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COAL ASH, RACE & CLASS IN NORTH CAROLINA
Libbie Weimer, MCRP
April 181h, 2016
The following document presents profiles of the fourteen coal ash sites and two permitted coal ash landfills in North Carolina. The report begins with summaries
of data collected across all sites. Then, the report details the sites. For each site, the report presents information about the residents within three study
distances— 1km, 3km and 5km from the edge of the pond or landfill. For each site and each study distance, the profile contains data on 1) demographics
including population and population density, race and ethnicity, and income; 2) cumulative impacts from other toxic facilities including number of facilities and
pounds of onsite toxic releases from those facilities. Each site profile summarizes this information in the final measure, 3) an environmental justice index score
that compares the 1 km, 3 km, and 5 km study level information to three regions: the state, the county, and the locality. The environmental justice index
incorporates impacts on low-income communities, communities of color and cumulative impacts into one score for each site.
For a more detailed explanation of the all methods used to create these profiles, please see the appendix. The accuracy of the results is limited by the data
available in the U.S Census. Due to racial and economic segregation, the report may overestimate or underestimate the impact of coal ash on communities of
color and/or low-income communities. While this problem exists with all small -area studies, unfortunately, the census is especially ill -suited for research
involving rural communities. The limitations of this analysis highlight the importance of ground-truthing the data by collaborating with members of the
communities profiled in this report.

REPORT SUMMARIES
A
Asheville
Dan River
y •Roxboro
8elews Creek A Mayo
Buck
Marshall Cape Fe � _4 Brickhaven
Riverbend Colon Mill
A Lee
Cliffside Alter
Weatherspoor
Legend Sutton
A Operational Coal Plants
Closed Coal Plants
0 40 80 160
Structural Fill Sites Miles
Figure 1. Locations of the fourteen coal ash ponds and two permitted coal ash landfill sites, with North Carolina county borders shown for reference.

POPULATION
Selews
Allen Asheville Creek
30K
25K
20K
10K
5K
OK
.
E
E
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Site Name ( Analysis Level
Suck Cape Fear Cliffs ide Ilan River Lee Marshall Mayo Riverbend Roxboro Sutton Weathers..
1000
900
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700
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300
200
100
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E E E E E E E E E E E E E E E E E E
Y Y Y s Y Y Y Y Y Y Y Y Y Y Y Y Y Y

RACE/ETHNICITY
Site Name ! Analysis Level
Bel ews
Allen Asheville Creek Buck Cape Fear ClifFside Dan River Lee Marshall Mayo Riverbend Roxboro Sutton Weathers,.
0.6
0.2
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Site Name d Arralysis Level
Belem
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St€a
INCOME
80
70K
as
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Sal(
40'K
30 K
20K
10K
teMedian Income
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E E E E E E E G E E E G c E� c E E E E E E G E E E E E E E G G G G E_ E_ E_ G E E_ E_ G
Y Y Y s Y Y Y Y Y Y Y Y s1 Y - - Y - - - Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y
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RIVERBEND STEAM STATION
DEMOGRAPHIC ANALYSIS
POPULATION Population Count
Site Name 1km 3km
Riverbend 689 4,177
Population Density
(people per sq. mi.)
5km 1km 3km 5km
14,831 285 406 276
RACE/ % Non -white % Black % Latino
ETHNICITY
Site Name 1km 3km 5km 1km 3km 5km 1km 3km 5km
Riverbend 15.6% 25.1% 24.9% 10.0% 17.9% 18.3% 3.1% 3.2% 4.8%
INCOME Median Income Estimate
Site Name 1km 3km 5km
Riverbend $ 110,351 $ 92,578 $ 81,460
CUMULATIVE IMPACTS
SITE NAME REFERENCE COUNTIES) ONE OR MORE TRI % OF COUNT(IES)' % OF COUNT(IES)' TRI
(*ACTIVE COAL SITES W/IN 5KM TRI SITES W/IN ONSITE RELEASES
PLANT) BUFFER 5KM BUFFER W/IN 5KM BUFFER
Riverbend Gaston, Mecklenburg N 1% 0%
Closest City: Mount Holly
Plant Status: Closed
Coal Ash Pond Acreage: 115
DEQ Site Prioritization: High

ENVIRONMENTAL JUSTICE INDEX — RIVERBEND
Indicator
Race/Ethnicity
Income
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Reference
Census
Region
State
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81,460
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MEAN
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National Ash Management Advisory Board
Dr. John L. Daniels, P.E. Dr. Jeffrey C. Evans, P.E. Dr. William E. Wolfe, P.E.
Chair Groundwater Subcommittee Chair Closure Plan Subcommittee Chair
Dr. Susan E. Burns, P.E., Member
Mr. Bob Deacy, Member
Dr. Garrick E. Louis, Member
Dr. Patricia D. Galloway, P.E.
Member and
Project Management Oversight Board Chair
Dr. Robert B. Jewell, Member
Dr. Lawrence L. Sutter, Member
Dr. Krishna R. Reddy, P.E., Member
Dr. Joyce S. Tsuji, DABT, Member
April 5, 2o16
Mr. Tom Reeder
Assistant Secretary
North Carolina Department of Environmental Quality
217 West Jones Street
Raleigh, NC 27603
RE: National Ash Management Advisory Board Comments on Proposed Risk Classifications
Dear Mr. Reeder,
This letter is written in response to the North Carolina Department of Environmental Quality's (DEO) request for
public comment on its proposed risk classifications of coal ash impoundments. Our comments are directed at
impoundments which have proposed classifications of low -intermediate, intermediate, and high, according to DEQ's
application of the Coal Ash Management Act (CAMA).
This letter has been compiled, reviewed and endorsed by the National Ash Management Advisory Board (NAMAB).
Note that Duke Energy is required to actively maintain the NAMAB for compliance with its Plea Agreement, as per
United States of America v. Duke Energy Business Services, LLC, and settlement in the United States District
Court for the Eastern District of North Carolina, Western Division. The NAMAB is an independent group of
experts chartered through Duke Energy and managed by the University of North Carolina at Charlotte (UNC
Charlotte). Board members provide advice to Duke Energy, but they are contracted with and report to UNC
Charlotte.
The NAMAB has been integrally involved in the review of groundwater assessment plans, comprehensive site
assessments, and corrective action plans, which have been submitted to DEQ Likewise, it has participated in the
review of stability and engineering related assessments and with the implementation of NAMAB-recommended
health and environmental assessments of risk. While licensed professionals are responsible for these work products,
the group is sufficiently aware of the site -specific conditions to which the CAMA risk classification criteria are being
applied. For example, licensed engineers and geologists, with support from health and environmental risk assessors,
have determined that there is no imminent hazard. Those same professionals have determined that existing
conditions at these sites do not present a substantial likelihood that death, serious illness, severe personal injury, or a
substantial endangerment to health, property, or the environment will occur.
In the abstract, a risk classification system is logical. In reality, DEQs risk classification cannot be de -coupled from
the prescriptive remedy approach defined by CAMA. A risk classification of intermediate or high (for instance high
priority as prescribed in the case of Asheville, Dan River, Riverbend and Sutton) by law requires excavation and re -
disposal to a new location without a scientific basis, and without consideration of broader immediate and life cycle
impacts to communities and the environment. Moreover, aggressive closure schedules preclude the pursuit of
beneficial use opportunities.

Excavation of coal ash is one method of addressing site's groundwater or stability concerns. However, based on
holistic and life cycle considerations, it may not be a safe, effective and sustainable alternative. Other alternatives
either individually or in combinations, such as capping, monitored natural attenuation, slurry cutoff walls, in -place
stabilization/fixation, pumping wells, permeable reactive barriers and volume reduction of impounded ash through
escalation of beneficial use, should be considered and compared on an impoundment by impoundment basis to
develop an effective, safe and sustainable remedial strategy. The efficacy of these alternative methods increases with
the amount of ash in any given location, i.e., the larger the impoundment, the smarter we need to be. The
environmental and geotechnical remediation business is very mature and has evolved beyond a "dig and haul"
mentality as the best and most environmentally protective solution.
The additional risk imposed by excavating and transporting ash from one location to another can exceed the potential
risk posed by leaving the ash in place. Risk drivers include the statistical certainty of traffic fatalities and injuries, as
tabulated by the National Highway Traffic Safety Administration. Likewise, excavation results in ecological
disturbance, ongoing site releases from ash disturbance for years and broader environmental impacts from resource
use and emissions, as noted by the U.S. Environmental Protection Agency (EPA). These risks and impacts should be
calculated and considered before embarking on the mass movement of tens of millions of tons of material.
Licensed engineers and scientists have the education and experience needed to select and design the means, methods
and timeline for closure activities. It may be appropriate for legislation to define the initiation of closure activities,
but it should not stipulate a prescriptive approach with specific completion dates. The latter depends on site -specific
details that are encountered as data are collected and professionally evaluated. This logic is understood by the
environmental professionals as well as the EPA in reference to its approach to evaluating corrective action:
"EPA understands that there are a variety of activities that may be necessary in order to select the appropriate remedy (e.g.,
discussions with affected citizens, state and local governments; conducting on -site studies or pilot projects); and, once selected, to
implement the remedy (e.g., securing on -site utilities if needed, obtaining any necessary permits, etc.). That is why EPA does not
find it appropriate to set specific timeframes for selecting the remedy or to begin implementing the selected remedy."
This logic was incorporated into CAMA, given the provision for the Coal Ash Management Commission (CAMC).
The CAMC existed to perform several tasks, one of which was to "Review and make recommendations on statutes and
rules related to the management of coal ash". That provision was intended to allow for a statutory response to evolving
data and analysis as has accumulated to date.
Unless the CAMA language for intermediate and high risk (and for that matter, for high priority sites) is changed,
the appropriate risk classification for virtually all impoundments is "Low". This is because a risk classification of
"Low" allows for all options to be considered, including full excavation, supported by the science and engineering and
protective of human health and the environment. This will allow DEQto review and approve a rational closure
option that is protective of the public and environment, based on site -specific conditions.
We would be pleased to meet with you or other DEQstaff at any time. Our board is composed of highly credentialed
and published experts with many years of experience on the relevant subjects from here and abroad. And we are
independent.
Respectfully,
Dr. John L. Daniels, P.E., Chair
(Professor and Chair of Civil and Environmental Engineering, UNC Charlotte)

Signed on behalf of entire NAMAB:
Dr. Jeffrey C. Evans, P.E., Groundwater Subcommittee Chair
(Professor and Chair of Mechanical Engineering, Bucknell University)
Dr. William E. Wolfe, P.E., Closure Plan Subcommittee Chair
(Professor Emeritus of Civil, Environmental and Geodetic Engineering, The Ohio State University)
Dr. Patricia D. Galloway, P.E., member and Project Management Oversight Board Chair
(President and CEO of Pegasus Global Holdings, Inc.)
Dr. Susan E. Burns, P.E., member
(Georgia Power Distinguished Professor of Civil and Environmental Engineering, Georgia Institute of Technology)
Dr. Robert B. Jewell, member
(Senior Research Engineer, University of Kentucky)
Dr. Lawrence L. Sutter, member
(Professor of Materials Science and Engineering, Michigan Technological University)
Dr. Garrick E. Louis, member
(Associate Professor of Systems Engineering, University of Virginia and Science Advisor, U.S. Department of State)
Mr. Bob Deacy, member
(Senior Vice President, Tennessee Valley Authority)
Dr. Krishna R. Reddy, P.E., member
(Professor of Civil and Environmental Engineering, University of Illinois at Chicago)
Dr. Joyce S. Tsuji, DABT, member
(Principal and Board -Certified Toxicologist, Exponent, Inc.)

cleanenergy.org
Southern A111once for
Clean Energy
April 18, 2016
N.C. Division of Water Resources
Groundwater Protection Section
N.C. Department of Environmental Quality
Attn: Debra Watts
1636 Mail Service Center
Raleigh, NC 27699-1611
VIA E-MAIL
RE: Public Comments on DEQ's Draft Ratings for Duke Energy's Coal Ash
Impoundments
Dear Ms. Watts,
1.866.522.SACE
www.cleanenergy.org
P.O. Box 1842
Knoxville, TN 37901
865.637.6055
46 Orchard Street
Asheville, NC 28801
828.254.6776
250 Arizona Avenue, NE
Atlanta, GA 30307
404.373.5832
P.O. Box 310
Indian Rocks Beach, FL 33785
954.295.5714
P.O. Box 13672
Charleston, SC 29422
843.225.2371
Thank you for the public comment opportunity regarding DEQ's draft ratings for Duke Energy's coal
ash impoundments. I'm pleased that Duke is already required to move some of its coal ash to proper
storage. I'm writing to urge you to rank every coal ash impoundment in North Carolina as high or
intermediate priority. Duke Energy should be required to remove all of the coal ash at each of its 14
power plants sites to dry, lined storage away from our waterways and groundwater, and from our most
vulnerable communities such as low-income communities or communities of color
Duke's leaking coal ash impoundments across the state continue to threaten ground and surface water.
State health officials advised communities close to Duke's facilities not to drink their well water
because of harmful pollutants like vanadium and hexavalent chromium. No family should have to
question the safety of their water. Yet rating impoundments as low risk would allow Duke to cap coal
ash in place, with nothing to stop groundwater from mixing with the ash and carrying contamination to
surrounding communities and waterways.
DEQ's rating process offers the best opportunity to properly deal with Duke's coal ash pollution and
ensure the health and safety of NC communities. Please ensure Duke's coal ash is moved to lined, dry
storage, away from our rivers and waterways and our most vulnerable communities
Thank you for your consideration,
Adam Reaves
High Risk Energy Coordinator
Southern Alliance for Clean Energy (SACE)
[e-mail]
828.254.6776 ext. 35

North Carolina
Doug Franklin, Hayesville
Sally MacMillan, Arden
Jody McClung, Weaverville
Greg Hamby, Kitty Hawk
Doris Whitfield, Raleigh
David Loven, Chapel Hill
Chris Berg, Flat Rock
Connie Leeper, Durham
Frank Bennett, Raleigh
Marcia Bennett, Raleigh
Michael Morgan, Swannanoa
M. Hazeltine, Sunset Beach
Janet Smith, Greenville
Jennifer Weiss, Raleigh
Beth Ullmer, Asheville
Margaret Horner, Leland
Steve Miller, Asheville
Jeannie McKinney, Durham
Jane Laping, Asheville
Ellen Chelmis, Asheville
Sarah Gilliam, Asheville
Sarah Davis, Raleigh
Elizabeth Bonzo-Savage, Madison
Mamie Colburn, Asheville
Jackson Leonard, Greensboro
Maxwell DeHoll, Asheville
Graham March, Asheville
Victoria Carlisle, Asheville
Rhonda Bolton, Hendersonville
Evan Willeford, Asheville
Shelby Sopina, Raleigh
Miles Neyen, Belmont
Molly Turner, Asheville
Banna Weldense, Asheville
Kaia Rubin, Asheville
Anna Emslie, Asheville
Janet Smith, Greenville
Patricia Hedrick, Charlotte
Adam Reaves, Asheville
Alan Spencer, Waynesville
Nancy Hitchcock, Hendersonville
John Coyle, Leland
cleanenergy.org
Clean Energy w
Cathy Williams, Hayesville
Gary Clontz, Clyde
Doug Wingeier, Asheville
Ann Karson, Candler
Frank Contreras, Asheville
Ann Kieffer, Asheville
Elizabeth Adams, Cary
Tennessee
Marty Menane, Knoxville
Lorraine Barker, Nashville
Nicholas Stamper, Philadelphia
Florida
Britany Perry, Longwood
Kimber Strawbridge, Jacksonville
Janice Hallman, Clearwater Beach
Sean McLaughlin, Clermont