/

/

I,

To

fflinois

Polluon

Control Board

‘

i4-D

100

W.

Randolph Street,

Suite

11-500

RICE

Chicago,

IL

60601

SEP

3

o

2008

From: Charles

H.

Norris,

PG.

ILLIt..jo

On Behalf ofHeart of

Illinois Group

Sierra Club and

o’tr01

BOard

Peoria Families

Against Toxic

Waste

/

f’

Date

September

24,

2008

f

/.

Re IPCB

Case

AS

08-10

-

----

if

\

On behalf of

Heart of Illinois Group

Sierra Club

and

Peoria Families

Against

Toxic

Waste,

I

offer

the

following

comments for

the

Board’s

consideration

in

the

request

by

Peoria

Disposal

Company

(PDC)

to

delist electric arc

dust

to allow the

disposal of that

waste

in municipal

landfills.

I

provide

these comments

as an

Illinois Professional

Geologist. I hold

license

number

196.001082, which

expires March 31,

2009.

For reference,

I

am

attaching

my resume to these

comments.

Upon

review of

the

application

materials, transcript,

Agency

and Staff comments and

questions,

and

Applicant responses,

there are

a

few topics I believe

warrant

further or new

comment.

The

first

of

these

is

the

limitations

of the TCLP

test

that

is relied upon as the basic

standard

justifying

the delisting

and

projecting

impacts that would

result from approving

the delisting.

The

second

topic

is the concept

of using

coal

combustion

waste

as a

stabilizing

agent

for

a metal-bearing

waste

stream

in

the

light

of its historic performance

in

the few

places where

that

performance

can

be

evaluated.

The third topic is the

practical

and

regulatory

relevance

of

the

first two

topics

to

the

anticipated

disposal

environment

of municipal

landfills and

the

natural

environments that

surround

them.

The Limitations

of the TCLP

The

Toxicity

Characteristics

Leaching

Procedure

(TCLP)

is

the USEPA-prescribed

laboratory

Page

1 of 11

---

testing protocol

that

is

used

to

rate certain solid

wastes

with

respect

to

the

potential toxicity

of

specific constituents.

It replaced

the

original extraction

procedure (EP-TOX)

for

that

purpose.

The

TCLP results are compared

to a

regulatory

gateway

to

determine

if

a

non-listed, non-exempt

solid

waste can be managed

under

the

rubric

of Solid

Waste

(Subtitle

D) or if it

must

be

managed

under

the

rubric of Hazardous

Waste

(Subtitle

C).

The

TCLP is not, however,

the

USEPA-prescribed

protocol for

the converse purpose,

of establishing

that

a

listed

hazardous

waste

is appropriately

managed under Subtitle

D.

A variety

of additional

regulatory

uses

for

the

TCLP

have

evolved

through

practice

and time.

Generally

these uses

are

predicated upon

the

perception

that

TCLP results

below

the regulatory

gateway

can

be scaled

relative

to that threshold

to reflect potential

real-world

leachate

composition

or risks

to

human health

and the

environment.

That perception,

and the

resulting

uses,

has

been

accepted

without critical

review or

a

scientific

demonstration

of

efficacy.

The TCLP

test was not designed

to

predict the

concentration of

any contaminant in

the waste

leachate

that

will form

under disposal

conditions. It

was

not

represented

as a protocol

capable

of

doing

so.

And,

the

inadequacy

of this

and similar index

tests

to predict

field

compositions

has

been

increasingly obvious

for

the last

two

decades

as

more

and

more regulatory

programs

have

attempted

to use

them

as

surrogates

for

or

predictors

of field

response of

wastes.

The Science

Advisory

Board

(SAB) for

the USEPA

has recognized

and

expressed

the

inadequacies of these

tests since

at

least 1991

and in 1999

called

for a

review

of agency

procedures

(USEPA,

1999).

The USEPA

funded research

by

the SAB

to

study

the

best

methods

for modeling

the

impacts

of

waste

disposal

on groundwater in terms

of risks

to

human health

and

the

environment. That

report

was

issued in 2004.

One

of the

elements of that

study was yet

more evaluation

of why

tests

like

the TCLP cannot

be used for

the purpose of predicting

field

leachates (Al-Abed,

2003). The SAB

report (USEPA, 2004)

documents that

as

long

ago

as

the

mid-1980s

it was recognized

that

field

observation

and computer modeling

were required

to

predict

how leachates would

evolve.

Page2of

11

---

The National

Research

Council

echoed

the

warning

of

the

inadequacy of

laboratory

characterization

tests

as

surrogates

for determining

field leachate composition

in their

investigation

of

coal combustion

ash disposal

in mined settings (NRC,

2006,

pp

145-152). The

USEPA,

in

its recently

released-for-comment

draft

risk assessment

of landfills

and lagoons

used

for disposal

of coal combustion

wastes,

ranked potential

sources of data

relative

to

their value

as

indicators

of real-world

leachate composition.

TCLP

and similar index tests

ranked

fourth

among

the

four available

data

types

(RTI, 2007).

On a

more personal

note, I was asked

to

serve

on

a

Technical Review

Committee

for

the

Commonwealth

of

Virginia’s Department

of Environmental Quality

to

review

regulations for the

beneficial

use

of industrial

solid wastes

and specifically

coal

combustion waste.

The committee

is comprised of a

broad spectrum

of stakeholders;

scientists, contractors,

generators,

users,

environmentalists,

and

industry.

It would be an

understatement

to

observe

that the meetings

of

this committee

have

been

somewhat contentious.

The

only

item before

the

committee

upon

which

there was

unanimity

was

the

proposition

that the

TCLP

and

similar index

laboratory tests

were

incapable

of predicting the

leachates that

would

form from the wastes

and

should not be

used

for that

purpose.

The

TCLP

test

is the

protocol

that

determines

if an unlisted, non-exempt

solid

waste will be

regulated

under Subtitle C.

That is its only

appropriate

use,

and

it

is

appropriate because

it

is

prescribed

for

that

purpose

by

regulation.

TCLP is not indicative

of

leachate

compositions

from

a waste

or

their

evolution in

the disposal

environment.

The

basis

for

the

concern

with

the

TCLP

is not that

it over-predicts concentrations

of inorganic contaminants

in

the

leachate,

but

that it

will

often under-predict

their

concentrations.

Coal Combustion

Waste

as

a

Stabilizing

Material

Coal

combustion

waste

(CCW)

constitutes

a group

of high volume

industrial

wastes that

are

exempt by

statute

(Bevill

Amendment)

from

regulation

as

Hazardous

Waste.

Were

these

wastes

not exempt,

some would

need be managed

under

Subtitle C based

upon TCLP

toxicity and/or

Page3of 11

---

conosivity

criteria. Inappropriate placement and

use

of

CCW

has resulted in

groundwater

contamination

and ecological

damage,

some

resulting in clean up or

remedial actions under

CERCLA.

Coal combustion wastes

are highly variable in

chemical

composition,

phase

(e.g., mineral and

glass)

composition, texture

and

grain size, and physical properties.

Coal

combustion

fly- and/or

bottom ash

can be highly reactive with

water, forming

a

variety of mineral suites depending

upon

things like water content, elemental composition, phase

composition,

and

placement

conditions.

Sometimes, the reactions produce

minerals

that can set up the CCW

analogous to

cement,

plaster of Paris,

or

wall

plaster.

The

set-up

reactions can be

created or enhanced

by the

addition of liming agents to a CCW that

has insufficient

lime

for

the reactions.

A liming agent

can be

calcium

oxide or hydrated calcium

oxide.

However, frequently

the

liming agent that is added

is

cement

kiln

dust

and/or lime kiln

dust. The two

materials are industrial solid wastes that,

like

CCW,

are

exempt by statute

(Bevill

Amendment)

from regulation

as

Hazardous

Waste.

Also like

CCW,

were

these

wastes not

exempt, some would need be

managed under Subtitle

C based

upon TCLP toxicity and/or

corrosivity criteria.

The

reactions of CCW,

or

CCW

mixed with

a

liming agent,

that cause

the material to set

up

are

often referred to as

pozzuolanic reactions. Unless

the

result of these reactions for

a

specific mix

is

a

suite

of silica-cement minerals, this term is inappropriately used. Usually the

minerals

that

initially

form

upon hydration are metal hydroxides,

sulfate

minerals, carbonate

minerals, or

more

exotic

minerals such

as

ettringite.

Since

only

the silica-cement

minerals have long-term

physical

and chemical stability,

other hydration products will deteriorate

by

leaching, reaction, and/or

recrystallization

fairly soon after formation. This is typically

the case.

Many power

companies

offer

a CCW

recycling product

of lime-enhanced fly ash touted for its

ability to set up

like a low-grade cement with a low permeability. These materials are marketed

or used

for things such as low-permeability

liners

under lagoons or landfills, structural

fill for

Page4of

11

---

construction,

and

waste stabilization media.

In

each application,

the

treatment

of

the

fly

ash with

a

lime

additive

purportedly

binds

the

inorganic

contaminants,

precluding

their leaching.

The

evidence

for

this

is

the

concentrations

produced

by

the TCLP

test.

The premise

behind

such

products

is

that

the

material

initially

formed

and placed

is permanent.

That

is, the product

is

non-reactive with

the

environment

around

it

and

that the

mineral

assemblage

that initially

forms

is not

intermediate

phases

that

will

react to

a different

assemblage

with

time.

Generally,

landfills

and

lagoons

that use

these

materials

are not

monitored.

When

they

are

monitored,

they

are

shown

to

fail. I have

over

the

course

of

the last

ten years

evaluated

four

such

facilities

across

the

country;

Fern Valley

in Pennsylvania,

Petersburg

in

Indiana,

Sunflower

in

Kansas

and the

Turns

Mine

in

Illinois.

In each

case,

the liner

material

deteriorated

to

the

point

that its

hydraulic

containment

was compromised

and

contamination

occurred.

Structural

fills of

lime-enhanced fly ash

are

even

less

frequently

monitored

than

lagoons

and

landfills

using

these

materials.

For

the

two cases

with

which

I

am familiar,

Bark

Camp

in

Pennsylvania

and Battleground

Golf

Course

in Virginia,

the

placement

of these

materials

as

fill

is

resulting

in

groundwater

contamination.

Waste

stabilization

is perhaps

the

most

common

use

of alkaline

fly ash

or

lime-enhanced

fly

ash.

Mixing

these

materials

with

wastes

that

otherwise

would

fail

the

TCLP

test

will

produce

leachates

with

compositions

that

allow

the

wastes

to be

disposed

as

special

wastes in

municipal

landfills.

In

these

cases,

there

is

no

monitoring

of

the stabilized

wastes

to

determine

any

time-

dependent

changes

to

the

leachate

they

produce.

There

are

three

cases

with

which

I

am

familiar,

however,

where

the disposal

occurred

outside

of

landfills

and

the behavior

of

the

materials

after

and

beyond

the

initial

TCLP characterization

can

be observed.

Two

of

these

are

the

structural

fills

mentioned

above;

Bark

Camp

and Battlefield

Golf

Course.

In

each

case,

the structural

fill

application

was

paired

with waste

stabilization.

Stabilized

wastes

at

Bark

Camp

were

fly ash,

cement

kiln

dust,

lime

kiln

dust

and harbor

dredgings.

At the

golf

course,

the stabilized

wastes

were

fly

ash

that was

creating

contamination

at its

landfill,

and

cement/lime

kiln

dusts.

In

both

cases,

although

the stabilization

process

allowed

the

TCLP

to

be

passed,

the

produced

leachate

Page5of

11

---

actively

creates

ground-

andlor

surface

water

contamination.

The

third

example

of

an inappropriate

reliance

on

CCW-stabilized

waste

with which

I am

familiar

is one

from

here

in

Denver.

It is

the best

documented

of those

with

which

I am

familiar.

The

USEPA

used

lime-enhanced

CCW

to

stabilize

waste

uranium

and

heavy

metals

in

a

large

mound

of tailings

within

Denver

itself.

The

tailings

were

excavated

and

processed

with

the

lime-enhanced fly

ash

for

stabilization. The

TCLP

results

showed

the metals

and uranium

were

not

mobile

for

the

duration

of

that

test

environment,

and

the stabilized

mix

was

returned

to the

site

for disposal.

Monitoring

results

from

the

disposal

site

after

all

the

tailings

were

stabilized

and

replaced

showed

that

contamination

from

the

site

quickly

exceeded

levels

that

predated

the

stabilization

project.

Now,

instead

of

exhuming

and transporting

the

mill

tailings

for

disposal,

the

USEPA

had

to exhume

and

transport

the

substantially

larger

mass

of

mill

tailings

and

CCW

stabilizing

material

for

disposal.

This

site

is

the Shattuck

Superfund

Site

and can

be

reviewed

at

http://www.wateronline.

comlarticle.mvclDespite-Fix-Shattucks-Legacy-is-Reaching-the-0002?V

NETCOOKIE=NO

or

with

a

Google

search

of

USEPA+Shattuck+Denver.

At issue

is not

how

the

stabilized

electric

arc

dust

will

respond

to

disposal

in

an

unconfined

environment,

because

it will

be

disposed

in

a

municipal

landfill.

There

are two

relevant

issues.

The first

is

the

inadequacy

of

the

TCLP

test

itself

with

respect

to

how

the

stabilized

waste

itself

will

initially

leach.

As described

above,

the

test

will

not

and cannot

predict

the

leachate

that

will

form

in

the

landfill

environment.

The

second

is

the

evolution

of

leachate

from

the

waste

with

time.

The

leachate

that

forms

in

the landfill

is

a

complex

process

that

is

waste,

not

water,

dominated.

Leachates

forming

in

the

disposal

setting

do

not develop

their

composition

within

a

one-day

period;

they

evolve

over

months

and

years.

The

compositions

of leachates

that

form

in

a

disposal

setting

are

not static.

They

evolve

in

space

as they

migrate

through

new

waste

or

rocks

and

soil

and

as

they

mix

with

other

waters

and

other

leachate.

They

also

evolve

in time,

as

constituents are

gained

or

lost

in

response

to

changing

compositions

of

the

waste

which

result

from

the leaching

itself,

as

Eh

or

pH

conditions

change

in

the

landfill

with

time,

as

the lime

enhanced

fly

ash

evolves

temporally,

and

as acted

upon

by biological agents.

Page

6

of 11

---

As discussed

in

the following section,

these changes

materially impact

the

performance

of and

risks

from

the

municipal

landfill. The

performance of and

risks from

the

landfill

are

beyond

what

was

considered when

the landfill

was

sited

by the

community. The performance

of and

risks from

the

landfill

are

also beyond what

was considered

by the

IEPA

in granting

the

construction and

operating permits.

The

Disposal Environment

The processed

mixture of electric arc

dusts, CCW,

liming agent(s),

and

whatever proprietary

ingredients are involved

are

to be

placed in

municipal

landfills.

The

electric

arc dust

does

not

have

a

defined

composition

or

range of

compositions,

because the

proposed

delisting

is not for

a

single source.

The

composition

and

character of

the disposal environment

cannot

be

determined

because

the proposed

delisting

will allow

placement in

any

number of

different

municipal

landfills.

Such

concerns

are dismissed

on assurances

from PDC. First, whatever

the

composition

of the electric arc

dust, the processed

and stabilized

wastes

will

pass

the TCLP

test.

Second,

the proprietary

stabilization

process

will initially

and perpetually

render the

contaminants

bound

and immobile.

The

basis

for

the

first

assurance is hollow.

The

TCLP

test does not

and

cannot predict

the

composition

of

the

leachate

and departures

from the

test results are

typically

greater than

predicted,

not less. Rhetoric

describing

the TCLP

as unfairly

aggressive

and

therefore

conservative

is

inaccurate. The TCLP

test is

a

short

duration,

water-dominated

protocol

with

no

limitations

or

control

of Eh,

gas

pressures,

or

biological

influences. Leachate

compositions are

also

limited

by

simple

solute

availability

in

the dilute protocol

environment.

For

example,

metals concentrations

in leachate

are strongly

dependent

upon

waste:water

ratios

(Al-Abed

2003), and

in

a

landfill that ratio

will be 10-fold

or

more

that

of the

TCLP

test.

Passing the TCLP test

does

not

provide

information

about the

leachate

from

these

wastes

in

the

landfill.

The USEPA knows

this through

the research

of its Science

Advisory Board. The

National

Academy of Science

knows

this.

The

Commonwealth

of

Pennsylvania

knows this

as

it

Page7of

11

---

tries

to

develop

a

meaningful testing

protocol

for CCW-related

waste streams.

Representatives

for

all stakeholders

in negotiations

of a Technical Review

Committee in

Virginia all know

this.

The

basis

for

the

second

assurance is

absurd. If there were only

one

electric

arc

waste

stream

that

always

had constant composition,

if

there

were

but

a single source of CCW

that had

constant

composition,

if there were

but

a

single

composition

for

each other

ingredient

of the

proprietary

mixture, and if

the waste were only going

to be placed

in

a

single landfill,

the

assertion

that

the

stabilization

process

will initially

and

perpetually

render

the

contaminants

bound

and immobile

would

still

be

indefensible.

It

is

indefensible, even

if

all of

those

elements

are

held absolutely

constant,

because

the

landfill

environment

changes

continually.

At time of disposal,

the waste

mix is

bathed with precipitation,

directly

or through daily

cover.

At some point, the

landfill environment

begins to lose

oxygen and become

reducing.

CCW

wastes

are typically

strongly

oxidized.

They are

a

source of

oxygen

to both

abiotic

and

biotic

reactions.

Minerals and mineral

assemblages

that

are

stable

at the waste face are

no longer in

chemical

equilibrium. Landfills

typically

have

acidic

environments

and lime-enhanced

CCW

wastes

are

alkaline.

Minerals, like ettringite

that is

stable

at very

high

pH, become unstable

at

more

neutral

pH. As

the

mineral

composition

moves to a new equilibrium,

the mobility

of

the

contaminants

change. The

strongly

reduced

environment

is not constant or

permanent,

however.

Air

can

penetrate locally or

generally.

Waste

deep

within

landfills

can catch fire,

spontaneously;

another environment,

and

another

temporary equilibrium,

and

more changes

to the waste

and the

contaminant mobility.

One cannot

maintain

a

perfectly

and perpetually

stable

waste

in an ever

changing

environment;

it

defies

the

laws

of

thermodynamics.

What one

can do, and what

appears to have

been done, is

a

waste processing

recipe

has been

developed

that

allows the

electric

arc dust

and

CCW to

suppress

the metal

mobility in the

environment of

the

TCLP

test

for

the

18-hour

duration of

that

test.

As

a

reward for

that skill in laboratory

chemistry,

the applicant requests

the right

to

so

process

that waste

from

any

sources and

place

it

in

any

of its

landfills.

Page8of

11

---

Does any

of

this make any difference to public

health,

safety,

and welfare

(local siting criteria)

or

human

health

and the environment

(IEPA

performance criteria)? Yes, it does.

The

local siting

authority was

not

presented

with

and did not accept an operating

plan that

proposed to

bring in

a

delisted

hazardous waste

stream in unknown quantities that

will react

at

unknown

rates

to

produce leachates of

unknown compositions. It is

not an

eventuality that

might

have been

reasonably anticipated by the

authority in

its

considerations, since

this

proposal is

unprecedented in its scope

and flexibility.

The

IEPA’s

construction and

operating

permits become

ineffective,

as

well. The requested

delisting,

in and

of itself, will provide

a

new

source

of

metals from

both the

electric

arc

dusts

and

the CCWs

to the

composition of the

landfill.

That new

source of metals would

be

expected to

increase the

concentration of metals in the

landfill

leachate

by

an unknown

and

unknowable

amount.

It is

the

practicing position

of the IEPA

that

concentration of

a

contaminant outside and

downgradient

of a

landfill is

linearly

proportional

to the

concentration

inside the

landfill.

That

assumption is the

premise behind the

accepted

use

of a unit concentration as

the

source

term

for

fate and

transport modeling done for the Groundwater Impact Assessment (GIA),

whether

the

model

is

POLLUTE,

MIGRATE, or MODFLOW/MT3D. Since

the

leachate composition

from

this new waste

is

unknown, the

incremental change to

the landfill leachate is unknown.

Generally, concentrations

in

a

municipal landfill leachate

can be

approximated

by

consideration

of

leachates observed

from other municipal landfills. But, in this

case,

there is no other

municipal

landfill

that

accepts

these

wastes,

let alone in this quantity or this form. Since the

source

term

concentration isn’t known, the downgradient plume concentration cannot be

simulated and

compliance

with

the performance

standard

cannot

be

demonstrated. Some

of

the

landfills

for which the

right

to dispose is sought

are directly

over

major regional

aquifers,

including the

Mahomet Aquifer. Such

resources

deserve fully defendable demonstrations of

probable

compliance, at a

minimum. That cannot

be

done

with what is

proposed in this

application.

Page9of 11

---

Personal

Comment

The

above

comments

represent

my opinions

as

a

professional

geologist.

Beyond

those

comments,

I

would

like

to offer

the

following

personal

observation.

In

the

past

few

years of

my career,

I have

observed a

trend

in

waste

management

and regulation

that

very much

concerns

me.

Waste

generators

and

waste

receivers/processors

are increasingly

exploiting

the

limitations

of

the TCLP

test and

some

of

its

regulatory

uses

to

circumvent

responsible

management

of

their

wastes.

Elsewhere,

this

approach

has

even been

used

to

justify

and approve

the open

placement

of

wastes

in

the environment

with

no pre-placement

site

characterization,

no post-placement

monitoring,

and no regulatory

oversight.

This

proposed

delisting

is part

of

that trend;

benignness

by

TCLP.

The decision

on

this

delisting

proposal

will

have

future

impacts

far beyond

this electric

arc

dust.

Because

of its breadth,

flexibility,

and

the

reliance

upon the TCLP,

I believe

there will

be more

such

applications,

each

pushing

the

envelope

further. If

this application

is

successful,

it will

be

but the

first

of a

new type

of delisting

applications.

Each

will use

parallel logic

and

a

parallel

approach.

Each

will

rely

upon

laboratory

bench chemistry

to produce

a

waste or

multi-waste

“product”

that

can

constrain contaminant

mobility under

the

conditions

and for

the

duration

of

the

TCLP

test,

with

no

consideration

of how

the

waste

will

actually

behave

upon disposal.

One

waste

at a

time,

using

this

application

as

a

template

and

its

approval

as

a precedent,

the

fundamental

concept

and

historical

practice

of

handling

the most

dangerous

wastes,

the Listed

Wastes,

more carefully

than

household

waste,

will

be undone.

I think

that

would

be a

mistake.

I thank you

for

your

attention

to

and consideration

of my

comments,

both

professional

and

personal.

References

Cited

Al-Abed,

Souhail,

2003,

Roadmap

for

Current

and

Long-tern

Research

on

Waste

Leaching,

Page

10

of 11

---

Office

of

Research

and

Development, National

Risk

Management Research

Laboratory,

United

States

Environmental

Protection

Agency,

Cincinnati

OH,

presentation

to

USEPA

Science

Advisory

Board,

June

17,

2003,

23

pp.

NRC,

2006,

Managing

Coal

Combustion

Residues

in

Mines,

Committee

on

Mine

Placement

of

Coal

Combustion

Wastes,

National

Research

Council

of

the

National

Academy

of

Sciences,

The

National

Academies

Press,

Washington, D.C.,

March,

2006.

RTI,

2007,

Human

and

Ecological

Risk

Assessment

of

Coal

Combustion

Wastes,

Draft,

Prepared

for

U.S.

Environmental

Protection

Agency,

Office

of

Solid

Waste,

Research

Triangle

Park,

North

Carolina, 333

pp,

available

at

www.regulations.gov,

docket

EPA-HQ-RCRA-2006-0796.

USEPA,

1999,

Waste

Leachabilitv:

The

Need

for Review

of Current

Agency

Procedures,

EPA

SAB-EEC-COM-99-002,

EPA

Science

Advisory

Board,

U. S.

Environmental Protection

Agency,

Washington

DC,

1999.

USEPA,

2004,

EPA’s

Multmedia.

Multipathway.

and

Multireceptor

Risk

Assessment

(3MRA)

Modeling

System,

EPA-SAB-05-003,

EPA

Science

Advisory

Board,

U. S.

Environmental

Protection

Agency,

Washington

DC,

November

2004,

128

pp.,

available

at

www.epa.gov/sab/fiscalo5

.htm.

Pagellof

11

---

Geo-Ilydro, Inc.

Charles

H. Norris,

P.G.

1928

East 14th

Avenue

(303) 322-3171

Denver CO

80206

cnorrisgeo-hydro.

corn

SuMMARY

OF

QuALifICATIoNs

Thirty

plus

years

of professional experience

in

geology,

hydrogeology and

management in

the

applied

and

theoretical

geosciences.

Experience

includes perfonnance,

oversight

review, or management

ofsite

assessment;

RIJFS;

computer

modeling

of

fluid

flow, contaminant transport,

and

geochemistiy

(applications

and code development);

policy

and

rule

making procedures; aquifer

evaluation; resource

development;

and litigation

support;

nationwide

and

internationally.

PRoFEssIoNAL ExPERIENcE

GEO-HYDRO, INC., Denver,

Colorado,

(1996-present), Principle,

CEO,

Vice-President

HYDRO-SEARCH, INC.,

Golden, Colorado,

(1992-1996),

Director

of Hydrogeology

UNIVERSITY OF ILLINOIS,

Urbana, illinois,

(1987-1992),

Research Associate; Manager,

Industrial

Consortium

for

Research and

Education

for

the

Laboratoiy for Supercomputing

in Hydrogeology

Consulting

HydrogeologistlGeologist,

Champaign,

illinois

and

Denver,

Colorado,

(1980-1992)

MGF OIL

CORPORATION,

Denver, Colorado, (1985

- 1986), Manager

Geological

Engineering

EMERALD

GAS

AND OIL,

Denver, Colorado, (1980

- 1986), President

and Owner

PETRO-LEWIS

CORPORATION,

Denver; Colorado

(1980), Districts

Geologist

TENNECO

OIL COMPANY,

Denver, Colorado

and Houston, Texas,

(1977-1980),

Senior

Geological

Engineer

AMOCO

INTERNATIONAL

OIL

COMPANY, Chicago,

illinois,

(1975-1977),

Senior Geologist

SHELL OIL

COMPANY, Houston

and Midland, Texas,

(1972-1975),

Exploration

Geologist

PRoFEssIoNAL REGIsTRATIoNs,

MEMBERsHIPs,

AND AFFILIATIoNs

Professional

Geologist:

Illinois (# 196-001082),

Indiana

(#2100),

Pennsylvania

(PG003994),

Utah

(#5532631-2250),

Wisconsin (# 924),

Wyoming (#2989)

Registered Environmental

Professional

(#53 50),

State

of

Colorado,

Petroleum Storage

Tank Fund

National

Ground Water

Association

Colorado Groundwater

Association

(Vice President 1999,

President 2000,

Past-President

2001)

Professional Geologists

of Indiana

(past)

The

Colorado

Mining

Association

(past)

Illinois

Groundwater

Association

(past)

American

Association

of Petroleum

Geologists

(past)

Phi Beta

Kappa,

Phi Kappa Phi,

Sigma Xi

EDUCATION

B.S.,

Geology, University of fflinois,

High

Honors

and Distinction

in

Geology,

1969

M.S.,

Geology,

University

of Washington,

National

Science

Foundation

Fellow,

1970

University

of

Illinois,

all

but dissertation

completed

for

Ph. D.,

Hydrogeology,

1992

---

Charles H.

Norris

(Continued)

PROJECT

ExPE1UENcE

R1/FS & GENERAL

STFEIZ%’vESTIGATIoNS

•

Manager

for technical assistance through a

Technical Assistance Program

(TAP) grant from PRPs to local

citizens’ group. Assistance

through grant to provide

assessment

and

feedback

on site

work products

as they

are developed

and implemented,

explain

the

remediation processes and activities to the

citizens, and serve

as

technical

liaison between citizens and

remediation team.

•

Modeler and hydrogeologic

consultant at

industrial tank farm adjacent to the Chicago

Sanitary and Ship

Canal in

northeastern Illinois. Assess hydrogeologic data,,

interpret aquifer testing, and

model groundwater

flow in

soil

and

fractured carbonate bedrock

in area of DNAPL accumulation as part

of site characterization

and

voluntary remediation design.

•

Manager and

hydrogeologist of

groundwater investigation at an industrial dump

site adjacent to the illinois

River

in north Central Illinois. Investigated

fate

and transport

of34

decades

of

disposal

of mixed, hazardous

industrial wastes at a

non-engineered floodplain dump site.

Expert

testimony

and legal support. Pre-trial

settlement provided

for

installation

of monitoring system

in lieu of site

characterization.

•

Manager

of groundwater flow modeling

performed

as

part of

the

groundwater characterization effort and

as

part of the

preliminary remedial designs.

The site is

a

Superfhnd site involving

both

organic

and

metals

contaminants

at a

wood treating facility

in

an

urban area in Alabama adjacent

to

a

major commercial

waterway.

•

Manager of groundwater

flow modeling performed

as

part of

the

groundwater characterization effort

and as

part ofthe 90%

and Final remedial designs. The site is

a

high proffle Superfund site involving both organic

and

metals

contaminants

at a wood

treating facility in Northern California.

•

Technical advisor

assisting in

the

evaluation

of aquifer

properties

and

well performances

for

an extraction

well field near Sacramento CA. A high volume pump and treat system

for chlorinated solvents showed

strong

and anomalous

decline

in productivity. Detailed

evaluation identified

both

possible

causes

and

recommended

operations changes to alleviate the

problems.

•

Technical advisor assisting

in

the

evaluation

of aquifer properties

and

well performances for

initial

installation of a

high volume extraction well field in Southern California. The chlorinated solvent plume

associated

with

a Superfund

site impacted

a

large area in

a

layered, heterogeneous groundwater basin

managed

intensively for public water supplies.

•

Senior

oversight

and

review in

the

evaluation of aquifer and soil properties, and

the

remediation of

the

soils

contamination and

groundwater impacts associated with compressor facilities of interstate

gas

transmission

companies. Various projects and sites in western Colorado, Wyoming,

and

the Texas panhandle.

•

Technical advisor for the Remedial Investigation/Feasibility Study (RIIFS) of

the

Landfill

Solids

and Gases

Operable Units at

the

Lowry Landfill CERCLA site located near Denver, Colorado.

This project

involved

the

characterization of the extent of potential

contamination within

the unsaturated

zone

adjacent to this high

profile site. Work involved extensive coordination and

interaction

with multiple

PRP

groups as well

as

various regulatory

agencies.

•

Project manager for independent oversight of

a

proposed low-level

radioactive waste

disposal site.

Task was

to

develop technical and legal program for governmentally funded intervener’s

case as

part

of adjudicatory

hearings on

a

high-profile, proposed disposal facility and involved identilying, retaining

and

educating legal

stafl retaining

a

team

of

technical

experts,

negotiating

fees,

coordinating work product and presentations,

---

Charles H.

Norris

(Continued)

providing

liaison with citizen’s

groups, responding

to

press and

integrating personal

testimony

on

hydrogeology

and modeling. Expert testimony

and

legal

support,

L4ND17LL SERVICES

•

Project

manager and hydrogeologist

for

a

geologic and hydrogeologic

assessment of existing

water

quality

and

off-site migration from

existing licensed landfill near Joliet

IL. Work includes groundwater flow

modeling

of remedial alternatives and groundwater

impact

assessments

of various alternatives for submittal

to

ffiPA.

•

Project

manager

and

hydrogeologist for a

geologic

and

hydrogeologic assessment

for

siting of

a proposed

expansion for

a

hazardous waste

landfill in Peoria County, Illinois. Expert

testimony

and

legal support.

Review

identified errors

in

application,

unaddressed contamination on

facility property,

and

inappropriate

modeling design and

implementation.

•

Project manager and

hydrogeologist for

a

geologic and hydrogeologic assessment

for

siting of a proposed

regional

landfill

by

expansion of local landfill in Ogle County,

Illinois. Expert testimony and

legal

support.

Review

identified

in errors application, unaddressed existing

leakage,

and potential

risk to public water

supply.

(Three hearings)

•

Project

manager

and

hydrogeologist

for

a geologic and hydrogeologic

assessment for siting of a proposed

regional

landfill

by

expansion of

local

landfill

in Kankakee County, Illinois. Expert testimony and legal

support.

Review identified errors in application,

unaddressed existing off-site leakage, and inappropriate

modeling

design

and

implementation. (Two hearings)

•

Project manager and

hydrogeologist for

a

geologic

and

hydrogeologic assessment of

a

proposed regional

landfill in Will County,

Illinois. Expert testimony

and

legal support. Research documented numerous errors

in application which

resulted in

underestimation

of

infiltration

rates and potential migration rates. Identified

evidence of

sub-karstic migration

pathway

from

site

to

nearby stream. Assisted with the

design of

the facility

monitoring system submitted and accepted by

IEPA.

•

Project

manager

and

hydrogeologist for

a

geologic and hydrogeologic assessment of

a

proposed

regional

landfill

expansion

at East Peoria, illinois. Research documented

current

leakage

from

the

existing

landfill

into the

regional unconfined aquifer within the cone of

depression of

the

municipal

water supply wells.

In

part as a

result of the evaluation, the proposed

expansion

has been abandoned. Expert testimony

and

legal

support.

•

Project manager and

hydrogeologist for

a

geologic

and

hydrogeologic assessment of

a

proposed regional

landfill at Ottawa,

Illinois. Provided testimony at

county

hearings identifying and documenting site-specific

conditions that

invalidated part of

the ground

water evaluation testing, necessitating the need to re-evaluate

the

groundwater

flow system and redesign the monitoring system.

Expert

testimony and

legal

support.

•

Project

manager and hydrogeologist for a geologic and

hydrogeologic assessment of existing

municipal

landifils and a proposed

landfill redesign

and

expansion

at

Salem,

illinois.

Provided testimony

at city

hearings

documenting existing

landfill

leakage and

identifying site-specific conditions

that

complicate

the

design

of

a

reliable

monitoring

system.

Expert testimony

and

legal

support.

•

Project manager and

hydrogeologist for site evaluations of

the geology and hydrogeology

of several

proposed

municipal

landfills

and a

landfill expansion in Bartholomew County, Indiana. The review of

the

expansion

demonstrated

inadequate

monitoring of

the

existing facility.

One

proposed

site showed possible,

current

ground

water usage from under the proposed facility and conditions that may preclude state-level site

approval.

---

Charles

H.

Norris

(Continued)

•

Project

manager

and hydrogeologist

serving in

consultation

to the

Board

of

Wayne

County,

fflinois,

regarding

a

proposed

expansion

to a

regional

landfill. Investigation

and

oversight

established

viability

of the physical

site

and

improvements

that

were

needed in operating

procedures and

monitoring

efforts.

Expert

testimony

and

legal

support.

•

Project

manager

and hydrogeologist

for an assessment

of an

existing

regional municipal

landfill at Urbana,

Illinois.

Principle

problems

included

ground

water contamination,

unplugged

well(s)

within the

facility

boundary

that

penetrated

the

aquifer

serving

public

water

supplies

and

a

monitoring system

inadequate

to

evaluate

the

contaminant

migration.

Results

of

the evaluation

include

an

expanded

system

of monitoring

wells,

improved

protocols

for

ground water

sampling

and

revised

statistical

procedures

to

determine

background

water chemistries.

•

Project

manager

and hydrogeologist

for a site

assessment

of

a

proposed

municipal

landfill

expansion

in

west

central Indiana.

Established

feasibility

of

using

the

engineering

and design

features of the

expansion

to

prevent contamination

from

the

pre-existing

non-engineered

facility.

•

Project hydrogeologist

for

a

site assessment

of

a

proposed

saturated-zone,

regional

baleffil

in central

Illinois.

Principal

problems involved

the

evaluation

ofthe hydrogeologic

characteristics

ofthe strip

mine spoils

within

which

excavation would

occur,

the

blasted

mine

bottom

upon which

the

liners

would be

built

and the

materials

available

for liner

construction.

Expert

testimony

and

legal

support.

•

Project

manager and

hydrogeologist

for

a

site

assessment

of a

proposed

municipal landfill

expansion

in

Livingston

County,

Illinois.

Principal problems

involved

the

evaluation of

the

impact of

shallow coal

tunnel

mining

beneath

the site

and

reaction of

waste

leachate with

unusual clay

mineralogy

important

to waste

isolation

at the

site. Expert

testimony.

•

Technical

reviewer

of site assessment

and

re-assessment

of

a

proposed inter-governmental

regional

landfill

in

central illinois.

Verified

unanticipated,

politically

unacceptable

risks

to

major

aquifer

system

sewing

public

water supplies.

Assisted

in

drafting oftechnical

policy

statement that

permitted

new siting efforts

to

proceed

in the

jurisdiction.

Expert

testimony.

WATER

RESOURCE

EVALUATION

& DEVELOPMENT

•

Manager

for

ground water

mcxleling effort

associated

with

the

development

of

a high-volume

ground-water

supply

and

delivery

project

in Colorado.

The

effort

included

investigating

and

evaluating

a

previously

used,

court-accepted

model, adapting

and updating

the

model,

and

applying

the

model

to assess

the

impacts

of

a

proposed

private

ground-water

diversion

project

that

would

be

the

largest

in

the

United

States.

Ongoing

effort

includes

subsequent

review

of alternative

proposed

model and

further litigation

support.

•

Manager

for

review of

an

application

for

an

expansion

of

a

large long-wall

mine in

southeastern

Ohio. The

review

identified

extensive

unrecognized

mining-related

impacts

to

water

supplies from

historic

mining

and

identified

hydrologic

risks

to a

unique

old-growth

forest

adjacent

to the

proposed

expansion,

and

resulted in

an appeal of

the application.

Expert

testimony

and legal

support.

•

Manager

for

ground

water

modeling

effort associated

with the

development

of a surface

reservoir designed

for

conjunctive

use of

ground and surface

water

to reduce peak

ground water

pumping

demands

in Denver

metro

area.

The effort

included investigating

and

evaluating a

previously used,

model,

adapting

and updating

the

model,

and applying

the

model

to assess

the impacts

of project

on other

water

rights.

Study

is

a

component

of the EIS.

•

Project

Manager

for multi-company

effort

to

model thermal

loading

of

northern Nevada

surface

waters as

a

---

Charles H.

Norris

(Continued)

result

of mine

dewatering

project.

Successful

liaison among

technical

staffs

and regulators

and

modeling

work

for

a

high

profile

EIS

resulted in

approval of discharge

permit.

•

Project

Hydrogeologist

for

the

feasibility study

of

a

small lake

for a

northern

Illinois nursety,

to

be used for

recreation,

fishing and

irrigation.

Evaluated

shallow and

intermediate ground

water and surface

run-off

reviewed

engineering

design and

directed

ground

and surface

water sampling

program

to

detennine

nutrient

levels.

HYDROCHEMIS

TRY

•

Principal investigator

for

grant

to

research the

geochemical implications

of

using

alkaline addition as one

means

for

preventing

and/or

remediating

inorganic contamination

resulting

from acid

mine/rock drainage.

Empirical

and

modeling evidence

showed

conditions under which alkaline

addition

can

cause

or

exacerbate

contamination

of some

constituents

of concern.

•

Project manager,

hydrogeologist,

geochemist

for

ongoing investigation

of metals contamination

of

a

trout

stream in West

Virginia. Impacts

from

natural

and industrial sources

, present and

past, evaluated

to

segregate

relative significance

of various sources.

Includes expert testimony

and legal support.

•

Project geochemist

and bydrogeologist

for evaluation

and critique

of modeling protocols

used by USEPA for

risk assessments

performed

as

part of regulatory

determinations

for

various

solid

wastes.

Identified errors in

methodology

and input that had

caused

previous

modeling to

mischaracterize

risks for settings

with

observed

damage cases.

Computer

modeling.

•

Geochemist and

hydrogeologist

for evaluations

of inorganic

groundwater

chemistry

at an

industrial

RCRA

site

neai

Joplin MO.

Federal lawsuit ified

pursuant to

PRP

contribution and sources

and timing of

contamination.

Was

able

to use

geochemical

interpretations to

establish significant elements

of aquifer

characteristics

and implications

for contamination

routes. Expert

testimony.

•

Project

hydrogeologist

and geochemist

for

evaluations

of proposed

coal

combustion waste

disposal

as part of

reclamation

activities

at surface coal

mines in Southwestern Indiana.

Efforts

were

targeted

toward refining

regulatory

framework

for

disposal

efforts,

establishing effective

characterization and

monitoring

programs

and

determining

appropriate operationandengineeringpractices.

Projectinvolvedextensive

interdisciplinary

effort

and

expert

testimony.

•

Project geochemist

for

the

investigation

of

the

impacts

of remediating acid

mine drainage by installing

bulkheads

to

flood

exhausted mine

working. Predictively

modeled water chemistries

in situ,

within

flooded

mine,

along

flow paths

and

upon

surface discharge.

Assisted in preparation

of testimony that resulted

in

permit approval

for the

San Juan

County,

Colorado

project.

•

Project

manager

and

project

geochemistlhydrogeologist

for investigation

ofpotential

environmental impacts

of

disposal

of coal combustion wastes

(CCW) as

part

of

a

reclamation plan at a

surface coal mine

in

northern

New

Mexico.

Performed

or directed geochemical, infiltration

and

flow modeling

of the proposed project

to

identify

optimum

disposal methods

and worst

case

impacts.

Presentation to State

resulted

in approval

of

this

precedent-setting

project.

•

Project

manager, geochemistlhydrogeologist

Investigating

a proposed

disposal/construction

project for

a

central

illinois ski mountain

from

co-generation

fly

ash

from

a major

food products manufacturer.

Involved

overseeing

an

engineering

review of

project

plans,

site

investigation

and

evaluation,

geochemical

modeling

of

initial

and

final

mineralogical composition

of

the

mass and of

the

leachate chemistry

and

evolution

and

the

impact

on the

hydrogeologic

and

structural

integrity of

the

project.

Expert testimony and legal

support.

---

Charles

H.

Norris

(Continued)

RELATED

PETROLEUMIM)USTRYEXPERJENCE

•

Project

manager

for

the

environmental

assessment

of 82

Texas

producing

properties

targeted

for

acquisition.

Evaluations

included

site walk-overs,

surface

soil

and

liquid

sampling,

radiological

monitoring

and

geoprobe

sampling

of

soils

and

ground

water.

The

assessments

documented

a

multitude

of impacts

from

both

exempt

and

non-exempt

wastes

that,

unrecognized,

could

have

resulted

in substantial

financial

exposure

to

the client.

•

Project

geologist

and

petrophysicist

for an

investigation

of

resource

potential

of

coal

bed

methane

in

San

Juan

Basin

of

New

Mexico

and

Colorado.

Study

focused

on innovative

log

analysis

techniques;

formation

water

chemistries,

production

rates

and

disposal

problems;

well

drilling,

completion and

re-completion

practices;

and

detailed

subsurface

facies

and

structural

mapping

and

stratigraphic

correlation

in

shallow

coal

beds

of

Kirtland/Fruitland/Pictured

Cliffs

shoreline

complex

and

relationships

to

overlying

Tertiary

sandstones.

•

Developed

a successful

play

in the

Hunton

and

Mississippi

Lime

formations

of northwest

Oklahoma.

The

play

recognized

the

secondary

porosity

systems

of

both formations

(dolomitization

and

fracturing,

respectively) and

the

genetic

significance

to

each

of the buried

topography

at the

intervening

unconformity.

•

Managed

a

detailed

reservoir

study

of

a Cotton

Valley

gas

field

in east

Texas

that

resulted

in

RRC

approval

of non-standard

spacing

based

upon

the

recognition

of

secondary

porosity

and

a

dual-conductivity

system

that

resulted

from

drape-induced

fractures.

The

revised

spacing

both

protected

resource

ownership

and

conserved

the

costs

of

infill

drilling.

Expert

testimony

and

legal

support.

•

Project

geologist,

petrophysicist and

expert

witness

for

various

contested

adjudicatory

hearings

apportioning

oil

and

gas

ownership.

Cases

involved

primary

recovery

of

oil/gas

and

secondary

recovery

of oil.

Accepted

as

expert

(geology,

hydrogeology,

and/or

geological

engineering)

in

Oklahoma,

Texas,

and

Wyoming.

ADDrn0NAL

PRoFEsSIoNAL

ExPERIENcE

•

Invited

presenter

to

National

Research

Council

of

the

National

Academy

of

Sciences,

Committee on Mine

Placement

of

Coal

Combustion

Wastes.

•

Appointed

member

ofa Quality

Assurance

Conunittee

under

the

West

Virginia

Department

of

Environmental

Protection.

The committee,

comprised

of

representatives

of

state

and

federal

regulators,

industry,

and

interveners,

was charged

with

a

year-long

review

of

state mining

applications

and approval

practices

relative

to

mining

under

the

state

and

federal

surface

mining

laws.

•

Invited

presenter

to

National

Research

Council

of

the National

Academy

of

Sciences,

Subcommittee on

Alternatives,

Study

on Coal

Waste

Impoundments.

•

Project

manager

and

hydrogeologist

for the

review

of Proposed

and

Revised

Proposed

Criteria

for

the Siting

of

a

Low

Level

Radioactive Waste

Disposal

Facility

in illinois.

Evaluation was targeted

toward

both

technical

content

and

processes

of

selection.

Testimony and

written

comments

led

to

significant

improvements

and

flexibility

in

the

Criteria

as finally

published.

•

Project

hydrogeologist

testifying

at

hearings

before

the Illinois

Pollution

Control

Board

on regulatory language

for the

illinois

Ground

Water

Protection

Act. Contributed major

conceptual

and

specific

language

changes

to

the

final

promulgated

rules

for

Ground

Water

Quality

Standards

and

Regulations

for

Existing

and

New

Activities

with

Setback

Zones

and

Regulated

Recharge

Areas.

Expert

testimony

and

legal

support.

•

Project

hydrogeologist

and

log

analyst

for

three

applications

to

U.S.

EPA

for

permits

to

continue

deep

well

---

Charles

H.

Norris

(Continued)

disposal of hazardous

wastes

in

east central

Illinois and

southern Ohio.

Project required

evaluation

of

geophysical

logging

data to

determine injection

zone and

confining layer properties,

regional

flow systems,

chemical interactions

of

the waste

stream with

the

native rock and

the

ability of

the

injection

system to isolate

the

waste

from

the environment.

REPORTS,

PREsENTATIoNs,

AND PuBLIcATIoNs

Norris, Charles H.,

2005,

“Water Quality Impacts

from Remediation Acid Mine

Drainage with Alkaline

Addition”,

draftversion released

to National Research

Council ofthe National Academy

of

Sciences,

Committee

on Mine

Placement

of Coal

Combustion Wastes, Geo-Hydro,

Inc.,

Denver

CO,

July 3, 2005

Norris,

C.

H.,

“notes

from

the

front.

. . Overview of

three sites”, invited paper

before National

Research

Council

of

the

National

Academy

of

Sciences, Committee

on Mine Placement of

Coal

Combustion

Wastes, Evansville IN,

March, 2005.

Norris,

Charles

H.,

2004,

“Environmental Concerns

and

Impacts

of

Power

Plant

Waste

Placement in

Mines”,

Presented at Harrisburg

PA, May 4-6,

2004.

Published

in Proceedings of

State

Regulation

of

Coal

Combustion By-Product

Placement

at

Mine

Sites: A

Technical

Interactive

Forum, Kimery

C

Vories

and

Anna

Harrington, eds,

by U.

S. Department of

Interior, Office of

Surface Mining, Alton

IL,

and Coal Research

Center, Southern

Illinois

University, Carbondale

IL.

Norris, C. H., “Developing

Reasonable

Rules for

Coal

Combustion

Waste

Placement in Mines.

Why?

When?

Where?

How?”, USEPA Contract

68-W-02-007,

1EI

Subcontract 7060-304,

Invited paper

at

USEPA

MRAM

meeting,

Rosslyn

VA, September, 2003.

Norris,

C.

H.,

“So,

You think You’re

a Geologist? (F.

Kafka

to

A. Liddell,

In

Wonderland)”,

Colorado Ground

Waster

Association Monthly Meeting,,

Denver

CO,

September, 2002.

Norris,

C.

H., “Assessment of

the

Anker

Energy

Corporation

proposal for mining

and

reclamation,

Upshur

County,

West Virginia,” Independent

evaluation on

behalfof

Anker

Energy Corporation

and

West

Virginia

Highlands

Conservancy, July,

2002.

Norris, C.

H., “Coal Combustion Waste:

Coming soon

to

a

neighborhood

(and

maybe

a faucet)

near

you.” Colorado

Ground

Waster Association

Monthly

Meeting,, Denver

CO. May,

2001.

Norris,

C.

H., “Slurry-to-ashes,

and

ashes-to... A case of

a coal

company

and

citizens working together

to evaluate

alternatives.”

Invited paper before

National

Research

Council

of the National Academy

of

Sciences,

Subcommittee

on Alternatives,

Study

on

Coal Waste

Impoundments,

St.

Louis

MO,

June,

2001.

Norris, C.H., and

C.

E. Hubbard,

“Use

of M1NTEQA2

and EPACMTP

to Estimate

Groundwater Pathway

Risks from

the

Land

Disposal

of Metal-Bearing

Wastes”,

for

Environmental

Technology

Council, submitted

as public

comment

to

USEPA

on regulatory determination

for Fossil

Fuel Combustion

Wastes, May, 1999.

Norris, C.H.,

“Report

on the

Determination

of

Intermittent

Streams

and the Potential

Impacts

of

Valley

Fill on

Area

Drainages,

Southern

West Virginia”,

expert report for

litigation prepared for

Mountain

State

Justice,

mc,

Charleston

WV, March,

1999.

Norris,

C.H., “Report on the Geology

and Hydrogeology

of the

Caterpillar Levee Site

with

an Evaluation

of Potential

Pathways on-

and

off-site

for the Movement

of Solid and

Hazardous Wastes”,

expert report for

litigation

prepared for

Citizens

for

a

Better

Environment,

Chicago IL,

March,

1998.

Norris,

C.H., “Dr

Pepper, Biorhythms,

and the Eight-Hour

Pmnping Test

“, Colorado

Ground Waster

Association

---

Charles

H. Norris

(Continued)

Annual

Meeting,

Golden

CO,

December, 1997.

Norris, C.H.,

“Characterizing Ash Composition

and

(vs.)

Projecting

Environmental

Impact for Purposes

ofPermitting

CCW

Disposal

“, Coal Combustion

By-Products Associated

with

Coal

Mining

- Interactive Forum,

Southern

Illinois University at Carbondale,

Carbondale IL, October,

1996.

Norris,

C.H.,

“Geochemical Modeling”.

Co-instructor for

Short Course

on

Hydrogeologic Issues Related

to Mine

Permitting, Reclamation and

Closure, SME Annual

Convention, Phoenix

AZ; March, 1996.

Norris,

C.H.,

An

Improved Method

for Middle Time Analysis

of Slug and Bail

Test. Unpublished.

1994.

Norris,

CR,

“Evolution

of

the

Landfill”,

presentation

as part

of

a

Telnet program, Garbage

Dilemma

Educational

Series, sponsored

by

fflinois Farm

Bureau and Cooperative

Extension Service

of

the College of

Agriculture,

University

of Illinois, Urbana, Illinois,

April

20, 1992.

Norris,

C.H., “Technical

Analysis

or Political

Acceptability:

The Domesticated Fowl

or its Ovum”,

Solid

Waste

Management

and

Local Govermuent

Workshop, sponsored

by Institute of Government

and Public

Affairs,

University of

illinois, Urbana, Illinois,

Jan-Apr, 1992.

Norris,

C.H., Report on

the Geology and Hydrogeology

[of

the]

SWDA

Proposed Landfill

Site,

Township

8 North,

Range 6 East, Section

31,

Bartholomew

County, Indiana, for

Central

States

Education

Center,

Champaign,

Illinois,

1991.

Norris,

C.H., Hydrogeology

and

Modeling of

the Proposed Illinois Low

Level Radioactive

Waste

Disposal

Site

at

Martinsville, Illinois;

testimony before

the LLRW Siting

Commission, October

and November,

1991,

Martinsville, Illinois.

Norris,

C.H., Ground Water Quality

Standards

for

the Illinois Ground

Water Protection

Act; testimony

before Illinois

Pollution

Control Board,

Chicago,

Illinois; February,

May, October

and December,

1990; May, 1991.

Norris, C.H.,

Hearing on

a

Petition for

a Special

Use Permit for

the

Construction of

a Ski Mountain in

Oakley

Township,

Macon

County,

Illinois; testimony before

the Macon

County Zoning

Board of Appeals;

February

16, 1990.

Norris,

CR,

Hearing

on

a

Solid

Waste

Disposal

Permit

for

the

Siting

of a Municipal Landfill for

Streator,

illinois;

testimony

before

the

Livingston

County Board;

August 6, 1990.

Norris,

CR,

In the matter of the Gallatin

National

Company

Proposed

Balefill, Fulton County,

Illinois,

written

comments

to

the illinois Environmental

Protection

Agency,

Springfield,

illinois, 1990.

Norris, C.H., 1990, Log

Analysis

of the

Allied

Chemical

Corporation

Waste Injection Well, Danville,

Illinois,

for

Alberto Nieto,

Champaign, Illinois.

Norris,

CR,

1989, Log Analysis

of

the Cabot

Corporation

Waste Disposal Wells,

Tuscola, illinois,

for

Alberto

Nieto,

Champaign, Illinois.

Norris,

C.H.,

Regulations

for Existing

and

New

Activities Within

Setback Zones

and

Regulated

Recharge

Areas

for

the

Illinois

Ground

Water

Protection Act;

testimony before

Illinois

Pollution

Control Board,

Chicago,

Illinois,

June,

1989.

Norris, C.H.,

and

C.M. Bethke,

(Abstract) “Mathematical

Models

of

Subsurface

Processes in Sedimentary

Basins”,

Conference

on Mathematical

and Computational

Issues in

Geophysical

Fluid

and Solid Mechanics,

Society

---

Charles H. Norris

(Continued)

for Industrial and

Applied Mathematics

Annual

Meeting,

Houston, Texas, September

28

(invited

paper),

1989.

Norris,

CR,

“An

Evaluation

ofthe Geology and

the

Monitoring

Well

Data [at

the]

City ofUrbana

Regional

Landfill”,

report

submitted

to the

City

of Urbana, Champaign

County,

Illinois, for Central

States Education

Center,

Champaign,

Illinois,

1989.

Norris, C.H.,

Gallatin

National

Proposed BalefillfLandflll

[at]

Fairview,

Illinois;

testimony

before Fairview

Town

Council,

Fairview,

Illinois,

November, 1988.

Norris,

CR,

“Evaluation of

the Hydrogeologic Factors

Influencing

Risk

[at the]

ISWDA

Regional Landfill

Site B”,

report submitted

to the Inter-Governmental

Solid

Waste Disposal

Association, Champaign

County,

Illinois,

1988.

Norris,

CR,

and

CM

Bethke,

“Status and Future Directions

of

Quantitative

Flow Modeling

in Sedimentaiy

Basins”,

Workshop on Quantitative

Dynamic

Stratigraphy

(QDS),

Colorado School of Mines,

Lost

Valley

Ranch,

Colorado, February 14-18,

1988.