless, excavation and removal stands as the only remediation measure that completely removes the source of contamination and, in conjunction with other measures described below, safeguards against future contamination. 3.2 Cap-In-place

A cap-in-place remedy utilizes a cap of low-permeability material, including clay and/or synthetic liners, to reduce the rate of water infiltration into the underlying coal ash. The cap may be equipped with an underdrain system to capture even small amounts of water that infiltrates through the cap material. In systems where contaminants are relatively fast-moving or biodegradable, capping provides more time for the chemicals to become degraded, protecting potential receptors downgradient. Cap-and-treat technology is also limited, however. Where contaminants exist in thick material that contains substantial water, continued leaching of contaminants to groundwater may occur, even with reduced infiltration. These materials can serve as a long-term source of groundwater impacts. 4.0 Opinions

Based on my review of the available reports and analysis of other data received to date, my opinions are, to a reasonable scientific certainty, the following: 4.1 The groundwater flow and transport model developed by HDR to evaluate

remediation scenarios at the site is fundamentally flawed.

The groundwater flow model developed for Duke has been constructed so that only one pattern of groundwater flow is possible; flow from the south site boundary northward to the Broad

13 April 2016

Remediation of Soil and Groundwater Expert Opinion of Cliffside Steam Station, Mooresboro, NC 6 Philip B. Bedient, Ph.D., P.E.

River. This effect is the result of the choice of hydraulic boundary conditions in the model, which can only result in this groundwater flow pattern. No-flow boundaries to the west and east are not realistic and pre-define the groundwater flow direction. The flow model developed for Duke allows groundwater to flow only generally northward, from the coal ash basins into the Broad River. The no-flow boundaries to the west channel this flow and pre-establish the flow direction. This a priori dictation of flow direction limits the utility of the model for investigating COI transport, and inaccurate flow paths also lead to erroneous expectations of contaminant migration pathways and mass loading to the Broad River. The southern boundary condition in the flow model is not technically supported. The no-flow boundary to the south presumes that there is a groundwater divide that follows the east-west trending ridge south of the site. There is not enough evidence to support this assumption of a distinct groundwater divide south of the site. The Duke model does not account for the significant pumping from wells in the vicinity of the coal ash ponds, which would serve to divert groundwater from the direction calculated by the flow model. Many groundwater wells near the boundaries of the flow model could affect groundwater flow patterns, and these are not included in the CAP I model. 4.2 The remediation scenarios evaluated by HDR are inadequate.

The cap-in-place remediation scenario evaluated by HDR will not cause groundwater standards to be met inside the compliance boundary, cause groundwater standards to be met beyond the compliance boundary, prevent coal ash contaminants from migrating across the compliance boundary, or prevent migration into Suck Creek and the Broad River for the foreseeable future. The CAP I prepared for Duke by HDR (HDR, 2015b) is not effective in addressing or mitigating the groundwater contamination occurring at this site as a result of the leakage of coal ash contents from coal ash disposal at the Cliffside Station. In Appendix C of the CAP (HDR, 2015b), Duke acknowledges that under the cap-in-place scenario, many COIs will remain above groundwater cleanup standards at the Broad River compliance boundary after 250 years. This conclusion is reached even when the soil-water partitioning coefficient (Kd) values for metals were significantly reduced during model calibration. Setting the Kd values equal to those determined in laboratory studies would result in much slower contaminant migration and more persistent exceedances at all compliance boundaries because of the much slower release of adsorbed COIs into groundwater. Of course, remediation measures that fail to meet groundwater standards beyond the compliance boundary will also fail to restore groundwater to the required standards within the compliance boundary. In the CAP Part 2 report (HDR, 2016), the cap-in-place scenario does not reduce a single COI concentration to below the groundwater standards after 100 years. The excavation and removal option would perform better than the cap-in-place option, as acknowledge by HDR in the CAP (HDR, 2015b). However, even under the excavation and removal scenario, several COIs are all projected to remain above cleanup standards at the Broad

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Remediation of Soil and Groundwater Expert Opinion of Cliffside Steam Station, Mooresboro, NC 7 Philip B. Bedient, Ph.D., P.E.

River compliance boundary after many decades. With a more appropriate value of Kd, it is likely that other constituents would also exceed groundwater cleanup levels at the Broad River compliance boundary. 4.3 Successful remediation of groundwater will require excavation and removal coupled

with hydraulic groundwater containment.

To eliminate ongoing migration of COIs across the compliance boundary, full excavation and removal of the ash from the landfill and the underlying unlined coal ash pit is necessary as a first step. The precedent for this degree of remediation is occurring currently in North Carolina among several sites. In addition, care will need to be taken with the excavation process due to the site’s proximity to the Broad River. This can be accomplished by means such as the construction of sheet piles and coffer dams, or by the installation of hydraulic control wells prior to excavation. Excavation alone, however, will not prevent discharges of COIs to the Broad River. Because of the significant depth of the bedrock unit and the rocky composition of the lower groundwater-bearing zones, barrier walls on the site boundaries are probably not feasible. Thus, the implementation of additional measures will be needed in order to meet groundwater standards under the excavation and removal approach. As a result, additional measures would need to be implemented following coal ash removal, such as hydraulic containment to remove COI-impacted groundwater so that COIs are maintained on Duke property. Ultimately, full excavation and removal of the ash coupled with the suggested additional measures is the most effective remedial approach. It is important to note that pairing such additional measures with lesser source control strategies, such as the cap-in-place option, will still not be sufficient to meet the groundwater standards. 5.0 References

Bedient, 1997. Ground Water Contamination: Transport and Remediation. Second Addition. Bedient, Philip B.; Rifai, Hanadi S.; Newell, Charles J. 1997.

HDR, 2015a. “Comprehensive Site Assessment Report, Cliffside Steam Station Ash Basin, HDR Engineering,” Inc. of the Carolinas, August 23, 2015.

HDR, 2015b. “Corrective Action Plan Part 1, Cliffside Steam Station Ash Basin,” HDR Engineering, Inc. of the Carolinas, November 20, 2015.

HDR, 2016. “Corrective Action Plan Part 2, Cliffside Steam Station Ash Basin,” HDR Engineering, Inc. of the Carolinas, February 19, 2016.

November 2, 2015 Philip B. Bedient, Ph.D., P.E.

Curriculum Vitae

ADDRESS: Herman Brown Professor of Engineering Department of Civil and Environmental Engineering Rice University/MS - 317 6100 Main St. / Houston, Texas 77005 (713) 348-4953 or fax (713) 348-5239 Email – bedient@rice.edu P.B. Bedient and Associates, Inc. 13910 Wilde Forest Court Sugar Land, TX 77498 (281) 491-3911 EDUCATION: B.S. Physics, University of Florida, Gainesville, Florida, 1969 M.S. Environmental Engineering, University of Florida, 1972 Ph.D. Environmental Engineering Sciences, University of Florida, 1975 PROFESSIONAL EXPERIENCE:

Herman Brown Professor of Engineering - Civil and Environmental Engineering- Rice University - July 2001 to present.

Professor - Environmental Engineering - Rice University - 1986 to 2001. Professor and Chair - Department of Environmental Science and Engineering, Rice University,

Houston, Texas, 1992 - 1999. Associate Professor - Environmental Engineering – 1980 - 1986. Assistant Professor - Environmental Engineering – 1975 - 1980. SCIENTIFIC SOCIETIES: American Society of Civil Engineers American Institute of Hydrology American Water Resources Association Association of Environmental Engineering Professors American Academy of Water Resources Engineers American Geophysical Union HONORS:

Diplomate - Water Resources Engineer, American Academy of Water Resources Engineers (2008) C.V. Theis Award from the American Institute of Hydrology (April 2007)

Fellow – American Society of Civil Engineers (April, 2006) Endowed Chair – Herman Brown Professor in Engineering (July, 2001) Shell Distinguished Chair in Environmental Science (1988-93) Phi Beta Kappa PROFESSIONAL COMMITTEES: SSPEED Center Committee 2007-2014 Expert Panel – “Impacts of Climate Change on Transportation Systems and Infrastructure in the

Gulf Coast” USDOT and USGS, 2005 - 2006 TS Allison Recovery Project - Technical Advisory Committee - 2002-2003 Harris County Flood Control District - Brays Bayou Federal Project Com – 1998- 2002

2 National Academy of Engineers (National Research Council) Committee on DoE Environmental Management Technologies (CEMT) - 1995-96 Committee on In-Situ Bioremediation - 1992-93 UNIVERSITY COMMITTEES: Undergraduate Curriculum Committee, 2005-2012 Accreditation (ABET/SACS) Committee, 2005-2012 Events and Reception Committee (Chair) 2012 Mentorship Committee 2012 Space Planning Committee, 2005-2012 CEE Student-Group Advisors 2012 BSCE Advisor 2012

Center for Civic Engagement Committee, 2007-2012 Parking Committee, 1998-2012

Search Committee, Civil and Environmental Engineering, (2001-2002) Chair, Dean of Engineering Search Committee, (1988) Computer Committee, Athletics Committee, 1998-2000 Advisory Council, School of Engineering, LICENSES: Professional Engineer, State of Texas, Environmental Engineering (45626) Professional Hydrologist, American Institute of Hydrology RESEARCH INTERESTS: Floodplain Management - Analysis of effects of land use changes and development patterns on flood

hydrographs and floodplain boundaries; use of lumped and distributed hydrologic models; detailed modeling of alternative flood control strategies and dynamic floodplain models. Analysis of the severe storm impacts in urban watershed areas using radar rainfall data, combined with GIS techniques for digital terrain and hydraulic modeling in Houston and other coastal areas in Texas.

Flood Alert Systems with Radar - The development of a real-time flood ALERT system (FAS) for

Brays Bayou and the Texas Medical Center in Houston, TX has been completed. The FAS currently uses NEXRAD radar for application to flood prediction and real-time flood alert systems. FAS2 is a second-generation system being implemented with funding from FEMA after TS Allison. TXDOT funded new FAS for inundated bridge crossings (2008).

Groundwater Contaminant Transport - Monitoring and modeling of groundwater hydrology and

contaminant movement from various waste sources, numerical and analytical methods for transport with biodegradation. Development and application of tracer studies and models for groundwater transport with biodegradation in a controlled release tank (ECRS), for studying degradation of PCE and TCE plumes and for ethanol in fuel spills. Analysis of plume dynamics at sites in California, Texas and Florida.

Hazardous Waste Site Evaluation - Monitoring and modeling of waste plumes associated with 35

hazardous waste sites nationally. Identification of extent of contamination, transport mechanisms, and control strategies. MODFLOW and RT3D modeling of transport and aquifer restoration using withdrawal-treatment and microbial degradation methods. Analysis of hazardous waste sites in California, Texas and Florida.

COURSES and STUDENTS:

• CEVE 412 - Hydrology and Watershed Analysis • CEVE 512 - Hydrologic Design Laboratory

3

• CEVE 101 - Fundamentals of Civil and Environmental Engineering • CEVE 415/515 - Water Resources Planning and Management (50%) • 13 Ph.D. and 60 M.S. degrees since 1975

RESEARCH STATEMENT:

Dr. Philip B. Bedient is also Herman Brown Professor of Engineering in the Dept of Civil and Environmental Engineering at Rice University. He teaches and performs research in surface and ground water hydrology, disaster management, and flood prediction systems. He served as Chair of Environmental Engineering from 1992 to 1999. He has directed 60 research projects over the past 36 years, has written over 180 articles in journals and conference proceedings. He is lead author on a text on “Hydrology and Floodplain Analysis” (Prentice Hall, 5th ed., 2012) used in over 75 universities across the U.S. Dr. Bedient received the Herman Brown endowed Chair of Engineering in 2002 at Rice University. He was elected to Fellow ASCE in 2006 and received the prestigious C.V. Theis Award from the American Institute of Hydrology in 2007. He earlier received the Shell Distinguished Chair in Environmental Science (1988 to 1993). He is the director of the Severe Storm Prediction Center (SSPEED) at Rice University (since 2007) consisting of a team of seven universities and 15 investigators from Gulf coast universities dedicated to improving storm prediction, education, and evacuation from disaster. The Center was approved by the Texas Legislature and is currently funded at over $4.5 million for 5 years from various sources including the Houston Endowment (Hurricane Ike Lessons Learned and Future Steps). A book has been developed and published by TAMU press titled “Lessons from Hurricane Ike” published in June 2012. The SSPEED Center has taken a zone approach to developing mitigation strategies and has identified four zones of interest in the Houston-Galveston region: the Houston Ship Channel, West Bayshore, Galveston Island and a Coastal Recreation Area. Dr. Bedient has over 37 years of experience working on flood and flood prediction problems in the U.S. He has evaluated flood issues in Texas, California, Florida, Louisiana, and Tennessee. He has worked on some of the largest and most devastating floods to hit the U.S. including the San Jacinto River flood of 1994, T.S. Frances in 1998, T.S. Allison in 2001, Hurricane Katrina in 2005, Hurricane Rita in 2005, Hurricane Ike in 2008, and the Nashville, TN flood of 2010. He routinely runs computer models such as HEC-HMS, HEC-RAS, SWMM, and VFLO for advanced hydrologic analysis. He developed one of the first radar based rainfall flood alert systems (FAS-3) in the U.S. for the Texas Medical Center. The SSPEED Center has put on a number of conferences, meetings, and training courses since 2007. Prominent national speakers have been invited to these conferences, which include attendees from academia, industry, consulting, and emergency managers. These conferences provide a forum for public discussion and response for decision and policy makers, and stakeholders. As a result of this work, we have received a large number of Rice News stories over the past several years, in the form of both video interviews with the media as well as newspaper coverage.

Dr. Bedient has been involved in the technology transfer area for more than two decades through the teaching of short courses for government, university, and private sectors. He has recently organized five conferences on Severe Storm flooding and recovery projects in 2001, 2003, and 2005, 2006, and 2007 on the Rice University campus. In 2008 he organized a new major conference on “Severe Storms Prediction and Global Climate in the Gulf Coast” in October 2008 which hosted speakers who experienced first hand the impacts of both hurricanes Katrina and Ike this past summer. More than 125 people attended on the Rice campus and the conference was highlighted with over 60 talks including the keynote from the director of the National Hurricane Center.

4 SURFACE WATER PROJECT

“SSPEED Center Proposal to the Houston Endowment Coastal Integrated”, Houston Endowment, 2011-2014, $3,195,451

“FAS3- Operational Support”, Texas Medical Center, 2012, $69,000

“Urban Resilience: Flooding in the Houston-Galveston Area”, Kinder. 2009-2012, $240,003

“White Oak Bayou BMP Demonstration Project – Cottage Grove Subdivision”, City of Houston, 2009-2013, $165,000.

“Residential Storm Surge Damage Assessment for Galveston County”, Texas General Land Office (GLO), 2012-2013, $100,000

“Rice University FEMA: Food Analysis”, Rice, 2011-2012, $70,000

“Amendment to Expand Development and Validation of the Online Storm Risk Calculator Tool for Public Usage”, City of Houston, 2011, $388,030

“Hurricane Ike: Lessons Learned and Steps to the Future”, Houston Endowment, 2009-2012, $1,250,000

“Libya AEL Training Grant”, AECOM, 2008-2010, $1.7 million over 2 years.

“Texas OEM SSPEED Training” University of Texas, 2008, $90,000

“Watershed Information Sensing and Evaluation System”, Houston Endowment (with UH), 2007-2010, $400,000.

“Advanced Flood Alert System for the TXDOT for Bridge Control at 288”, HGAC, 2007-2011 $200,000.

“Civil and Environmental Engineering for the 21st Century”, NSF Dept Reform Grant, 2005-2007, $100,000.

“CASA – Collaborative Adaptive Sensing of the Atmosphere – the Houston Testbed”, NSF, 2003 – 2009, $110,000, ($90,000 for 2006-07).

“FAS2 - Operational Support”, Texas Medical Center, 2003-2012, $69,000 .

“Flood Alert System (FAS2) for the Texas Medical Center and Brays Bayou”, FEMA, 2002-2003, $300,000.

“Multi-Purpose Water Management Technology for the Texas Mexico Border”, Advanced Technology Program, 2000-2001, $129,000.

“Analysis of Clear Creek Watershed,” Galveston Bay Preservation Foundation, 1999-2000, $15,000.

“Flood Alert System - Maintenance and Support”, Texas Medical Center, 1998-2002, $271,000.

5

“Flood Prediction System for the Texas Medical Center”, Texas Medical Center, 1997-1998, $262,000.

“The Effects of Changing Water Quality and Market Inefficiencies on Water Resource Allocation in the Lower Rio Grande Valley”, Energy and Environmental Systems Institute, Rice University, 1996-1997, $12,000.

"Characterization of Laguna Madre Contaminated Sediments", Environmental Protection Agency, 1995, $68,500.

"Role of Particles in Mobilizing Hazardous Chemicals in Urban Runoff", Environmental Protection Agency, 1992-95, $240,000. (P. B. Bedient, Co-P.I.).

"Galveston Bay Characterization Report", Galveston Bay National Estuary Program, 1991-1992, $35,000.

"Characterization of Non-Point Sources and Loadings to Galveston Bay", Galveston Bay National Estuary Program, 1990-1991, $125,000.

"Linkages between Sewage Treatment Plant Discharges, Lake Houston Water Quality, and Potable Water Supply during Storm Events", City of Houston, 1984-1985, $42,200.

"Plan of Study for Upper Watershed Drainage Improvements and Flood Control - San Jacinto River Basin", subcontract from R. Wayne Smith, Engineer, 1984-85, $120,260.

"Harris Gully Sub watershed Study", South Main Center Association, 1983-1984. $15,000.

"Sedimentation and Nonpoint Source Study of Lake Houston", Houston-Galveston Area Council, 1981-1982, $55,000.

"Environmental Study of the Lake Houston Watershed - Phase II", Houston-Galveston Area Council, 1980-1981, $30,000.

"Evaluation of Effects of Storm water Detention in Urban Areas", matching grant with City of Houston Health Department, Office of Water Research and Technology (OWRT), Washington, D.C., and City of Houston Public Health Engineering, 1980-81, $116,000.

"Environmental Management of the Lake Houston Watershed", Funded by City of Houston, Dept. of Public Health, 1978-80, $80,000.

"A Preliminary Feasibility Report for Bear Creek, Texas, Local Protection Project", Grant to Southwest Center for Urban Research, Funded by U.S. Army Corps of Engineers, 1977-78, $47,000.

"Environmental Study of New Iberia Navigation Port and Channel, Louisiana", Funded to Rice Center, 1979, $50,000.

"Strategies for Flood Control on Cypress Creek, Texas", Funded by U.S. Corps of Engineers, Galveston, Texas, 1977, $9,500.

"Water Quality Automatic Monitoring and Data Management Information System", Funded by City of Houston, Dept. of Public Health, 1977-1978, $62,414.

"Maximum Utilization of Water Resources in a Planned Community", The Woodlands Project, 1975-1976.

6 GROUNDWATER PROJECTS

“A Large-Scale Experimental Investigation of the Impact of Ethanol on Groundwater Contamination”, (P.J.J. Alvarez – Co-P.I.) American Petroleum Institute, 2004-2007, $120,000.

“A Large-Scale Experimental Investigation of the Impact of Ethanol on Groundwater Contamination”, Gulf Coast Hazardous Substances Research Center, 2004-2005, $45,000.

“A Large-Scale Experimental Investigation of the Impact of Ethanol on Groundwater Contamination”, Gulf Coast Hazardous Substances Research Center, 2003-2004, $95,000.

"Chlorinated Solvent Impact and Remediation strategies in the Dry Cleaning Industry”, Gulf Coast Hazardous Substances Research Center, 2000 – 2003, $149,400.

"Design Manual for the Extraction of Contaminants from Subsurface Environments", Environmental Protection Agency, 1994-2002, $4,500,000.

"Development of Data Evaluation/Decision Support System for Bioremediation of Subsurface Contamination", Environmental Protection Agency, 1993-1996, $450,000.

Shell Distinguished Chair in Environmental Science, Shell Oil Company Foundation, 1988-1993, $750,000.

"Evaluation of Nitrate-Based Bioremediation: Eglin Air Force Base", Environmental Protection Agency, 1992-1993, $120,000.

"Decision Support System for Evaluating Remediation Performance with Interactive Pump-and-Treat Simulator", Environmental Protection Agency, 1992-1994, $250,000.

"Characterization of Oil and Gas Waste Disposal Practices and Assessment of Treatment Costs", Department of Energy, 1992-94, $200,000.

"Subsurface Monitoring Data for Assessing In-Situ Biodegradation of Aromatic Hydrocarbons (BTEX) in Groundwater", American Petroleum Institute, 1991-93, $170,000.

"System 9 GIS System", Prime Computers, 1989-90, $50,000.

"Effects of Various Pumping and Injection Schemes and Variable Source Loading on Biorestoration", American Petroleum Institute, 1988-90, $186,000.

"Parameter Estimation System for Aquifer Restoration Model", U.S. Environmental Protection Agency, 1987-89, $400,000.

"Distribution of BIOPLUME II", National Center for Ground Water Research (EPA), 1987-88, $40,000.

"Development and Application of a Groundwater Modeling Data Base for Hazardous Waste Regulation", American Petroleum Institute, 1987-88, $40,000.

"Practical Procedures for Evaluating Attenuation of Ground Water Contaminants Due to Biotransformation Process", National Center for Ground Water Research (EPA), 1986-87, $150,000.

7

"Modeling and Field Testing of Contaminant Transport with Biodegradation and Enhanced In Situ Biochemical Reclamation", National Center for Ground Water Research (EPA), 1985-88, $249,000.

"Ground Water Modeling for the Houston Water Plant", City of Houston, subcontracts from Law Engineering & Testing Co., 1985-86, $127,000.

"Environmental Fate and Attenuation of Gasoline Components in the Subsurface", American Petroleum Institute, 1984-86, $78,300.

"Simulation of Contaminant Transport Influenced by Oxygen Limited Biodegradation", National Center for Ground Water Research (EPA), 1984-85, $25,500.

"Ground Water Pollutant Transport along Flow Lines for Hazardous Waste Sites", National Center for Ground Water Research (EPA), 1983-85, $167,000.

"Math Models for Transport and Transformation of Chemical Substances in the Subsurface", National Center for Ground Water Research (EPA), Subcontract from Oklahoma State University, 1982-83, $15,000.

"Characterization of Ground Water Contamination from Hazardous Waste Sites", National Center for Ground Water Research (EPA), 1982-83, $113,000.

"Characterization of Ground Water Contamination from Hazardous Waste Sites". National Center for Ground Water Research (EPA), 1980-82, $45,000.

PUBLICATIONS AND PRESENTATIONS

A. Books or Related Chapters

1. Fang, Z., Sebastian A., and Bedient, P.B. 2014. “Modern Flood Prediction and Warning

Systems.” Handbook of Engineering Hydrology: Fundamentals and Applications (Chapter 21), Vol. 1, Taylor & Francis Inc. ISBN-10:1466552417.

2. Bedient, P. B. and W. C. Huber, 2012, “Hydrology and Floodplain Analysis”, 5th Ed. Prentice-Hall Publishing Co., Upper Saddle River, NJ, February 2012, 800 page textbook.

3. Bedient, P. B., 2012 “Lessons learned from Hurricane Ike” Ed. Philip Bedient. College Station, TX: Texas A&M University Press, College Station, TX: 2012, 194 Pages

4. Rifai H.S., Borden R.C., Newell C.J. and Bedient P.B., “ Modeling Remediation of Chlorinated solvent plumes” In Situ Remediation of Chlorinated solvent Plumes, Chapter 6, H.F. Stroo, C.H. Ward Editors, Springer, N.Y. 2010, 145 pp.

5. Fang, Z., Safiolea, E., Bedient, P.B. (2006) “Enhanced Flood Alert and Control Systems for Houston.” In Chapter 16, Coastal Hydrology and Processes, Ed. By Vijay P. Singh and Y. Jun Xu, Water Resource Publications, LLC, pp. 199-210

6. Capiro, N.L. and Bedient P.B. "Transport of Reactive Solute in Soil and Groundwater" The Water Encyclopedia (2005): 524-531.

7. Horsak, R.D., Bedient, P.B., Thomas, F.B., and Hamilton, C. "Pesticides”, Environmental Forensics (2005).

8

8. Thompson, J.F. and Bedient, P.B. “Urban Storm Water Design and Management,” The Engineering Handbook, Chapter 94, CRC Press, 2004, 21 pp.

9. Bedient, P. B., Rifai H. S., and Newell C. J., “Ground Water Contamination: Transport and Remediation”, 2nd Ed. PTR Publ., Upper Saddle River, NJ, 1999, 605 pages.

10. Charbeneau, R. J., Bedient, P. B. and Loehr R. C., “Groundwater Remediation”, Technomic Publishing Co., Inc., Lancaster, PA 1992, 188 pages.

B. Peer Reviewed Journal Publications

1. Bass, B., Juan, A., Gori, A., Fang, Z., and Bedient, P.B. (2015). 1. 2015 Memorial Day Storm Flood Impacts for Changing Watershed Conditions in Brays Bayou, Houston, TX. ASCE Journal of Hydrologic Engineering (in-review).

2. Torres, Jacob M., Benjamin Bass, Nicholas Irza, Zheng Fang, Jennifer Proft, Clint Dawson, Morteza Kiani, and Philip Bedient. "Characterizing the hydraulic interactions of hurricane storm surge and rainfall–runoff for the Houston–Galveston region." Coastal Engineering 106 (2015): 7-19.

3. Juan, A, Fang, Z., and Bedient, P.B. "Developing a Radar-Based Flood Alert System for Sugar Land, Texas." Journal of Hydrologic Engineering (2015).

4. Brody, S.D., Sebastian, A., Blessing, R., & Bedient, P.B. (2015). Case-study results from

southeast Houston, Texas: Identifying the impacts of residential location on flood risk and loss. Journal of Flood Risk Management, (accepted for publication). doi: 10.1111/jfr3.12184

5. Fang, N., Dolan G., Sebastian, A., & Bedient, P.B. (2014). Case Study of Flood Mitigation and

Hazard Management at the Texas Medical Center in the Wake of Tropical Storm Allison in 2001. ASCE Natural Hazards Review, 15(3). doi: 10.1061/(ASCE)NH.1527-6996.0000139.

6. Christian, J, Fang, Z., Torres, J., Deitz, R. and Bedient, P.B. "Modeling the Hydraulic Effectiveness of a Proposed Storm Surge Barrier System for the Houston Ship Channel during Hurricane Events." Natural Hazards Review 16, no. 1 (2014): 04014015

7. Burleson, Daniel W., Hanadi S. Rifai, Jennifer K. Proft, Clint N. Dawson, and Philip B. Bedient. "Vulnerability of an industrial corridor in Texas to storm surge." Natural Hazards 77, no. 2 (2015): 1183-1203.

8. Sebastian, A., Proft, J., Dawson, C., & Bedient, P.B. (2014). Characterizing hurricane storm surge

behavior in Galveston Bay using the SWAN+ADCIRC model. Coastal Engineering, 88, 171-181. doi: http://dx.doi.org/10.1016/j.coastaleng.2014.03.002.

9. Brody, S.D., Blessing, R., Sebastian, A., & Bedient, P.B. (2014). Examining the impact of land use/land cover characteristics on flood losses. Journal of Environmental Planning and Management, 57(8), 1252-1265. doi: 10.1080/09640568.2013.802228.

10. Brody, S.D., Blessing, R., Sebastian, A., and Bedient, P.B. (2013). “Delineating the Reality of Flood Risk and Loss in Southeast, TX.” ASCE Natural Hazards Review, 14, 89-97.doi: 10.1061/(ASCE) NH.1527-6996.0000091.

9

11. Fang, Z., Sebastian A., and Bedient, P.B. 2014. “Modern Flood Prediction and Warning

Systems.” Handbook of Engineering Hydrology: Fundamentals and Applications (Chapter 21), Vol. 1, Taylor & Francis Inc. ISBN-10:1466552417.

12. Teague, A., J. Christian, and P. Bedient. (2013) “Use of Radar Rainfall in an Application of Distributed Hydrologic Modeling for Cypress Creek Watershed, Texas”. Journal of Hydrologic Engineering. DOI: 10.1061/(ASCE) HE.1943-5584.000056.

13. Doubleday, G., Sebastian, A., Luttenschlager, T., and Bedient, P.B. (2013). “Modeling

Hydrologic Benefits of Low Impact Development: A Distributed Hydrologic Model of The Woodlands, TX.” Journal of American Water Resources, 1-13. doi: 10.1111/jawr.12095.

14. Christian, J., A. Teague, L. Dueñas-Osario, Z. Fang, and P. Bedient, (2012). “Uncertainty in Floodplain Delineation: Expression of Flood Hazard and Risk in a Gulf Coastal Watershed.” Journal of Hydrological Processes, doi: 10.1002/hyp.9360.

15. Ray, T., Stepinski, E., Sebastian, A., Bedient, P.B. (2011)“Dynamic Modeling of Storm Surge and Inland Flooding in Texas Coastal Floodplain” ”, Journal of Hydraulic Engineering, ASCE, Vol. 137, No.10, October 2011, ISSN 0733-9429/2011/10-1103-1110

16. Fang, Z., Bedient, P. B., and Buzcu-Guven, B. (2011). “Long-Term Performance of a Flood Alert System and Upgrade to FAS3: A Houston Texas Case Study”. Journal of Hydrologic Engineering, ASCE Vol. 16, No. 10, October 1, 2011, ISSN 1084-0699/2011/10-818-828.

17. Teague, A., Bedient, P. and Guven, B. (2010). “Targeted Application of Seasonal Load Duration Curves using Multivariate Analysis in Two Watersheds Flowing into Lake Houston” (JAWRA-10-0003-P.R1). Journal of American Water Resources Association. Accepted.

18. Fang, Z, Zimmer, A., Bedient, P. B, Robinson, H., Christian, J., and Vieux, B. E. (2010). “Using a Distributed Hydrologic Model to Evaluate the Location of Urban Development and Flood Control Storage”. Journal of Water Resources Planning and Management, ASCE, Vol. 136, No. 5, September 2010, ISSN 0733-9496/2010/5-597-601.

19. Fang, Z., Bedient, P. B., Benavides J.A, and Zimmer A. L. (2008). “Enhanced Radar-based Flood Alert System and Floodplain Map Library”. Journal of Hydrologic Engineering, ASCE, Vol. 13, No. 10, October 1, 2008, ISSN 1084-0699/2008/10-926-938.

20. Gomez, D. E., De Blanc, P. C., Rixey, W., Bedient, P.B., Alvarez, P. J.J. (2008), “Evaluation of Benzene Plume Elongation Mechanisms Exerted by Ethanol Using RT3D with a General Substrate Interaction Module” Water Resource Research Journal, Vol. 44, May.

21. Rifai, H.S., Borden, R. C., Newell, C. J., and Bedient, P.B. “Modeling Dissolved Chlorinated Solvents in Groundwater and Their Remediation,” in SERDP monograph on Remediation of Dissolved Phase Chlorinated Solvents in Groundwater, (accepted) 2007.

22. Bedient, P. B., Holder, A., and Thompson, J. F., and Fang, Z. (2007). “Modeling of Storm water Response under Large Tailwater Conditions – Case Study for the Texas Medical Center”. Journal of Hydrologic Engineering, Vol. 12, No. 3, May 1, 2007.

23. Capiro, N.L., Stafford, B.P., Rixey, W.G., Alvarez, P.J.J. and Bedient, P.B. "Fuel-Grade Ethanol Transport at the Water Table Interface in a Pilot-Scale Experimental Tank" Water Research, 41(3), pp. 656-654, 2007.

24. Bedient, P.B., Rifai, H.S., Suarez, M.P., and Hovinga, R.M. “Houston Water Issues” Chapter in Water for Texas. Jim Norwine and J.R. Giardino, Eds. pp. 107-121, 2005.

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25. Characklis, G.W., Griffin, R.C., and Bedient, P.B. "Measuring Long-term Benefits of Salinity Reduction" Journal of Agricultural and Resource Economics, 30 (1) (2005): 69-93.

26. Bedient, P.B., Horsak, R.D., Schlenk, D., Hovinga, R.M., and Pierson, J.D. "Environmental Impact on Fipronil to Louisiana Crawfish Industry" Environmental Forensics (2005): 289-299.

27. Characklis, G. W., Griffin, R.C., and Bedient, P.B. "Measuring the Long-term Benefits of Salinity Reduction" Journal of Agricultural and Resource Economics, 30(1), pp.69-93, 2005.

28. Vieux, B.E. and Bedient, P.B. “Assessing urban hydrologic prediction accuracy through event reconstruction” Journal of Hydrology, 299(3-4), pp. 217-236. Special Issue on Urban Hydrology, 2004.

29. Thompson, J.F. and Bedient, P.B. “Urban Storm Water Design and Management” The Engineering Handbook, Chapter 94, CRC Press, 2004, 21 pp.

30. Capiro, N.L. and Bedient P.B. “Transport of Reactive Solute in Soil and Groundwater” The Encyclopedia of Water, John Wiley and Sons, Inc., New York, NY, USA pp. 524-531, 2005.

31. Bedient, P.B., Holder, A., and Benavides, J. “Advanced Analysis of T.S. Allison’s Impacts” submitted to Jn. of American Water Resources Assn., 2004.

32. Bedient, P. B., A. Holder, J. Benavides, and B. Vieux “Radar-Based Flood Warning System applied to TS Allison, ASCE Journal of Hydrologic Engineering, 8(6), pp 308-318, Nov, 2003.

33. Glenn, S., Bedient, P.B., and B. Vieux “Ground Water Recharge Analysis Using NEXRAD in a GIS Framework” submitted to Ground Water, October 2002.

34. Bedient, P.B., Vieux, B.E., Vieux, J.E., Koehler, E.R., and H.L. Rietz “Mitigating Flood Impacts of Tropical Storm Allison” accepted by Bulletin of American Meteorological Society, 2002.

35. El-Beshry, M., Gierke, J.S., and P.B. Bedient “Practical Modeling of SVE Performance at a Jet-Fuel Spill Site” ASCE Journal of Environmental Engineering pp. 630-638, (127) 7, July 2001.

36. El-Beshry, M.Z., Gierke, J.S., and P.B. Bedient “Modeling the Performance of an SVE Field Test” in Chapter 7, Vadose Zone Science and Technology Solutions, Brian B. Looney and Ronald W. Falta Editors, Vol. II, pp. 1157-1169, (2000).

37. Rifai, H.S., Brock, S.M. Ensor, K.B., and P.B. Bedient "Determination of Low-Flow Characteristics for Texas Streams" ASCE Journal of Water Resources Planning and Management, (126)5, pp.310-319, September-October 2000.

38. Bedient, P.B., Hoblit, B.C., Gladwell, D.C., and B.E. Vieux “NEXRAD Radar for Flood Prediction in Houston” ASCE Journal of Hydrologic Engineering, 5(3), pp. 269-277, July 2000.

39. Hamed, M.M., Nelson, P.D., and P.B. Bedient “A Distributed Site Model for Non-equilibrium Dissolution of Multicomponent Residually Trapped NAPL” Environmental Modeling and Software, (15), pp. 443-450, September 2000.

40. Holder, A.W., Bedient, P.B., and C.N. Dawson “FLOTRAN, a Three-dimensional Ground Water Model, with Comparisons to Analytical Solutions and Other Models” Advances in Water Resources, pp. 517-530. 2000.

41. Rifai, H.S., Bedient, P.B., and G.L. Shorr “Monitoring Hazardous Waste Sites: Characterization and Remediation Considerations” Journal of Environmental Monitoring, 2(3), pp. 199-212, June 2000.

42. Hoblit, B.C., Baxter, E.V., Holder, A.W., and P.B. Bedient “Predicting With Precision” ASCE Civil Engineering Magazine, 69(11), pp. 40-43, November 1999.

43. Bedient, P.B., Holder, A.W., Enfield, C.G., and A.L. Wood “Enhanced Remediation Demonstrations at Hill Air Force Base: Introduction” Innovative Subsurface Remediation: Field Testing of Physical, Chemical, and Characterization Technologies, Mark L. Brusseau, et al., eds., pp. 36-48, American Chemical Society, Washington, DC, 1999.

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44. Holder, A.W., Bedient, P.B., and J.B. Hughes “Modeling the Impact of Oxygen Reaeration on Natural Attenuation” Bioremediation Journal, 3(2): 137-149, June 1999.

45. Characklis, G.W., Griffin, R.C., and P.B. Bedient “Improving the Ability of a Water Market to Efficiently Manage Drought” Water Resources Research, (35) 3, 823-831, March 1999.

46. Vieux, B.E. and P.B. Bedient “Estimation of Rainfall for Flood Prediction from WSR-88D Reflectivity: A Case Study, 17-18 October 1994” Weather and Forecasting, 1998 American Meteorological Society, 13:2, 407-415, June 1998.

47. Bedient, P.B. “Hydrology and Transport Processes” Subsurface Restoration, C.H. Ward, J.A. Cherry and M.R. Scalf, editors, Ann Arbor Press, Chelsea, MI, 59-73, 1997.

48. Hamed, M.M. and P.B. Bedient “On the Performance of Computational Methods for the Assessment of Risk from Ground-Water Contamination” Ground Water, 35(4), 638-646, July-August 1997.

49. Hamed, M.M. and P.B. Bedient “On the Effect of Probability Distributions of Input Variables in Public Health Risk Assessment” Risk Analysis, 17(1), 97-105, 1997.

50. Hamed, M.M., Bedient, P.B., and J.P. Conte “Numerical Stochastic Analysis of Groundwater Contaminant Transport and Plume Containment” Journal of Contaminant Hydrology, 1996, 24 pp.

51. Hamed, M.M., Bedient, P.B., and C.N. Dawson “Probabilistic Modeling of Aquifer Heterogeneity Using Reliability Methods” Advances in Water Resources, 19(5), 277-295, 1996.

52. Sweed, H., Bedient, P.B., and S.R. Hutchins "Surface Application System for In-Situ Bioremediation: Site Characterization and Modeling" Groundwater Journal, 34(2), 211-222, 1996.

53. Hamed, M.M., Conte, J.P., and P.B. Bedient "Uncertainty Analysis of Subsurface Transport of Reactive Solute Using Reliability Methods" Groundwater Models for Resources Analysis and Management, CRC Press, Inc., Chapter 8:123-135 1995.

54. Hamed, M.M., Conte, J.P., and P.B. Bedient "Probabilistic Screening Tool for Groundwater Contamination Assessment" ASCE Journal of Environmental Engineering, 121(11): 767-775, (1995).

55. Rifai, H.S. and P.B. Bedient "A Review of Biodegradation Models: Theory and Applications" Groundwater Models for Resources Analysis and Management, CRC Press, Inc., Chapter 16:295-312 (1995).

56. Rifai, H. S., Newell, C. J., Bedient, P.B., Shipley, F.S., and R.W. McFarlane, The State of the Bay, The Galveston Bay National Estuary Program, Webster, TX, 232 pp. (1994).

57. Rifai, H.S. and P.B. Bedient "Modeling Contaminant Transport and Biodegradation in Ground Water" Advances in Environmental Science Groundwater Contamination, Volume I: Methodology and Modeling, Springer-Verlag, New York, NY (1994).

58. Bedient, P.B. and H.S. Rifai "Modeling in Situ Bioremediation" In Situ Bioremediation, When Does It Work?” National Academy Press, pp. 153-159 (1993).

59. Rifai, H. S., Bedient, P.B., Hendricks, L.A., and K. Kilborn "A Geographical Information System (GIS) User Interface for Delineating Wellhead Protection" Ground Water, 31:3, pp. 480-488 (1993).

60. H. S. Rifai, Newell, C. J., and P.B. Bedient "Getting to the Nonpoint Source with GIS" Civil Engineering, June, pp. 44-46 (1993).

61. H. S. Rifai, Newell, C. J., and P.B. Bedient "GIS Enhances Water Quality Modeling" GIS World, August, pp. 52-55 (1993).

62. Bedient, P.B., Schwartz, F.W., and H.S. Rifai "Hydrologic Design for Groundwater Pollution

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Control" Handbook of Hydrology, McGraw Hill, pp. 29.1-29.47 (1993).

63. Wise, W.R., Robinson, G.C., and P.B. Bedient "Chromatographic Evidence for Nonlinear Partitioning of Aromatic Compounds Between Petroleum and Water" Ground Water, 30(6): 936-944. (Nov. - Dec. 1992).

64. Charbeneau, R.J., Bedient, P.B., and R.C. Loehr, Groundwater Remediation, Technomic Publishing Co., Inc., Lancaster, PA, 188 pages (1992).

65. Bedient, P.B. and H.S. Rifai "Ground Water Contaminant Modeling for Bioremediation: A Review" Journal of Hazardous Materials, 32:225-243 (1992).

66. Kilborn, K., Rifai, H.S., and P. B. Bedient "Connecting Groundwater Models and GIS" Geo Info Systems, pp. 26-31, (February 1992).

67. Rifai, H. S. and P. B. Bedient "Modeling Contaminant Transport and Biodegradation in Ground Water" To be published in Textbook: Advances in Environmental Science Groundwater Contamination, Volume I: Methodology and Modeling, Springer Verlag, (In Press) (September 1991).

68. Newell, C.J., Rifai, H.S., and P.B. Bedient "Characterization of Non-Point Sources and Loadings to Galveston Bay" Galveston Bay National Estuary Program, Houston, Texas, 150 pp (October 1991).

69. Rifai, H.S., Long, G.P., and P.B. Bedient "Modeling Bioremediation: Theory and Field Application" In Situ Bioreclamation Applications and Investigations for Hydrocarbon and Contaminated Site Remediation, Ed. by R. E. Hinchee and R. F. Olfenbuttel, Battelle Memorial Institute, Butterworth-Heinemann, Boston, (1991).

70. Kilborn, K., Rifai, H.S., and P.B. Bedient "The Integration of Ground Water Models with Geographic Information Systems (GIS)" 1991 ACSM/ASPRS 10 Annual Convention, Baltimore, Maryland, In Technical Papers, vol. 2, pp. 150-159, (March 1991).

71. Wise, W.R., Chang, C.C., Klopp, R.A., and P. B. Bedient "Impact of Recharge Through Residual Oil Upon Sampling of Underlying Ground Water" Ground Water Monitoring Review, pp. 93-100 (Spring 1991).

72. Rifai, H.S. and P.B. Bedient "Comparison of Biodegradation Kinetics with an Instantaneous Reaction Model for Ground Water" Water Resource. Res. 26:637-645 (1990).

73. Newell, C.J., Hopkins, L.P., and P.B. Bedient "A Hydrogeologic Database for Ground Water Modeling" Ground Water 28:703-714 (1990).

74. Newell, C.J., Haasbeek, J.F., and P.B. Bedient "OASIS: A Graphical Decision Support System for Ground Water Contaminant Modeling" Ground Water 28:224-234 (1990).

75. Chiang, C.Y., Wheeler, M.F., and P.B. Bedient "A Modified Method of Characteristics Technique and Mixed Finite Elements Method for Simulation of Ground Water Contaminant Transport" Water Resource. Res. 25:1541-1549 (1989).

76. Todd, D.A., Bedient, P.B., Haasbeek, J.F., and J. Noell "Impact of Land Use and NPS Loads on Lake Water Quality" ASCE J. Environmental Engr. Div. 115:633-649 (1989).

77. Borden, R.C., Lee, M.D., Thomas, J.M., Bedient, P.B., and C.H. Ward “In Situ Measurement and Numerical Simulation of Oxygen Limited Biotransformation" Ground Water Monitoring Review. Rev. 9:83-91 (1989).

78. Rifai, H.S., Bedient, P.B., Wilson, J.T., Miller, K.M., and J.M. Armstrong "Biodegradation Modeling at an Aviation Spill Site" ASCE J. Environmental Engr. Div. 114:1007-1019 (1988).

79. Satkin, R.L. and P.B. Bedient "Effectiveness of Various Aquifer Restoration Schemes under Variable Hydrogeologic Conditions" Ground Water Monitoring Review. , 26:488-498 (1988).

80. Todd, D.A. and P B. Bedient "Stream Dissolved Oxygen Analysis and Control" (Closure), ASCE

13

J. Environmental Engr. Div. 113:927-928 (1987).

81. Freeberg, K.M., Bedient, P.B., and J.A. Connor "Modeling of TCE Contamination and Recovery in a Shallow Sand Aquifer" Ground Water Monitoring Review. 25:70-80 (1987).

82. Borden, R.C. and P.B. Bedient "In Situ Measurement of Adsorption and Biotransformation at a Hazardous Waste Site" Water Resources Report. Bull. 23(4): 629-636 (1987).

83. Borden, R.C., Bedient, P.B., Lee, M.D., Ward, C.H., and J.T. Wilson " Transport of Dissolved Hydrocarbons Influenced by Oxygen Limited Biodegradation: 2. Field Application" Water Resources Report. Res. 22:1983-1990 (1986).

84. Borden, R.C. and P.B. Bedient "Transport of Dissolved Hydrocarbons Influenced by Reaeration and Oxygen Limited Biodegradation: 1. Theoretical Development" Water Resources Report. Res. 22:1973-1982 (1986).

85. C.H. Ward, Tomson, M.B., Bedient, P.B., and M.D. Lee "Transport and Fate Processes in the Subsurface" In R. C. Loehr, and J.F. Malina, Jr., eds., Land Treatment, A Hazardous Waste Management Alternative, Center for Research in Water Resources, University of Texas, Austin, TX, pp. 19-39. (1986).

86. Wilson, J.T., McNabb, J.F., Cochran, J.W., Wang, T.H., Tomson, M.B., and P.B. Bedient "Influence of Microbial Adaptation on the Fate of Organic Pollutants in Ground Water" Environ. Toxicol. Chem. 4:721-726 (1985).

87. Bedient, P.B. "Overview of Subsurface Characterization Research" In Ward, C.H., Giger, W., and P. L. McCarty, eds., Ground Water Quality, John Wiley & Sons, Inc., New York, NY, pp. 345-347 (1985).

88. Bedient, P.B., Flores, A., Johnson, S., and P. Pappas "Floodplain Storage and Land Use Analyses at the Woodlands, Texas" Water Resources Research. Bull. 21:543-551 (1985).

89. Hutchins, S.R., Tomson, M.B., Bedient, P.B., and C.H. Ward "Fate of Trace Organics During Land Application of Municipal Wastewater" CRC Crit. Rev. Environ. Control 15:355-416 (1985).

90. Todd, D.A. and P.B. Bedient "Stream Dissolved Oxygen Analysis and Control" ASCE J. Environmental Engr. Div. 111:336-352 (June 1985).

91. Chiang, C.Y. and P.B. Bedient "PIBS Model for Surcharged Pipe Flow" ASCE J. Hydraulics Div. 112:181-192 (1985).

92. Bedient, P.B., Borden, R.C., and D.I. Leib "Basic Concepts for Ground Water Transport Modeling" In Ward, C.H., Giger, W., and P.L. McCarty, eds., Ground Water Quality, John Wiley & Sons, Inc., New York, NY, pp. 512-531, (1985).

93. Bedient, P.B., Rodgers, A.C., Bouvette, T.C., and M.B. Tomson "Ground Water Quality at a Creosote Waste Site" Ground Water 22:318-319 (1984).

94. Bedient, P.B. and P.G. Rowe, eds., Urban Watershed Management: Flooding and Water Quality, Rice University Studies, 205 pp. (March 1979).

95. Bedient, P.B., Huber, W.C., and J. Heaney “Environmental Model of the Kissimmee River Basin” ASCE Water Resources Planning and Management, Vol. 103, No. WR2, (1977).

Conference Proceedings and Other Technical Publications

1. Juan, A., Fang, Z., and Bedient, P. B. (2012). “Flood Warning Indicator: Establish a Reliable Radar-Based Flood Warning System for Sugar Land, Texas”, American Geophysical Union (AGU) 2012 Fall Meeting, San Francisco, CA, December 3-7.

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2. Deitz, R., Christian, J. K., Wright, G., Fang, Z., and Bedient, P. B. (2012). “Linkage of Rainfall-Runoff and Hurricane Storm Surge in Galveston Bay”, American Geophysical Union (AGU) 2012 Fall Meeting, San Francisco, CA, December 3-7.

3. Bedient, P. B., Doubleday, G., Sebastian, A., and Fang, Z. (2012). “Distributed Hydrologic Modeling of LID in the Woodlands, Texas”, American Geophysical Union (AGU) 2012 Fall Meeting, San Francisco, CA, December 3-7.

4. Burcham, M., Bedient, P. B., McGuire, T., Adamson, D.,. New Ch., (2012) Occurrence of Sustained Treatment Following Enhanced Anaerobic Bioremediation at Chlorinated Solvent Sites , AGU Fall Meeting, San Francisco, California, December 3-7 2012

5. Fang, Z. and Bedient, P., Performance Evaluation of a NEXRAD-Based Flood Warning during

Recent Events in 2012 , AGU Fall Meeting, San Francisco, California, December 3-7 2012

6. Juan, A., Fang, Z. and Bedient, P., Radar-based Flood Warning Indicator for the Upper Oyster Creek Watershed in Sugar Land, Texas AGU Fall Meeting, San Francisco, California, December 3-7 2012

7. Environmental and Water Res. Inst. (EWRI) 2012 Congress, Organized three sessions for

SSPEED research results. Albuquerque, New Mexico, May 20-24 2012.

8. Fang, Z. and Bedient, P. B. (2012). “Creating Flood Alert Systems in Coastal Areas”, SSPEED Conference – Gulf Coast Hurricanes: Mitigation and Response, Houston, Texas, April 10.

9. Fang, Z. and Bedient, P. B. (2012). “Advanced Radar-Based Flood Warning System for Urban Areas and its Performance Evaluation”, SSPEED Conference – Gulf Coast Hurricanes: Mitigation and Response, Houston, Texas, April 11.

10. Teague, A, and Bedient, P. B. (2011). “Visualization of Hydrologic Simulations with Pollutant Load Estimation for Cypress Creek Watershed, Houston, Texas”. 2011 World Environmental and Water Resources Congress. Palm Springs California 22-26 May 2011.

11. Christian, J. K., Fang, Z., and Bedient, P. B. (2011). “Probabilistic Floodplain Delineation”, 2011 World Environmental and Water Resources Congress, Palm Springs, California. May 22-26

12. Fang, Z., Juan, A., Bedient, P. B., Kumar, S., and Steubing, C. (2011). “Flood Warning Indicator: Establishing a Reliable Radar-Based Flood Warning System for the Upper Oyster Creek Watershed”, ASCE/TFMA, TFMA 2011 Annual Conference, Sugar Land, Texas, April 11- 14.

13. Bedient, P. B. and Fang, Z. (2010). "Advanced Radar-based Flood Warning System for Hurricane-prone Urban Areas and Performance during Recent Events", 2nd International Conference on Flood Recovery, Innovation and Response (FRIAR), Milano, Italy, May 26-28.

14. Fang, Z., Juan, A., Bedient, P. B., Kumar, S., and Steubing, C. (2010). "Flood Alert System for Upper Oyster Creek Watershed in Sugar Land, Texas using NEXRAD, HEC-HMS, HEC-RAS, and GIS", ASCE/TFMA, TFMA 2010 Annual Conference, Fort Worth, Texas, June 7- 10.

15. Fang, Z. and Bedient, P. B. (2010). "Radar Applications in Flood Warning System for an Urban Watershed in Houston, Texas", Remote Sensing and Hydrology 2010 Symposium - Special Session on Flood Forecasting and Management with Remote Sensing and GIS, Jackson Hole, WO, September 27 -30.

16. Bedient, P. B., Fang, Z., and Vieux, B. E. (2010). "Radar-based Flood Warning System for the Texas Medical Center and Performance Evaluation", National Flood Workshop, Houston, Texas, October 24-26.

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17. Teague, A. and Bedient, P. 2010. “Distributed Modeling of Water Quality in Cypress Creek Watershed, Houston, Texas”. 21st Century Watershed Technology: Improving Water Quality and the Environment, EARTH University, Costa Rica, February 21-24, 2010.

18. Teague, A. and Bedient, P. 2010. “Visualization of Hydrologic Simulations in Support of Water Quality Applications for Cypress Creek, Houston, Texas”. Conference Proceedings. Annual Water Resources Conference, American Water Resources Association. November 1-4, 2010, Philadelphia, PA.

19. Teague, A. and Bedient, P. 2010. “Distributed Water Quality Modeling for a Drinking Water Source Watershed for the City of Houston, Texas”. Conference Proceedings. World Environmental and Water Resources Congress. May 16-20, 2010, Providence, RI.

20. Fang, Z. and Bedient, P.B. (2009). “Radar-based Flood Warning System for Houston and Its Performance Evaluation”. American Geophysical Union (AGU) 2009 Fall Meeting, December 14-18, San Francisco, CA.

21. Fang, Z. and Bedient, P.B. (2009). “Radar-based Flood Alert System for Coastal Area and Collaborated Efforts for Disaster Prevention and Risk Management”. IRCD 34th Annual Natural Hazards Research and Applications Workshop – Hazards and the Economy: Challenges and Opportunity, July 15-18, Boulder, CO.

22. Fang, Z. and Bedient, P.B. (2009). “Flood Inundation Prediction and Performance during Hurricane Ike”. Proceedings of World Environmental & Water Resources Congress 2008, Environmental and Water Resources Institute (EWRI), ASCE, Kansas City, Missouri, May 17-21.

23. Robinson, H., Fang, Z. and Bedient, P.B. (2009). “Distributed Hydrologic Modeling of the Yuna River Watershed in the Dominican Republic”. Proceedings of World Environmental & Water Resources Congress 2008, Environmental and Water Resources Institute (EWRI), ASCE, Kansas City, Missouri, May 17-21.

24. Ray, T., Fang, Z., and Bedient, P.B. (2009). “Assessment of Flood Risk Due to Storm Surge in Coastal Bayous Using Dynamic Hydraulic Modeling”. Proceedings of World Environmental & Water Resources Congress 2008, Environmental and Water Resources Institute (EWRI), ASCE, Kansas City, Missouri, May 17-21.

25. Fang, Z. and Bedient, P.B. (2009). “Advanced Radar-based Flood Forecasting Systems for a Highly Urbanized Coastal Area and SSPEED Center”, ASCE/TFMA Flood Awareness and Flood Response Workshop, April 29, San Marcos, TX.

26. Fang, Z. and Bedient, P.B. (2009). “Flood Warning Systems for Urban Flooding”. Grand Challenges in Coastal Resiliency I: Transforming Coastal Inundation Modeling to Public Security, January 20-21, Baton Rouge, LA.

27. Fang, Z. and Bedient, P.B. (2008). “NEXRAD Radar-based Hydraulic Flood Prediction System for a Major Evacuation Routes in Houston”. American Geophysical Union 2008 Fall Meeting, December 15-19, San Francisco, CA.

28. Fang, Z. and Bedient, P.B. (2008). “Advanced Flood Alert System with Hydraulic Prediction for a Major Evacuation Route in Houston”. Proceedings of American Water Resources Association (AWRA) Annual Conference 2008, New Orleans, Louisianan, November 17-20.

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29. Fang, Z. and Bedient, P.B. (2008). “Flood Inundation Prediction and Performance during Hurricane Ile”. Proceedings of Severe Storm Prediction and Global Climate Impact in the Gulf Coast Conference 2008, Houston, Texas, October 28-31.

30. Bedient, P.B. and Fang, Z. (2008). “Predicting and Managing Severe Storms in the Gulf Coast through University Research”. Proceedings of Severe Storm Prediction and Global Climate Impact in the Gulf Coast Conference 2008, Houston, Texas, October 28-31.

31. Robinson, H., Fang, Z. and Bedient, P.B. (2008). “Distributed Hydrologic Model Development in the Topographically Challenging Yuna River Watershed, Dominican Republic”. Proceedings of Severe Storm Prediction and Global Climate Impact in the Gulf Coast Conference 2008, Houston, Texas, October 28-31.

32. Ray, T., Fang, Z. and Bedient, P.B. (2008). “Assessment of Flood Risk Due to Storm Surge in Coastal Bayous Using Dynamic Hydraulic Modeling”. Proceedings of Severe Storm Prediction and Global Climate Impact in the Gulf Coast Conference 2008, Houston, Texas, October 28-31.

33. Fang, Z. and Bedient, P.B. (2008). “Floodplain Map Library (FPML): Innovative Method for Flood Warning System for Urban Watershed in Houston, TX”. Proceedings of World Environmental & Water Resources Congress 2008, Environmental and Water Resources Institute (EWRI), ASCE, Honolulu, Hawaii, May 13-16.

34. Bedient, P.B., “Foresight Panel on Environmental Effects” Houston-Galveston Area Council, Houston, Texas, February 5, 2008

35. Bedient, P.B., Fang, Z., Hovinga, R, M., “Flood Warning System (FAS2) Rice University Training, Houston, Texas, January 15, 2008

36. Bedient, P.B., Fang, Z., Hovinga, R, M., SSPEED Meeting, Houston, Texas, November 16, 2007

37. Fang, Z. and Bedient, P.B. “Real-time Hydraulic Prediction Tool – Floodplain Map Library (FPML)”. American Water Resources Association 2007 Annual Conference, Albuquerque, New Mexico, November 12-15, 2007

38. Fang, Z. and Bedient, P.B. “Enhanced NEXRAD Radar-based Flood Warning System with Hydraulic Prediction Feature: Floodplain Map Library (FPML)”. American Geophysical Union 2007 Fall Meeting, San Francisco, CA. December 10-14, 2007

39. Fang, Z. and Bedient, P.B. “The Future of Flood Prediction in Coastal Areas” Severe Storm Prediction, Evacuation, and Education from Disasters Conference, Rice University, Houston Texas, May 8-10, 2007

40. Bedient, P.B. and Fang, Z. “Radar-based Flood Warning System Using Dynamic Floodplain Map Library.” Proceedings of World Environmental & Water Resources Congress 2007, Environmental and Water Resources Institute (EWRI), ASCE, Tampa, Florida, May 15-19, 2007

41. Bedient, P.B., and C. Penland “A Radar Based FAS for Houston’s Texas Medical Center” IDRC Conference, Davos, Switzerland, Aug 2006.

42. Safiolea, E. and P.B. Bedient "Comparative Analysis of the Hydrologic Impact of Land Use Change and Subsidence in an Urban Environment" Proceedings of AWRA GIS Conference, Houston, TX, May 8-10, 2006.

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43. Bedient, P.B., Fang, Z., and R. Hovinga "Prediction for Severe Storm Flood Levels for Houston Using Hurricane Induced Storm Surge Models in GIS Frame" Proceedings of AWRA GIS Conference, Houston, TX, May 8-10, 2006.

44. Fang, Z., Safiolea, E., and P.B. Bedient "Enhanced Flood Alert and Control Systems for Houston" Proceedings of 25th American Institute of Hydrology Conference, Baton Rouge, LA, May 21-24, 2006.

45. Gordon, R. and P.B. Bedient "Rice University Engineers Without Borders: An Exercise in International Service Learning" Proceedings of the ASE Education Conference, Chicago, June 18-21, 2006.

46. Gordon, R., Benavides, J.A., Hovinga, R., Whitko, A.N., and P.B. Bedient "Urban Floodplain Mapping and Flood Damage Reduction Using LIDAR, NEXRAD, and GIS" Proceedings of the 2006 AWRA Spring Specialty Conference: GIS and Water Resources IV, Houston, TX, May 8-10, 2006.

47. Fang, Z. and P.B. Bedient "IP2 Houston Flood Alert and Response-2006" CASA Meeting, Estes Park, Co, October 16-17, 2006.

48. Safiolea, E., Bedient, P.B., and B.E. Vieux "Assessment of the Relative Hydrologic Effects of Land Use Change and Subsidence Using Distributed Modeling" (July 2005).

49. Holder, A.W., Hoblit, B., Bedient, P.B., and B.E. Vieux “Urban Hydrologic Forecasting Application Using the NEXRAD Radar in Houston” Proceedings of the Texas Section American Society of Civil Engineers, Austin, TX, pp. 279-288, April 5-8, 2000.

50. Benavides, J.A., Pietruszewski, B., Stewart, E., and P.B. Bedient “A Sustainable Development Approach for the Clear Creek Watershed” Proceedings of the Texas Section American Society of Civil Engineers, Austin, TX, pp. 269-278, April 5-8, 2000.

51. Bedient, P.B., Rifai, H.S., and C.W. Newell "Decision Support System for Evaluating Pump-and-Treat Remediation Alternatives" Pollution Modeling: Vol. 1, Proceedings for Envirosoft 94, November 16-18, 1994, San Francisco, CA, Edited by P. Zannetti, Computational Mechanics Publications, Wessex Inst of Technology, Southampton, UK.

52. Hamed M.M. and P.B. Bedient “Uncertainty Analysis of Natural Attenuation in Groundwater Systems,” Proceedings of the In Situ and On-Site Bioremediation Symposium, New Orleans, LA, 1997, 1:43-48.

53. Hamed, M.M., Holder, A.W., and P.B. Bedient “Evaluation of Reaeration Using a 3-D Groundwater Transport Model” Proceedings of the In Situ and On-Site Bioremediation Symposium, New Orleans, LA, 1997, 1:75-80.

54. Holder, A.W., Bedient, P.B., and J.B. Hughes “TCE and 1,2-DCE Biotransformation Inside a Biologically Active Zone” Proceedings of the First International Conference on Remediation of Chlorinated and Recalcitrant Compounds, Monterey, CA, May 18-21, 1:219-224, 1998.

55. Hamed M.M. and P.B. Bedient “Uncertainty Analysis of Natural Attenuation in Groundwater Systems” Proceedings of the In Situ and On-Site Bioremediation Symposium, New Orleans, LA, 1997, 1:43-48.

56. Hamed, M.M., Holder, A.W., and P.B. Bedient “Evaluation of Reaeration Using a 3-D Groundwater Transport Model” Proceedings of the In Situ and On-Site Bioremediation Symposium, New Orleans, LA, 1997, 1:75-80.

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57. Hamed, M.M., Bedient, P.B., and J.P. Conte “Probabilistic Modeling of Contaminant Transport in the Subsurface” Proceedings of the International Association of Hydro geologists Conference Solutions ‘95”, Edmonton, Canada, June 4-10, 1995.

58. Bedient, P.B., Rifai, H.S., and C.W. Newell "Decision Support System for Evaluating Pump-and-Treat Remediation Alternatives" Pollution Modeling: Vol. 1, Proceedings for Envirosoft 94, November 16-18, 1994, San Francisco, CA, Edited by P. Zannetti, Computational Mechanics Publications, Wessex Institute of Technology, Southampton, UK.

59. Burgess, K. S., Rifai, H. S., and P. B. Bedient "Flow and Transport Modeling of a Heterogeneous Field Site Contaminated with Dense Chlorinated Solvent Waste" Proceedings of the Petroleum Hydrocarbons and Organic Chemicals in Ground Water: Prevention, Detection, and Restoration, Houston, TX (Nov. 10-12, 1993).

60. Hamed, M., Conte, J., and P. B. Bedient "Reliability Approach to the Probabilistic Modeling of Ground Water Flow and Transport" Proceedings of the Petroleum Hydrocarbons and Organic Chemicals in Ground Water: Prevention, Detection, and Restoration, Houston, TX (Nov. 10-12, 1993).

61. Rifai, H.S. and P.B. Bedient "Ground Water Contaminant Modeling for Bioremediation: A Review" Proceedings of the 4th Annual Symposium on Ground Water: The Problem and Some Solutions, The Gulf Coast Hazardous Substance Research Center, Lamar University, Beaumont, Texas, 101-121 (April 2-3, 1992).

62. Thomas, J.M., Duston, K.L., Bedient, P.B., and C.H. Ward "In Situ Bio-restoration of Contaminated Aquifers and Hazardous Waste Sites in Texas" Proceedings for the Petro-Safe 92, 3rd Annual Environmental and Safety Conference for the Oil, Gas & Petrochemical Industries, Houston, TX, Vol. 3, pp. 889-898 (1992).

63. Bedient, P.B., Long, G.P., and H.S. Rifai "Modeling Natural Biodegradation with BIOPLUME II" Proceedings of the 5th International Conference, Solving Ground Water Problems with Models, Dallas, Texas, pp 699-714. (February 11-13, 1992).

64. Robinson, G.C. and P.B. Bedient "Modeling a Time-Variant Source of Contamination" Proceedings of the Petroleum Hydrocarbons and Organic Chemicals in Ground Water: Prevention, Detection, and Restoration, Houston, Texas, pp. 531-540. (November 20-22, 1991).

65. Chang, C. and P. B. Bedient "Multiphase Unsaturated Zone Flow and Transport Model for Ground Water Contamination by Hydrocarbon" Proceedings of the Petroleum Hydrocarbons and Organic Chemicals in Ground Water: Prevention, Detection, and Restoration, Houston, Texas, pp. 515-529 (November 20-22, 1991).

66. Bedient, P.B., Vance, L.A., and H.S. Rifai "Implementation of Wellhead Protection Programs Utilizing Geographical Information Systems" Proceedings of the Eighth National Conference on Microcomputers in Civil Engineering, University of Central Florida and The American Society of Civil Engineers, Orlando, Florida, pp. 87-90 (October 1990).

67. Rifai, H.S., Bedient, P.B., and C.J. Newell "Review and Analysis of the Toxicity Characteristics Composite Landfill Model" Proceedings of the Petroleum Hydrocarbons and Organic Chemicals in Ground Water: Prevention, Detection and Restoration, The Association of Ground Water Scientists and Engineers (NWWA), Houston, Texas, pp.143-157 (October 1990).

68. Rifai, H.S. and P.B. Bedient "A TC Model Alternative for Production Waste Scenarios" Proceedings of the First International Symposium on Oil and Gas Exploration and Production Waste Management Practices, U.S. Environmental Protection Agency, New Orleans, LA, pp.

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955-965 (September 1990).

69. Chang, C.C., Wise, W.R., Klopp, R.A., and P.B. Bedient "In Situ Source Release Mechanism Study at an Aviation Gasoline Spill Site: Traverse City, Michigan" Proceedings of the Fourth National Outdoor Action Conference on Aquifer Restoration, Ground Water Monitoring and Geophysical Methods, Las Vegas, NV, pp. 459-473 (May 1990).

70. Hopkins, L.P., Newell, C.J., and P.B. Bedient "A Hydrogeologic Database for the Hazardous Waste Regulatory Modeling" Proceedings of the Petroleum Hydrocarbons and Organic Chemicals in Ground Water Conference, National Water Well Association, Houston, TX, pp. 265-279 (November 1989).

71. Alder-Schaller, S.E. and P.B. Bedient "Evaluation of the Hydraulic Effect of Injection and Pumping Wells on In Situ Bioremediation" Proceedings of the Petroleum Hydrocarbons and Organic Chemicals in Ground Water Conference, National Water Well Association, Houston, TX, pp. 191-201 (November 1989).

72. Smythe, J.M., Bedient, P.B., and R.A. Klopp “Cone Penetrometer Technology for Hazardous Waste Site Investigations” Proceeding of the Second National Outdoor Action Conference on Aquifer Restoration, Ground Water Monitoring and Geophysical methods, Association of Ground Water Scientists and Engineers, Las Vegas, NV, pp. 71-94 (1989).

73. Rifai, H.S. and P.B. Bedient "Bio-restoration Modeling of a Pilot Scale Field Experiment" Proceedings of the National Water Well Association on Solving Ground Water Problems with Models, Indianapolis, IN, pp. 1187-1203 (1989).

74. Wheeler, M.F., Dawson, C., and P.B. Bedient "Numerical Modeling of Subsurface Contaminant Transport with Biodegradation Kinetics" Proceedings of the NWWA Conference on Petroleum Hydrocarbons and Organic Chemicals in Ground Water, Houston, TX, pp. 47l-489 (1987).

75. Newell, C.J. and P.B. Bedient "Development and Application of a Ground Water Modeling Database and Expert System" Proceedings of the NWWA Conference on Petroleum Hydrocarbons and Organic Chemicals in Ground Water, Houston, TX, pp. 559-578 (1987).

76. Rifai, H.S. and P. B. Bedient "BIOPLUME II - Two Dimensional Modeling for Hydrocarbon Biodegradation and In Situ Restoration" Proceedings of the NWWA Conference on Petroleum Hydrocarbons and Organic Chemicals in Ground Water, Houston, TX, pp. 431-450 (1987).

77. Wheeler, M.F., Dawson, C.N., and P.B. Bedient "Numerical Simulation of Microbial Biodegradation of Hydrocarbons in Ground Water" Proceedings of the NWWA/IGWMC Conference on Solving Ground Water Problems with Models, Denver, CO, February 10-12, Vol. 1, pp. 92-109 (1987).

78. Chiang, C.Y. and P.B. Bedient "Simplified Model for a Surcharged Stormwater System" Proceedings of the Third Int'l Conf. on Urban Storm Drainage, Goteborg, Sweden, pp. 387-396 (1985).

79. Wang, T.H., Curran, C.M., Bedient, P.B., and M.B. Tomson "Ground Water Contamination at Conroe Creosote Waste Disposal Site" Proceedings of the Second Int'l Conf. on Ground Water Quality Research, OSU University Printing Services, Stillwater, OK, pp. 50-52 (1985).

80. Borden, R.C., Bedient, P.B., and T. Bouvette "Modeling Ground Water Transport at Conroe Creosote Waste Site" Proceedings of the Second Int'l Conf. on Ground Water Quality Research, OSU University Printing Services, Stillwater, OK, p. 88-90 (1985).

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81. Todd, D.A. and P.B. Bedient "Use of Qual-II to Model Stream Protection Alternatives" Proceedings of the ASCE 1984 National Conference on Environmental Engineering, Los Angeles, CA, June 1984, pp. 60-65 (1984).

Invited Lectures (Recent)

1. The Resilience and Adaptation to Climate Risks Workshop: NASA Johnson Space Center and the Houston/Galveston Area, March 8, 2012, Houston, Texas

2. Bedient, P.B., SSPEED Conference. Chair and Organizer, “Hurricane Ike, Revisited,” September 14, 2009, Houston, Texas.

3. Bedient, P.B., SSPEED Conference. Chair and Organizer, “Severe Storm Prediction and Global Climate Impact in the Gulf Coast,” Sponsored by American Institute of Hydrology. October 29-31, 2008, Houston, Texas. (Attended by over 150 guests and speakers).

4. Bedient, P.B., SSPEED Conference. Chair and Organizer, “Severe Storm Prediction and Global Climate Impact in the Gulf Coast,” Sponsored by American Institute of Hydrology. October 29-31, 2008, Houston, Texas. (Attended by over 150 guests and speakers).

5. Bedient, P.B., Robinson, and H., Fang, Z. (2008). “Distributed Hydrologic Model Development in the Topographically Challenging Yuna River Watershed, Dominican Republic”. Meeting in Dominican Republic before the President October 20, 2008.

6. Bedient, P.B. (June, 2008) Plan for the Dominican Republic Flood Study, before the Ministers of Education, Environment, and Economic Development.

7. Bedient, P.B. "Advanced Flood Alert Systems in Texas" International Disaster Response Conference, Daves, Switzerland, August 28, 2006.

8. Bedient, P.B. "IP2 Flood Alert System for Houston" CASA Meeting NSF Review, UMASS. April, 2006.

9. Bedient, P.B. "Severe Storm Impacts in the Gulf Coast" Severe Storm Impacts and Disaster Response in Gulf Coast, Houston, Rice University, March 15-16, 2006.

10. Bedient, P.B. "Living with Severe Storms in the Gulf Coast- Scientia Lecture" Rice University, Houston, TX. (September 2005).

11. Bedient, P.B., Fang, Z., Safiolea, E., and B.E. Vieux "Enhanced Flood Alert System for Houston" 2005 National Hydrologic Council Conference: Flood Warning Systems, Technologies and Preparedness, Sacramento, California. (May 16-20)

12. Fang, Z. and Bedient, P.B. “Enhanced Flood Alert and Control Systems for Houston” Proceedings of the 25th American Institute of Hydrology Conference: Challenges of Coastal Hydrology and Water Quality. Baton Rouge, Louisiana, May 21-24, 2006.

13. Fang, Z., Bedient, P.B., and R. Hovinga “Prediction of Severe Storm Flood Levels for Houston Using Hurricane Induced Storm Surge Models in a GIS Frame” Proceedings of AWRA 2006 Spring Specialty Conference: GIS and Water Resources IV. Houston, Texas, May 8-10, 2006.

14. Bedient, P.B. "Impacts of Climate Change on Transportation Systems and Infrastructure” Gulf Coast Study, Lafayette, LA. (May 2005)

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15. Capiro, N.L., Da Silva, M.L.B., Stafford, B.P., Alvarez, P.J.J., and P.B. Bedient "Changes in Microbial Diversity Resulting from a Fuel-Grade Ethanol Spill" Eighth International Symposium on In Situ and On-Site Bioremediation, Baltimore, MD. (June 2005).

16. Safiolea, E. and P. B. Bedient "Assessment of the Relative Hydrologic Effect of Land Use Change and Subsidence Using Distributed Modeling” EWRI Watershed Management Conference, Williamsburg, VA. (July 9-22, 2005)

17. Capiro, N.L., Stafford, B., He, X., Rixey, W.G., and P.B. Bedient “A Large-Scale Experimental Investigation of Ethanol Impacts on Groundwater Contamination” Presentation at the Fourth International Conference on Remediation of Chlorinated and Recalcitrant Compounds; Monterey, CA; May 2004.

18. Capiro, N.L., Da Silva, M.L.B., Stafford, B.P., Alvarez, P.J.J., and P.B. Bedient “Changes in Microbial Diversity Resulting from a Fuel-Grade Ethanol Spill” Accepted for Presentation at The Eighth International Symposium on In Situ and On-Site Bioremediation; Baltimore, MD. June 2005.

19. Safiolea, E. and P.B. Bedient “Analysis of Altered Drainage Patterns and Subsidence Impact Using a Distributed Hydrologic Model” AWRA Annual Water Resources Conference in Orlando FL, November 2004.

20. Safiolea, E. and Philip B. Bedient ” Assessment of the Relative Hydrologic Effect of Land Use Change and Subsidence using Distributed Modeling” EWRI Watershed Management Conference in Williamsburg VA, Jul19-22, 2005.

21. Bedient, P.B. and J.A. Benavides “Use of QPE and QPF for Flood Alert (FAS2) in the Houston, TX Test Bed“ CASA NSF ERC Conference, “ Estes Park, CO, October, 2004.

22. Capiro, N.L., Adamson, D.T., McDade, J.M., Hughes, J.B., and P.B. Bedient “Spatial Variability of Dechlorination Activity Within a PCE DNAPL Source Zone” Presentation The 7th International Symposium In Situ and On-Site Bioremediation; Orlando, FL; June 2003

23. Benavides, J.A. and P.B. Bedient "Improving the Lead-Time and Accuracy of a Flood Alert System in an Urban Watershed" 2003 AWRA Annual Conference, San Diego, California, November 2003.

24. Whitko, A.N. Bedient, P.B., and S. Johnson "Sustainable Flood Control Strategies in the Woodlands – Thirty Years Later" 2003 AWRA Annual Conference, San Diego, California, November 2003.

25. Safiolea E., Hovinga, R., and P.B. Bedient " Impact of Development Patterns on Flooding in Northwest Houston using LIDAR Data” 2003 AWRA Annual Conference, San Diego, California, November 2003

26. Benavides, J.A. and P.B. Bedient "Improving the Performance of a Flood Alert System Designed for a Rapidly Responding Urban Watershed" 2003 Conference on Flood Warning Systems Technologies and Preparedness, Dallas, Texas. October 2003.

27. Bedient, P.B., Holder, A., and Baxter Vieux “A Radar-Based Flood Alert System (FAS) Designed for Houston, TX” International Conference on Urban Storm Drainage, Portland, OR, September 2002.

28. Holder, A., Stewart, E., and P.B. Bedient “Modeling an Urban Drainage System with Large Tailwater Effects under Extreme Rainfall Conditions” International Conference on Urban Storm

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Drainage, Portland, OR, September 2002.

29. Glenn, S., Bedient, P.B., and B. Vieux “Analysis of Recharge in Ground Water Using NEXRAD in a GIS Format” AWRA Summer Specialty Conference, Keystone, CO, July, 2002.

30. Bedient, P.B. “Flood ALERT System (FAS) for Brays Bayou and the TMC” T.S. Allison: A Brays Bayou Event, Rice University Conference Presentation, and November 13, 2001.

31. Bedient, P.B. “Flood ALERT System for the Texas Medical Center” Hurricanes and Industry, Houston Conference Presentation, November 7, 2001.

32. Bedient, P.B. and J.A. Benavides "Analyzing Flood Control Alternatives for the Clear Creek Watershed in a Geographic Information Systems Framework" presented at ASCE's EWRI Spring 2001 World Water & Environmental Resources Congress Conference.

33. Hoblit, B.C., Bedient, P.B., B.E. Vieux, and A. Holder “Urban Hydrologic Forecasting: Application Issues Using WSR-88D Radar” Proceedings American Society of Civil Engineers Water Research, Planning and Management 2000 Conference, Minneapolis, MN, August 2000.

34. Spexet, A., Bedient, P.B., and M. Marcon “Biodegradation and DNAPL Issues Associated with Dry Cleaning Sites” Proc. Natural Attenuation of Chlorinated Solvents, Petroleum and Hydrocarbons Conference, Bruce Alleman and Andrea Leeson Eds., 5(1), pp. 7-11, Battelle Press, Columbus, Ohio, 1999.

Duke Energy Memorandum Regarding CAMA Requirements

2-19-15 NCDENR Conditional Approval of Revised Groundwater Assessment Work Plan

9-18-15 NCDENR Draft Comprehensive Site Assessment Comments