Amended NEBA Expert Report Belews Marshall Roxboro

NET ENVIRONMENTAL BENEFIT ANALYSIS OF
PROPOSED REMEDIAL ALTERNATIVES TO
ADDRESS ALLEGED RELEASES FROM COAL ASH
IMPOUNDMENTS AT THE
BELEWS CREEK, MARSHALL, AND ROXBORO
STEAM STATIONS
AMENDED
Expert Opinion of:
Joseph P. Nicolette
Prepared by:
EPS
1050 Crown Pointe Parkway, Suite 550
Atlanta, Georgia 30338
Tel: [phone]
September 30, 2016

NET ENVIRONMENTAL BENEFIT ANALYSIS OF PROPOSED
REMEDIAL ALTERNATIVES TO ADDRESS ALLEGED RELEASES
FROM COAL ASH IMPOUNDMENTS AT THE BELEWS CREEK,
MARSHALL, AND ROXBORO STEAM STATIONS
AMENDED
Expert Opinion of:
Joseph P. Nicolette
EPS
Environmental Planning Specialists, Inc.
1050 Crown Pointe Pkwy, Suite 550
Atlanta, GA 30338
Tel: [phone]
September 30, 2016

EPS
NET ENVIRONMENTAL BENEFIT ANALYSIS OF PROPOSED REMEDIAL
ALTERNATIVES TO ADDRESS ALLEGED RELEASES FROM COAL ASH
IMPOUNDMENTS AT THE BELEWS CREEK, MARSHALL, AND ROXBORO STEAM
STATIONS
AMENDED
September 30, 2016
TABLE OF CONTENTS
1 INTRODUCTION....................................................................................................... 1
1.1 Background................................................................................................1
1.2 Summary of Opinions................................................................................ 2
1.3 Qualifications............................................................................................. 4
1.3.1 General...........................................................................................4
1.3.2 NEBA and Site Remediation Experience ........................................ 4
1.3.3 Ecosystem Service Valuation.......................................................... 5
2 NEBA AND APPLICATION TO SITE REMEDIATION...................................................... 6
2.1
What is NEBA?..........................................................................................
6
2.1.1 Why is a NEBA Analysis Necessary for Developing Appropriate
Remedial Actions for the Belews Creek, Marshall, and Roxboro
CoalAsh Basins?............................................................................
8
2.1.2 Summary.......................................................................................14
2.1.3 Understanding Risks and Injury ....................................................
15
3 NEBA
EVALUATION METHODS AND ANALYSIS.......................................................
17
3.1
Alternative Construction Analysis............................................................
18
3.2
Traffic and Implementation Safety Risk Analysis .....................................
20
3.3
Air Emissions and Energy Use Analysis ..................................................
20
3.4
Human Health Risk Analysis....................................................................
20
3.5
Ecological Habitat Service Analysis.........................................................
21
3.6
Cost Analysis...........................................................................................
32
4 NEBA
SUMMARY RESULTS...................................................................................
33
4.1 Risks Driving Remedial Alternative Selection .......................................... 33
4.2 NEBA Assessment Parameter Evaluation ............................................... 40
4.2.1 Implementation Health and Safety Risks ...................................... 44
4.2.2 Truck Trips.................................................................................... 46
4.2.3 Air Emissions................................................................................ 48
4.2.4 Energy Use................................................................................... 50
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4.2.5
Ecological Habitat Services...........................................................
52
4.2.6
Costs.............................................................................................
54
4.2.7
Each Site - Data Combined...........................................................
56
4.2.7.1 Belews Creek Steam Station ...........................................
56
4.2.7.2 Marshall Steam Station ....................................................
60
4.2.7.3 Roxboro Steam Station ....................................................
64
4.2.8
Cumulative Assessment................................................................
68
5 OPINIONS............................................................................................................. 69
6 REFERENCES....................................................................................................... 73
7 EXPERT REPORTS REVIEWED................................................................................ 78
Appendices
Appendix A Remedial Alternatives Construction Analysis
Appendix B Traffic and Implementation Risk Analysis
Appendix C Air Emissions and Energy Analysis
Appendix D Human Health Risk Analysis
Appendix E Ecological Habitat Services
Appendix F Joseph Nicolette CV
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I INTRODUCTION
I was retained on this project to conduct a net environmental benefit analysis (NEBA) of three
remedial alternatives for the Duke Energy Carolinas, LLC or Duke Energy Progress, LLC ("Duke
Energy") Belews Creek, Marshall, and Roxboro Steam Station sites. The three alternatives
evaluated were monitored natural attenuation (MNA), cap -in-place with MNA (CIP), and
comprehensive removal with NINA (Removal). The NEBA was used to compare how the remedial
alternatives for each site differ with regard to their human and ecological chemical and physical
risk profiles, environmental footprint (e.g., environmental and community benefits and costs);
ecological habitat service value; human recreational use value; air emissions (e.g., greenhouse
gases (GHG) and criteria pollutants); and monetary costs. Background on the development of the
proposed remedial alternatives is provided in the following section, followed by a summary of my
opinions, an overview of NEBA, my qualifications, the NEBA analysis, and, based on the NEBA,
my overall opinions regarding appropriate remedial alternatives for the Belews Creek, Marshall,
and Roxboro Steam Station sites. I reserve the right to supplement my opinions should additional
information become available.
1.1 Background
Coal ash stored in unlined basins associated with the Duke Energy Belews Creek, Marshall, and
Roxboro Steam Station sites has resulted in some elevated metal concentrations in groundwater
and limited on-site surface water features (e.g., seeps) at these sites. These sites are currently the
subject of an enforcement action brought by the North Carolina Department of Environmental
Quality (NCDEQ). Organizations represented by the Southern Environmental Law Center
("Intervenors") are also parties to this litigation. The litigation seeks to establish violations of state
law concerning migration of constituents of interest from these basins to surface water and
groundwater, and impose a remedy for such violations.
After this litigation commenced, North Carolina enacted the Coal Ash Management Act (CAMA).
CAMA, within the North Carolina General Assembly Session Law 2014-122, requires the owner
of coal combustion waste surface impoundments (e.g., Duke Energy) to conduct groundwater
monitoring, assessment and remedial activities as necessary at coal ash basins across the state.
Duke Energy was required to submit a Groundwater Assessment Plan (GAP) to NCDEQ by
December 31, 2014. Comprehensive Site Assessment (CSA) documents that reported the results
of site characterization activities were required to be submitted within 180 days of approval of the
GAP. Information developed under the CSAs (HDR 2015a, 2015b; SynTerra 2015a) provided the
data to be used to prepare Corrective Action Plans (CAPS) that were to be submitted to NCDEQ
within 90 days of submittal of the CSA. An agreement between Duke Energy and NCDEQ
resulted in breaking the CAP document into two parts: Part 1 and Part 2 (HDR 2015c, 2015d,
2016a, 2016b; SynTerra 2015b, 2016a). The CAP documents evaluated three alternatives (for
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some criteria, only in a qualitative manner) for the remediation of on-site groundwater according
to the following criteria:
• Effectiveness;
• Implementability/feasibility;
• Environmental sustainability;
• Cost; and
• Stakeholder input.
NCDEQ classified the impoundments as either "High", "Intermediate", or "Low risk". The CAMA
specifies that any impoundments classified by NCDEQ as "High" be closed no later than
December 31, 2019 by dewatering the waste and either a) excavating the ash and converting the
impoundment to an industrial landfill, or b) excavating and transporting the waste off-site for
disposal in an appropriately licensed landfill. "Intermediate" risk impoundments are required to be
closed similarly to "High" risk impoundments, but under a closure deadline of December 31, 2024.
Impoundments classified as "Low" by NCDEQ must be closed by December 31, 2029 either
similarly to the "High" and "Intermediate" risk sites, or by dewatering to the extent practicable
and capping the waste in place.
The Belews Creek, Marshall, and Roxboro Steam Station sites were most recently proposed (May
18, 2016) to be classified as "Intermediate" by NCDEQ, which would require closure by
dewatering the waste and either a) excavating the ash and converting the impoundment to an
industrial landfill, or b) excavating and transporting the waste off-site for disposal in an
appropriately licensed landfill. In the May 18, 2016 proposed classifications, surface water, dam
safety, and groundwater were ranked individually'.
A summary of my opinions regarding the overall net benefit associated with the proposed remedies
to address alleged releases to groundwater and surface water is presented below.
1.2 Summary of Opinions
• The Intervenors failed to take a holistic view of all of the environmental and community
impacts and risks (environmental footprint) associated with alternative implementation
during their remedial evaluation stage. This has skewed their remedy selection and leads
' It should be noted that there were recent amendments to the CAMA pursuant to NC House Bill 630 (ratified July 1,
2016 and signed by the governor on July 14, 2016). Important points associated with these amendments include:
under the new 130A-309.21 l (c 1), Duke Energy must provide a permanent alternative water supply to nearby residents
with drinking water wells. Generally, this will be by providing connection to municipal water, but there is a provision
that allows for Duke Energy to provide a filtration system at the household's election in some circumstances. Duke
Energy must provide permanent alternative water supply as soon as practical but no later than October 15, 2018;
however, the Department may grant an extension of time of up to a year if needed. Also, under the new 130A -
0309.213(d), no later than 30 days after the deadline set in 130A-309.211(cl) or any extension granted thereunder,
the Department shall issue a final classification for each impoundment. If an impoundment has established permanent
water supplies as required by 130A-309.211(cI) and if it has rectified any dam safety deficiencies, it will be classified
"Low" risk.
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them to advocate for a remedy (Removal) that is less protective of the environment and the
community.
• The Intervenors do not consider the environmental footprint of the Removal alternatives,
nor do they consider methods to reduce the footprint of these alternatives at any of the three
sites. Metrics that may have significant social and economic impacts (e.g., GHG emissions,
extended truck traffic through local communities, pollutant emissions, energy and resource
consumption) or ecological impacts (e.g., terrestrial and aquatic habitat disturbance
associated with removal, capping, or the development of off-site disposal units) were not
considered quantitatively by the Intervenors.
• Developing a remedy should employ a NEBA evaluation to develop sustainable remedial
alternatives that manage site risks while maximizing benefits and minimizing costs to the
public.
• Human health risks associated with implementation of the Removal alternative far
outweigh the marginal, if any, human health risks given the current and projected future
state of the groundwater condition.
• The impact of metals in groundwater on groundwater ecosystem service flows provided by
each individual site is marginal, if any.
• The Removal alternative will cause more ecological injury through the destruction of
habitat than the ecological injury projected by the risk assessment.
• The Removal remedy that the Intervenors propose for the Belews Creek, Marshall, and
Roxboro Steam Station sites does not appear to provide any net benefit to off-site
ecological or human use services, over other alternatives.
o The Removal alternative will create greater harm to the environment compared to other
alternatives.
o The Removal alternative will create greater risks (and nuisance) to the local community
(via the extensive truck traffic) and to workers compared to other alternatives.
• In comparing the CIP alternative to the Removal alternative, the Removal alternative has
a much greater environmental footprint and creates significantly more environmental and
community harm. This is consistent with the Tennessee Valley Authority findings in their
review of CIP and Removal alternatives for coal ash as part of their programmatic
Environmental Impact Statement (EIS) (Tennessee Valley Authority 2016).
• The Intervenors base their arguments for Removal on risks based solely upon chemical
concentrations of the constituents of interest (COIs) in groundwater and limited surface
water seep areas. In doing so, they neglected to consider factors other than chemical
concentrations during the implementation of their preferred remedial alternative that also
have the potential to influence, either positively or negatively, human health and ecological
risks and services.
• The Intervenors' proposal for Removal is unjustified and, from a net benefit analysis,
detrimental.
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• There is no need to order closure, much less closure by Removal, to remedy the alleged
violations in this case. A basic NEBA demonstrates that the Intervenors' proposed remedy
(Removal) is clearly disproportionate to the risk.
1.3 Qualifications
1.3.1 General
The basis for my opinions presented herein include my 30+ years of experience as an
environmental consultant; my educational background; my research and professional experience
in NEBA, remedial alternatives analysis, natural resource damage assessment (NRDA), and
ecosystem servicez valuation; review of the CSA, CAP Part 1, and CAP Part 2 documents, and
supplemental CSA's for each site (HDR 2015a through HDR 2015d; HDR 2016a through 2016d;
SynTerra 2015a, 2015b; SynTerra 2016a, b); and analyses conducted at my direction. In addition,
I conducted site visits at these three locations during the period of June 7-10, 2016. I hold an M.S.
degree in Fisheries Management from the University of Minnesota (1983), a B.S. degree in
Environmental Resource Management from Penn State University (1980), and am a certified
fisheries scientist with the American Fisheries Society. My CV is provided in Appendix F.
1.3.2 NEBA and Site Remediation Experience
I co-authored the first formalized NEBA framework for remediation and restoration of
contaminated sites with co-authors from the United States Environmental Protection Agency
(USEPA) and Oak Ridge National Laboratory in 2003 (Efroymson et al. 2003). The formalized
NEBA framework has been recognized by the National Oceanic and Atmospheric Administration
(NOAA), the USEPA, the USEPA Science Advisory Board (USEPA SAB)3, and the Australian
Maritime Safety Authority. I have over 24 years of experience in the application of NEBA concepts
and ecosystem service valuation approaches on over 75 projects with experience in over 16
countries. These projects have included NEBA approaches to compare land management
alternatives and remediation alternatives for groundwater, sediment, and soils and at various sites.
These projects have included work for the USEPA, the U.S. Department of Defense, and private
industry. Example projects include Crab Orchard National Wildlife Refuge; National Aeronautics
and Space Administration (NASA) Edwards Air Force Base; NASA Marshall Space Flight Center;
Army Base Realignment and Closure sites in Washington, Alabama, California, and Illinois;
Prince William Sound, Alaska; Hudson River, New York; Troutdale, Oregon; Rocky Mountain
2 The natural resources provided by the earth's ecosystems serve as the building block upon which human well-being
flows. Ecosystems represent a complex and dynamic array of animal, plant, and microbe along non -living physical
elements interacting as a functioning unit. This gives rise to many benefits, known as ecosystem services, which are
the benefits people obtain from naturally functioning ecosystems (Nicolette et al. 2013a).
3 United States Environmental Protection Agency (USEPA) Science Advisory Board (SAB). 2009. Valuing the
Protection of Ecological Systems and Services (EPA -SAB -09-012). Washington, DC: USEPA Science Advisory
Board.
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Arsenal, CO; Homestead AFB, Florida; Tennessee Valley Authority, Tennessee; and Calcasieu
River Estuary, Louisiana.
1.3.3 Ecosystem Service Valuation
I pioneered the ecological service valuation method known as habitat equivalency analysis (HEA)
prior to its codification into NRDA regulations in the United States. I have applied these methods
to a multitude of cases across the United States as well as internationally. My experience includes
over 75 NRDA-related cases, spanning from the Exxon Valdez release up through the Deepwater
Horizon incident. I was the lead author of a book chapter (published in May of 2013 by the Oxford
Press) that provided an overview of the NRDA regulations and the development of HEA and
resource equivalency analysis (REA) approaches (Nicolette et al. 2013b). The book was entitled
The EU Liability Directive: A Commentary. I led Chapter 9 that was entitled "Experience with
Restoration of Environmental Damage." I am a Senior Principal and Ecosystem Services Practice
Director with Environmental Planning Specialists, Inc. (EPS), in Atlanta, Georgia. I have served
on the Steering and/or Planning Committee of the Community of Ecosystem Services sponsored
by the United States Geological Survey since 2008.
I bill $240 per hour through EPS for my time.
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2 NEBA AND APPLICATION TO SITE
REMEDIATION
NEBA has been identified by USEPA as an important decision-making tool in the Superfund
program (USEPA SAB 2009). In addition, the USEPA Superfund program supports the adoption
of `green site assessment and remediation', which is defined as the practice of considering all
environmental impacts of studies, selection and implementation of a given remedy, and
incorporating strategies to maximize the net environmental benefit of cleanup actions. USEPA has
committed to prioritizing and emphasizing green remediation approaches and maximizing the net
environmental benefit of Superfund cleanups (USEPA 2013).
As examples, USEPA and other federal agencies used NEBA to guide remedial decision-making,
including recent remediation work on the Kalamazoo River (USEPA 2012a). The NOAA and the
United States Coast Guard (USCG) identify the use of NEBA to evaluate opportunities for no net
loss of resources and habitats during oil spill response planning (Aurand et al. 2000; NOAA 2011),
and have used NEBA to evaluate environmental responses on the Gulf of Mexico (NOAA 2011).
The United States Army Environmental Center (USAEC) also identifies NEBA as an important
tool for assessing natural resource injury (USAEC 2005).
2.1 What is NEBA?
In a site remediation context, a NEBA is a framework for comparing site remedial alternatives that
includes the incorporation of a broad array of human, social, economic and environmental metrics
to demonstrate differences among the various remedial alternatives with regard to human and
ecological chemical and physical risk profiles; community and socioeconomic benefits and costs;
ecological habitat value; human recreational use value; GHG emissions and criteria pollutants; and
remedial costs. The formalized framework for NEBA, as recognized by the USEPA Science
Advisory Board (USEPA SAB 2009), is provided in Efroymson et al. 2003 and 2004.
A NEBA framework can be used to demonstrate the net positive or negative changes in ecosystem
service (ecological, social, and economic) values between various remedial alternatives. A NEBA
framework also is useful for assessing and comparing the sustainability of different remedial
alternatives through the quantification of impacts over time associated with the implementation
and long-term performance of each alternative (Efroymson et al. 2004; Nicolette et al. 2013a).
NEBA has been shown to be an objective approach for evaluating the risks, benefits, and tradeoffs
associated with different alternatives for remediation and environmental restoration work
(Efroymson et al. 2003, 2004; USEPA 2009a; NOAA 2011). The NEBA approach is consistent
with USEPA risk management objectives (USEPA 2009b) and provides a framework to help
USEPA comply with its policy, guidance, and direction, particularly with large scale remedial
programs where the benefits and impacts of potential alternatives are significant and need to be
evaluated closely.
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A NEBA framework incorporates quantified analyses that consider changes in various metrics that
influence ecosystem service values which, in turn, help to highlight differences between remedial
alternatives. NEBA is a systematic process for quantifying and comparing the benefits and costs
among competing alternatives; it does not rely solely on monetization but rather also includes non -
monetary environmental metrics. A NEBA framework for comparing each remedial alternative
should include, among others, the incorporation of a broad array of metrics to demonstrate
associated changes in human and ecological chemical and physical risk profiles; community and
socioeconomic issues; ecological habitat value; human recreational value effects; GHG emissions;
and remedial costs.
NEBA is similar to cost -benefit analysis (CBA), which USEPA and other federal agencies have
used for decades to support decision-making. NEBA and CBA both consider time -accumulated
service flows (i.e., benefits and costs over time); since these benefits and costs occur over varying
time frames, they can be normalized to their net present value using a discount rate. The NEBA
approach, however, moves beyond the traditional CBA approach by demonstrating environmental
stewardship and sustainability through the quantification of environmental metrics. A NEBA
typically involves the comparison of several management alternatives that may include: (1) leaving
the site condition "as is"; (2) physically, chemically or biologically treating the site condition; (3)
improving ecological value through restoration alternatives that do not directly focus on removal
of site materials; or (4) a combination of those alternatives (Efroymson et al. 2004). Understanding
these benefits, and how they may change among remedial actions, maximizes benefits to the
environment and the public while managing costs and site risks.
As stated in Efroymson et al., 2004, "This framework for NEBA should be useful when the balance
of risks and benefits from remediation of a site is ambiguous. This ambiguity arises when the
contaminated site retains significant ecological value, when the remedial actions are themselves
environmentally damaging, when the ecological risks from the contaminants are relatively small,
uncertain, or limited to a component of the ecosystem, and when remediation or restoration might
fail." As set forth more fully below, these are precisely the circumstances present with the Duke
Energy sites that I have analyzed.
NEBA typically considers a broader range of environmental effects than the traditional human
health and ecological risk assessment processes that drive remedial action decisions. Typically,
these processes consider only the remedial alternatives' ability to limit exposure and human risks
from a chemical condition. The effects on other ecosystem services (e.g., human use and
ecological benefits) associated with implementation of a remedial alternative are typically not
considered in the traditional remedy selection process. A NEBA shows formally the positive and
negative effects on ecosystem services4 and/or surrogate metrics associated with a remedial action
in relation to the incremental changes in risk. By considering the effects of a given remedial
alternative on all services provided by the site, the net effects on all service flows are considered,
including any potential loss of services. In some cases, for example, a remedial alternative may
destroy or significantly degrade the ecological landscape and achieve little or no reduction in
4 A NEBA can also be referred to as a net ecosystem service analysis (MESA) (Nicolette et al. 2013b).
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ecological or human health risk. In simpler terms, NEBA can be used to determine, for each
remedial alternative, whether "the cure is worse than the disease."
2.1.1 Why is a NEBA Analysis Necessary for Developing Appropriate Remedial
Actions for the Belews Creek, Marshall, and Roxboro Coal Ash Basins?
1. The effects of the Removal or CIP remedial alternatives on ecosystem services have not
been fully quantified. As such, this can lead to remedial alternatives that can either:
— cause more ecological injury through the destruction of habitat than the ecological
injury projected by the risk assessment (e.g., "the cure is worse than the disease"), or;
— provide a marginal benefit or no net increase in ecosystem service value for the effort
expended; this is especially true when ecological risks from the contaminants are
relatively small, uncertain, or limited to a component of the ecosystem.
It is important to understand that within the regulatory cleanup framework (e.g., as applied
in North Carolina), the selection of remedial alternatives to address the site condition is
typically based upon the potential for the chemical to pose a human health and/or
ecological risk (or in some circumstances, the remedial action is considered necessary
simply to address impaired groundwater regardless of risk) and the cost of the alternative.
Within this framework, the net effect that a remedial action may have on the ecosystem,
positive or negative, is rarely formally quantified when considering among remedial
alternatives. It is my understanding, however, that a court exercising its equity jurisdiction
to fashion a remedy for a violation of environmental regulations has the ability to consider
the broader implications of its actions. The NEBA fits squarely within the type of analysis
that I understand a court would employ in considering injunctive relief.
2. NEBA Will Improve the Validity of the Remedial Evaluation Decision -Making Process to
Stakeholders
Intervenors have not fully considered the environmental impacts, health risks and socio-
economic consequences of both the short-term and the long-term impacts of the remedial
alternatives. Each certain or possible impact should have been included in a formal analysis
using a NEBA framework.
A NEBA is needed to provide a scientifically -sound basis for remedial decision-making.
Specifically, and per USEPA guidance, the NEBA provides transparency and consistency
in the evaluation and decision-making process so that stakeholders and the public are aware
of the full extent of potential social, health, and environmental impacts of the proposed
remedy.
The Intervenors provide insufficient information to demonstrate that they adequately and
transparently considered important factors with environmental, social and economic
implications consistent with policy, guidance and direction. Specifically, they did not
demonstrate (1) a preference for green remediation or a sustainable solution; (2) the
environmental footprints of the various remedial alternatives; (3) the environmental and
social risks associated with the various remedial alternatives; and (4) the consideration of
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net environmental, economic and social benefits. The court should not, therefore, adopt
the Intervenors' proposed remedy.
3. NEBA Support in Decision -Making Mandated by USEPA
NEBA has been conducted by several federal agencies, including USEPA, because it
provides an approach for balancing the risks, benefits and tradeoffs associated with
competing remedial alternatives in a transparent manner by which all stakeholders can
understand the basis for a decision. The merits of using a NEBA framework (based on
formally quantified metrics) for transparent decision-making associated with site
remediation, compensatory restoration and ecosystem service tradeoffs have been
discussed by various authors (Efroymson et al. 2003, 2004; Colombo et al. 2012; Nicolette
et al. 2013a).
The need for transparency in decision-making is made apparent in the 1995 USEPA Risk
Characterization Program memorandum by Carol Browner, former USEPA Administrator
(USEPA 1995). In the Browner memorandum, the core values that the USEPA is striving
to achieve are transparency, clarity, consistency and reasonableness. These same core
values have been repeated often in USEPA guidance from the 1990s to the present.
Excerpts from the Memorandum Written by Former USEPA Administrator,
Carol Browner (USEPA 1995)
"First, we must adopt as values transparency in our decision-making process and
clarity in communication with each other and the public regarding environmental risk
and the uncertainties associated with our assessments of environmental risk. "
"Second, because transparency in decision-making and clarity in communication will
likely lead to more outside questioning of our assumptions and science policies, we
must be more vigilant about ensuring that our core assumptions and science policies
are consistent and comparable across programs, well grounded in science, and that
they fall within a `zone of reasonableness. " While I believe that the American public
expects us to err on the side of protection in the face of scientific uncertainty, I do not
want our assessments to be unrealistically conservative. We cannot lead the fight for
environmental protection into the next century unless we use common sense in all we
do. "
As an example, NEBA was used by the USEPA at the Woodlands Superfund site located
in New Jersey where it was applied to assess the ecological impacts of the preferred
remedial groundwater action. The NEBA demonstrated that the preferred remedy (pump
and treat) would cause injury to the ecosystem, while a lower cost alternative (air
sparge/vapor extraction) would not cause injury and would save $87 million in remedial
costs. The Record of Decision was subsequently changed to the air sparge/vapor extraction
alternative supported by the NEBA. In this case, the downgradient portion of the
groundwater plumes at both sites was allowed to naturally attenuate. The USEPA deemed
the application of NEBA as successful in an agency -published report describing the
remedial decision at the Woodlands Superf ind site (Exhibit 1, USEPA 2001).
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Exhibit 1. Example USEPA groundwater Record of Decision change based on a NEBA.
Region
1640
1293
:..
Cnound water
state supported the
Fed= 13Oe hours
change The Site is
ry
Con. = JO
Woodland%, NJ
located in a [Alfa] area
1 "(ROD -A)
1+'1199
and the local populmon
Est'd Sa}ings =
Route ?_'
suppons tau remcdsy
S 81.6 M
Rause i32
change.
Type of Change: From - ground nater pump and treat: To - air spargingisod vapor extraction and natural attenuation -
Factual Basis-. STAG memo indicated that the ground water pump and treat system would dewater the nearby wellands. In
addltwn. durmg remedial &-sign. the PRP successfully identified altrruances that would. meet ROD objectives ai much lower
cost
4. A systematic, transparent, and scientifically -based approach for a fully informed remedial
decision-making process is needed.
A NEBA is a comparative analysis that incorporates ecosystem service values and provides
stakeholders a basis to balance the risks, benefits and trade-offs associated with competing
management alternatives. Incorporation of ecosystem service valuation concepts with
formally quantified values within an alternatives decision-making process provides
decision makers with an opportunity to make informed choices about the net benefits of
actions that affect the environment. By "informed," I mean an approach that is:
— systematic,
— transparent and understandable to stakeholders,
— non -arbitrary,
— scientifically -based and defendable,
— quantitative in nature where possible,
— based on internationally recognized concepts and approaches, and
— considerate of all stakeholder concerns thus providing a holistic perspective to the
decision-making process.
NEBA incorporates the use of ecosystem service valuation concepts and methods that have
been litigation -tested and upheld in federal court (United States 1997, 2001) to evaluate
changes in habitat value over time. In addition, a variety of human use economics -based
models can be incorporated into a NEBA to evaluate changes in human use value
(recreational, commercial, aesthetic, educational, scientific, etc.) over time. A NEBA can
also incorporate implementation risks, chemical contamination risks, and a variety of proxy
metrics (e.g. GHGs) to help in differentiating between alternatives.
S. It is the public policy of the State of North Carolina to carefully consider the environmental
impacts associated with each remedial alternative as part of the decision-making process
for selection of a preferred remedy. This is consistent with the direction and policy of the
State of North Carolina Environmental Policy Act (SEPA) and Federal USEPA policy,
guidance, and direction for remedial decision-making.
Determining the appropriate remedy for this case requires a consistent, detailed and
transparent assessment of the environmental, social and economic impacts associated with
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remedial alternatives specified for each site. The following examples from the USEPA and
the State of North Carolina illustrate the importance of providing consistent, adequate,
clear, and transparent information.
Example 1. Risk managers must assess and balance risks between site contaminants and
proposed remedies (USEPA 1997).
EPA Superfund Ecological Risk Assessment (ERA) Guidance (Step 8) specifically
states that:
"The risk manager must balance (1) residual risks posed by site contaminants before
and after implementation of the selected remedy with (2) the potential impacts of the
selected remedy on the environment independent of contaminant effects. "
"In instances where substantial ecological impact will result from the remedy (e.g.,
dredging a wetland), the risk manager will need to consider ways to mitigate the impact
of the remedy and compare mitigated impacts to the threats posed by the site
contamination. "
Example 2. This balance should be incorporated into the decision-making process for
contaminated sites (USEPA 2005).
"Project managers are encouraged to use the concept of comparing net risk reduction
between alternatives as part of their decision-making process for contaminated
sediment sites, within the overall framework of the NCP remedy selection criteria.
Consideration should be given not only to risk reduction associated with reduced
human and ecological exposure to contaminants, but also to risks introduced by
implementing the alternatives [..] Evaluation of both implementation risk and residual
risk are existing important parts of the NCP remedy selection process. By evaluating
these two concepts in tandem, additional information may be gained to help in the
remedy selection process. "
Example 3. Feasibility Studies should include a comparison of environmental footprints
(USEPA 2008).
"Green remediation focuses on maximizing the net environmental benefit of cleanup,
while preserving remedy effectiveness as part of the Agency's primary mission to
protect human health and the environment [..] Key opportunities for integrating core
elements of green remediation can be found when designing and implementing cleanup
measures. Regulatory criteria and standards serve as a foundation for building green
practices. Key elements include reducing atmospheric release of toxic or priority
pollutants, and reducing emissions of greenhouse gases that contribute to climate
change."
DCN: HWIDENCO02A 11 September 30, 2016

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"In accordance with green remediation strategies, feasibility studies could include
comparison of the environmental footprint expected from each cleanup alternative,
including GHG emissions, carbon sequestration capability, and water drawdown
(lowering of the water table or surface water levels). "
Example 4: Green remediation technologies should be considered for response actions
(USEPA 2011 a, 2011 b).
The USEPA Superfund program supports the adoption of "green site assessment and
remediation", which is defined as the practice of considering all environmental impacts
of studies, selection and implementation of a given remedy, and incorporating
strategies to maximize the net environmental benefit of cleanup actions. USEPA has
established a "Clean & Green" policy to enhance the environmental benefits of
Superfund cleanups by promoting technologies and practices that are sustainable. The
policy applies to all Superfund cleanups. Under this policy, certain green remediation
technologies will serve as touchstones for response actions.
Example 5: USEPA has identified a framework to quantify various metrics to help
understand and reduce a project's environmental footprint (USEPA 2012b).
"Green remediation strategies can include a detailed analysis in which components of
a remedy are closely examined and large contributions to the footprint are identified.
More effective steps can then be taken to reduce the footprint while meeting regulatory
requirements driving the cleanup [...J. The term "environmental footprint" as
referenced in the methodology comprehensively includes metrics such as energy use
and water use as well as air emissions to fully represent the effects a cleanup project
may have on the environment. "
"The methodology is a general framework to help site teams understand the remedy
components with the greatest influence on the project's environmental footprint.
Quantifying the metrics can serve as an initial step in reducing the remedy footprint.
The overall process allows those involved in the remedial process to analyze a remedy
from another perspective and potentially yields viable and effective improvements that
may not have been identified otherwise. "
Example 6: The State of North Carolina has declared, in its State Environmental Policy
Act (SEPA) (§ 113A-3), that it shall be the continuing policy of the State of North
Carolina to conserve and protect its natural resources (North Carolina 1971).
The State of North Carolina has declared, in its SEPA (§ 113A-3), "that it shall be the
continuing policy of the State of North Carolina to conserve and protect its natural
resources and to create and maintain conditions under which man and nature can exist
in productive harmony. Further, it shall be the policy of the State to seek, for all of its
citizens, safe, healthful, productive and aesthetically pleasing surroundings; to attain
DCN: HWIDENCO02A 12 September 30, 2016

0
the widest range of beneficial uses of the environment without degradation, risk to
health or safety; and to preserve the important historic and cultural elements of our
common inheritance. (1971, c. 1203, s. 3.)"
Consistent with this declaration and USEPA direction, the State of North Carolina
Waste Management Division integrates its programs with federal cleanup programs.
The question arises, have the proposed remedial solutions been properly vetted as to
their protection of natural resources and are they providing the widest range of
beneficial uses of the environment without degradation? For the reasons set forth in
this document, the Intervenors' proposal for a remedy (Removal) fails this test.
Example 7. Guidelines for establishing remediation goals at Resource Conservation and
Recovery Act (RCRA) Hazardous Waste Sites (NCDEQ 2013)
The Hazardous Waste Sites (HWS) goal is that RCRA facilities remediate all releases
of hazardous waste or hazardous constituents to unrestricted use levels. For
groundwater, the unrestricted use level is the North Carolina Division of Water Quality,
15A NCAC 2L groundwater standard (2L) or site-specific background concentration.
For soil, the unrestricted use level is either the site-specific background concentration
or the lowest of a soil screening level protective of groundwater and the health -based
residential Preliminary Soil Remediation Goal (PSRG). Unrestricted use levels are the
starting points for the HWS preliminary screening process. The HWS does recognize
that, in some cases, it may be infeasible to remediate to unrestricted use levels.
Although USEPA has classified coal ash and coal combustion residuals as non-
hazardous, these guidelines represent an important reference tool for the present
situation. If the HWS guidelines recognize a NEBA approach to remediation of
hazardous waste, then NEBA should also apply to non -hazardous wastes as well.
Example 8. Planning and Promoting Ecological Land Reuse of Remediated Sites (ITRC
2006, State of North Carolina is a Member)
"The Interstate Technology and Regulatory Council (ITRC) Ecological Land Reuse
Team has developed this guidance document to promote ecological land reuse as an
integrated part of site remediation strategies and as an alternative to conventional
property development or redevelopment. This reuse may be achieved through a design
that considers natural or green technologies or through more traditional cleanup
remedies. The decision process presented here helps stakeholders to integrate future
land use and stakeholder input into an ecological land end -use -based remediation
project. "
"Ecological benefits have not traditionally been designed into, nor credited to, the
value of the reusable land until successful remediation was completed. Now, natural
and green technologies can improve the ecology of the site as long as they support the
intent of the land's use and do not jeopardize the elimination or reduction of the human
DCN: HWIDENCO02A 13 September 30, 2016

0
or environmental risk. Consideration of ecological benefits, as well as the end use of
an environmentally impacted site, is an integral component of the remediation
process.
This guidance raises the question, has the ecology and end land use been properly
considered in the development of the remedy? It is clear that the Intervenors have not
considered these values in advocating their proposed remedy.
Example 9: In a recent Memorandum (August 2, 2016), the USEPA recommends
approaches for Superfund programs to consider conducting a best practices or footprint
analysis and using greener cleanup activities through the CERCLA cleanup process
(USEPA 2016).
As stated in this reference, OSWER's "... goal is to evaluate cleanup actions
comprehensively to ensure protection of human health and the environment and to
reduce the environmental footprint of cleanup activities, to the maximum extent
possible. In considering these Principles, OSWER cleanup programs will assure that
the cleanups and subsequent environmental footprint reduction occur in a manner that
is consistent with statutes and regulations governing EPA cleanup programs and
without compromising cleanup objectives, community interests, the reasonableness of
cleanup time frames, or the protectiveness of the cleanup actions. "
In addition, the memorandum outlines five key factors that regional staff should
generally consider when implementing greener cleanups (i.e., minimize total energy
use and maximize use of renewable energy; minimize air pollutants and greenhouse
gas emissions; minimize water use and impacts to water resources; reduce, reuse, and
recycle materials and waste; and protect land and ecosystems).
2.1.2 Summary
A NEBA should be conducted by the Court to determine the remedy for this case, since remedial
decision-making policy and guidance obligates the regulatory authorities to evaluate the
environmental and community impacts associated with potential remedial actions and dictates that
the remedies should be sustainable and demonstrate a net environmental benefit to the public.
USEPA has made "greener" cleanups part of its cleanup program mission, which the USEPA has
stated strives to reduce adverse impacts on the environment, use natural resources and energy
efficiently, minimize or eliminate pollution at its source, use renewable energy and recycled
materials whenever possible, and reduce waste to the greatest extent possible. According to
USEPA, the practice of "green remediation" involves strategies that consider all environmental
effects associated with remedy implementation at contaminated sites, and the selection of
alternatives that maximize the net environmental benefit of cleanup actions (USEPA 2008).
The use of a NEBA evaluation ensures that on a site-specific basis, decision -makers consider, at
the remedy selection stage, not only the benefits of a remedial approach, but also the residual risks
DCN: HWIDENC002A 14 September 30, 2016

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associated with the approach and the risks associated with implementing the remedial approach.
This differs from the traditional approach of either considering implementation risks at the remedy
implementation stage or assuming that remedial approaches will be 100% effective on
implementation, thereby bypassing any consideration of residual risk. NEBA is consistent with
the National Oil and Hazardous Substances Pollution Contingency Plan's (NCP) 9 -point criteria
(40 CFR §300.430(e)(9)(iii)), which require evaluation and balancing of short-term and long-term
risks and benefits, including residual risk. Failure to take a holistic view of all of the
environmental and community impacts and risks associated with alternative implementation
during the remedial evaluation stage can skew remedy selection and result in a remedy that
is less protective of the environment and the community.
The NEBA was conducted to examine key parameters associated with remedial alternatives
proposed at the Belews Creek, Marshall, and Roxboro Steam Station sites. This analysis follows;
however, prior to discussing the NEBA analysis, I provide a brief discussion on the difference
between "perceived" risk, "real" risk, and injury. These distinctions are important when
determining appropriate remedial actions.
2.1.3 Understanding Risks and Injury
It is important to understand the distinction between risk and injury and the ramifications that this
distinction has on remedial alternative selection. In the 1998 USEPA Guidelines for Ecological
Risk Assessment (EPA/630/R-95/002F) (an expansion and replacement for the 1992 ecological
risk assessment guidelines), risk assessment is defined as "...a process that evaluates the likelihood
that adverse ecological effects may occur or are occurring as a result of exposure to one or more
stressors" (USEPA 1998). "Risks" result from the existence of a hazard and uncertainty about its
expression. Uncertainty is defined as "Imperfect knowledge concerning the present or future state
of the system under consideration; a component of risk resulting from imperfect knowledge of the
degree of hazard or of its spatial and temporal pattern of expression" (Suter 1993). Since a "risk"
evaluation typically looks at the "likelihood" of an adverse effect, it thus includes an implied level
of uncertainty in an effect. Thus, simply put, a "risk" represents the "potential" that adverse effects
may occur (with some level of uncertainty), not a definitive measure of observable effects.
In many cases, uncertainty in risk assessment is handled through the use of layers of conservative
assumptions (e.g., use of maximum concentrations, extended exposure periods, unrealistic
exposure assumptions) that cumulatively may predict a risk when, in fact, no injury is occurring
(a "perceived" risk). As such, there may be no adverse effects, and no "real" risks in an area where
contaminant concentrations are above a criterion and remediation is being required. A key function
in the strategic site assessment is to be able to understand and differentiate between what would
be considered a "perceived" risk versus a "real" risk.
The meaning of observable effect to a natural resource is very different than a "risk" to a natural
resource. This distinction is important when it comes to understanding those effects that have been
documented (quantified/measured) through actual field studies, versus those effects that "may
have" or "potentially have" occurred, or those effects that "may" or "potentially" be occurring now
and/or into the future. The differentiation between risk and observable effects (i.e., injury) has
been made prominent based upon the NRDA regulations in CERCLA (43 CFR 11), where the
DCN: HWIDENC002A 15 September 30, 2016

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public is to be compensated for natural resource injury that has occurred as a result of a release.
Under NKDA, the lost natural resource services (injury) are quantified so that an appropriately
scaled restoration program can be developed ("service -to -service" equivalency approach). In this
approach, injury must be measured (with some level of certainty) and used to develop the scale of
the restoration program. Thus, there is some certainty that there is indeed injury and therefore, that
restoration or remediation is required and adequate.
DCN: HWIDENCO02A 16 September 30, 2016

EPS
3 NEBA EVALUATION METHODS AND
ANALYSIS
The basic NEBA evaluation presented herein for the Belews Creek, Marshall, and Roxboro coal
ash basins compared the MNA, CIP, and Removal alternatives as to how they would affect,
positively or negatively, ecosystem service values (human use and ecological) and associated
metrics for each site; and therefore provide an improved understanding of the environmental
footprint and community risks associated with the alternatives. In order to conduct the NEBA
analysis, several key factors were identified and considered to help establish an understanding of
the environmental footprint that would be associated with the various alternatives. These included:
1. chemical risks associated with contaminant exposures (ecological and human);
2. health and safety and implementation risks (mortality, injuries, illness);
3. physical impacts on the habitats and related ecological services associated with the actions;
4. GHG's and other criteria air pollutants;
5. energy use;
6. community impacts (e.g., increased traffic, accidents);
7. human use value (groundwater, recreation, hunting, etc.); and
8. costs.
These factors resulted in specific parameters that were considered to help assess predicted changes
over time, given implementation of the remedial alternatives. For the analysis, I considered the
following parameters:
• human health - public off-site contaminant exposure (wader, boater, swimmer);
• human health - on-site contaminant exposure (commercial industrial worker, construction
worker, trespasser);
• human health - fish consumption (recreational, subsistence fishermen);
• human health - drinking water (i.e., from groundwater consumption);
• implementation risks - truck traffic related accidents/mortality;
• implementation risks - on-site worker safety;
• community nuisance — truck trips (e.g., relates to noise, dust, aesthetics);
• energy use — cumulative energy requirements;
• GHGs;
• pollutant emissions (e.g., NOX, particulate matter) - truck traffic, on-site construction
(yellow iron);
• ecological habitat services (terrestrial, aquatic, avian);
• groundwater services;
DCN: HWIDENCO02A 17 September 30, 2016

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• human recreational uses; and
• capital costs including long-term operations and maintenance (O&M).
Although the above parameters were considered in the analysis, not all were able to be quantified
given the lack of available information. Therefore, the NEBA presented herein is not fully
comprehensive in the scope of the supporting quantitative evaluations — the most pertinent and
impactful elements are quantified. Other elements, if considered, would push the NEBA further in
the disparity amongst the remedial alternatives considered. Those parameters not quantified were
considered from a qualitative standpoint in support of evaluating the environmental footprint and
community risks associated with the remedial alternatives. The analysis is sufficiently robust,
however, to require rejection of the Intervenors' proposed remedy.
3.1 Alternative Construction Analysis
As part of the evaluation, it was necessary to evaluate the construction activities, equipment
necessary, etc. that would be associated with the proposed remedial alternatives in order to
understand those factors that would affect the environmental footprint and associated risks
associated with the proposed remedial alternatives.
A construction and cost analysis for the MNA, CIP and Removal alternatives was conducted for
the Belews Creek, Marshall, and Roxboro Steam Stations. The three remedial alternatives
evaluated were based on the remedial assessment completed by HDR Engineering, Inc. and
SynTerra Corporation as detailed in the Corrective Action Plan, Part 2 for each respective steam
station (HDR 2016a, 2016b; SynTerra 2016a). The quantity of ash and land coverage of the
existing ash basins for each steam station were provided by Duke Energy.
The construction analysis was subdivided into three categories: land disturbance, project duration,
and cost. The detailed analysis of construction implementation details for the three alternatives,
for each of the three sites considered, is provided in Appendix A. This analysis developed the
following information in support of the various components of the quantitative evaluation:
• Types of equipment used and duration [air emissions, energy];
• Land disturbance footprint (ecological habitat alteration);
• Road miles traveled [air emissions; truck trips, safety risks];
• Dimensions of work zones [safety risks]; and
• Costs.
As shown in Figure 1, the CIP alternative is estimated to require 4.6, 9.3, and 8.2 years at the
Belews Creek, Marshall, and Roxboro Steam Station sites, respectively. In comparison, the
Removal alternative is estimated to require 22.4, 50.7, and 63.8 years to implement (for ash
excavation and transport only) at the Belews Creek, Marshall, and Roxboro Steam Station sites,
respectively. The affected acreage for each alternative at each site, both direct on-site and off-site
impacts, is presented in Figure 2 and detailed in Appendix A.
DCN: HWIDENC002A 18 September 30, 2016

70
60
50
Figure 1. Projected Duration (years) of the CIP and Removal alternatives
50.7
L
>
40
C
O
+�
30
M
22.4
D
20
10
4.6
9.3
-
IR
0
Belews
Marshall
C MINA
CIP Removal
*Removal with MNA duration includes ash basin excavation
and transportto landfill only.
Landfill construction and landfill closureare not included.
1200
N 1000
C
600
m
J
400
L
3
a+
0 200
0
EPS
63.8
Roxboro
Figure 2. Projected acreage affected by the CIP and Removal
alternatives
420
335
294
504
579 579
168 226 506 506
283 283
0 0 0
MNA CIP Removal MNA CIP Removal MNA CIP Removal
Belews Marshall Roxboro
■ On-site Off-site
The parameter quantification was conducted within the following analyses: implementation safety
risk (fatalities, injury, illness, property damage), air emissions (truck trips, GHG emissions - CO2e,
criteria pollutant emissions, energy use), human and ecological health, ecological habitat
alterations, and cost. Each of these analyses are discussed, in turn, in the following sections.
DCN: HWIDENCO02A 19 September 30, 2016

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3.2 Traffic and Implementation Safety Risk Analysis
Multiple accidents associated with coal ash removal and management construction activities have
been documented and include fatalities and property damage. Selected examples of these include
incidents in South Carolina, Tennessee, West Virginia, Ohio, Pennsylvania, Wisconsin, and
Illinois (see "Selected Examples of Truck Traffic and Construction Implementation Related
Accidents over the past 10 years" section of the Reference Section of this report). The risk of life
to workers and public due to construction activities for each alternative was quantified. National
statistics were used to evaluate the fatality and non -fatality (injury/illness) risks, as well as property
damage incidents associated with truck traffic and onsite implementation for the three sites
considered. The quantitative evaluation of implementation safety risks is provided in Appendix B
with the summary results presented in Section 4.2.1.
3.3 Air Emissions and Energy Use Analysis
Air emissions can be divided into two separate categories, criteria pollutants and GHGs. The
criteria pollutants, which were established in the Clean Air Act of 1970, consist of carbon
monoxide (CO), nitrogen oxides (NOX), ozone, sulfur oxides (SOX), particulate matter (PM), and
lead. These pollutants cause adverse health and environmental effects when present above specific
concentrations in the atmosphere. For the purposes of this evaluation, NO, and PM were evaluated
based on their expected emissions from the activities involved in the remedial activities. Based on
previous experience with air emissions from remedial activities, the impacts from the other criteria
pollutants were expected to be minimal and so were not included in this evaluation. Criteria
pollutants are also referred to as criteria pollutants. Greenhouse gases, which consist primarily of
carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), and fluorinated gases, were also
determined by USEPA to have adverse health and environmental effects due to their contribution
to climate change. The quantitative evaluation of each of these types of air emissions, as well as
truck trips and energy use, for the three remedial alternatives, specific to each of the sites
considered is provided in Appendix C. The results are presented in Sections 4.2.2, 4.2.3, and 4.2.4.
3.4 Human Health Risk Analysis
Potential impacts to humans in contact with chemicals in environmental media were estimated for
30 years after implementation of the three remedial alternatives. A current condition (i.e., year
2015-2016) risk assessment was conducted for each site as part of each CAP Part 2 document.
These risk assessments formed the basis of estimating the risks in the future for the three different
remedial alternatives. It is important to note that the purpose of this risk analysis is to compare
the three different remedial alternatives; the analysis does not necessarily represent the true risk
remaining after implementation of a particular remedial action alternative given the numerous
assumptions and data extrapolations that were necessary in order to conduct this "forward
projection" analysis.
DCN: HWIDENC002A 20 September 30, 2016

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The receptors evaluated included a commercial/industrial worker, construction worker, trespasser,
boater, swimmer, and waders. There were two considerations in extrapolating the current risk
assessment to the future condition: the first was to forward project into the future (30 years from
implementation/completion of the remedial action); the second was to project (estimate) the
changes to various environmental media due to a given remedial action. The detailed evaluation
of human health risks projected under each remedial action alternative, for each of the sites
considered, is provided in Appendix D. The results are presented in Section 4.1.
3.5 Ecological Habitat Service Analysis
The purpose of this evaluation was to understand how implementation of the Removal and CIP
alternatives might affect ecological habitat service values associated with the Belews Creek,
Marshall, and Roxboro Steam Station sites6. The analysis for each site consisted of three main
steps as follows:
1. The first step was to identify the general habitat types existing within the areas that would
be impacted by the remedial alternatives at each site and to estimate the surface area of
each habitat type. This step combined habitat type boundaries presented in the CAP
(available as GIS "shape" boundary layers), aerial photography reviews, site visit
observations, and an updated GIS analysis. The basins that would be impacted, along with
selected site specific photographs, are presented for the Belews Creek (Figures 3-7),
Marshall (Figures 8-12), and Roxboro (Figures 13-17) sites, respectively.
2. The second step was to develop assumptions regarding the timing and level of impact (i.e.,
projected change in ecological service value over time) that implementation of each
alternative would have on the major habitat types evaluated. The general assumptions as
to the timing and level of impact projected for each alternative at each site were based upon
the construction analysis information provided in Appendix A and professional experience
with remedial activity implementation.
3. The third step was to estimate the change (i.e., loss) in the net present value (NPV) of
ecological habitat services that would be projected to occur given the habitats, acreages,
and assumptions developed as part of Steps 1 and 2. An estimate of the NPV of the losses
in ecological habitat value were developed through the use of the HEA methodology. In
this case, projected habitat alterations (e.g., removal, displacement of habitat) were used to
directly assess changes in ecological habitat quality and resulting value. My evaluation
included both the major direct on-site and off-site habitat impacts. Indirect impacts
associated with alternative implementation were not estimated, as such, my estimation of
impacts are conservative (i.e., underestimate projected losses).
s There were insufficient data to evaluate subsistence and recreational fishermen.
6 It should be noted that ecological risks, as currently understood, were used to inform the overall assessment as to
how implementation of the CIP and Removal alternatives might affect the current risks. This is discussed further in
Section 4.1.
DCN: HWIDENCO02A 21 September 30, 2016

0
The detailed quantitative evaluation of the loss of ecological habitat service value projected under
the CIP and Removal alternatives, for each of the three sites, is provided in Appendix E. The results
are presented in Section 4.2.5.
DCN: HWIDENCO02A 22 September 30, 2016

Figure 3
EPS Site Reconnaissance
June 2016
Belews Creek Steam Station
Belews Creek, NC
Figure Narrative
Shows vantage point locations
for photographs taken during
EPS site reconnaissance on
June 9, 2016.
Notes
Legend
Basin
Stream
Site Visit Photo Locations
Blue arrows indicate the
general direction that the
photograph was taken
N
A
500 1,000
Feet
Environmental Planning Specialists, Inc.
DCN: HWIDENCO02A 23 September 30, 2016

EPS
Figure 4. Belews Creek Steam Station wildlife habitat enhancement project (in partnership
with the North Carolina Wildlife Resources Commission and the National Wild Turkey
Federation (Photo 1 location on Figure 3)
Figure 5. Wetland habitat expanse within the Belews Creek Steam Station ash basin (Photo
2 location on Figure 3)
DCN: HWIDENCO02A 24 September 30, 2016

EPS
Figure 6. Island habitat within the Belews Creek Steam Station ash basin (Photo 3 location
on Figure 3)
Figure 7. Outlet stream from the ash basin at Belews Creek Steam Station (Photo 4
location on Figure 3)
DCN: HWIDENC002A 25 September 30, 2016

Figure 8
EPS Site Reconnaissance
June 2016
Marshall Steam Station
Terrell, NC
Figure Narrative
Shows vantage point locations
for photographs taken during
EPS site reconnaissance on
June 7, 2016.
Notes
Legend
Basins
=Active Ash Basin
Q Dry Ash Landfill Phase 1 [Retired Landfill]
Q Dry Ash Landfill Phase 2 [Retired Landfill]
Q PV Structural Fill
SIE Site Visit Photo Locations
Blue arrows indicate the
general direction that the
photograph was taken
N
A
500 1,000
Feet
Environmental Planning Specialists, Inc.
DCN: HWIDENCO02A 26 September 30, 2016

EPS
Figure 9. Heron nests overlooking the surface water habitat at the ash basin of the
Marshall Steam Station (Photo 1 location on Figure 8)
Figure 10. Close-up view of the heron nests overlooking the surface water habitat at the
ash basin of the Marshall Steam Station (Photo 2 location on Figure 8)
DCN: HWIDENCO02A 27 September 30, 2016

EPS
Figure 11. Wetland within the ash basin at the Marshall Steam Station (Photo 3 location
on Figure 8)
Figure 12. Forest habitat growing on ash material at the Marshall Steam Station (Photo 4
location on Figure 8)
DCN: HWIDENCO02A 28 September 30, 2016

M r
VWV1
' I
k'A
I Q,
Rr Legend
Basins
1966 Semi -Active Basin
' 1973 Active Ash Basin
Lined Monofill (above East Basin)
2 Unlined Monofill (above East Basin)
Site Visit Photo Locations
Blue arrows indicate the
general direction that the
,f4 photograph was taken
N
A
0 500 1,000
Feet
Environmental Planning Specialists, Inc.
DCN: HWIDENCO02A 29 September 30, 2016

EPS
Figure 14. View of wetlands and surface water looking into the ash basin at Roxboro Steam
Station (Photo 1 location on Figure 13)
Figure 15. Game land area near the Roxboro Steam Station (Photo 2 location on Figure 13)
DCN: HWIDENCO02A 30 September 30, 2016

EPS
Figure 16. Outfall thermal mixing zone area at Roxboro Steam Station (Photo 3 location on
Figure 13)
Figure 17. Cormorants resting in the thermal mixing zone area (Photo 4 location on Figure
13)
r
M �
MOL:MWO
DCN: HWIDENC002A 31 September 30, 2016

0
3.6 Cost Analysis
The quantitative evaluation of remedial alternative cost estimates for the three remedial
alternatives, for each of the three sites considered, are provided in Appendix A and presented in
Section 4.2.6.
DCN: HWIDENCO02A 32 September 30, 2016

0
4 NEBA SUMMARY RESULTS
The analyses developed as presented in Appendices A-E provide quantification of a variety of
metrics that can be used to ascertain the relative environmental footprint that one remedial
alternative may have in comparison to another. In addition, we can evaluate how risks change
through the implementation of the alternatives. In evaluating the information developed to date, I
have developed several opinions as to the risks and benefits that would be associated with
implementation of the alternatives. Prior to presenting my opinions, I provide summaries of the
information that support my opinions.
4.1 Risks Driving Remedial Alternative Selection
Developing an appropriate remedy is based on a solution that manages site risks while maximizing
benefits to the public and minimizing cost. For the Belews Creek, Marshall, and Roxboro Steam
Station sites, risks that the final remedy should look to manage include potential human health and
ecological risks. The remedy should effect a meaningful change in reducing the human health
and/or ecological risk that is the basis for the remedy. Without a meaningful change in a risk
parameter, the remedy should look to minimize environmental harm and reduce cost.
A "forward projection" of human health risks was conducted across the progression of the more
aggressive remedial action alternatives (MNA to CIP to Removal) at each of the three sites (Belews
Creek, Marshall, and Roxboro) and is presented in Figures 18-20, respectively (see Appendix D).
In addition to projected human health risks, Figures 18-20 also include the estimation of current
ecological risks provided in the available CAP 2 documents for the Belews Creek, Marshall, and
Roxboro Steam Station sites (HDR 2016a, 2016b, and SynTerra 2016a, respectively). The current
ecological risk categorization depicted in the figures is based upon the lowest observed effect level
(LOAEL). The LOAEL was used since all of the ecological risk assessments require additional
data and further refinement is needed to address uncertainties associated with the evaluation of
these scenarios such as the occurrence of the ecological receptors in the areas adjacent to the ash
basins, the bioavailability of any source or background COIs applicable to the risk assessments,
and refinement of the exposure and toxicity assumptions used in the ecological risk
characterization. These refinements would likely reduce potential ecological risks further.
That said, the ecological risk information for the Belews Creek, Marshall, and Roxboro sites
support a risk categorization that there is no unacceptable risk to ecological receptors at these sites
in the current condition. The LOAEL risk categorization information is provided for the Belews
Creek, Marshall, and Roxboro sites in Tables 1, 2, and 3, respectively.
It is my understanding that the question of source -related versus background COIs is to be addressed by other Duke
Energy experts. As such, I reserve the right to supplement my opinions on this point when their reports become
available to me.
DCN: HWIDENCO02A 33 September 30, 2016

High Risk
Y
N
Moderate
a. Risk
R
ar
Low Risk
NUA
High
Y
N
> Mode
M
M
a
Low
N
Figure 18. Belews Creek Steam Station -Human Health and Ecological
Risks
MNA CIP Removal
■ Groundwater (drinking water consumption) ❑ Public off-site contaminant exposure
❑ On -Site contaminant exposure ❑ Ecological Risk
NUA - no unacceptable risk
Figure 19. Marshall Steam Station - Human Health and Ecological Risks
ate
i s k
3
0
tisk a a a
z z z
lA
> > j > j > j D
z z z z z z z z
MNA CIP Removal
■ Groundwater (drinking water consumption) ❑ Public off-site contaminant exposure
❑ On -Site contaminant exposure 0 Ecological Risk
NUA -no unacceptable risk
EPS
DCN: HWIDENC002A 34 September 30, 2016
s
3
0
a a
a
a
a
a
a
a
a
a a
> >
z z
>
z
>
z
>
z
>
z
>
z
>
z
>
z
> >
z z
MNA CIP Removal
■ Groundwater (drinking water consumption) ❑ Public off-site contaminant exposure
❑ On -Site contaminant exposure ❑ Ecological Risk
NUA - no unacceptable risk
Figure 19. Marshall Steam Station - Human Health and Ecological Risks
ate
i s k
3
0
tisk a a a
z z z
lA
> > j > j > j D
z z z z z z z z
MNA CIP Removal
■ Groundwater (drinking water consumption) ❑ Public off-site contaminant exposure
❑ On -Site contaminant exposure 0 Ecological Risk
NUA -no unacceptable risk
EPS
DCN: HWIDENC002A 34 September 30, 2016

High Ri
Y
d
2 Modera
m
Ri
w
Low Ri
NUA
Figure 20. Roxboro Steam Station - Human Health and Ecological Risks
SK
to
sk
a
3
0
sk a
a
a
a
a
a
a
a
a
a
a
Z
D
Z
>
Z
>
Z
>
Z
n
Z
:DD
Z
Z
D
Z
Z
Z
MNA
■ Groundwater (drinking water consumption)
❑ On -Site contaminant exposure
NUA -no unacceptable risk
CIP Removal
❑ Public off-site contaminant exposure
■ Ecological Risk
EPS
DCN: HWIDENCO02A 35 September 30, 2016

Table 1. Belews Creek Ecological Hazard Quotients (HQ)t for COPECs.
Analyte
Wildlife Receptor HQ Estimated using the "Lowest Observed Adverse Effects Level"
Aquaticz
Mallard Duck Great Blue Heron I Muskrat River Otter
Eco Area 1 Surface Water, AOW Water & Sediment and Sedimenta
Aluminum
0.003
0.0005
0.5
0.005
Arsenic
0.0002
0.02
Barium
0.03
0.05
0.07
0.004
Beryllium
0.00006
0.0002
Boron
0.0001
0.001
0.003
0.0003
Cadmium
0.00000005
0.003
0.0000002
0.0001
Cobalt
0.000004
0.01
0.00006
0.001
Copper
0.002
0.006
0.01
0.001
Lead
0.000002
0.00002
0.00001
0.000002
Manganese
0.001
0.01
0.03
0.008
Mercury
0.00000001
0.002
0.0000006
0.0007
Nickel
0.000002
0.001
0.0002
0.0005
Selenium
0.000009
0.1
0.0005
0.04
Strontium
0.00001
0.00002
Zinc
0.0000004
0.01
0.000009
0.002
Chloride
Eco Area 2 AOW Water and AOW Sediment 4
Aluminum
0.003
0.00002
1
0.00006
Arsenic
0.00009
0.02
Barium
0.01
0.2
0.1
0.004
Beryllium
0.00003
0.00003
Boron
0.0002
0.007
0.02
0.0005
Cadmium
0.00000007
0.02
0.000001
0.0002
Cobalt
0.00004
0.4
0.002
0.01
Copper
0.0007
0.002
0.01
0.0001
Lead
0.0000001
0.000007
0.000004
0.0000002
Manganese
0.0009
0.8
0.09
0.2
Mercury
0.00000006
0.03
0.00001
0.003
Nickel
0.000004
0.007
0.001
0.001
Selenium
0.00001
0.6
0.003
0.06
Strontium
0.00005
0.00002
Zinc
0.0000002
0.02
0.00002
0.0008
Chloride
Eco Area 3 Surface Water, Sediment & AOWs 5
Aluminum
0.004
0.003
0.9
0.03
Arsenic
0.0002
0.02
Barium
0.03
0.2
0.09
0.02
Beryllium
0.00002
0.00004
Boron
0.01
0.1
0.4
0.03
Cadmium
0.00000005
0.005
0.0000004
0.0001
Cobalt
0.000006
0.02
0.0001
0.002
Copper
0.002
0.03
0.01
0.005
Lead
0.00001
0.0002
0.0001
0.00002
Manganese
0.002
0.4
0.05
0.2
Mercury
0.00000007
0.01
0.000005
0.004
Nickel
0.000003
0.002
0.0003
0.0006
Selenium
0.00002
0.2
0.001
0.07
Strontium
0.0007
0.0008
Zinc
0.000005
0.2
0.0001
0.02
DCN: HWIDENCO02A 36 September 30, 2016

Table 1. Belews Creek Ecological Hazard Quotients (HQ)l for COPECs.
Analyte
Wildlife Receptor HQ Estimated using the "Lowest Observed Adverse Effects Level"
AquaticZ
Mallard Duck Great Blue Heron Muskrat River Otter
Chloride
Eco Area 4 AOW Water and AOW Sediment 6
Aluminum
0.003
0.0010
0.8
0.005
Arsenic
0.00004
0.006
Barium
0.01
0.04
0.06
0.002
Beryllium
0.00001
0.00002
Boron
0.0001
0.002
0.005
0.0002
Cadmium
0.0000001
0.01
0.000001
0.0003
Cobalt
0.000001
0.006
0.00004
0.0004
Copper
0.0009
0.02
0.008
0.002
Lead
0.000004
0.0001
0.00006
0.000005
Manganese
0.0004
0.02
0.01
0.008
Mercury
0.00000002
0.006
0.000002
0.001
Nickel
0.000003
0.003
0.0005
0.0009
Selenium
0.00002
0.5
0.003
0.1
Strontium
0.00002
0.00001
Zinc
0.000002
0.09
0.00006
0.006
Chloride
Eco Area 5 AOW Water and AOW Sediment 7
Aluminum
0.002
0.00002
1.0
0.00005
Arsenic
0.00004
0.01
Barium
0.02
0.06
0.2
0.002
Beryllium
0.00003
0.00002
Boron
0.000001
0.00004
0.0001
0.000003
Cadmium
0.00000001
0.002
0.0000002
0.00003
Cobalt
0.000002
0.01
0.00009
0.0005
Copper
0.0010
0.002
0.01
0.0002
Lead
0.00000003
0.000001
0.0000007
0.00000004
Manganese
0.0006
0.09
0.04
0.02
Mercury
0.000000003
0.001
0.0000005
0.0002
Nickel
0.0000009
0.001
0.0002
0.0002
Selenium
0.000002
0.08
0.0004
0.01
Strontium
0.000008
0.000004
Zinc
0.000001
0.1
0.00008
0.005
Chloride
Notes:
'A Hazard Quotient is estimated by dividing the Exposure Point Concentration for that species by its respective Toxicity Reference Value for the
COPEC.
2 Exposures are adjusted for the proportion of this exposure area that represents the animal's home range, i.e. 1 acres/10 acres = 0.1.
3 Reproduced from Table 6-5 of Appendix F of Corrective Action Plan Part 2: Belews Creek Steam Station Ash Basin (March 4, 2016).
4 Reproduced from Table 6-6 of Appendix F of Corrective Action Plan Part 2: Belews Creek Steam Station Ash Basin (March 4, 2016).
5 Reproduced from Table 6-7 of Appendix F of Corrective Action Plan Part 2: Belews Creek Steam Station Ash Basin (March 4, 2016).
6 Reproduced from Table 6-8 of Appendix F of Corrective Action Plan Part 2: Belews Creek Steam Station Ash Basin (March 4, 2016).
7 Reproduced from Table 6-9 of Appendix F of Corrective Action Plan Part 2: Belews Creek Steam Station Ash Basin (March 4, 2016).
HQ >= 1
DCN: HWIDENCO02A 37 September 30, 2016

Table 2. Marshall Ecological Hazard Quotients (HQ)t for COPECs.
Analyte
Wildlife Receptor HQ Estimated using the "Lowest Observed Adverse Effects Level"
Aquatic
Mallard Duck Great Blue Heron Muskrat River Otter
Eco Area 1 AOW Water, Sediment and Surface Water
Aluminum
0.000003
0.0001
0.007
0.0007
Barium
0.03
0.4
0.1
0.02
Beryllium
0.0004
0.0005
Cadmium
0.00000006
0.007
0.0000006
0.0001
Chromium (Total)
0.003
0.01
0.000002
0.0000002
Cobalt
0.00005
0.2
0.001
0.01
Copper
0.00001
0.3
0.0007
0.03
Lead
0.0001
0.003
0.002
0.0002
Manganese
0.00008
0.4
0.02
0.2
Mercury
0.0000001
0.04
0.00001
0.008
Nickel
0.000007
0.006
0.001
0.002
Selenium
0.00007
0.007
0.3
Thallium
0.02
0.08
Vanadium
0.003
0.01
0.07
Zinc
0.000005
0.2
0.0002
0.02
Chloride
Eco Area 2 Surface Water
Aluminum
0.0000002
0.00008
0.004
0.00006
Barium
0.0000007
0.04
0.0001
0.0002
Chromium (Total)
0.00000008
0.0001
0.000000004
3E-10
Cobalt
0.0000002
0.008
0.00005
0.00006
Copper
0.00000001
0.002
0.000006
0.00003
Lead
0.00000004
0.000009
0.000005
0.00000006
Manganese
0.0000004
0.02
0.0006
0.0008
Nickel
0.0000002
0.001
0.0002
0.00005
Selenium
0.0000002
0.04
0.0002
0.001
Thallium
0.0002
0.0001
Vanadium
0.000002
0.04
0.00004
0.00004
Zinc
0.00000002
0.008
0.000006
0.00007
Chloride
Notes:
IA Hazard Quotient is estimated by dividing the Exposure Point Concentration for that species by its respective Toxicity Reference Value for the
COPEC.
2 Exposures are adjusted for the proportion of this exposure area that represents the animal's home range, i.e. 1 acres/10 acres = 0.1.
3 Reproduced from Table 6-5 of Appendix F of Corrective Action Plan Part 2: Marshall Steam Station Ash Basin (March 3, 2016).
a Reproduced from Table 6-6 of Appendix F of Corrective Action Plan Part 2: Marshall Steam Station Ash Basin (March 3, 2016).
5 This HQ result is based on a statistical outlier. If the outlier is removed from the underlying dataset, the resulting HQ is 0.03.
HQ >= 1
DCN: HWIDENCO02A 38 September 30, 2016

Table 3. Roxboro Ecological Hazard Quotients (HQ)I for COPECs.
Analyte
Wildlife Receptor HQ Estimated using the "Lowest Observed Adverse Effects Level"
Terrestrial2
American Robin Red -Tailed Hawk Meadow Vole Red Fox
Ash Basin
Aluminum
0.1
0.00000004
0.9 0.000007
Boron
0.007
0.000007
0.006 0.00002
Copper
0.07
0.0005
0.02 0.0006
Lead
0.1
0.0005
0.004 0.0002
Manganese
0.08
0.000007
0.2 0.00008
Mercury
0.02
0.0006
0.007 0.001
Molybdenum
0.04
0.0002
0.06 0.002
Vanadium
0.7
0.008
Zinc
0.2
0.0008
0.01 0.0006
Gypsum Pad
Aluminum
0.02
0.2
Manganese
0.5
0.000001
1.0 0.00002
Mercury
0.0000008
0.000000002
0.000004 0.000000010
Molybdenum
0.1
0.00007
0.2 0.0008
Selenium
I IF=
0.0002
0.0004
Vanadium
0.2
0.003
AquatiC2
Mallard Duck
Great Blue Heron
Muskrat River Otter
Hyco Reservoirs
Aluminum
0.000005
0.0002
0.01 0.001
Barium
0.03
0.1
Manganese
0.003
0.06
0.1 0.02
Notes:
A Hazard Quotient is estimated by dividing the Exposure Point Concentration for that species by its respective Toxicity Reference Value for
the COPC.
2 Exposures are adjusted for the proportion of this exposure area that represents the animal's home range, i.e. 1 acres/10 acres = 0.1.
3 Reproduced from Table 6-3 of Appendix D of Corrective Action Plan Part 2: Roxboro Steam Electric Plant (February 2016).
° Reproduced from Table 6-4 of Appendix D of Corrective Action Plan Part 2: Roxboro Steam Electric Plant (February 2016).
5 Reproduced from Table 6-5 of Appendix D of Corrective Action Plan Part 2: Roxboro Steam Electric Plant (February 2016).
HQ >= 1
DCN: HWIDENCO02A 39 September 30, 2016

0
As will be noted in these figures, there are no unacceptable off-site human health risks at any of
the three sites$. For the on-site scenarios, nearly all forward projected risks are below the most
conservative risk thresholds (i.e., a Hazard Index of unity (1) for non -carcinogens, and an Excess
Lifetime Cancer Risk (ELCR) of lE-6). The only identified risk above this lower threshold was
for an on-site commercial/industrial worker at the Belews Creek, Marshall, and Roxboro sites
where the projected risk was between 1.5E-6 and 4.9E-6. For the sake of the NEBA exercise, this
level of risk was considered as "low" even though it is within the EPA accepted risk range of IE -
4 to 1 E-6.
Therefore, a more reasonable scenario would likely drive the "perceived" risk within a "no
unacceptable risk" range ("real" risk range) at the three sites. Given this, it is apparent that the
implementation of the remedial alternatives of CIP or Removal are not likely to provide any benefit
from a risk management standpoint.
Groundwater Service Value
It should be recognized that a groundwater aquifer has the potential to provide a variety of service
flows (USEPA 1995). The services that potentially can be provided by groundwater are listed in
Table 4, including those parameters that can be evaluated to understand effects to groundwater
services. As can be seen in Table 4, adverse groundwater service effects appear to be marginal if
any. This is supported by the groundwater risk analysis conducted by Lisa Bradley, PhD (Haley
and Aldrich 2016). Thus, the question arises, are the environmental and community risks that will
arise from remedy implementation and the implementation costs worth incurring to manage what
appears to be marginal levels of risk, if any? Based on the evaluation conducted herein and as
demonstrated in this section, it is evident that the projected environmental and community impacts
associated with implementing the Removal alternative far outweigh any benefit associated with
implementation of the Removal alternative.
4.2 NEBA Assessment Parameter Evaluation
I next consider how the remedial actions might affect other parameters that are important to human
health, community perspectives, and ecological resources. A demonstration as to how the
assessment parameters were estimated to be affected given the MNA, CIP and Removal
alternatives is presented in a series of figures. In each figure, each individual parameter with the
greatest adverse impact is set to 1 (on the right vertical axis), regardless of alternative. Then, all
other corresponding parameter values are presented proportional to the highest value for that
a Fish consumption scenarios (recreational and subsistence) were not evaluated in the "forward projection" modeling
as there is too little information to estimate whether any "true" risk exists for this scenario (not likely however, as the
original risk assessments were overly conservative as they used limited site data and assumed unrealistic exposures).
The risk assessments included in the CAP 2 reports used two overly conservative assumptions: 1) the bioconcentration
factors that were used to estimate fish tissue concentrations based on surface water concentrations were very
conservative (most notably the factor used for cobalt is known to be overly conservative (ATSDR 2004) for freshwater
fish), and 2) the surface water concentrations used were from limited on-site surface water sampling, not from surface
water collected in the receiving stream or reservoir.
DCN: HWIDENCO02A 40 September 30, 2016

Table 4. Groundwater Services, Effects, and Parameter Evaluation.
FUNCTION: STORAGE OF WATER
EFFECTS
SERVICE
FUNCTION: DISCHARGE TO
EFFECTS
SERVICE
RESERVE (STOCK)
EFFECT
STREAMS/LAKES/WETLANDS
EFFECT
Change in Welfare from Increase or Decrease in
Drinking Water through Surface
Change in Welfare from Increase or Decrease in
Drinking Water;
Availability of Drinking Water, Change in Human
No
Water Supplies;
Availability of Drinking Water, Change in Human
No
Health or Health Risks
Health or Health Risks
Water for Crop Irrigation;
Change in Value of Crops or Production Costs,
No
Water for Crop Irrigation through
Change in Value of Crops or Production Costs,
No
Change in Human Health or Health Risks
Surface Water Supplies;
Change in Human Health or Health Risks
Change in Value of Livestock Products or
Water for Livestock through Surface
Change in Value of Livestock Products or Production
Water for Livestock;
Production Costs, Change in Human Health or
No
Water Supplies;
Costs, Change in Human Health or Health Risks
No
Health Risks
Water for Food Product
Change in Value of Food Products or Production
Water for Food Product Processing
Change in Value of Food Products or Production
Processing;
Costs, Change in Human Health or Health Risks
No
through Surface Water Supplies;
Costs, Change in Human Health or Health Risks
No
Water for Other Manufacturing
Change in Value of Manufactured Goods or
Water for Other Manufacturing
Change in Value of Manufactured Goods or
Processes;
Production Costs;
No
Processes through Surface Water
Production Costs;
No
Supplies;
Heated Water for Geothermal
Provision of Cooling Water for
Power Plants;
Change in Cost of Electricity Generation
No
Power Plants through Surface Water
Change in Cost of Electricity Generation
No
Supplies
Change in Cost of Maintaining Public or Private
Cooling Water for Other Power
Provision of Erosion, Flood, and
Property, Change in Human Health or Health Risks
Plants;
Change in Cost of Electricity Generation
No
Storm Protection
through Personal Injury Protection, Change in
No
Economic Output Attributable to Use of Surface
Water Supplies for Disposing Wastes
Change in Human Health or Health Risks Attributable
Transport and Treatment of Wastes
to Change in Surface Water Quality, Change in
Water/Soil Support System
Change in Cost of Maintaining Public or Private
and Other By -Products of Human
Animal Health or Health Risks Attributable to Change
Preventing Land Subsidence;
Property
No
Economic Activity through Surface
in Surface Water Quality, Change in Economic Output
No
Water Supplies
Attributable to Use of Surface Water Supplies for
Disposing Wastes
Erosion and Flood Control
Change in Cost of Maintaining Public or Private
Support of Recreational Swimming,
Change in Quantity or Quality Recreational Activities,
through Absorption of Surface
Property
No
Boating, Fishing, Hunting, Trapping
Change in Human Health or Health Risks
No
Water Run -Off;
and Plant Gathering
Medium for Wastes and Other
Change in Human Health or Health Risks
Support of Commercial Fishing,
By -Products of Human Economic
Attributable to Change in Ground water Quality
No
Hunting,
Change in Value of Commercial Harvest or Costs
No
Activity;
Trapping, Plant Gathering
Change in Human Health or Health Risks
Attributable to Change in Water Quality, Change
Marginal,
Support of On -Site Observation or
Clean Water through Support of
in Animal Health or Health Risks Attributable to
if any, see
Study of Fish, Wildlife, and Plants
Change in Quantity or Quality of On -Site Observation
Living Organisms;
Change in Water Quality, Change in Value of
Appendix
for Leisure, Educational, or Scientific
or
No
Economic Output or Productions Costs
Study Activities
Attributable to Change in
D
Purposes
P
Water Quality
Passive or Non -Use Services
Marginal,
Support of Indirect, Off -Site Fish,
Change in Quantity or Quality of Indirect, Off -Site
(e.g., Existence or Bequest
Change in Personal Utility
if any
Wildlife, and Plant Uses (e.g.
Activities
No
Motivations).
viewing wildlife photos)
Change in Human Health or Health Risks Attributable
Provision of Clean Air through
to
Support of Living Organisms
Change in Air Quality, Change in Animal Health or
No
Health Risks Attributable to Change in Air Quality
Change in Human Health or Health Risks Attributable
to
Marginal,
Provision of Clean Water through
Change in Water Quality, Change in Animal Health or
if any, see
Support of Living Organisms
Health Risks Attributable to Change in Water Quality,
Appendix
Change in Value of Economic Output or Productions
Costs
D
Attributable to Change in Water Quality
Change in Human Health or Health Risks Attributable
to
Regulation of Climate through
Change in Climate, Change in Animal Health or
Support of Plants
Health Risks Attributable to Change in Climate,
No
Change in Value of Economic Output or Production
Costs Attributable to Change in Climate
Provision of Non -Use Services (e.g.,
Existence Services) Associated with
Marginal,
Surface Water Body or Wetlands
Change in Personal Utility or Satisfaction
if any
Environments or Ecosystems
Supported by Ground water
DCN: HWIDENC002A 41 September 30, 2016

0
specific parameter. This permits multiple parameters with varying scales to be displayed on the
same graph and for relative comparison of projected parameter changes between alternatives. The
higher a bar moves upward from the x-axis, the greater the environmental, health and safety, or
social impact. This approach allows for the alternatives to be evaluated and compared visually in
a holistic manner, including in comparison to changes in human and ecological risks (left vertical
axis) associated with implementation of each alternative.
It should be recognized that the approach taken in the overall NEBA analysis was to approximate
the parameter values for each of the alternatives based upon consistent assumptions where
applicable. As such, the parameter estimates are approximate values and not intended to be exact,
but enough to identify impacts and differences between alternatives to a reasonable degree of
certainty.
The overall results of the NEBA are presented in Table 5 and the following figures demonstrate
how ecological and human health risks and the estimated parameter values are projected to change
given implementation of the CIP and Removal alternatives. The figures are presented in turn, for
each of the following parameter groups by site: implementation health and safety risks, truck trips,
air emissions (criteria pollutants), energy use, ecological habitat losses, and costs (Figures 21-38).
Following these figures, three graphics are presented for each site. The first displays all assessment
parameters, the second compares projected health impacts between alternatives, and the third
compares GHG and NO. emissions to established reporting and permitting thresholds (Figures 39-
47). Additionally, a cumulative graphic is provided that displays the combined effect across all
three sites (Figure 48).
DCN: HWIDENC002A 42 September 30, 2016

Table 5. Overall NEBA Summary Table.
NEBA Considerations
Ecological
Human Health Pathways
Ecological
Social
Costs
Pathway
Habitat Services
Groundwater
Public off-site
On -Site
Truck traffic
Implementation
Implementation
Wetland and
CHC emissionss/
Ecological Risk'
(drinking water
contaminant
contaminant
Fish Consumption
Truck traffic
incidents-
risks -project
Truck Trips -Public
Terrestrial Habitat
Surtaca Water
Overall Ecological
carbon foot-
Priority pollutant
Total Energy
Capital and 0&M
NEBA Framework
consumption)
exposure''°
exposure,
r
incidents -risk
properton damage
accident rate
Roadss
Value
Habitat Value
Habitat Value
emissions
Used
printin g
o
Environmental
Justice Concerns
Site
Alternative
Metric(s)
Metric(s)
Metric(s)
Metric(s)
Metric(s)
Metric(s)
Metric(s)
Metric(s)
Metric(s)
Metric(s)
Metric(s)
Metric(s)
Metric(s)
Metric(s)
Metric(s)
Metric(s)
no unacceptable
no unacceptable
HI/ELCR-no
HI/ELCR-no
no unacceptable
risk, low risk,
risk, low risk,
unacceptable risk,
unacceptable risk,
risk, low risk,
Fatalities (F) andFatalities
Incidents
(F) and
Trips- Public
Lost dSAYs
Lost dSAYs
Lost dSAYs
Tons/yr and tons
Tons/yr of NOx,
MM BTU
Net present value
moderate risk,
moderate risk,
low risk, moderate
low risk, moderate
moderate risk,
injuries/illnesses (I)
injuries/illnesses (I)
Roads
of CO2e emitted
PM30/2.5 emitted
in real dollars
high risk
high risk
risk, high risk
risk, high risk
high risk
Monitored Natural
NUA
Low Risk
Baseline=
Attenuation (MINA)
NUA
NUA
0.028/4E-07
0.1/5E-06
Baseline
Baseline
Baseline
0
Baseline
Baseline
Baseline
Baseline
Baseline
Baseline
$ 7,315,000
NUA
NUA
F-0.09
F-0.06
7,346.72 tons/yr
NOx-29.10
$ 135,473,237
BeleWS
Cap-in-Place(CIP)
NUA
NUA
0.023/9E-08
0.03/IE-06
I-2.5
7'2
1-84
123,502
940
7,440
8,380
33,794.90 tons
PNOx-29.101
388,509
Above Baseline
NUA
NUA
F-0.42
F-0.15
30,934.77 tons/yr
NOx-142.99
$ 978,550,099
Removal
NUA
NUA
0.009/4E-08
0.002/7E-09
I 12
35
I 40
626,744
1,255
7,440
8,695
296,678.32 tons
PM10/2.5-6.12
3,588,214
Above Baseline
Monitored Natural
NUA
Low Risk
Baseline=
Attenuation (MINA)
NUA
NUA
0.00/-
0.3/2E-06
Baseline
Baseline
Baseline
0
Baseline
Baseline
Baseline
Baseline
Baseline
Baseline
$ 9,020,000
NUA
NUA
$ 281,695,437
Marshall
Cap -in -Plate (CIP)
NUA
NUA
F-0.18
15
F-0.12
252,637
3,969
6,641
10,610
7,396.18 tons/yr
NOx-29.26
792,688
0.00/--
0.08/4E-07
-5.0
1-17
68,784.43 tons
PM10/2.5-1.01
Above Baseline
NUANUA
F-0.96
F-0.32
30,942.17 tons/yr
NOx-143.01
$ 2,182,785,686
Removal
NUA
NUA
0.001/--
0.0002/1E-09
I 27
80
I 85
1,415,546
4,899
6,641
11,540
656,544.05 tons
PM10/2.5-6.12
7,965,004
Above Baseline
Monitored Natural
NUA
Low Risk
Baseline=
Attenuation (MINA)
NUA
NUA
0.1/--
0.1/3E-06
Baseline
Baseline
Baseline
0
Baseline
Baseline
Baseline
Baseline
Baseline
Baseline
$ 9,872,500
NUA
NUA
F-0.16
F-0.10
7,358.07 tons/yr
NOx-29.14
$ 244,323,179
ROXbOfO
Cap -in -Plate (CIP)
NUA
NUA
0.1/--
0.03/8E-07
44
13
1-15
220,755
2,767
3,839
6,607
60,336.16 tons
PM10/2.5-1.01
709,604
Above Baseline
NUA
NUA
F-1.2
F-0.39
30,939.49 tons/yr
NOx-143.00
$ 2,753,042,583
Removal
NUA
NUA
0.1/--
0.0003/--
34
101
1-106
1,779,563
5,163
3,839
9,002
795,005.21 tons
PM10/2.5-6.12
9'977'837
Above Baseline
Notes:
Current Baseline: Parameters are measured as a change from the current condition for each site. Footnotes:
MINA - Monitored Natural Attenuation 1. Insufficient data to evaluate
CIP - Cap -in -Place with MINA 2. Highest Hazard Index / ELCR 30 years after implementation
Removal- Full Removal with MINA NUA: No Unacceptable Risk: HI<1; ELCR <1E-06
Abbreviations: Low Risk: 1 < HI < 3; 1E-06 < ELCR < SE -05
DSAY: discounted service acre year Moderate Risk: 1<HI<3; 1E-05<ELCR <1E-04
ELCR: excess lifetime cancer risk High Risk: HI > 3; ELCR > 1E-04
F: fatalities 3. Construction worker, Commercial/Industrial Worker or Trespasser
GHG: greenhouse gas 4. Swimmer, Boater, Wader
HI: hazard index S. Truck trips include transport of cap material and linerfor Capping with MNA and include transport of ash, closure/cap material,
1: injuries/illnesses and liner for Removal with NINA
NEBA: net environmental benefit analysis 6.GHG emissions include both direct(consumption) and indirect (well -to -pump) contributions
O&M: operation and management 7. Based on Appendix F of Corrective Action Plan Part2: Belews Creek Steam Station Ash Basin, Appendix F of Corrective Action Plan Part 2:
Marshall Steam Station Ash Basin, and Appendix D of Corrective Action Plan Part2: Roxboro Steam Electric Plant.
DCN: HWIDENCO02A 43 September 30, 2016

4.2.1 Implementation Health and Safety Risks
Figure 21. Belews Creek Steam Station -Implementation Health and
Safety Risk
o
a o
High Risk 1
Y
d'
Moderate
+� Risk
M
v
Low Risk
NUA
High Ri
Y
Moderal
MRis
cc
oc
o!
Low Ri:
NU,
0
0
O y
� n �
Y
3
a s
> > , a a a
z z z m m m m m z z z z z z z z
MNA CI P Removal
■ Groundwater (drinking water consumption) ❑ Public off-site contaminant exposure
❑ On -Site contaminant exposure ❑ Ecological Risk
■ Truck traffic incidents -Fatalities ■ Truck traffic incidents -Injuries/Illness
Truck traffic incidents - property damage only Implementation risks - Fatalities
Implementation risks - Injuries/Illness NUA - no unacceptable risk
Figure 22. Marshall Steam Station - Implementation Health and Safety
Risks
o
L
k
0
3
0
k>> J� m m m m >
z z z z z z z
MNA CIP
■ Groundwater (drinking water consumption)
❑ On -Site contaminant exposure
■ Truck traffic incidents -Fatalities
Truck traffic incidents - property damage only
Implementation risks - Injuries/Illness
z z z z
�r
Removal
❑ Public off-site contaminant exposure
❑ Ecological Risk
■ Truck traffic incidents -Injuries/Illness
Implementation risks - Fatalities
NUA - no unacceptable risk
W
to
0.75
s
V
d
u
a
0.5 O
a
m
c
O
Y
0.25 G
O
CL
0
1
d
oc
0.75
s
V
N
V
Gl
0.5 O
a`
f6
C
O
0.25 G
O
0
M
EPS
DCN: HWIDENCO02A 44 September 30, 2016

Y
Figure 23. Roxboro Steam Station - Implementation Health and Safety
Risks
a o 0
m � o
I
MNA CIP Removal
■ Groundwater (drinking water consumption)
❑ On -Site contaminant exposure
■ Truck traffic incidents -Fatalities
n Truck traffic incidents - property damage only
■ Implementation risks- Injuries/Illness
❑ Public off-site contaminant exposure
■ Ecological Risk
■ Truck traffic incidents -Injuries/Illness
Implementation risks- Fatalities
NUA - no unacceptable risk
0.25 a
0
EPS
DCN: HWIDENCO02A 45 September 30, 2016

4.2.2 Truck Trips
Figure 24. Belews Creek Steam Station -Truck Trips
3
0
High Risk
Y
0
'z
a
a
GJ
a
a
z z
Moderate
z o
M
Risk
z
v
a a
> >
z z
z
>
z 0
z
z
z
z
Low Risk
z
z
z
z
NUA
z z
z z
Figure 24. Belews Creek Steam Station -Truck Trips
3
0
s
3
0
0
a a
a
a
a
a
a
z z
aa
z o
z
z
z
z
MNA CI P Removal
■ Groundwater (drinking water consumption) ❑ Public off-site contaminant exposure
❑ On -Site contaminant exposure ❑ Ecological Risk
Implementation Truck Trips- Public Roads NUA - no unacceptable risk
High Risk
Y
H
Moderate
+� Risk
ro
W
Low Risk
NUA
Figure 25. Marshall Steam Station -Truck Trips
MNA CIP Removal
■ Groundwater (drinking water consumption) ❑ Public off-site contaminant exposure
❑ On -Site contaminant exposure ■ Ecological Risk
Implementation Truck Trips - Public Roads NUA -no unacceptable risk
1
v
to
0.75
s
U
v
S
u
d
0.5 01
C
C
0
Y
0.25 Q.
O
CL
0
1
v
Oo
0.75 %
L
U
d
V
ai
0.5 2
CL
m
c
0
.Y
0.25 C
O
CL
0
EPS
DCN: HWIDENCO02A 46 September 30, 2016
s
3
0
a a
a
aa
a
a
a
a
a a
> >
z z
>
z 0
z
z
z
z
-1:1z
z
z
z
z
z
z
z
z z
z z
MNA CIP Removal
■ Groundwater (drinking water consumption) ❑ Public off-site contaminant exposure
❑ On -Site contaminant exposure ■ Ecological Risk
Implementation Truck Trips - Public Roads NUA -no unacceptable risk
1
v
to
0.75
s
U
v
S
u
d
0.5 01
C
C
0
Y
0.25 Q.
O
CL
0
1
v
Oo
0.75 %
L
U
d
V
ai
0.5 2
CL
m
c
0
.Y
0.25 C
O
CL
0
EPS
DCN: HWIDENCO02A 46 September 30, 2016

High Ri
Y
H
j Modera
m
Ri
v
Low Ri
NU
Figure 26. Roxboro Steam Station -Truck Trips
sk
to
sk
n
o
o
sk a a J a a a a a a a a a
> > > >
z z z z z z z
z z z z z z z z z z z
0
MNA
CIP
■ Groundwater (drinking water consumption)
❑ On -Site contaminant exposure
Implementation Truck Trips- Public Roads
Removal
❑ Public off-site contaminant exposure
o Ecological Risk
NUA -no unacceptable risk
W
00
0.75
s
u
N
U
N
0.5 O
a`
m
c
0
0.25 a
O
0
M
EPS
DCN: HWIDENCO02A 47 September 30, 2016
MNA
CIP
■ Groundwater (drinking water consumption)
❑ On -Site contaminant exposure
Implementation Truck Trips- Public Roads
Removal
❑ Public off-site contaminant exposure
o Ecological Risk
NUA -no unacceptable risk
W
00
0.75
s
u
N
U
N
0.5 O
a`
m
c
0
0.25 a
O
0
M
EPS
DCN: HWIDENCO02A 47 September 30, 2016

4.2.3 Air Emissions
High Risk
Y
d
Moderate
f0 Risk
v
z
Low Risk
NUA
Figure 27. Bel ews Creek Steam Station -Air Emissions
M C O
M
o m v
M N �
a
L
3
v v v v
a a a 'N 'N 'N v a ¢ ¢ a
> > > >
z z z z z z z
m
m m m
1
v
0.75
t
U
v
Y
V
d
0.5 2
a
c
0
0
0.25 a
0
MNA CIP Removal
■ Groundwater (drinking water consumption) ❑ Public off-site contaminant exposure
❑ On -Site contaminant exposure ■ Ecological Risk
■ GHG emissions -tons/yr CO2e emitted ■ GHG emissions -tons of CO2e emitted
Criteria pollutant emissions - tons/yr of NOx Criteria pollutant emissions - tons/yr of PM10/2.5
NUA - no unacceptable risk
Figure 28. Marshall Steam Station - Air Emissions
o
M tp
High Risk 1
Low F
NL
skl
n
N ~O
d
W .-1
3 �
v v v o
isk ¢¢ a a a a a a a a a
> > > > > > > > > > >
z z z z z z z z z z z
MNA
■ Groundwater (drinking water consumption)
❑ On -Site contaminant exposure
■ GHG emissions -tons/yr CO2e emitted
Criteria pollutant emissions - tons/yr of NOx
NUA - no unacceptable risk
DCN: HWIDENC002A
a.
0
CIP Removal
❑ Public off-site contaminant exposure
■ Ecological Risk
■ GHG emissions -tons of CO2e emitted
Criteria pollutant emissions - tons/yr of PM10/2.5
48
CL
September 30, 2016

High Risk
Y
H
j Moderate
' Risk
m
a
Low Risk
NUA
Figure 29. Roxboro Steam Station - Air Emissions o
m o
s
r � 16
MNA CIP Removal
EPS
W
0.75 =
M
s
u
Ol
u
N
0.5 O
aL
m
c
0
L
0
0.25 C
0
■ Groundwater (drinking water consumption) ❑ Public off-site contaminant exposure
❑ On -Site contaminant exposure 19 Ecological Risk
■ GHG emissions -tons/yr CO2e emitted LK GHG emissions -tons of CO2e emitted
Criteria pollutant emissions - tons/yr of NOx Criteria pollutant emissions - tons/yr of PM10/2.5
NUA -no unacceptable risk
a
DCN: HWIDENCO02A 49 September 30, 2016
N
�
�
O
N
m
�
v
o
>
>
>
z
z
z
z z
m m m m
z z
z
z
z z
z
MNA CIP Removal
EPS
W
0.75 =
M
s
u
Ol
u
N
0.5 O
aL
m
c
0
L
0
0.25 C
0
■ Groundwater (drinking water consumption) ❑ Public off-site contaminant exposure
❑ On -Site contaminant exposure 19 Ecological Risk
■ GHG emissions -tons/yr CO2e emitted LK GHG emissions -tons of CO2e emitted
Criteria pollutant emissions - tons/yr of NOx Criteria pollutant emissions - tons/yr of PM10/2.5
NUA -no unacceptable risk
a
DCN: HWIDENCO02A 49 September 30, 2016

4.2.4 Energy Use
High Risk
-
-19
fY
N
Moderate
.M
Risk
a
z
Low Ri!
NUA
High Ri
Y
Cr
Modera
m
Ri
v
Low Ri
NU
Figure 30. Belews Creek Steam Station - Energy Use
MNA CIP Removal
■Groundwater(drinkingwater consumption) ❑ Pub Iicoff-site contaminant exposure
❑ On -Site contaminant exposure ■ Ecological Risk
Total Energy Used - MMBtu NUA -no unacceptable risk
Figure 31. Marshall Steam Station - Energy Use
sk
a
3
0
k ¢
¢
a =
a
a
a
a
¢
a
¢ ¢
>
z
>
z
to
>
z
>
z
>
z
>
z
>
z
>
z
>
z
> >
z z
MNA CIP Removal
■Groundwater(drinkingwater consumption) ❑ Pub Iicoff-site contaminant exposure
❑ On -Site contaminant exposure ■ Ecological Risk
Total Energy Used - MMBtu NUA -no unacceptable risk
Figure 31. Marshall Steam Station - Energy Use
sk
8
to
sk
3
o
m
sk a
a
a =
a
a
a
a ^
a
a
¢
a
>
z
>
z
>
z
>
z
z
z
z
z
z
z
z
z
z
z
z
Z
z
z
A
MNA
■ Groundwater (drinking water consumption)
❑ On -Site contaminant exposure
Total Energy Used - MMBtu
CIP Removal
❑ Public off-site contaminant exposure
M Ecological Risk
NUA - no unacceptable risk
t
v
00
0.75 @
t
U
ate..
V
d
0.5 O
a`
m
c
0
0.25 a
O
CL
0
I
m
0.75
U
V
41
V
G1
0.5
a
m
c
0
0.25 0
CL0
CL
0
EPS
DCN: HWIDENCO02A 50 September 30, 2016

High Ri
Y
j Modera
+' Ri
m
a
Low Ri
NU,
Figure 32. Roxboro Steam Station - Energy Use
s
m
to
s
3
o'
0
�
s a
a
a =
a
a
a
a
0
�
a
a
a
a
z
z
>
z
>
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
0
MNA CIP
■ Groundwater (drinking water consumption)
❑ On -Site contaminant exposure
Total Energy Used - MM Btu
Removal
❑ Public off-site contaminant exposure
• Ecological Risk
NUA - no unacceptable risk
W
oa
0.75
M
U
N
U
a)
0.5 O
aL
m
c
0
L
0.25 0
O
0
CL
EPS
DCN: HWIDENCO02A 51 September 30, 2016

4.2.5 Ecological Habitat Services
High Risk
Y
N
> Moderate
M Risk
v
Y
Low Risk
NUA
Figure 33. Bel ews Creek Steam Station -Ecological Habitat Service Losses
a
1
MNA
■ Groundwater (drinking water consumption)
❑ On -Site contaminant exposure
■ Terrestrial Habitat Value- lost dSAYs
■ Overall Ecological Habitat Value -lost cISAYs
High Risk
W
Gl
Moderate
6 Risk
v
Low Risk
NUA
CIP Removal
❑ Public off-site contaminant exposure
■ Ecological Risk
Aquatic Habitat Value - lost dSAYs
NUA-no unacceptable risk
a
nn
0.75
s
V
d
V
d
0.5 0a
c
O
O
a
0.25 O
0
Figure 34. Marshall Steam Station - Ecological Habitat Service Losses
a
a
v
1
K
3
3
cli
>
z
z
z
>
z
>
z
>
z
m m
>
z
m
> >
z z
>
z
>
z
> >
z z
>
z
MNA
■ Groundwater (drinking water consumption)
❑ On -Site contaminant exposure
■ Terrestrial Habitat Value- lost dSAYs
■ Overall Ecological Habitat Value -lost cISAYs
High Risk
W
Gl
Moderate
6 Risk
v
Low Risk
NUA
CIP Removal
❑ Public off-site contaminant exposure
■ Ecological Risk
Aquatic Habitat Value - lost dSAYs
NUA-no unacceptable risk
a
nn
0.75
s
V
d
V
d
0.5 0a
c
O
O
a
0.25 O
0
Figure 34. Marshall Steam Station - Ecological Habitat Service Losses
a
a
v
1
MNA
■ Groundwater (drinking water consumption)
❑ On -Site contaminant exposure
■ Terrestrial Habitat Value - lost cISAYs
■ Overall Ecological Habitat Value -lost cISAYs
CIP Removal
❑ Public off-site contaminant exposure
■ Ecological Risk
Aquatic Habitat Value - lost dSAYs
NUA - no unacceptable risk
CL
v
on
0.75
s
V
Ol
V
Q)
O
0.5 a
75
c
O
Y
O
Q
0.25 O
0
a
EPS
DCN: HWIDENCO02A 52 September 30, 2016
K
3
cli
>
z
z
z
> >
z z
z z
z z
>
z
z
z
z z
z z
z
z
MNA
■ Groundwater (drinking water consumption)
❑ On -Site contaminant exposure
■ Terrestrial Habitat Value - lost cISAYs
■ Overall Ecological Habitat Value -lost cISAYs
CIP Removal
❑ Public off-site contaminant exposure
■ Ecological Risk
Aquatic Habitat Value - lost dSAYs
NUA - no unacceptable risk
CL
v
on
0.75
s
V
Ol
V
Q)
O
0.5 a
75
c
O
Y
O
Q
0.25 O
0
a
EPS
DCN: HWIDENCO02A 52 September 30, 2016

High Ri
Y
> Modera
m Ri
v
Low Ri
NU
Figure 35. Roxboro Steam Station - Ecological Habitat Service Losses
o
Y
K
3
_ _
z z z
n
MNA
z z z z
■ Groundwater (drinking water consumption)
13 On -Site contaminant exposure
■ Terrestrial Habitat Value - lost dSAYs
■ Overall Ecological Habitat Value - lost dSAYs
CI P
a
0.75 C
R
s
u
-8
N
V
O1
0.5 O
CL`
A
c
0
0
0.25 C
, 0
Removal
❑ Public off-site contaminant exposure
r! Ecological Risk
Aquatic Habitat Value - lost dSAYs
NUA - no unacceptable risk
a
EPS
DCN: HWIDENC002A 53 September 30, 2016

4.2.6 Costs
High Ris
Y
N
Gl
Moderatf
M Risl
d
Low Risk
NUA
Figure 36. Belews Creek Steam Station - Costs
0
z zz z z z z
V
MNA CIP Removal
■ Groundwater (drinking water consumption) ❑ Public off-site contaminant exposure
❑ On -Site contaminant exposure ❑ Ecological Risk
■ Capital Cost - Net Present Value (Millions) NUA - no unacceptable risk
Figure 37. Marshall Steam Station - Costs
High Risk
Y
N
Moderat(
Low Ris
NUA
MNA CIP Removal
■ Groundwater (drinking water consumption) ❑ Public off-site contaminant exposure
❑ On -Site contaminant exposure ❑ Ecological Risk
■ Capital Cost - Net Present Value (Millions) NUA - no unacceptable risk
DCN: HWIDENCO02A 54
1
d
0.75 c
M
s
v
d
v
v
0.5 01
C
O
M
O
0.25 C
O
1
W
0.75
M
s
u
d
V
d
0.5
a
c
0
Y
Q
0.25 CL
O
CL
0
September 30, 2016
3
0
>
>
>
z
z
z
z
z
z>
z
MNA CIP Removal
■ Groundwater (drinking water consumption) ❑ Public off-site contaminant exposure
❑ On -Site contaminant exposure ❑ Ecological Risk
■ Capital Cost - Net Present Value (Millions) NUA - no unacceptable risk
DCN: HWIDENCO02A 54
1
d
0.75 c
M
s
v
d
v
v
0.5 01
C
O
M
O
0.25 C
O
1
W
0.75
M
s
u
d
V
d
0.5
a
c
0
Y
Q
0.25 CL
O
CL
0
September 30, 2016

Figure 38. Roxboro Steam Station - Costs
MNA
■ Groundwater (drinking water consumption)
❑ On -Site contaminant exposure
■ Capital Cost - Net Present Value (Millions)
CIP Removal
❑ Public off-site contaminant exposure
O Ecological Risk
W
0.75 =
t
Gl
V
d
0.5 O
a
c
O
it
O
0.25 a
O
0
a
EPS
DCN: HWIDENCO02A 55 September 30, 2016
3
o
�
a
a
a
a
a
a
a
a
a
a
a
>
z
>
z
>
z
>
z
z
z
z
z
z
z
z
MNA
■ Groundwater (drinking water consumption)
❑ On -Site contaminant exposure
■ Capital Cost - Net Present Value (Millions)
CIP Removal
❑ Public off-site contaminant exposure
O Ecological Risk
W
0.75 =
t
Gl
V
d
0.5 O
a
c
O
it
O
0.25 a
O
0
a
EPS
DCN: HWIDENCO02A 55 September 30, 2016

EPS
4.2.7 Each Site - Data Combined
This section provides a comparison, based on the evaluation conducted herein, of the potential
impacts of the CIP and Removal alternatives in relation to one another and the NINA alternative
for each site.
4.2.7.1 Belews Creek Steam Station
As can be seen in Figure 39, the Removal alternative provides significantly more adverse impacts
when compared to the CIP alternative, without providing a meaningful reduction in risk. In
addition, the CIP alternative is projected to provide significantly more impacts when compared to
the NINA alternative, without providing a meaningful reduction in risk.
High Risk
,Y,4 Moderate
cC Risk
Figure 39. Belews Creek Steam Station - Summary
7 00
I ti
't� ^ N
nmioo Mo
Low Risk
NUA
MNA CIP Removal
■ Groundwater (drinking water consumption)
0 On -Site contaminant exposure
■ Truck traffic incidents -Fatalities
Truck traffic incidents - property damage only
Implementation risks - Injuries/Illness
■ GHG emissions -tons/yr CO2e emitted
Criteria pollutant emissions - tons/yr of NOx
Total Energy Used - MMBtu
■ Capital Cost - Net Present Value (Millions)
0.75 v
bn
C
s
u
M
a
0.5
a
C
O
0.25
O
CL
O
L
a
0
❑ Public off-site contaminant exposure
Ecological Risk
■ Truck traffic incidents -Injuries/Illness
Implementation risks - Fatalities
Implementation Truck Trips - Public Roads
GHG emissions -tons ofCO2e emitted
Criteria pollutant emissions - tons/yr of PM10/2.5
■ Overall Ecological Habitat Value -lost cISAYs
NUA - no unacceptable risk
DCN: HWIDENCO02A 56 September 30, 2016

0
A comparison of the human health risk driving the remedial action and the risks projected from
implementation of the alternatives follows. The human health risks associated with
implementing either the CIP or Removal alternatives at Belews Creek Steam Station far
outweigh the human health risks that are driving a remedy in the first place. By way of
example, this assertion is supported in Figure 40 and by the following:
• The chance that someone may get cancer due to exposure to chemicals at the site (without
any active remediation) is 5E-6, assuming the scenario evaluated. This means that if one
hundred million people have significant exposure to chemicals at the site, that five of them
might get cancer (or 5 of 1,000,000). To put this into perspective, the American Cancer
Society estimates the lifetime risk for a male to develop some type of cancer in their
lifetime is 43.31% (or 433,100 out of 1,000,000 people)9. There will be far fewer than
1,000,000 people with exposure at the site; if one assumes that 100 people have exposure,
then approximately 0.0005 people would have an increased risk of getting cancer.
• Although it is unlikely that someone would get cancer due to exposure at the site, there is
a real likelihood that people would be injured and possibly die under either of the two
active remedial alternatives (i.e., CIP or Removal). There is a statistical likelihood that 11
people would be injured and 0.15 people might die under the capping scenario at Belews
Creek Steam Station. Similarly, it is likely that 52 people would be injured and 0.57 might
die under the Removal scenario.
• There is also a risk to human health from breathing in pollutants emitted into the air due to
implementation of the remedial alternatives. The EPA has established threshold levels for
air emissions that are to be protective of human health. In the case of NOx, the emissions
under the Removal alternative are 3.6 times higher than the permitting threshold
established by the USEPA to be protective of the National Ambient Air Quality Standard.
This means there is a real likelihood that persons working at the site or along the
transportation route could incur health impacts as a result of the implementing the Removal
alternative. High NOx levels can result in causing or worsening respiratory disease (such
as emphysema and bronchitis), aggravating existing heart disease, and increased hospital
admissions and premature deaths10. These impacts would disproportionately affect
minority and economically disadvantaged people, as statistics show that such communities
are more likely to live within close proximity to the routes on which trucks would transport
material from the site to a disposal area". This raises significant environmental justice
concerns.
9 http://www.cancer.org/cancer/cancerbasics/lifetime-probability-of-developing-or-dying-from-cancer
i0 https://www3.epa.gov/airquality/nitrogenoxides/health.html
"htlps://www3.epa. og v/airqualiiy/nitroizenoxides/health.html
https://www.cdc.gov/mmwr/preview/mmwrhtml/su6203a8.htm
DCN: HWIDENC002A 57 September 30, 2016

EPS
Figure 40. Belews Steam Station
Number of Persons with Negative Health Impacts Projected for Proposed
Alternatives
(excludes health impacts due to air pollution)
52
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CIP
Removal
In regard to other impacts on the nearby community, such as noise, nuisance, etc., and
overarching climate impacts, it should be recognized that:
• The duration of the CIP and the Removal alternatives is projected to take a minimum of
4.6 and 22.4 years, respectively;
• The evaluation estimated a projected number of truck trips on nearby public roads in the
local community of over 123,000 and 625,000, for the CIP and Removal alternatives,
respectively, over the life of the projects;
• The energy consumption of each alternative is equivalent to the energy expenditure of
1,800 and 9,700 personal vehicles commuting five days a week for the duration of the CIP
and Removal alternatives, respectively;
• The estimated costs of the CIP and the Removal alternatives are projected to be about $143
Million and $986 Million, respectively;
• The projected yearly GHG emissions would exceed the USEPA established reporting
threshold for the Removal alternative (Figure 41a).
• The projected yearly NOx emissions would exceed the USEPA established threshold for
major modifications under the Prevention of Significant Deterioration program for the
Removal alternative (Figure 41b). -
In comparing the ecological risks to the ecological injury projected from implementation of the
alternatives, the ecological injury associated with implementing either the CIP or Removal
alternatives at the Belews Creek Steam Station far outweigh any ecological risks predicted
with chemical concentrations.
12 The significance levels in the Prevention of Significant Deterioration program are cited for an order of magnitude
comparison. I take no position on whether the activity in fact triggers the requirement for a PSD permit.
DCN: HWIDENCO02A 58 September 30, 2016

50,000
v
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T
}
Fp 25,000
0
200
0
Figure 41a. GHG Emissions projected by remedial alternative compared tot he GHG
Reporting Threshold - Belews Steam Station
7,347
0
30,935
MNA CIP Removal
GHG emissions - tons/yr CO2e emitted —GHG Reporting Threshold (25,000 tons)
Figure 41b. NOx Emissions projected by remedial alternative compared to the
NOx Permitting Threshold - Belews Steam Station
0
MNA
29
CIP
143
Removal
Criteria pollutant emissions -tons/yr of NOx —NOx Permitting Threshold (40 Tons)
EPS
The basic NEBA conducted herein indicates that implementation of the CIP and Removal
alternatives increase fatality, injury, health/illness and property damage risks of the local
community, increase community nuisance such as noise and pollution, and increase ecological
habitat destruction. As such, Intervenors' proposal for Removal is unjustified and, from a net
benefit analysis, detrimental.
DCN: HWIDENCO02A 59 September 30, 2016

0
4.2.7.2 Marshall Steam Station
As can be seen in Figure 42, the Removal alternative provides significantly more adverse impacts
when compared to the CIP alternative, without providing a meaningful reduction in risk. In
addition, the CIP alternative is projected to provide significantly more impacts when compared to
the NINA alternative, without providing a meaningful reduction in risk.
High Risk
Y
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> Moderate
Risk
G1
Low Risk
NUA
Figure 42. Marshall Steam Station - Summary - N 80 N
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❑ Groundwater (drinking water consumption)
❑ On -Site contaminant exposure
■ Truck traffic incidents -Fatalities
Truck traffic incidents - property damage only
■ Implementation risks- Injuries/Illness
■ GHG emissions -tons/yr CO2e emitted
Criteria pollutant emissions - tons/yr of NOx
Total Energy Used - MM Btu
■ Capital Cost- Net Present Value (Millions)
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■ Ecological Risk
■ Truck traffic incidents -Injuries/Illness
Implementation risks - Fatalities
■ Implementation Truck Trips - Public Roads
■ GHG emissions -tons ofCO2e emitted
Criteria pollutant emissions - tons/yr of PM10/2.5
■ Overall Ecological Habitat Value - lost cISAYs
NUA - no unacceptable risk
A comparison of the human health risk driving the remedial action and the risks projected from
implementation of the alternatives follows. The human health risks associated with
implementing either the CIP or Removal alternatives at Marshall Steam Station far
outweigh the human health risks that are driving a remedy in the first place. By way of
example, this assertion is supported in Figure 43 and by the following:
• The chance that someone may get cancer due to exposure to chemicals at the site (without
any active remediation) is 2E-6, assuming the scenario evaluated. This means that if one
million people have significant exposure to chemicals at the site, that two of them mei ht
DCN: HWIDENCO02A 60 September 30, 2016

0
get cancer (or 2 of 1,000,000). To put this into perspective, the American Cancer Society 13
estimates the lifetime risk for a male to develop some type of cancer in their lifetime is
43.31% (or 433,100 out of 1,000,000 people). There will be far fewer than 1,000,000
people with exposure at the site; if one assumes that 100 people have exposure, then
approximately 0.0002 people would have an increased risk of getting cancer.
• Although it is unlikely that someone would get cancer due to exposure at the site, there is
a real likelihood that people would be injured and possibly die due to active remediation
(i.e., capping or Removal). There is a statistical likelihood that 22 people would be injured
and 0.3 people might die under the capping scenario at Marshall Steam Station. Similarly,
it is likely that 112 people would be injured and 1.3 might die under the Removal scenario.
• There is also a risk to human health from breathing in pollutants emitted into the air due to
implementation of the remedial alternatives. In the case of NO,, the emissions under the
Removal alternative are 3.6 times higher than the permitting threshold established by the
USEPA to be protective of the National Ambient Air Quality Standard. This means there
is a real likelihood that persons working at the site or along the transportation route could
incur health impacts as a result of the implementing the Removal alternative. High NOx
levels can result in causing or worsening respiratory disease (such as emphysema and
bronchitis), aggravating existing heart disease, and increased hospital admissions and
premature deaths14. These impacts would disproportionately affect minority and
economically disadvantaged people, as statistics show that such communities are more
likely to live within close proximity to the routes on which trucks would transport material
from the site to a disposal area15. This raises significant environmental justice concerns.
Figure 43. Marshall Steam Station
Number of Persons with Negative Health Impacts Projected for Proposed
Alternatives
(excludes health impacts due to air pollution)
112
v
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MNA CIP Removal
13 http://www.cancer.org/cancer/cancerbasics/lifetime-probability-of-developing-or-dying-from-cancer
14 https://www3.epa.aov/airgualiiy/nitrogenoxides/health.html
"https://www3.epa. og v/airgualiiy/nitrolzenoxides/health.html
https://www.cdc.gov/mmwr/preview/mmwrhtml/su6203a8.httn
DCN: HWIDENCO02A 61 September 30, 2016

0
In regard to other impacts on the nearby community, such as noise, nuisance, etc., it should be
recognized that:
• The duration of the CIP and the Removal alternatives is projected to take a minimum of
9.3 and 50.4 years, respectively;
• The evaluation estimated a projected number of truck trips on nearby public roads in the
local community of over 253,000 and 1,416,000 for the CIP and Removal alternatives,
respectively, over the life span of each project;
• The energy consumption of each alternative is equivalent to the energy expenditure of
1,800 and 9,700 personal vehicles commuting five days a week for the duration of the CIP
and Removal alternatives, respectively;
• The estimated costs of the CIP and the Removal alternatives are projected to be about $291
Million and $2.2 Billion, respectively;
• The projected yearly GHG emissions would exceed the USEPA established reporting
threshold for the Removal alternative (Figure 44a).
• The projected yearly NOX emissions would exceed the USEPA established threshold for
major modifications under the Prevention of Significant Deterioration program for the
Removal alternative (Figure 44b)16
50,000
v
v
T
W
Gl
N
O
u
a
25,000
c
0
r
Figure 44 a. GHG Emissions projected by remedial alternative compared to
the GHG Reporting Threshold - Marshall Steam Station
7,396
0
30,942
MNA CIP Removal
�GHG emissions - tons/yr CO2e emitted —GHG Reporting Threshold (25,000 tons)
16 The significance levels in the Prevention of Significant Deterioration program are cited for an order of magnitude
comparison. I take no position on whether the activity in fact triggers the requirement for a PSD permit.
DCN: HWIDENCO02A 62 September 30, 2016

200
v
T
LU
x
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m
100
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Figure 44b. NOx Emissions projected by remedial alternative compared to
the NOx Permitting Threshold - Marshall Steam Station
29
0
143
MNA CIP Removal
Criteria pollutant emissions -tons/yr of NOx -NOx Permitting Threshold (40 Tons)
In comparing the ecological risks to the ecological injury projected from implementation of the
alternatives, the ecological injury associated with implementing either the CIP or Removal
alternatives at the Marshall Steam Station far outweigh any ecological risks predicted with
chemical concentrations.
The basic NEBA conducted herein indicates that implementation of the CIP and Removal
alternatives increase fatality, injury, health/illness and property damage risks of the local
community, increase community nuisance such as noise and pollution, and increase ecological
habitat destruction. These impacts appear to outweigh the human and ecological risks that are
driving the remediation in the first place. As such, Intervenors' proposal for Removal is unjustified
and, from a net benefit analysis, detrimental.
DCN: HWIDENCO02A 63 September 30, 2016

0
4.2.7.3 Roxboro Steam Station
As can be seen in Figure 45, the Removal alternative provides significantly more adverse impacts
when compared to the CIP alternative, without providing a meaningful reduction in risk. In
addition, the CIP alternative is projected to provide significantly more impacts when compared to
the NINA alternative, without providing a meaningful reduction in risk.
High RisF
Y
Moderat
+• Ris
m
v
Low Ris
NUA
Figure 45. Roxboro Steam Station - Summary
0
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■ Groundwater (drinking water consumption)
❑ On -Site contaminant exposure
■ Truck traffic incidents -Fatalities
Truck traffic incidents - property damage only
■ Implementation risks - Injuries/Illness
■ GHG emissions - tons/yr CO2e emitted
Criteria pollutant emissions - tons/yr of NOx
FM Total Energy Used - MM13tu
■ Capital Cost - Net Present Value (Millions)
m n
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❑ Public off-site contaminant exposure
■ Ecological Risk
■ Truck traffic incidents -injuries/Illness
Implementation risks - Fatalities
■ Implementation Truck Trips - Public Roads
■ GHG emissions -tons of CO2e emitted
Criteria pollutant emissions - tons/yr of PM10/2.5
■ Overall Ecological Habitat Value -lost dSAYs
NUA - no unacceptable risk
A comparison of the human health risk driving the remedial action and the risks projected from
implementation of the alternatives follows. The human health risks associated with
implementing either the CIP or Removal alternatives at Roxboro Steam Station far outweigh
the human health risks that are driving a remedy in the first place. By way of example, this
assertion is supported in Figure 46 and by the following:
• The chance that someone may get cancer due to exposure to chemicals at the site (without
any active remediation) is 3E-6, assuming the scenario evaluated. This means that if one
DCN: HWIDENCO02A 64 September 30, 2016

0
million people have significant exposure to chemicals at the site, that two of them might -
get cancer (or 3 of 1,000,000). To put this into perspective, the American Cancer Society"
estimates the lifetime risk for a male to develop some type of cancer in their lifetime is
43.31% (or 433,100 out of 1,000,000 people). There will be far fewer than 1,000,000
people with exposure at the site; if one assumes that 100 people have exposure, then
approximately 0.0003 people would have an increased risk of getting cancer.
• Although it is unlikely that someone would get cancer due to exposure at the site, there is
a real likelihood that people would be injured and possibly die due to active remediation
(i.e., capping or Removal). There is a statistical likelihood that 19 people would be injured
and 0.56 people might die under the capping scenario at Roxboro Steam Station. Similarly,
it is likely that 140 people would be injured and 1.6 might die under the Removal scenario.
• There is also a risk to human health from breathing in pollutants emitted into the air due to
implementation of the remedial alternatives. In the case of NO., the emissions under the
Removal alternative are 3.6 times higher than the permitting threshold established by the
USEPA to be protective of the National Ambient Air Quality Standard. This means there
is a real likelihood that persons working at the site or along the transportation route could
incur health impacts as a result of the implementing the Removal alternative. High NOX
levels can result in causing or worsening respiratory disease (such as emphysema and
bronchitis), aggravating existing heart disease, and increased hospital admissions and
premature deaths18. These impacts would disproportionately affect minority and
economically disadvantaged people, as statistics show that such communities are more
likely to live within close proximity to the routes on which trucks would transport material
from the site to a disposal area19. This raises significant environmental justice concerns.
Figure 46. Roxboro Steam Station
Number of Persons with Negative Health Impacts Projected for Proposed
Alternatives
17 http://www.cancer.org/cancer/cancerbasics/lifetime-probability-of-developing-or-dying-from-cancer
18 https://www3.epa. og v/airqualiiy/nitrogenoxides/health.html
19hllps://www3.epa. og v/airquali , /nitrogenoxides/health.html
https://www.cdc.gov/mmwr/preview/mmwrhtml/su6203a8.htm
DCN: HWIDENCO02A 65 September 30, 2016
(excludes health impacts due to air pollution)
140
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MNA
CIP
Removal
17 http://www.cancer.org/cancer/cancerbasics/lifetime-probability-of-developing-or-dying-from-cancer
18 https://www3.epa. og v/airqualiiy/nitrogenoxides/health.html
19hllps://www3.epa. og v/airquali , /nitrogenoxides/health.html
https://www.cdc.gov/mmwr/preview/mmwrhtml/su6203a8.htm
DCN: HWIDENCO02A 65 September 30, 2016

0
In regard to other impacts on the nearby community, such as noise, nuisance, etc., it should be
recognized that:
• The duration of the CIP and the Removal alternatives is projected to take a minimum of
8.2 and 63.8 years, respectively;
• The evaluation estimated a projected number of truck trips on nearby public roads in the
local community of over 221,000 and 1,780,000 for the CIP and Removal alternatives,
respectively, over the life span of each project;
• The energy consumption of each alternative is equivalent to the energy expenditure of
1,800 and 9,700 personal vehicles commuting five days a week for the duration of the CIP
and Removal alternatives, respectively;
• The estimated costs of the CIP and the Removal alternatives are projected to be about $254
Million and $2.763 Billion, respectively.
• The projected yearly GHG emissions would exceed the USEPA established reporting
threshold for the Removal alternative (Figure 47a).
• The projected yearly NOX emissions would exceed the USEPA established threshold for
major modifications under the Prevention of Significant Deterioration program for the
Removal alternative (Figure 47b)20.
50,000
v
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v
v
25,000
C
c
0
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rara
(9
Figure 47a. GHG Emissions projected by remedial alternative compared to
the GHG Reporting Threshold - Roxboro Steam Station
7,358
0
30,939
MNA CIP Removal
� GHG emissions - tons/yr CO2e emitted —GHG Reporting Threshold (25,000 tons)
20 The significance levels in the Prevention of Significant Deterioration program are cited for an order of magnitude
comparison. I take no position on whether the activity in fact triggers the requirement for a PSD permit.
DCN: HWIDENCO02A 66 September 30, 2016

200
v
LU
X
O
Z
m
100
C
H
C
O
E
W
X
O
Z
0
EPS
Figure 47b. NOx Emissions projected by remedial alternative compared to
the NOx Permitting Threshold - Roxboro Steam Station
MNA CIP Removal
Criteria pollutant emissions -tons/yr of NOx -NOx Perm ittingThreshold (40 Tons)
In comparing the ecological risks to the ecological injury projected from implementation of the
alternatives, the ecological injury associated with implementing either the CIP or Removal
alternatives at the Roxboro Steam Station far outweigh any ecological risks predicted with
chemical concentrations.
The basic NEBA conducted herein indicates that implementation of the CIP and Removal
alternatives increase fatality, injury, health/illness and property damage risks of the local
community, increase community nuisance such as noise and pollution, and increase ecological
habitat destruction. These impacts appear to outweigh the human and ecological risks that are
driving the remediation in the first place. As such, Intervenors' proposal for Removal is unjustified
and, from a net benefit analysis, detrimental.
In a recent article published in the Roxboro Times, the evolution from removal to cap -in-place to
handle coal ash was discussed by State Representative Larry Yarborough and that this change was
good for the citizens of North Carolina. Several points consistent with the NEBA conducted herein
were mentioned within that article (Yarborough 2016). These points included a reference to EPA
studies of coal ash finding it to be non-toxic, and that removal would entail significant effort and
disruption of the neighboring communities for many years (e.g., dump trucks travelling through
communities, etc.).
DCN: HWIDENCO02A 67 September 30, 2016

EPS
4.2.8 Cumulative Assessment
In order to put the cumulative effect of implementing the CIP and Removal alternatives in relation
to one another, a comparison of the alternatives is provided in Figure 48. As can be seen, the
cumulative adverse impacts associated with the Removal alternative are significantly higher when
compared to the CIP alternative.
High Risk
Y
H
fY
Moderate
+ Risk
ca
a
Low Risk
NUA
Figure 48. Cumulative Assessment - Belews Creek, Marshall, and Roxboro
Steam StatinnS
M Oo Vt
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■ Groundwater (drinking water consumption)
❑ On -Site contaminant exposure
■ Truck traffic incidents -Fatalities
Truck traffic incidents - property damage only
Implementation risks - Injuries/Illness
■ GHG emissions -tons/yr CO2e emitted
Criteria pollutant emissions - tons/yr of NOx
Total Energy Used - MMBtu
Aquatic Habitat Value- lost dSAYs
■ Capital Cost- Net Present Value (Millions)
CIP Removal
1
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tw
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s
u
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d
0.5 0 -
CL a
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❑ Public off-site contaminant exposure
❑ Ecological Risk
■ Truck traffic incidents -Injuries/Illness
Implementation risks - Fatalities
Implementation Truck Trips - Public Roads
GHG emissions -tons of CO2e emitted
Criteria pollutant emissions - tons/yr of PM10/2.5
■ Terrestrial Habitat Value - lost dSAYs
■ Overall Ecological Habitat Value -lost cISAYs
NUA - no unacceptable risk
DCN: HWIDENCO02A 68 September 30, 2016
N
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MNA
■ Groundwater (drinking water consumption)
❑ On -Site contaminant exposure
■ Truck traffic incidents -Fatalities
Truck traffic incidents - property damage only
Implementation risks - Injuries/Illness
■ GHG emissions -tons/yr CO2e emitted
Criteria pollutant emissions - tons/yr of NOx
Total Energy Used - MMBtu
Aquatic Habitat Value- lost dSAYs
■ Capital Cost- Net Present Value (Millions)
CIP Removal
1
W
tw
0.75 co
s
u
M
Gl
u
d
0.5 0 -
CL a
0
❑ Public off-site contaminant exposure
❑ Ecological Risk
■ Truck traffic incidents -Injuries/Illness
Implementation risks - Fatalities
Implementation Truck Trips - Public Roads
GHG emissions -tons of CO2e emitted
Criteria pollutant emissions - tons/yr of PM10/2.5
■ Terrestrial Habitat Value - lost dSAYs
■ Overall Ecological Habitat Value -lost cISAYs
NUA - no unacceptable risk
DCN: HWIDENCO02A 68 September 30, 2016

0
5 OPINIONS
• The Intervenors failed to take a holistic view of all of the environmental and community
impacts and risks (environmental footprint) associated with alternative implementation
during their remedial evaluation stage. This has skewed their remedy selection and leads
them to advocate for a remedy (Removal) that is less protective of the environment and the
community.
• The Intervenors do not consider the environmental footprint of the Removal alternative,
nor do they consider methods to reduce the footprint of these alternatives at any of the three
sites. Metrics that may have significant social and economic impacts (e.g., GHG emissions,
extended truck traffic, pollutant emissions through local communities, energy and resource
consumption) or ecological impacts (e.g., terrestrial and aquatic habitat disturbance
associated with removal, capping, or the development of off-site disposal units) were not
considered quantitatively by the Intervenors.
• Developing a remedy for the violations alleged requires employment of a NEBA evaluation
to develop sustainable remedial alternatives that manage site risks while maximizing
benefits and minimizing costs to the public.
• The Intervenors do not address four critical aspects of large, complex projects and
associated remedial evaluations:
o Sustainability and green remediation practices were not evaluated quantitatively;
o Social and community impacts were not evaluated quantitatively;
o Environmental footprints such as carbon and other greenhouse gas emissions were not
evaluated quantitatively; and,
o Net environmental, economic and social benefits and costs were not evaluated either
qualitatively or quantitatively.
• Based upon the NEBA evaluation, the Intervenors have not considered their obligation to
the public to develop sustainable remedial alternatives that manage site risks while
maximizing benefits and minimizing costs to the public.
• Based upon the NEBA presented herein, neither Removal or CIP is warranted as a remedy
for the violations alleged.
• The impact of metals in groundwater on groundwater ecosystem service flows provided by
each individual site is marginal, if any.
• The Removal remedy that the Intervenors propose for the Belews Creek, Marshall, and
Roxboro Steam Station sites does not appear to provide any net benefit to off-site
ecological or human use services, over other alternatives.
o The Removal alternative will create greater harm to the environment compared to other
alternatives.
o The Removal alternative will create greater risks (and nuisance) to the local community
(via the extensive truck traffic) and to workers compared to other alternatives.
DCN: HWIDENCO02A 69 September 30, 2016

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• Human health and ecological risk evaluations, on which the site classifications and
subsequent remedial alternatives for the Belews Creek, Marshall, and Roxboro Steam
Station sites are based, use highly if not overly conservative inputs and assumptions, and
mainly represent "perceived" risks, not "real" risks.
• The Removal alternative will not change human or ecological risk scenarios to any
meaningful level, compared to other alternatives.
• Human health risks associated with implementation of the Removal alternative far
outweigh the human health risks projected, given the current and projected state of
groundwater contamination.
• A refinement of both the human and ecological risk assessments will reduce "perceived"
risks substantially, providing for the consideration of less -intrusive alternatives for
managing "real" risks, if any.
• The marginal benefits to the "perceived" risk profile accomplished by the Intervenors'
proposed remedy do not justify the extreme differences in the cost profile, costs which are
largely borne by the communities served by Duke Energy.
• Based upon my evaluation, the Removal alternative would create greater environmental
and human health impacts at each of the three sites, compared to other alternatives.
• In comparing the CIP alternative to the Removal alternative, the Removal alternative has
a much greater environmental footprint and creates significantly more environmental and
community harm. This is consistent with the Tennessee Valley Authority findings in their
review of CIP and Removal alternatives for coal ash as part of their programmatic EIS
(Tennessee Valley Authority 2016).
• At all three sites, it appears that the following will occur should the Removal remedy
advocated by the Intervenors be implemented:
o The Removal alternative will cause more ecological injury through the destruction of
habitat than the ecological injury projected by the risk assessment, and;
o The Removal alternative provides no net increase in ecosystem service value for the
effort expended; the remedial actions are selected to address marginal, uncertain, and
localized/limited risks.
• With regard to the Removal alternative, the Intervenors have failed to demonstrate clear
and transparent consideration of the following often -stated Agency objectives:
Objective #1: Remedies should protect human health and the environment.
Remediation work should remove unacceptable risks to human health and to the
environment, with due consideration of the costs, benefits and technical feasibility
of the alternatives.
Objective #2: Remedies require safe working practices.
Remediation work should be safe for on-site workers, local communities and the
environment.
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Objective #3: Remedial decision-making should consider sustainability.
Remediation decisions should be made with regard to the current and future
implications of environmental, social and economic factors. A sustainable
remediation solution should deliver the maximum net benefit achievable.
Objective #4: Remedial decisions and their underlying foundations should be
transparent.
Remediation decisions, including the assumptions and supporting data used to
reach them; should be documented in a clear and easily understood format.
Objective #S: Remedial decisions require good governance and stakeholder
involvement.
Remediation decisions should be made with regard to the views of stakeholders and
follow a clear process in which they can participate. In situations where a non-
optimal remediation decision must be made, because of other factors that are more
influential, a clear and transparent record of indicating why such a decision was
taken should be a minimum requirement in any decision making process.
Objective #6: Remedial decisions are based on sound science.
Decisions should be made on the basis of sound science, relevant and accurate data,
and clearly explained assumptions. Decisions should be based on the best available
information and should be justifiable and reproducible.
• Aside from recognizing the traditional requirements associated with remedial alternative
selection, namely protection of human health and the environment and compliance with
applicable or relevant and appropriate requirements), the Intervenors failed to present
evidence of an evaluation of the significant differences (if any) in the environmental
footprint when comparing the CIP and Removal alternatives that meets the requirements
prescribed by federal agency guidance (USEPA 2012b).
• The Intervenors base their arguments for Removal on risks based solely upon chemical
concentrations of the COIs in groundwater and limited surface water seep areas, and do not
provide information as to how those alternatives will change contaminant risk scenarios.
In doing so, they neglected to consider factors other than chemical concentrations during
the implementation of their preferred remedial alternative that also have the potential to
influence, either positively or negatively, human health and ecological risks and services.
• The Belews Creek, Marshall, and Roxboro Steam Station sites meet the definition as to
when a NEBA would be of value in evaluating site remedial alternatives .21 The site
information indicates that these sites retain significant ecological value in their current
state. The Removal alternative proposed by the Intervenors will be environmentally
damaging, the ecological risks from the COI's are relatively small, uncertain, or limited to
21 "This framework for NEBA should be useful when the balance of risks and benefits from remediation of a site is
ambiguous. This ambiguity arises when the contaminated site retains significant ecological value, when the remedial
actions are themselves environmentally damaging, when the ecological risks from the contaminants are relatively
small, uncertain, or limited to a component of the ecosystem, and when remediation or restoration might fail."
(Efroymson et al. 2004).
DCN: HWIDENC002A 71 September 30, 2016

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a component of the ecosystem, and remediation or restoration may not be fully effective in
managing COI mobility.
• The Intervenors' proposal for Removal is unjustified and, from a net benefit analysis,
detrimental.
• There is no need to order closure, much less closure by Removal, to remedy the alleged
violations in this case. A basic NEBA demonstrates that the Intervenors' proposed remedy
(Removal) is clearly disproportionate to the risk.
DCN: HWIDENC002A 72 September 30, 2016

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6 REFERENCES
ATSDR 2004. Cobalt Toxicity Profile (www.atsdr.cdc. og v/tomrofiles/tp33.pdf).
Aurand, D., Walko, L., and Pond, R. 2000. Developing Consensus Ecological Risk Assessments:
Environmental Protection in Oil Spill Response Planning A Guidebook. United States
Coast Guard. Washington, DC. 148p.
Colombo, F., Nicolette, J., Wenning, R., and Travers, M. 2012. Incorporating Ecosystem
Valuation in the Assessment of Risk and Remedy Implementation. Chemical Engineering
Transactions. 28, 55-60. DOI: 3303/CET1228010
Efroymson, R., Nicolette, J., and Suter, G. 2003. A Framework for Net Environmental Benefit
Analysis for Remediation or Restoration of Petroleum -Contaminated Sites; ORNL/TM-
2003/17; Oak Ridge National Laboratory: Oak Ridge, TN, USA, 2003.
Efroymson, R., Nicolette, J., and Suter, G. 2004. A Framework for Net Environmental Benefit
Analysis for Remediation or Restoration of Contaminated Sites. Environmental
Management. 34,315-331.
Haley & Aldrich, Inc. April 2016. Report on Evaluation of Water Supply Wells in the Vicinity of
Duke Energy Ash Basins in North Carolina. Lisa Bradley.
HDR Engineering, Inc. of the Carolinas (HDR). 2015a. Comprehensive Site Assessment Report,
Belews Creek Steam Station Ash Basin. September 9, 2015.
HDR. 2015b. Comprehensive Site Assessment Report, Marshall Steam Station Ash Basin.
September 8, 2015.
HDR. 2015c. Corrective Action Plan Part 1, Belews Creek Steam Station Ash Basin. December 8,
2015.
HDR. 2015d. Corrective Action Plan Part 1, Marshall Steam Station Ash Basin. December 7, 2015.
HDR. 2016a. Corrective Action Plan Part 2, Belews Creek Steam Station Ash Basin. March 4,
2016.
HDR. 2016b. Corrective Action Plan Part 2, Marshall Steam Station Ash Basin. March 3, 2016.
HDR. 2016c. Comprehensive Site Assessment Supplement 2, Belews Creek Steam Station Ash
Basin. August 11, 2016.
HDR. 2016d. Comprehensive Site Assessment Supplement 2, Marshall Steam Station Ash Basin.
August 4, 2016.
Interstate Technology and Regulatory Council (ITRC). 2006. Planning and Promoting Ecological
Land Reuse of Remediated Sites. Washington, DC: ITRC, Ecological Reuse Team.
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National Oceanic and Atmospheric Administration (NOAA). 2011. (Shigenaka, G.) Summary
Report for Fate and Effects of Remnant Oil Remaining in the Environment. Annex M -
Net Environmental Benefit Analysis. National Oceanic and Atmospheric Administration.
Nicolette, J., Burr, S., and Rockel, M. 2013a. A Practical Approach for Demonstrating
Environmental Sustainability and Stewardship through a Net Ecosystem Service Analysis.
Sustainability 2013, 5, 2152-2177; doi:10.3390/su5052152, Published May 10, 2013.
Nicolette, J., Goldsmith, B., Wenning, R., Barber, T., and Colombo, F. 2013b. Chapter 9:
Experience with Restoration of Environmental Damage. In & L. Bergkamp (Ed.) & B.
Goldsmith (Ed.), The EU Environmental Liability Directive: A Commentary. Oxford
University Press. May 10, 2013.
North Carolina. 1971. North Carolina Environmental Policy Act of 1971. (1971, c. 1203, s. 1;
1991, c. 431, s. 1.)
North Carolina Department of Environmental Quality (NCDEQ). 2013. Division of Waste
Management, Hazardous Waste Section. Guidelines for Establishing Remediation Goals
at RCRA Hazardous Waste Sites. December 11, 2013.
Suter, G.W., II. 1993. Ecological Risk Assessment. Lewis Publishers, Boca Raton, Florida.
SynTerra. 2015a. Comprehensive Site Assessment Report, Roxboro Steam Electric Plant.
September 2, 2015.
SynTerra. 2015b. Corrective Action Plan Part 1, Roxboro Steam Electric Plant. December 1, 2015.
SynTerra. 2016a. Corrective Action Plan Part 2, Roxboro Steam Electric Plant. February 29, 2016.
SynTerra. 2016b. Comprehensive Site Assessment Supplement 2, Roxboro Steam Electric Plant.
August 1, 2016.
Tennessee Valley Authority. 2016. Final Ash Impoundment Closure Environmental Impact
Statement Part I — Programmatic NEPA Review. Project Number: 2015-31, June 2016.
United States 1997. United States v. Melvin Fisher. United States District Court for the Southern
District of Florida, Key West Division Case Numbers 92-10027-CIV-DAVIS, and 95-
10051-CIV-DAVIS. Decided 30 July 1997, Filed 30 July 1997. 977 F. Supp. 1193; 1997
U.S. Dist. LEXIS 16767.
United States 2001. United States of America and Internal Improvement Trust Fund v. Great Lakes
Dredge and Dock Company. United States District Court for the Southern District of
Florida D. C. Docket No. 97 -02510 -CV -EBD.
United States Army Environmental Center. 2005. United States Army Natural Resource Injury
Guidance. September. http://aec.army.mil/portals/3/cleanup/nri-guide.pdf
United States Environmental Protection Agency (USEPA) 1995. A Framework for Measuring the
Economic Benefits of Groundwater. Office of Water and Office of Policy, Planning and
Evaluation. EPA 230-B-95-003. October 1995.
DCN: HWIDENC002A 74 September 30, 2016

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USEPA. 1997. Ecological Risk Assessment Guidance for Superf ind: Process for Designing and
Conducting Ecological Risk Assessments (EPA 540-R-97-006). Washington, DC:
USEPA, OSWER.
USEPA. 1998. Guidelines for Ecological Risk Assessment (EPA/630/R-95/002F). Washington,
DC.
USEPA 2001. Updating Remedy Decision at Select Superfund Sites. Biannual Summary Report
FY 1998 and FY 1999. USEPA Office of Emergency Response (OERR) (EPA 540-R-01-
00, OSWER 9355.0-76) March 2001, 84 pp.
USEPA. 2005. Contaminated Sediment Remediation Guidance for Hazardous Waste Sites (EPA -
540 -R-05-012, OSWER 9355.0-85). Washington, DC: USEPA, OSWER.
USEPA. 2008. Green Remediation: Incorporating Sustainable Environmental Practices into
Remediation of Contaminated Sites (EPA 542-R-08-002). Washington DC: USEPA,
OSWER.
USEPA. 2009a. Endangerment and Cause or Contribute Findings for Greenhouse Gases Under
Section 202(a) of the Clean Air Act. Washington DC: Federal Register 74, no. 239: 66,
496-66, 546.
USEPA. 2009b. Principles for Greener Cleanups. Washington DC: USEPA, OSWER.
USEPA. 2011a. Greener Cleanups: Contracting and Administrative Toolkit. Washington, DC:
USEPA, OSWER.
USEPA. 201 lb. Deferral for CO2 emissions from bioenergy and other biogenic sources under the
Prevention of Significant Deterioration (PSD) and Title V programs: Proposed rule (EPA -
HQ -OAR -2011-0083). Washington DC: Federal Register 76, no. 54: 15, 249-15, 266.
USEPA. 2012a. "Re: Proposed Order for Recovery of Submerged Oil." Letter to Enbridge
Energy, Limited Partnership. 3 Oct. 2012. MS. N.p.
https://www3.epa. og v/region5/enbridgespill/pdfs/20121003-cover-letter-re-proposed-
order.pdf
USEPA. 2012b. Methodology for Understanding and Reducing a Project's Environmental
Footprint (EPA 542-R-12-002). Washington DC: USEPA, OSWER, Office of Superfund
Remediation and Technology Innovation.
USEPA. 2013. Region 4 Superfund Annual Report 2013. USEPA.
http://www.el2a. og v/region4/soerfund/images/allmedia/pdfs/
annualreport2013.pd£
USEPA. 2016. Consideration of Greener Cleanup Activities in the Superfund Cleanup Process.
Memorandum from J. Woolford, C. Bertrand, C. Mackey, and R. Albores to the Regional
Superfund National Program Managers. Regions 1-10 and Regional Counsels, Region 1-
10. 14 pp. August 2, 2016.
USEPA Science Advisory Board (SAB). 2009. Valuing the Protection of Ecological Systems and
Services (EPA -SAB -09-012). Washington, DC: USEPA Science Advisory Board.
DCN: HWIDENC002A 75 September 30, 2016

EPS
Yarborough, Larry (North Carolina State Representative). Roxboro Courier -Times, 07-27-16.
http://www.personcountylife.com/news/2016-07-
27/Editorial/Coal ash law echan changes are _good _for our_citizens.html
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Selected Examples of Truck Traffic and Construction Implementation Related
Accidents over the past 10 years (Web -accessed September 27, 2016)
August 2016, Wisconsin
//www.wsaw.com/content/news/Truck-accident-leads-to--39094433 I.html
June 2016, South Carolina
http://thejoumalonline.com/2016/06/13/hwy-247-fataliiy/
June 2016, Kansas City Missouri
http: //fox4kc. com/2016/06/20/semi-carrying-fly-ash-involved-in-wreck-spills-it-all-over-
highway
March 2015, Pennsylvania
htW: //www.wtae. com/news/triaxle-truck-crashes-spills-fly-ash-on-route-22/31754308
December 2013, West Virginia
http://www.tristateupdate.com/story/24295024/fatal-crash-on-i-64 jams-up-traffic-near-institute-
wv-fatal-fatality-multi-vehicle
July 2009, Tennessee
httD: //www.knoxnews. com/news/local/truck-driver-killed-in-accident-at-kiniiston-ash-shill-site-
eep-409808217-359305271.html
July 2006, Ohio (loading dump truck with ash, pit collapsed)
//www.osha.L-ov/Dls/imis/accidentsearch.accident detail?id=201954740
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7 EXPERT REPORTS REVIEWED
Bedient, Philip B. 29 February 2016. Expert Opinion of Remediation of Soil and Groundwater at
the Allen Steam Station Operated by Duke Energy Carolinas, LLC, Belmont, North
Carolina.
Bedient, Philip B. 29 February 2016. Expert Opinion of. Remediation of Soil and Groundwater at
the Cliffside Steam Station Operated by Duke Energy Carolinas, LLC, Mooresboro, North
Carolina.
Bedient, Philip B. May 13, 2016. Expert Opinion of. Remediation of Soil and Groundwater at the
Marshall Steam Station Operated by Duke Energy Carolinas, LLC, Terrell, North Carolina.
Campbell, Steven K. and Richard K. Spruill. 29 February 2016. Expert Report. Buck Steam
Station, 1555 Dukeville Road, Salisbury, NC 28146.
Campbell, Steven K. and Richard K. Spruill. May 12, 2016. Expert Report. Buck Steam Station,
1555 Dukeville Road, Salisbury, NC 28146.
Campbell, Steven K. and Richard K. Spruill. May 12, 2016. Expert Report, Addendum #1. Buck
Steam Station, 1555 Dukeville Road, Salisbury, NC 28146.
Cosler, Douglas J. February 29, 2016. Expert Report of Allen Steam Station Ash Basins Belmont,
North Carolina.
Cosler, Douglas J. February 29, 2016. Expert Report of. Cliffside Steam Station Ash Basins
Mooresboro, North Carolina.
Cosler, Douglas J. April 18, 2016. Expert Report of. Marshall Steam Station Ash Basin, Terrell,
North Carolina.
Haley & Aldrich, Inc. April 2016. Report on Evaluation of Water Supply Wells in the Vicinity of
Duke Energy Ash Basins in North Carolina. Lisa Bradley.
Hutson, Mark A. February 2016. Expert Report of. Mayo Steam Electric Plant Roxboro, NC.
Hutson, Mark A. May 2016. Expert Report of. Belews Creek Steam Station Ash Basin, Belews
Creek, NC.
Hutson, Mark A. May 2016. Expert Report of Roxboro Steam Electric Plant, Semora, NC.
Parette, Robert. May 13, 2016. Opinions of the Appropriateness of Monitored Natural Attenuation
in Conjunction with Cap -in -Place at the Roxboro Steam Station, Semora, NC.
Parette, Robert. May 13, 2016. Opinions of the Appropriateness of Monitored Natural Attenuation
in Conjunction with Cap -in -Place at the Belews Creek Steam Station, Belews Creek, NC.
Parette, Robert. May 13, 2016. Opinions of the Appropriateness of Monitored Natural Attenuation
in Conjunction with Cap -in -Place at the Marshall Steam Station, Terrell, NC.
Parette, Robert. May 13, 2016. Opinions of the Appropriateness of Monitored Natural Attenuation
in Conjunction with Cap -in -Place at the Buck Steam Station, Salisbury, NC.
DCN: HWIDENCO02A 78 September 30, 2016

EPS
Supplemental Expert Reports Reviewed
Campbell, Steven K. and Richard K. Spruill. August 30, 2016. Expert Report, Addendum #1. Buck
Steam Station, 1555 Dukeville Road, Salisbury, NC 28146.
Campbell, Steven K. and Richard K. Spruill. August 30, 2016. Expert Report, Addendum #2. Buck
Steam Station, 1555 Dukeville Road, Salisbury, NC 28146.
Cosler, Douglas J August 30, 2016. Supplemental Expert Report of Allen, Cliffside, and Marshall
Steam Station Ash Basins North Carolina.
Hutson, Mark A. August 2016. Supplemental Expert Report of. Belews Creek Steam Station Ash
Basin, Belews Creek, NC.
Hutson, Mark A. August 2016. Supplemental Expert Report of. Mayo Steam Electric Plant
Roxboro, NC.
Hutson, Mark A. August 2016. Supplemental Expert Report of. Roxboro Steam Electric Plant,
Semora, NC.
Parette, Robert. August 30, 2016. Supplemental Opinions of the Appropriateness of Monitored
Natural Attenuation in Conjunction with Cap -in -Place at the Allen, Belews Creek, Buck,
Cliffside, Marshall, Mayo, and Roxboro Steam Station, North Carolina.
DCN: HWIDENC002A 79 September 30, 2016

EPS
APPENDIX A
Remedial Alternatives Construction Analysis
Appendix A — Remedial Alternatives Construction Analysis A-1 September 30, 2016

REMEDIAL ALTERNATIVE CONSTRUCTION
ANALYSIS
A construction and cost analysis for three remedial alternatives, monitored natural attenuation
(MNA), cap -in-place with MNA (CIP), and comprehensive removal with MNA (Removal) was
conducted for the Belews Creek, Marshall and Roxboro Steam Stations. The three remedial
alternatives evaluated are based on the remedial assessment completed by HDR Engineering, Inc.
(HDR) and SynTerra Corporation (SynTerra) as detailed in the Corrective Action Plan (CAP), Part
2 for each respective steam station (HDR 2016a, 2016b; SynTerra 2016). The quantity of ash in
the basins and ash storage units for each steam station was provided by Duke Energy. Land
coverage dimensions were determined via GIS polygon analysis from shape files provided by HDR
and SynTerra (as provided in the CAP Part 2 documents).
The construction analysis is subdivided into three categories as summarized in Table 1 through
Table 3 following this text. Supporting calculation worksheets (Tables A-1 to A-13) are provided
at the end of this Appendix.
Appendix A — Remedial Alternatives Construction Analysis A-2 September 30, 2016

Al TABLE 1. LAND USE DISTURBANCE
The first analysis task was to evaluate the land use disturbance associated with each remedial
alternative for each site, which established the basis for other tasks under the construction and cost
analysis. Note that the NINA only alternative is not included in Table 1 as no significant land use
disturbance occurs under this alternative.
The CIP alternative involves construction of a synthetic cover system (i.e., a Subtitle D cap design)
over the surface -area footprint of the ash basin(s). This alternative also involves the support of an
off-site soil borrow pit to provide the material for use in the cap. The comprehensive Removal
alternative involves excavation of materials contained within the ash basin(s), and transport of the
ash material to a new off-site landfill constructed specifically for the purpose of the particular site's
ash disposal. It was assumed that a new off-site landfill will be needed for the excavated ash
because of the insufficient space on-site and the lack of available landfills capable of accepting
such large volumes of material. Note that under this alternative, additional land disturbance is
incurred associated with the offsite landfill. The following parameters or assumptions were
applied in evaluating the land cover alteration associated with the CIP and Removal alternatives.
AM Cap -in -Place (CIP) Assumptions:
1. The size of each cap is set equal to the current footprint of the existing ash basins.
2. The borrow material for cap construction is sourced from an off-site location 25 miles
away.
3. To determine borrow area size, the borrow area is set to a maximum depth of 10 feet (ft)
and a side slope of 3 ft/ft.
4. A 50 -ft perimeter buffer strip is included in the borrow area footprint.
A1.2 Comprehensive Removal (Removal) Assumptions:
1. A conversion of 1.2 tons per cubic yard of ash is assumed based on a study by the Electric
Power Research Institute (EPRI) (EPRI 2009).
2. To determine landfill size, each landfill is limited to a maximum height of 100 ft and a side
slope of 3.5 ft/ft.
3. A 300 -ft perimeter buffer strip is included in the landfill footprint.
4. To determine borrow area size, the borrow area is set to a maximum depth of 10 ft and a
side slope of 3 ft/ft.
5. The borrow area is assumed to exist on the same property parcel as the off-site landfill. It
is assumed this distance is 1 mile (2 -mile round trip) from the landfill proper.
6. A 50 -ft perimeter buffer strip is included in the borrow area footprint.
Appendix A — Remedial Alternatives Construction Analysis A-3 September 30, 2016

0
A2 TABLE 2. PROJECT DURATION
The second analysis task evaluated the anticipated duration of each remedial alternative. The
Removal alternative comprises three primary tasks: 1) construction of an off-site landfill, 2)
excavation, transport and placement of ash into the constructed landfill, and 3) closure of the
landfill with a synthetic cap. The CIP alternative comprises cap construction activities, which are
assumed to be limited by the rate at which capping material (i.e. soil and clay) can be imported
from a borrow area and placed on-site.
A2.1 Removal Assumptions:
1. Landfill construction assumes a per acre activity rate of 1 day for clear & grub, 28 days for
earthwork, 7 days for survey control, 14 days for liner/leachate system installation, and 4
days for liner soil cover. Activities will occur concurrently; therefore, the rate of earthwork
is the limiting factor for the construction rate.
2. Ash basin excavation, transport to landfill, and ash placement assumes an annual haul rate
of 540,000 tons based on 50 trucks with 2 loads per day at 20 tons apiece, operating 12
hours per day for 270 days per year. Haul distance assumes 25 miles to the landfill (50 -
mile round trip).
3. Landfill closure assumes that the landfill capping rate is subject to import rate of cover
material. Import of cover material assumes an annual haul rate of 648,000 CY based on 6
trucks with 10 loads per day at 40 CY apiece, operating 12 hours per day for 270 days per
year. Haul distance assumes 1 mile from the on-site borrow area.
A2.2 Cap -in -Place Assumptions:
1. Cap Construction: Assumes an annual haul rate of 540,000 tons based on 50 trucks with 2
loads per day at 20 tons apiece, operating 12 hours per day for 270 days per year. Haul
distance assumes 25 miles to the landfill (50 -mile round trip).
Appendix A — Remedial Alternatives Construction Analysis A-4 September 30, 2016

EPS
A3 TABLE 3. COST SUMMARY OF
ALTERNATIVE REMEDIAL ACTIONS
The third analysis task was to project expenditures required to implement each remedial alternative
based on the modeled parameters for land use disturbance and project duration. Construction
material cost, labor, and equipment rates are based on data from the Remedial Action Cost
Engineering and Requirements System (RACER) Software Package, Version 11.1.12.0 and from
communications with an industry expert (James R. Nelson, P.G., FGS, personal communication,
June 17, 2016). Landfill construction cost is estimated based on economic data cited in U.S.
Environmental Protection Agency research (USEPA 2014), which reports landfill construction
cost ranges from $300,000 to $800,000 per acre. A cost per acre of $600,000 was applied to for
the current cost analysis.
Appendix A — Remedial Alternatives Construction Analysis A-5 September 30, 2016

A4 REFERENCES
Electric Power Research Institute. 2009.
Environmental Issues. September 2009.
0
Coal Ash: Characteristics, Management and
HDR. 2016a. Corrective Action Plan Part 2, Allen Steam Station Ash Basin. February 19, 2016.
HDR. 2016b. Corrective Action Plan Part 2, Buck Steam Station Ash Basin. February 19, 2016.
HDR. 2016c. Corrective Action Plan Part 2, Cliffside Steam Station Ash Basin. February 12, 2016.
Nelson, James R. 2016. Personal communication. June 17, 2016.
SynTerra. 2016. Corrective Action Plan Part 2, Mayo Steam Electric Plant. February 29, 2016
USEPA. 2014. Municipal Solid Waste Landfills, Economic Impact Analysis for the Proposed New
Subpart to the New Source Performance Standards. June 2014.
Appendix A — Remedial Alternatives Construction Analysis A-6 September 30, 2016

Table 1. Land Use Change Summary
Assumption:
Ash density: 1.2 tons/CY
Notes:
MNA: Monitored Natural Attenuation
CY: Cubic Yards
CIP: Cap in Place
1. Estimated landfill footprint based on 100' height and 3.5 side slope, plus 300 foot buffer for development/construction support.
2. Borrow Area: Excavation area based on 10 depth, plus 50 foot buffer for development/construction support.
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-7
REMOVAL
CIP
Site
Existing Ash Pond/
Ash Fill Area
Volume of Ash
Landfill Construction
1
Area
Landfill Cap Borrow
2
Material Area
Landfill Total
CIP Borrow Material Areae
Acre
CY
Acre
Acres
Acres
Acres
Belews
283
10,075,000
162
64
226
168
Marshall
579
22,825,000
293
127
420
335
Roxboro
506
28,716,667
350
154
504
294
Total:
1,368
61,616, 667
805
345
1,150
797
Assumption:
Ash density: 1.2 tons/CY
Notes:
MNA: Monitored Natural Attenuation
CY: Cubic Yards
CIP: Cap in Place
1. Estimated landfill footprint based on 100' height and 3.5 side slope, plus 300 foot buffer for development/construction support.
2. Borrow Area: Excavation area based on 10 depth, plus 50 foot buffer for development/construction support.
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-7

Table 2. Project Duration Summary
Notes:
CIP: Cap -in-place
MNA: Monitored Natural Attenuation
Model Assumptions:
REMOVAL
CIP
REMOVAL
Construction
Ash Excavation &Closure/Cap
Transport
Cap Construction
Work Days/Week
CIP
6
Site
6
Construction'
50
Ash Excavation, Transport & Placement
Closure/Cap3
Hours/Day
12
Cap Construction
12
12
Years
Work Days
Hours
Years
Work Days
Hours
Years
Work Days
Hours
Years
Work Days
Hours
Belews
2.4
722
8,667
22.4
6,045
72,540
1.4
368
4,421
4.6
1,233
14,799
Marshall
4.9
1,469
17,631
50.7
13,695
164,340
2.8
763
9,154
9.3
2,523
30,273
Roxboro
6.0
1,804
21,652
63.8
17,230
206,760
3.5
937
11,244
8.2
2,204
26,452
Total:
13.3
3,995.8
47,949.9
136.9
36,970.0
443,640.0
7.7
2,068.3
24,819.2
22.1
5,960.3
71,523.6
Notes:
CIP: Cap -in-place
MNA: Monitored Natural Attenuation
Model Assumptions:
1. Landfill Construction: Assumes a per acre activity rate of 1 day for clear & grub, 28 days for earthwork, 7 days for survey control, 14 days for liner/leachate system installation, and 4 days for liner soil cover.
2. Ash Basin Excavation & Transport to Landfill: Assumes an annual haul rate of 540,000 tons based on 50 trucks with 2 loads per day at 20 tons apiece, operating 12 hours per day for 270 days per year. Haul distance assumes 25 miles to landfill (50 miles round-
trip).
3. Landfill Closure: Assumes landfill capping rate is subject to import rate of cover material. Assumes an annual haul rate of 648,000 CY based on 6 trucks with 10 loads per day at 40 CY apiece, operating 12 hours per day for 270 days per year. Haul distance assumes
1 miles from on-site borrow area.
4. CIP Cap Construction: Assumes an annual haul rate of 540,000 tons based on 50 trucks with 2 loads per day at 20 tons apiece, operating 12 hours per day for 270 days per year. Haul distance assumes 25 miles to landfill (50 miles round-trip).
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-8
REMOVAL
CIP
Schedule Assumptions
Construction
Ash Excavation &Closure/Cap
Transport
Cap Construction
Work Days/Week
6
6
6
6
Work Weeks/Year
50
45
45
45
Hours/Day
12
12
12
12
Construction Days/Year
300
270
270
270
1. Landfill Construction: Assumes a per acre activity rate of 1 day for clear & grub, 28 days for earthwork, 7 days for survey control, 14 days for liner/leachate system installation, and 4 days for liner soil cover.
2. Ash Basin Excavation & Transport to Landfill: Assumes an annual haul rate of 540,000 tons based on 50 trucks with 2 loads per day at 20 tons apiece, operating 12 hours per day for 270 days per year. Haul distance assumes 25 miles to landfill (50 miles round-
trip).
3. Landfill Closure: Assumes landfill capping rate is subject to import rate of cover material. Assumes an annual haul rate of 648,000 CY based on 6 trucks with 10 loads per day at 40 CY apiece, operating 12 hours per day for 270 days per year. Haul distance assumes
1 miles from on-site borrow area.
4. CIP Cap Construction: Assumes an annual haul rate of 540,000 tons based on 50 trucks with 2 loads per day at 20 tons apiece, operating 12 hours per day for 270 days per year. Haul distance assumes 25 miles to landfill (50 miles round-trip).
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-8

Table 3. Cost Summary
Table 4. Cost Summary
Notes:
Construction and materail costs developed from Remedial Action Cost Engineering and Requirements System (RACER) Software Package, Version 11.1.12.0
Project durations and equipment levels based on persoannal communication with industry expert
MINA: Monitored Natural Attenuation
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-9
REMOVAL
SiteMonitoring
(Site
Onl
10% Contingency
CIP
Belews
$6,650,000
Site
$7,315,000
Ash Excavation,
$8,200,000
Monitoring (Site
$9,020,000
Roxboro
$8,975,000
Monitoring (Site
$9,872,500
Total:
$23,825,000
Construction
Transport &
Closure/Cap
and Landfill)
10% Contingency
TOTAL
Cap Construction
Only)
10% Contingency
TOTAL
Placement
Belews
$68,917,694
$760,845,768
$56,577,444
$10,890,101
$88,634,090.70
$985,865,099
$129,807,488
$6,650,000
$12,980,748.78
$142,788,236.5
Marshall
$134,963,654
$1,726,857,881
$115,513,627
$13,395,116
$197,733,516.19
$2,188,463,794
$264,286,761
$8,200,000
$26,428,676.06
$290,715,436.64
Roxboro
$164,577,744
$2,166,179,832
$167,787,319
$14,515,699
$249,854,489.45
$2,762,915,083
$231,086,981
$8,975,000
$23,108,698.10
$254,195,679.1
Total:
$368,459,092
$4,653,883,481
$339,878,390
$38,800,916
$536,222,096
$5,937,243,976
$625,181,229
$23,825,000
$62,518,123
$687,699,352
Notes:
Construction and materail costs developed from Remedial Action Cost Engineering and Requirements System (RACER) Software Package, Version 11.1.12.0
Project durations and equipment levels based on persoannal communication with industry expert
MINA: Monitored Natural Attenuation
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-9
SiteMonitoring
(Site
Onl
10% Contingency
TOTAL
Belews
$6,650,000
$665,000
$7,315,000
Marshall
$8,200,000
$820,000
$9,020,000
Roxboro
$8,975,000
$897,500
$9,872,500
Total:
$23,825,000
$2,382,500
$26,207,500
Notes:
Construction and materail costs developed from Remedial Action Cost Engineering and Requirements System (RACER) Software Package, Version 11.1.12.0
Project durations and equipment levels based on persoannal communication with industry expert
MINA: Monitored Natural Attenuation
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-9

Table Al. Road Travel Summary
Notes:
MNA: Monitored Natural Attenuation
1. 25 miles one-way, public roads.
2. 1 miles one-way, on-site (non-public road) travel only.
3. 100 miles one-way, public roads.
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-10
REMOVAL
CIP
Site
Ash Transport
Trips Miles'
Closure/Cap Material
Trips Miles'
Liner Material
Trips Miles'
Closure/Cap Material
Trips Miles'
Liner Material
Trips Miles'
Belews
604,500
30,225,000
22,107 44,214
137
27,356
123,323
6,166,153
179
35,720
Marshall
1,369,500
68,475,000
45,768 91,536
278
55,654
252,271
12,613,545
366
73,152
Roxboro
1,723,000
86,150,000
56,221 112,442
342
68,344
220,436
11,021,800
319
63,898
Total:
3,697,000
184,850,000
124,096 248,192
757
151,355
596,030
29,801,497
864
172,771
Notes:
MNA: Monitored Natural Attenuation
1. 25 miles one-way, public roads.
2. 1 miles one-way, on-site (non-public road) travel only.
3. 100 miles one-way, public roads.
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-10

Table A2. Liner Specifications
Roll Dimensions
30 Mil
40 mil
60 mil
80 mil
100 mil
1. Width (feet):
23
23
23
23
23
2. Length (feet)
1000
750
500
375
300
3. Area (square feet):
23,000
17,250
11,500
8,625
6,900
4. Gross Weight (pounds, approx.)
3,470
3,470
3,470
3,470
3,470
Landfill Option
Site Liner Area (ft2) Cap Area Liner Rolls Cap Rolls Truck Trips Miles
Belews 4,494,270 4,943,697 391
430
137 27,356
Marshall 9,143,180 10,057,498 795
875
278 55,654
Roxboro 11,227,990 12,350,789 976
1,074
342 68,344
2,162
2,378
757 151,355
CIP Option
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-1 1
Total Ash Basin Area
Site
Ash Basin (ft2)
Rolls
Truck Trips
Miles
(Acres)
Belews
283
12,323,478
1,072
179
35,720
Marshall
579
25,237,583
2,195
366
73,152
Roxboro
506
22,044,845
1,917
319
63,898
5,183
864
172,771
Assumptions
Rolls/Truck:
6
Travel Distance (mile):
100
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-1 1

Table A3. Monitoring Cost Estimate
Landfill Monitoring
Site Landfill Width (ft) # MWs Well Installation Days/Event Analytical Cost Labor Cost Equipment Cost Reporting Events/Year Annual Cost 100 Years
Belews 2,120 14 $49,466 4 $4,239.94 $5,653.25 $1,059.98 $10,000.00 2 $41,906 $4,240,101.00
Marshall 3,024 20 $70,555 5 $6,047.54 $8,063.38 $1,511.88 $10,000.00 2 $51,246 $5,195,116.11
Roxboro 3,351 22 $78,186 6 $6,701.64 $8,935.52 $1,675.41 $10,000.00 2 $54,625 $5,540,699.09
MYA Monitoring
Well Network Size: Assumes one well every 300 feet on down -gradient side of landfill, and one well every 600 feet per side and up -gradient side.
Analytical Cost/Well:
$300.00
Sample Events/Year:
2
Site
# MWs Days/Event Analytical Cost
Labor Cost
Equipment Cost
Reporting Events/Year
Annual Cost
100 Years
Belews
30 8 $9,000.00
$12,000.00
$2,250.00
$10,000.00 2
$66,500
$6,650,000
Marshall
40 10 $12,000.00
$16,000.00
$3,000.00
$10,000.00 2
$82,000
$8,200,000
Roxboro
45 11 $13,500.00
$18,000.00
$3,375.00
$10,000.00 2
$89,750
$8,975,000
Assumptions:
Well Network Size: Assumes one well every 300 feet on down -gradient side of landfill, and one well every 600 feet per side and up -gradient side.
Analytical Cost/Well:
$300.00
Sample Events/Year:
2
Day Labor Rate:
$1,600.00
Equipment Dy Rate:
$300.00
Wells Sampled/Day:
4
Reporting Cost:
$10,000
Well Install Cost:
$3,500
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-12

Landfill Requirements
Site Tons
CY ft3
Table A4. Off -Site Landfill Size and Cost Estimate
Belews 12,090,000 10,075,000 272,025,OOC
Marshall 27,390,000 22,825,000 616,275,000
Roxboro 34,460,000 28,716,667 775,350,000
Total: 73,940,000 61,616,667 1,663,650,OOC
OUTPUT
GOAL SEEK CALCULATION - LANDFILL GEOMETRY
Height
Bottom (Landfill Base)
S1 (ft) Bl (ft2)
Top
52 (ft)
B2 (ft2)
Volume (ft3)
100
2,1201 4,494,270
1,420
2,016,313
272,025,000
100
3,0241 9,143,180
2,324
5,399,903
616,275,000
100
3,3511 11,227,990
2,651
7,026,843
775,350,000
Conversion
tons per CY: 1.2
Landfill Parameters:
Height (ft) 100
Slope: 3.5
Landfill Cost/Acre
Low:
High:
$300,000
$600,000
Buffer Width
Width (ft) 300
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-13

Table A5. Estimated Duration of Landfill Construction
Site Size (Acres)
Construction days
Years
Const. Hours
Belews 103
722.2
2.4
8,667
Marshall 210
1469.3
4.9
17,631
Roxboro 258
1804.3
6.0
21,652
Total:
571 3,996 13 47,950
Activity
Duration/acre (days)
Clear/Grub
1
Excavation/Earthwork:
28 Limiting factor - Used as construction rate
Surveying
7
Liner/Leachate System
14
Protective Soil Liner
4
Construction Teams (sets of equipment)
# Construction Teams
4
Project Duration Details
Days/Week
6
Weeks/Year
50
Hours/day
12
Construction days/year
300
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-14

Table A6. Landfill Closure Cost Worksheet (RACER)
Imported
Import Duration
Folder Assembly Level Data Report (RACER)
Site Material Volume
(yrs)
Trips
Travel Miles
Days
Hours
Belews 884,289
1.4
22,107
44,214
368
4,421
Marshall 1,830,722
2.8
45,768
91,536
763
9,154
Roxboro 2,248,839
3.5
56,221
112,442
937
11,244
Total: 7,919,949
12.2
197,999
395,997
3,300
39,600
Project Duration Details
1.43
$2,912,425
Below
Capping
Annual Haul Rate ICY):
648,000
105
ACR
2,623.43
423.05
# Trucks:
6
$336,525
Below
Capping
33080507
Truck CY:
40
CY
21.97
2.17
1.40
Trips/Day:
10
Belew
Capping
33080571
60 Mil
Days/Week
6
0.40
0.20
0.01
Weeks/Year
45
Barrow
Hours/day
12
Fill Distance (miles):
Capping
17030233
Crawler-
4421
HR
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-15
Folder Assembly Level Data Report (RACER)
Phase
Technology
Assembly No.
Assembly
Qty
UOM
Materials
Labor
Equipment
Equip. Units Extended Cost
Bele.
Capping
17030423
Unclassifie
423,105
CY
21.97
0.92
0.72
$9,993,371
Below
Capping
18050301
Loam or
105,776
LCV
21.17
4.94
1.43
$2,912,425
Below
Capping
18050402
Seeding,
105
ACR
2,623.43
423.05
161.57
$336,525
Below
Capping
33080507
Clay, Low
355,408
CY
21.97
2.17
1.40
$9,075,175
Belew
Capping
33080571
60 Mil
5,026,483
SF
0.40
0.20
0.01
$2,566,353
Barrow
Below
Capping
17030233
Crawler-
4421
HR
$0.00
$57.39
$79.54
4
$2,421,713
Belew
ICapping
17030706
DS with U-
4,421
HR
$0.00
$59.86
$106.51
2
$1,471,191
Belew
Capping
17030226
988 7.0 1
4,421
HR
1 $0.00
$59.861
$84.96
2 1
$1,280,627
Belew
Capping
17030295
on
35 Ton.
4,421
HR
$0.00
$55.72
$89.09
2
$1,280,538
CAP
Belew
Capping
17030704
D6 with A-
4421
HR
$0.00
$59.86
$60.12
2
$1,060,970
Belew
Capping
17030101
Rough
507,716
SY
$0.00
$0.28
$0.31
$299,552
Belew
Capping
17030431
580K, 1.0
4,421
HR
$0.00
$59.86
$20.70
$356,191
Below
Capping
18050413
Watering
105
ACR
$154.66
$38.83
$36.99
$24,177
Belew
Capping
17030233
Crawler-
4,421
HR
$0.00
$57.39
$79.54
$605,428
Belew
Capping
33010505
50 KW
368
DAY
$0.00
$0.00
$163.38
1
$60,198
Imported
884,289
CY
Direct Cost:
$33,744,434
Direct+
$53,991,095
Marshall
Capping
17030423
Unclassifie
834,161
CY
21.97
0.92
0.72
$19,702,170
Marshall
Capping
18050301
Loam or
208,540
LCY
21.17
4.94
1.43
$5,741,916
Marshall
Capping
18050402
Seeding,
207
ACR
2,623.43
423.05
161.57
$663,490
Marshall
Capping
33080507
Clay, Low
700,695
CY
21.97
2.17
1.40
$17,891,925
Marshall
ICapping
33080571
60 Mil
9,909,832
SF
0.401
0.20
0.01
$5,059,626
Marshall
Capping
17030423
Unclassifie
41,782
CY
21.97
0.92
0.72
$986,866
Marshall
Capping
18050301
Loam or
10,446
LCY
21.17
4.94
1.43
$287,608
Marshall
Capping
18050402
Seeding,
10
ACR
2,623.43
423.05
161.57
$33,235
Marshall
Capping
33080507
Clay, Low
35,097
CY
21.97
2.17
1.40
$896,192
Marshall
Capping
33080571
40 Mil
496,375
SF
0.29
0.20
0.01
$253,433
Barrow
Marshall
Capping
17030233
Crawler-
9,154
HR
$0.00
$57.39
$79.54
4
$5,013,614
Marshall
Capping
17030706
D8 with U-
9,154
HR
$0.00
$59.86
$106.51
2
$3,045,772
Marshall
Capping
17030226
988 7.0
9154
HR
$0.00
$59.86
$84.96
2
$2,651,251
Marshall
Capping
17030295
35 Ton
9,154
HR
$0.00
$55.72
$89.09
2
$2,651,068
CAP
Marshall
Capping
17030704
D6 with A-
9,154
HR
$0.00
$59.86
$60.12
2
$2,196,500
Marshall
Capping
17030101
Rough
1,051,151
SY
$0.00
$0.28
$0.31
$620,179
Marshall
Capping
17030431
580K 1.0
9,154
HR
$0.00
$59.86
$20.70
$737,415
Marshall
Capping
18050413
Watering
217
ACR
$154.66
$38.83
$36.99
$50,056
Marshall
Capping
17030233
Crawler-
9,154
HR
$0.00
$57.39
$79.54
$1,253,404
Marshall
Capping
33010505
50 KW
763
DAY
$0.001
$0.00
$163.38
1 1
$124,626
Imported
1,830,722
CY
Direct Cost:
$69,860,346
Direct+
$111,776,553
Roxoboro
Capping
17030423
Unclassifie
834,161
CY
21.97
0.92
0.72
$19,702,170
Roxoboro
Capping
18050301
Loam or
208,540
LCV
21.17
4.94
1.43
$5,741,916
Roxoboro
Capping
18050402
Seeding,
207
ACR
2,623.43
423.05
161.57
$663,490
Roxoboro
Capping
33080507
Clay, Low
700,695
CY
21.97
2.17
1.40
$17,891,925
Roxoboro
Capping
33080571
60 Mil
9,909,832
SF
0.40
0.20
0.01
$5,059,626
Roxoboro
Capping
17030423
Unclassifie
241,838
CY
21.97
0.92
0.72
$5,712,016
Roxoboro
Capping
18050301
Loam or
60,460
LCY
21.17
4.94
1.43
$1,664,685
Roxoboro
ICapping
18050402
Seeding,
60
ACR
2,623.43
423.05
161.57
$192,355
Roxoboro
Capping
33080507
Clay, Low
203,144
CY
21.97
2.17
1.40
$5,187,193
Roxoboro
Capping
33080571
60 Mil
2,873,040
SF
0.29
0.20
0.01
$1,466,877
Barrow
Roxoboro
Capping
17030233
Crawler-
11,244
HR
$0.00
$57.39
$79.54
4
$22,604,769
Roxoboro
Capping
17030706
IDS with U-
11,244
HR
$0.00
$59.86
$106.51
2
$3,741,393
Roxoboro
Capping
17030226
988 7.0
11,244
HR
$0.001
$59.86
$84.96
2
$3,256,768
Roxoboro
Capping
17030295
35 Ton,
11,244
HR
$0.00
$55.72
$89.09
2
$3,256,543
CAP
Roxoboro
Capping
17030704
D6with A-
11,244
HR
$0.00
$59.86
$60.12
2
$2,698,156
Roxoboro
Capping
17030101
Rough
1,291215
SY
$0.00
$0.28
$0.31
$761,817
Roxoboro
ICapping
17030431
580K, 1.0
11,244
HR
$0.00
$59.86
$20.70
$905,832
Roxoboro
Capping
18050413
Watering
60
ACR
$154.66
$38.83
$36.99
$13,820
Roxoboro
Capping
17030233
Crawler-
11,244
HR
$0.00
$57.391
$79.54
$1,539,667
Roxoboro
Capping
133010505
150 KW,
937
DAY
$0.00
$0.001
$163.38
1 1
$153,090
Imported
2,248,839
CY
I
Direct Cost,I
$102,214,111
Direct +1
$163,542,577
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-15

Table A7. Off -Site Landfill Closure - Borrow Area Size
INPUT
Site
Belews
Marshall
Roxboro
Ej
Total:
OUTPUT
GOAL SEEK CALCULATION - BORROW PIT
Height
Imported Material
Top
S2 (ft)
Site
Volume (ft3)
ft3
1,575 2,480,884
Volume (CY)
2,295,474
Belews
884,289
23,875,794
Marshall
1,830,722
49,429,484
Roxboro
2,248,839
60,718,640
Total:
4,963,849
134,023,918
Site
Belews
Marshall
Roxboro
Ej
Total:
OUTPUT
GOAL SEEK CALCULATION - BORROW PIT
Height
Bottom
S1 (ft) B1 (ft2)
Top
S2 (ft)
B2 (ft2)
Volume (ft3)
10
1,575 2,480,884
1,515
2,295,474
23,875,794
10
2,253 5,076,941
2,193
4,810,156
49,429,484
10
2,494 6,220,307
2,434
5,924,621
60,718,640
Borrow
Area (ft2)
Acres
Buffer Acres
Total Acreag
2,480,884
57
7.2
64.2
5,076,941
117
10.3
126.9
6,220,307
143
11.5
154.2
Total:
316
29
345
Borrow Parameters: Buffer Width
Height (ft) 10 Width (ft) 50
Slope: 3
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-16

Table A8. Excavation, Transportation and Placement of Ash
Site Ash Tons Duration (yrs) Trips Travel Miles Days Hours
Belews 12,090,000 22.39 604,500 30,225,000 6,045 72,540
Marshall 27,390,000 50.72 1,369,500 68,475,000 13,695 164,340
Roxboro 34,460,000 63.81 1,723,000 86,150,000 17,230 206,760
Total: 73,940,000 137 3,697,000 184,850,000 36,970 443,640
Project Duration Details/Assumptions:
Assembly Description
Annual Haul Rate (tons):
540,000
# On -road transport Trucks:
50
# Off-road transport trucks:
4
Truck (tons/load):
20
Truck Trips/Day:
2
Active Excavators:
4
Actvive Bulldozers:
2
Days/Week
50
Weeks/Year
45
Water Truck($/day)
$100
Landfill Distance (miles):
25
Hours per work day; 12
Hours per year: 3,240
Level 2 I Phase Name I Assembly No.
Assembly Description
Qty
UOM
Materials
Labor
Equipment SubBid
Equip. Units
Extended Cost
Duke NC Belews 17030285
12 CY (20 Ton), Dump
72,540
HR
$0.00
55.72
33.41
$0.00
50
$323,274,510
17030233
Crawler -mounted, 3.125
72,540
HR
$0.00
$57.39
$79.54
$0.00
4
$39,731,609
17030706
D8 with U -Blade
72,540
HR
$0.00
$59.86
$106.51
$0.00
2
$24,136,960
17030226
988, 7.0 CY, Wheel
72,540
HR
$0.00
$59.86
$84.96
$0.00
1
$10,505,243
17030295
35 Ton, 769, Off-
72,540
HR
$0.00
$55.72
$89.09
$0.00
4
$42,018,070
18050413
Watering with 3,000-
6,045
DAY
$0.00
$38.83
$0.00
$0.00
1
$234,727
17030431
580K, 1.0 CY, Backhoe
72,540
HR
$0.00
$59.86
$20.70
$0.00
1
$5,843,822
33010505
10 KW, 120/240 VAC,
6,045
DAY
$0.00
$0.00
$0.00
$163.38
1
$987,632
33230516
8" Submersible Pump
6,045
DAY
$0.00
$0.00
$0.00
$48.60
2
$587,574
Landfill
17030704 D6 with A -blade
72,540
HR
$0.00
$59.86
$60
$0
2
$17,406,698
Direct Cost: $464,726,845
Direct+ $743,562,952
Level 2 I I Phase Name jAssemblyNo.j
Assembly Description
Qty
UOM
Materials
Labor
Equipment SubBid
Equip. Units
Extended Cost
Duke NC Marshall 17030285
12 CY (20 Ton), Dump
164,340
HR
$0.00
55.72
33.41
$0.00
50
$732,381,210
17030233
Crawler -mounted, 3.125
164,340
HR
$0.00
$57.39
$79.54
$0.00
4
$90,012,305
17030706
D8 with U -Blade
164,340
HR
$0.00
$59.86
$106.51
$0.00
2
$54,682,492
17030226
988, 7.0 CY, Wheel
164,340
HR
$0.00
$59.86
$84.96
$0.00
1
$23,799,719
17030295
35 Ton, 769, Off-
164,340
HR
$0.00
$55.72
$89.09
$0.00
4
$95,192,302
18050413
Watering with 3,000-
13,695
DAY
$0.00
$38.83
$0.00
$0.00
1
$531,777
17030431
580K, 1.0 CY, Backhoe
164,340
HR
$0.00
$59.86
$20.70
$0.00
1
$13,239,230
33010505
10 KW, 120/240 VAC,
17,230
DAY
$0.00
$0.00
$0.00
$163.38
1
$2,815,037
33230516
8" Submersible Pump
36,970
DAY
$0.00
$0.00
$0.00
$48.60
2
$3,593,484
Landfill
17030704 D6 with A -blade
164,340
HR
$0.00
$59.86
$60
$0
2
$39,435,026
Direct Cost: $1,055,682,582
Direct + $1,689,092,131
Level 2 I I Phase Name I Assembly No.
Assembly Description
Qty
UOM
Materials
Labor
Equipment SubBid I
Equip. Units
Extended Cost
Duke NC Roxboro 17030285
12 CY (20 Ton), Dump
206,760
HR
$0.00
55.72
33.41
$0.00
50
$921,425,94C
17030233
Crawler -mounted, 3.125
206,760
HR
$0.00
$57.39
$79.54
$0.00
4
$113,246,587
17030706
D8 with U -Blade
206,760
HR
$0.00
$59.86
$106.51
$0.00
2
$68,797,322
17030226
988, 7.0 CY, Wheel
206,760
HR
$0.00
$59.86
$84.96
$0.00
1
$29,942,983
17030295
35 Ton, 769, Off-
206,760
HR
$0.00
$55.72
$89.09
$0.00
4
$119,763,662
18050413
Watering with 3,000-
17,230
DAY
$0.00
$38.83
$0.00
$0.00
1
$669,041
17030431
580K, 1.0 CY, Backhoe
206,760
HR
$0.00
$59.86
$20.70
$0.00
1
$16,656,586
33010505
10 KW, 120/240 VAC,
17,230
DAY
$0.00
$0.00
$0.00
$163.38
1
$2,815,037
33230516
8" Submersible Pump
17,230
DAY
$0.00
$0.00
$0.00
$48.60
2
$1,674,756
Landfill
17030704 D6 with A -blade
206,760
HR
$0.00
$59.86
$60
$0
2
$49,614,130
Direct Cost: $1,324,606,045
Direct+ $2,119,369,672
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-17

Table A9. Landfill Cost Summary
Landfill Construction
Ash Dig & Transport
$1500
Erosion/Control
Engineering/Survey
Engineering/Survey
Acres (Landfill
Acres (Ash
Site Design/Planning
Landfill Construction Cost
Measures
Oversight
Site Total
Foot Print)
Cost/Acre
Belews $5,000,000
$61,904,549
$323,151.22
$1,689,994
$68,917,694
162
$426,535
Marshall $5,000,000
$125,939,120
$586,395.92
$3,438,138
$134,963,654
293
$460,316
Roxboro $5,000,000
$154,655,512
$700,136.52
$4,222,095
$164,577,744
350
$470,130
Total: $15,000,000
$342,499,181
$1,609,684
$9,350,228
$368,459,092
Total:
$3,000,000
Ash Dig & Transport
Assumptions
Erosion Meas. (per acre): $2,000
Eng/Survey Oversight Details
Engineer (day)
$1500
Survey crew (day)
Erosion/Control
Engineering/Survey
6
Acres (Ash
52
Site
Design/Planning
Ash Dig &Transport
Measures
Oversight
Site Total
Ponds)
Cost/Acre
Belews
$1,000,000
$743,562,952
$565,816.25
$15,717,000
$760,845,768
283
$2,689,374
Marshall
$1,000,000
$1,689,092,131
$1,158,750.37
$35,607,000
$1,726,857,881
579
$2,980,552
Roxboro
$1,000,000
$2,119,369,672
$1,012,160.00
$44,798,000
$2,166,179,832
506
$4,280,311
Total:
$3,000,000
$4,552,024,755
$2,736,727
$96,122,000
$4,653,883,481
Landfill Closure/Cap
Erosion/Control
Engineering/Survey
Site
Design/Planning
Closure
Measures
Oversight
Site Total
Acres (Barrow)
Cost/Acre
Belews
$1,500,000
$53,991,095
$128,370.10
$957,979
$56,577,444
64
$881,474
Marshall
$1,500,000
$111,776,553
$253,791.65
$1,983,282
$115,513,627
127
$910,303
Roxboro
$1,500,000
$163,542,577
$308,499.46
$2,436,242
$167,787,319
154
$1,087,764
Total:
$4,500,000
$329,310,226
$690,661
$5,377,503
$339,878,390
Assumptions
Erosion Meas. (per acre): $2,000
Eng/Survey Oversight Details
Engineer (day)
$1500
Survey crew (day)
$750
Days/Week
6
Weeks/Year
52
Hours/Day
12
Annual Hours
3744
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-18

Table A10. Cap Cost Worksheet (RACER)
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-19
Folder Assembly
L—I Data
Report (RACER)
... ............
... ............
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-19

Table A11. Off -Site Source Material - Borrow Area Size
INPUT
Site Imported Material ft3
Volume (CY)
Belews 2,466,461 66,594,450
Marshall 5,045,418 136,226,281
Roxboro 4,408,720 119,035,435
Total: 11,920,599 321,856,165
OUTPUT
GOAL SEEK CALCULATION - BORROW PIT
Height
Bottom
Top
Volume (ft3)
S1 (ft) B1 (ft2)
S2 (ft) B2 (ft2)
10
2,611 6,814,877
2,551 6,505,213
66,594,450
10
3,721 13,844,679
3,661 13,401,7771
136,226,281
10
3,480 12,111,150
3,420 11,697,137
119,035,435
Site
Borrow
Area (ft2)
Acres
Ffer Ac tal Acrea
Belews
6,814,877
156
12.0 168.4
Marshall
13,844,679
318
17.1 334.9
Roxboro
12,111,150
278
16.0 294.0
Total:
752
1 45 797
Borrow Parameters:
Height (ft) 10
Slope: 3
Buffer Width
Width (ft) 50
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-20

Table Al2. CIP Cost Summary
*Planning, survey, permits
Construction Cost Details
Subtitle D (non -hazardous) cap design and construction
Off -Site source of capping materials
40 Mil HDPE Liner
Current scenario does not account for any consolidation of ash material
Erosion/Control: Assumed cost of $2,000/acre
Dewatering/Treatment Details
System Mobilization $150,000
Operation $3,000 day
Utilization 50%
Assume discharge under NPDES permit
Eng/Survey Oversight Details
Engineer $1,500 day
Survey $750 day
Days/Week 6
Weeks/Year 52
Imported Material
540,000
# Trucks:
Erosion/Control
Engineering/Survey
20
Site Design*
Construction Cost
Dewatering/ Treatment
Measures
Oversight
Site Total
Belews $1,000,000
$123,035,426
$1,999,846
$565,816
$3,206,399
$129,807,488
Marshall $1,000,000
$251,634,904
$3,934,063
$1,158,750
$6,559,043
$264,286,761
Roxboro $1,000,000
$219,886,945
$3,456,540
$1,012,160
$5,731,336
$231,086,981
Total: $3,000,000
$594,557,275
$9,390,449
$2,736,727
$15,496,778
$625,181,229
*Planning, survey, permits
Construction Cost Details
Subtitle D (non -hazardous) cap design and construction
Off -Site source of capping materials
40 Mil HDPE Liner
Current scenario does not account for any consolidation of ash material
Erosion/Control: Assumed cost of $2,000/acre
Dewatering/Treatment Details
System Mobilization $150,000
Operation $3,000 day
Utilization 50%
Assume discharge under NPDES permit
Eng/Survey Oversight Details
Engineer $1,500 day
Survey $750 day
Days/Week 6
Weeks/Year 52
Imported Material
540,000
# Trucks:
50
Truck CY:
20
Site Volume (CY)
Import Duration (yrs)
Trips
Travel Miles
Days
Hours
Belews 2,466,461
4.6
123,323
6,166,153
1,233
14,799
Marshall 5,045,418
9.3
252,271
12,613,545
2,523
30,273
Roxboro 4,408,720
8.2
220,436
11,021,800
2,204
26,452
Total: 11,920,599
22
596,030
29,801,497
5,960
71,524
Project Duration Details
Annual Haul Rate (CY):
540,000
# Trucks:
50
Truck CY:
20
Trips/Day:
2
Days/Week
6
Weeks/Year
45
Hours/day
12
Fill Distance (miles):
25
Erosion Control & Measures
$/acre 2000
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-21

Table A13. Projected Excavation Details for Stations of Interest
Station
Basin
Approximate Volume
(Tons)
Surface Area
Perimeter
(sq ft) (Ac)
(ft)
Belews Creek
Active Ash Basin
12,090,000
12,323,478
283
36,884
Belews Creek Total 12,090,000
12,323,478 283
Marshall
Active Ash Basin
16,020,000
19,048,749
437
64,312
Marshall Basins Total 16,020,000
Retired Landfill (Permit 18-04) 4,880,000
2,553,334 59
11,248
Structural Fill 6,490,000
3,635,500 83
8,755
Marshall Fills/Landfills Tota 14 11,370,000
Marshall Total 27,390,000
25,237,583 579
Roxboro
West Ash Pond
12,540,000
8,223,139
189
26,979
East Ash Pond 6,960,000
5,842,412 134
22,456
Roxboro Basins Total 19,500,000
Unlined Monofill and Subgrade Fill( above East Pond) 7,640,000
4,917,389 113
10,124
Lined Monofill( above East Pond) 7,320,000
3,061,904 70
7,405
Roxboro Fills/Landfills Tota 14 14,960,000
Roxboro Total 34,460,000
22,044,845 506
Notes:
1. Typical Scenario assumes 500,000 tons/year excavated. This equates to approximately 50, 24ton trucks performing 2 truck turns per day while operating 12 hours per day, 6 days
per week, for 45 weeks per year.
2. Aggressive Scenario assumes 1,000,000 tons/year excavated. This equates to approximately 100, 20,ton trucks performing 2 truck turns per day while operating 12 hours per day, 6
days per week, for 45 weeks per year.
3. Distance to final deposition location assumed to be 25 miles, 1 truck turn would be 50 miles.
4. Quantity includes ash located in permitted landfills, ash fills, and structural fills located on top of the ash basin(s). While these structures are not "CCR surface impoundments" under
the Coal Ash Management Act and, therefore, not subject to the statute's closure provisions, this figure includes the quantities in these structures in the event Duke Energy is required
to excavate them along with the basins.
September 30, 2016
Appendix A -Remedial Alternatives Construction Analysis A-22

EPS
APPENDIX B
Traffic and Implementation Risk Analysis
Appendix B —Traffic and Implementation Risk Analysis B-1 September 30, 2016

0
B I OVERVIEW
The risk to the health and life of workers and the public due to construction activities for each
alternative should be considered during the selection process. Additionally, the risk of property
damage should also be evaluated. National statistics were used to evaluate the fatality,
injury/illness, and property damage risks associated with truck traffic and onsite implementation
for the Belews Creek, Marshall, and Roxboro facilities.
Appendix B — Traffic and Implementation Risk Analysis B-2 September 30, 2016

0
B2 TRUCK TRAFFIC RISK
The risks of fatality and injury due to truck traffic associated with ash Removal and CIP are
presented on Table 1 of this appendix. Data on annual fatalities and injuries associated with large -
truck traffic and large -truck miles traveled per year was taken from the National Highway Traffic
Safety Administration's (NHTSA) large truck traffic safety fact sheet for 2014 (NHTSA 2016).
This is the most recent data available and accounts for fatalities and injuries for truck occupants as
well as non -truck occupants. Averages of the calculated fatality and injury rates for the years 2010
through 2014 were also examined and found to be similar to the 2014 rates. The reference values
used for the truck traffic risk calculations are given in Table 2 of this appendix.
Total truck driving miles were calculated for the construction analysis for each facility.
Significantly more truck miles are associated with Removal than with CIP. Transporting borrow
pit and liner material was also considered in these calculations.
In addition to the risk of health and life to the workers and the public, the risk of property damage
resulting from truck traffic was also considered for both alternatives. Data for Property Damage
Only (PDO) crashes involving large trucks (Federal Motor Carrier Safety Administration 2016)1
was used to estimate the expected number of PDO incidents for both alternatives at each facility.
The results are presented in Table 1 and the reference values are included in Table 2.
1 The most recent published PDO data (2014) were used in our analyses.
Appendix B — Traffic and Implementation Risk Analysis B-3 September 30, 2016

0
B3 IMPLEMENTATION RISK
In addition to truck traffic risks, there are substantial occupational (worker) risks associated with
performing the excavation, landfill construction, and cap construction. Occupational risks
calculated for remedial alternative implementation are also presented on Table 1. Data on
occupational fatalities and nonfatal injuries and illnesses were gathered from the Bureau of Labor
Statistics (BLS) National Consensus of Fatal Occupational Injuries in 2014 (Preliminary Results)
News Release (BLS 2015a), Fatal Occupational Injuries, Total Hours Worked, and Rates of Fatal
Occupational Injuries by Selected Worker Characteristics, Occupations, and Industries, Civilian
Workers, 2014 (BLS 2015b), and Employee -Reported Workplace Injuries and Illnesses, 2014
News Release (BLS 2015c). The reference values used for the occupational risk calculations are
given in Table 3.
Data from the forestry and logging industry (NAICS code 113) were used to calculate the fatality
and injury/illness risks associated with clearing wooded land for borrow pits and the proposed
landfills (if applicable). According to the BLS, "Industries in the Forestry and Logging subsector
grow and harvest timber on a long production cycle (i.e., of 10 years or more)" and include logging
equipment operators and heavy truck and tractor -trailer drivers. Mature tree removal at this caliber
is expected to occur at each facility where land will be cleared for a borrow pit and to prepare for
landfill construction. While a landfill area will only be cleared for the removal option, a borrow
pit will be needed for both alternatives (Removal and CIP). If additional tree removal will be
needed that has not been accounted for in either the borrow or proposed landfills areas, the fatality
and injury/illness risks will increase.
Data from the construction industry (NAICS code 23) were used to calculate the fatality and
injury/illness risks associated with excavation, landfill construction, and cap construction work,
where relevant. According to the BLS, "The construction sector comprises establishments
primarily engaged in the construction of buildings or engineering projects. Establishments
primarily engaged in the preparation of sites for new construction and establishments primarily
engaged in subdividing land for sale as building sites also are included in this sector." Occupations
falling in this category include construction laborers, operating engineers, first-line supervisors,
and heavy truck and tractor -trailer drivers. The excavation of the ash basins, construction of offsite
landfills, and the construction of an in-place cap all fall under this industry and therefore
construction -based risk statistics were used for these project phases in this evaluation.
Time and manpower to clear the land and complete construction for each alternative were
estimated based on scope and are outlined in Appendix A. A ratio of two days to clear one acre of
wooded land was used to calculate the total hours worked clearing the borrow pit and proposed
landfill areas.
Appendix B — Traffic and Implementation Risk Analysis B-4 September 30, 2016

EPS
B4 SAMPLE CALCULATIONS
B4.1 Truck Traffic Risk Calculations
B4.1.1 Fatalities due to Truck Traffic
Ft,2014
Ft = x Dt
Dt,2014
B4.1.2 Injuries due to Truck Traffic
It,2014
It = x Dt
Dt,2014
B4.1.3 PDO Truck Crashes
pt,2014
Pt = X Dt
Dt,2014
B4.2 Implementation Risk Calculations
134.2.1 Fatalities due to Implementation
F. _ FL,2014 X T + FC,2014 x T
1 — L C
TL,2014 TC,2014
B4.2.2 Injuries and Illnesses due to Implementation
IIL,2014 x T+ IC,2014 x T
Ii _ - L C
TL,2014 TC,2014
B4.3 Definitions
Ft = Fatalities resulting from truck traffic, including workers and non -workers (number of persons)
Ft,2014 = Fatalities resulting from large truck traffic, including truck occupants and other people, in
the United States in 2014 (number of persons) (NHTSA 2016)
Dt,2014 = Large -truck miles traveled in the United States in 2014 (miles) (NHTSA 2016)
Dt = Total truck distance traveled (miles), calculated (see Appendix A)
It = Injuries resulting from truck traffic, including workers and non -workers (number of cases)
Appendix B — Traffic and Implementation Risk Analysis B-5 September 30, 2016

EPS
It,2014 = Injuries resulting from large truck traffic, including truck occupants and other people, in
the United States in 2014 (number of cases) (NHTSA 2016)
Pt = Property damage only (PDO) truck crashes resulting from large truck traffic (number of
incidents) (FMCSA 2016)
P t,2014 = PDO crashes involving large trucks in the United States in 2014 (number of incidents)
(FMCSA 2016)
Fi = Fatalities resulting from implementation of the selected remedy (number of persons)
FL,2014 = Occupational fatalities in the forestry and logging industry in the United States in 2014
(number of persons) (BLS 2015b)
TL,2014 = Total hours worked in the forestry and logging industry in the United States in 2014
(hours) (BLS 2015b)
TL = Total hours worked clearing wooded land (hours), calculated based on a clearing rate of 2
acres per day and a crew size of 24 persons (see Appendix A)
Fc,2014 = Occupational fatalities in the construction industry in the United States in 2014 (number
of persons) (BLS 2015b)
Tc,2014 = Total hours worked in the construction industry in the United States in 2014 (hours) (BLS
2015b)
Tc = Total hours worked completing remedy (hours), calculated (see Appendix A)
Ii = Injuries and illnesses resulting from implementation of the selected remedy (number of cases)
IL,2014 = Nonfatal occupational injuries and illnesses in the forestry and logging industry in the
United States in 2014 (number of cases) (BLS 2015c)
Ic,2014 = Nonfatal occupational injuries and illnesses in the construction industry in the United
States in 2014 (number of cases) (BLS 2015c)
Appendix B — Traffic and Implementation Risk Analysis B-6 September 30, 2016

0
B5 RESULTS
The calculations show that Removal and constructing an offsite landfill will produce significantly
more fatalities and injuries or illnesses for each site considered when compared to the CIP
alternative. With the highest risk of personal injury (workers and the general public) and personal
property damage (i.e., road accidents) over the lifespan of the project (see Table 1), the Roxboro
facility should expect approximately 34 injuries to the general public (including truck occupants)
resulting from traffic accidents and 106 worker injuries from construction activities associated
with Removal. Alternately, approximately 4-5 injuries to the general public (including truck
occupants) and 15 worker injuries from construction activities are estimated to result from CIP for
Roxboro. If all three facilities proceed with the comprehensive removal alternative, then a total of
approximately 74 injuries to the general public (including truck occupants) and 231 worker injuries
should be expected, along with 216 incidents of public property damage resulting from truck
crashes on public roads. The CIP alternative exhibits less risk with an estimated total of 12 injuries
to the public (including truck occupants) and 41 injuries to workers across all three sites. A total
of 3-4 fatalities may result from the Removal option while up to only one may result from the CIP
option (totaling all three sites). With monitored natural attenuation, the incident rates are negligible
as the risks associated with trucking and construction are removed.
A summary of estimated injury and traffic incident rates for the Belews Creek, Marshall, and
Roxboro facilities is provided in Table 1.
Appendix B — Traffic and Implementation Risk Analysis B-7 September 30, 2016

0
B6 REFERENCES
Bureau of Labor Statistics (BLS). (2015a). National Consensus of Fatal Occupational Injuries in
2014 (Preliminary Results) News Release, available September 17, 2015. U.S. Department
of Labor.
BLS. (2015b). Fatal occupational injuries, total hours worked, and rates of fatal occupational
injuries by selected worker characteristics, occupations, and industries, civilian workers,
2014. Retrieved from the Bureau of Labor Statistics website:
http://www.bls.gov/iif/oshwc/cfoi/cfoi rates_2014hb.pdf
BLS. (2015c). Employer -Reported Workplace Injuries and Illnesses - 2014 News Release,
available October 29, 2015. U.S. Department of Labor.
Federal Motor Carrier Safety Administration (FMCSA). (2016). Large Truck and Bus Crash Facts
2014. Retrieved from the Federal Motor Carrier Safety Administration website:
https://www.fmcsa.dot.gov
National Highway Traffic Safety Administration (NHTSA). (2016). Traffic Safety Facts, Large
Trucks, 2014 Data, DOT HS 812 279, Revised May 2016. U.S. Department of
Transportation. Washington, D.C.
Appendix B — Traffic and Implementation Risk Analysis B-8 September 30, 2016

Table 1. Summary of Traffic and Implementation Risks
Table 2. Truck Traffic Risk Reference Values
Large -truck miles
Number of truck
Number of "other
REMOVAL
:
Number of "other
Total number of
PDO Crashes
CIP
worked (millions) -
Fatalities per hour
Total number of
Estimated
Estimated
Estimated Injuries
Estimated Injuries
Estimated Large-
Estimated
Estimated
Estimated Injuries
Estimated Injuries
Estimated Large -
Site
Involving Large
millions 1
2014 1
2014 1
fatalities per mile
2014 1
2014 1
mile 6
Trucks - 2014 9
279,132
657
Fatalities from
Fatalities from
or Illnesses from
or Illnesses from
Truck Crashes
Fatalities from
Fatalities from
or Illnesses from
or Illnesses from
Truck Crashes
Truck Traffic 1
Implementation 2'3
Truck Traffic 1
Implementation 4'6
Resulting in PDO
Truck Traffic 1
Implementation 2,3
Truck Traffic 1
Implementation 4,5
Resulting in PDO
Belews Creek
0.42
0.15
12
40
35
0.09
0.06
2.5
8.4
7.2
Marshall
0.96
0.32
27
85
80
0.18
0.12
5.0
17
15
Roxboro
1.2
0.39
34
106
101
0.16
0.10
4.4
15
13
Total:
2.6
0.86
74
231
216
0.42
0.28
12
41
35
Table 2. Truck Traffic Risk Reference Values
Large -truck miles
Number of truck
Number of "other
Number of truck
Number of "other
Total number of
PDO Crashes
Fatalities - 2014
worked (millions) -
Fatalities per hour
Total number of
incident rate -
per hour worked -
23
(total number)
traveled - 2014
occupant fatalities
p
people" fatalities -
6
occupant injuries -
people" injuries -
injuries per truck
Involving Large
millions 1
2014 1
2014 1
fatalities per mile
2014 1
2014 1
mile 6
Trucks - 2014 9
279,132
657
1 3,246
1.40E-08
27,000
84,000
3.98E-07
326,000
Table 3. Implementation Risk Reference Values
Notes:
MNA - Monitored Natural Attenuation
PDO - Property Damage Only
Values represent total expected fatalities and injuries or illnesses over the estimated lifespan of the project, excluding post MNA activitie!
(1) - Fact Sheet, Traffic Safety Facts 2014 Data. NHTSA's National Center for Statistics and Analysis, DOT HS 812 279, Washington, DC, revised May 2016
(2) - Bureau of Labor Statistics. National Consensus of Fatal Occupational Injuries in 2014 (Preliminary Results) News Release. Table 2. Fatal occupational injuries by industry and selected event or exposure, 2014. September 17, 2015
(3) - Bureau of Labor Statistics. Fatal occupational injuries, total hours worked, and rates of fatal occupational injuries by selected worker characteristics, occupations, and industries, civilian workers, 2014
(4) - Bureau of Labor Statistics. Employer -Reported Workplace Injuries and Illnesses - 2014 News Release. Table 2. Numbers of nonfatal occupational injuries and illnesses by case type and ownership, selected industries, 2014. October 29, 2015
(5) - Bureau of Labor Statistics. Employer -Reported Workplace Injuries and Illnesses - 2014 News Release. Table 1. Incidence rates of nonfatal occupational injuries and illnesses by case type and ownership, selected industries, 2014. October 29, 2015
(6) - Calculated from data provided in reference (1)
(7) - Calculated from data provided in reference (3)
(8) - Calculated from data provided in references (4) and (5)
(9) - Federal Motor Carrier Safety Administration Analysis Division, Large Track and Bus Crash Facts 2014. March 2016.
Appendix B Traffic and Implementation Risk Analysis B-9 September 30, 2016
Total hours
Injuries/Illnesses -
Injuries/Illnesses
Injuries/illnesses
Industry
Fatalities - 2014
worked (millions) -
Fatalities per hour
2014 (total
incident rate -
per hour worked -
23
(total number)
3
7
worked - 2014
6
S
2014
number)4
2014
2014
Forestry and
logging
92
180
5.11E-07
2,800
5.1
2.55E-05
(NAICS code 113)
Construction
874
18,168
4.81E-08
200,900
3.6
1.80E-05
(NAICS code 23)
Notes:
MNA - Monitored Natural Attenuation
PDO - Property Damage Only
Values represent total expected fatalities and injuries or illnesses over the estimated lifespan of the project, excluding post MNA activitie!
(1) - Fact Sheet, Traffic Safety Facts 2014 Data. NHTSA's National Center for Statistics and Analysis, DOT HS 812 279, Washington, DC, revised May 2016
(2) - Bureau of Labor Statistics. National Consensus of Fatal Occupational Injuries in 2014 (Preliminary Results) News Release. Table 2. Fatal occupational injuries by industry and selected event or exposure, 2014. September 17, 2015
(3) - Bureau of Labor Statistics. Fatal occupational injuries, total hours worked, and rates of fatal occupational injuries by selected worker characteristics, occupations, and industries, civilian workers, 2014
(4) - Bureau of Labor Statistics. Employer -Reported Workplace Injuries and Illnesses - 2014 News Release. Table 2. Numbers of nonfatal occupational injuries and illnesses by case type and ownership, selected industries, 2014. October 29, 2015
(5) - Bureau of Labor Statistics. Employer -Reported Workplace Injuries and Illnesses - 2014 News Release. Table 1. Incidence rates of nonfatal occupational injuries and illnesses by case type and ownership, selected industries, 2014. October 29, 2015
(6) - Calculated from data provided in reference (1)
(7) - Calculated from data provided in reference (3)
(8) - Calculated from data provided in references (4) and (5)
(9) - Federal Motor Carrier Safety Administration Analysis Division, Large Track and Bus Crash Facts 2014. March 2016.
Appendix B Traffic and Implementation Risk Analysis B-9 September 30, 2016

EPS
APPENDIX C
Air Emissions and Energy Use Analysis
Appendix C —Air Emissions and Energy Use Analysis C-1 September 30, 2016

0
C I INTRODUCTION
The expected air pollutant emissions and energy consumption were estimated as part of the NEBA
framework for the remedial alternatives under consideration. Air emissions can be divided into
two separate categories, criteria pollutants and greenhouse gases (GHGs).
C1.1 Criteria Pollutants
The criteria pollutants, which were established in the Clean Air Act of 1970, consist of carbon
monoxide (CO), nitrogen oxides (NOx), ozone, sulfur oxides (SOX), particulate matter (PM), and
lead. These pollutants were determined to cause adverse health & environmental effects when
present above specific concentrations in the atmosphere. For the purposes of this evaluation, NOx
and PM were evaluated based on their expected emissions from the activities involved in the
remedial activities. Based on previous experience with air emissions from remedial activities, the
impacts from the other criteria pollutants were expected to be minimal and so were not included
in this evaluation. For example, the sulfur content in the fuels, that are typically converted to SOx,
have been reduced by regulations to the extent that they are nearly negligible. Regulations have
also significantly reduced the VOC emissions from engines to the extent that they are relatively
small by comparison with NOx emissions.
In addition to the harmful effects of direct exposure to NOx, their emissions are also precursors in
the formation of ozone (another criteria pollutant), acid rain, and fine particulate matter. Therefore,
based on the anticipated quantity of NOx emissions combined with their environmental and health
effects, the NOx emissions were estimated as part of this NEBA analysis.
Particulate matter is subdivided into two categories: coarse particulate matter (particles that have
a diameter of 10 microns or less) also known as PM 10; and fine particulate matter (particles that
have a diameter of 2.5 microns or less), also known as PM2.5. These are particles that generally
pass through the throat and nose and enter the lungs. Once inhaled, these particles can affect the
heart and lungs and cause serious health effects. Because the health effects and expected emissions
of PM 10 and PM2.5 are significant, they have also been estimated for this NEBA analysis.
C1.2 Greenhouse Gases
GHGs, which consist primarily of carbon dioxide (CO2), methane (CH4), nitrous oxide (N20),
and fluorinated gases, were also determined by USEPA to have adverse health and environmental
effects due to their contribution to climate change. Climate change is expected to result in public
health risks associated with heat waves, increased smog, extreme weather events, and mosquito -
spread diseases among others. Climate change is also expected to affect environmental factors,
such as sea level and acidity. Each of the individual GHG pollutants has a different Global
Warming Potential (GWP), a relative measure of the heat trapped by each gas compared to CO2.
Appendix C — Air Emissions and Energy Use Analysis C-2 September 30, 2016

EPS
The net effect of potential GHG emissions have been normalized to a standard called "CO2
equivalent' (CO2e) based on their relative GWPs.
Additionally, the analysis of GHG emissions includes both direct and indirect GHG emissions.
Direct GHG emissions are those that are emitted directly from the engines used in the earth moving
and material transport involved in the remedial alternatives. Indirect GHG emissions are those
associated with the production of the fuel burned in the engines. These emissions are typically
called "Well -to -Pump" (WTP), which refers to processes and activities involved in producing a
fuel through when that fuel reaches a fueling station. This may include raw material extraction,
transportation, fuel production, distribution, and storage. For the purposes of this study, only WTP
GHG emissions are considered as indirect emissions. Indirect emissions in the PTW (Pump -to -
Wheels) stage, such as refueling and evaporation, are not included as indirect emissions.
C1.3 Energy Consumption
In addition to air emissions, the energy consumed as part of the remedial activities was assessed.
Although there may be some small amounts of electricity used by the monitoring equipment, this
analysis was confined to the energy in the fuels consumed by the earth moving and material
transport equipment involved.
Appendix C — Air Emissions and Energy Use Analysis C-3 September 30, 2016

0
C2 EMISSION ESTIMATION
Air pollutant emissions resulting from the three remedial alternatives were evaluated. As
described above, the pollutants analyzed were restricted to nitrogen oxides (NOx), particulate
matter (PM 10/PM2.5), and greenhouse gases (GHG). These were selected as being the pollutants
for which the impact to the environment would be significant, based on experience gained from
analysis of similar projects. Appropriate emission factors were taken from a variety of regulator -
approved sources, such as Off -Road Model Mobile Source Emission Factors from South Coast Air
Quality Management District and Direct Emissions from Mobile Combustion Sources from
USEPA Center for Corporate Climate Leadership. The indirect GHG emissions were developed
from the fuel usages that were determined as part of the energy analysis. Each emission factor
source is referenced in notes below the emissions tables provided at the end of this Appendix
report.
C2.1 Monitoring Only
For the first remedial alternative, which consists of leaving the ash in place and periodically
monitoring the groundwater (i.e., Monitored Natural Attenuation (MNA)), it was assumed that the
air emissions would be negligible. Further, even if the minimal emissions associated with
monitoring were evaluated, these emissions would be duplicated for the other two alternatives, as
the monitoring would be required for all three alternatives. Therefore, the first alternative
represents the baseline for evaluating the emissions from the other two alternatives.
C2.2 Cap in Place (CIP)
For the second alternative, Cap -in -Place with MNA (CIP), the emissions from the necessary on-
site activities plus the emissions from the trucks transporting the cap material to the site were
evaluated. The on-site activities consist of earth moving and compacting equipment, on-site
trucks, a diesel generator, and the personal vehicles used by workers to commute to and from the
site. For the truck emissions associated with the transportation of cap material, it was assumed
that the material would be brought from a site 25 miles from the ash ponds. A liner would also be
required for this project, and it is assumed that the liner would be transported from a facility 100
miles away. This evaluation focuses primarily on the direct emissions from the engines associated
with the on-site activities and truck transport. Indirect GHG emissions were also analyzed and
added to the direct GHG emissions to provide a more complete carbon footprint. Estimates for
fugitive dust from unpaved roads and material handling are not included although it is expected
that some of the dust would be PM10 or, to a significantly lesser extent, PM2.5. The duration of
the project was determined based on the amount of material needed to cap the ash ponds.
Appendix C — Air Emissions and Energy Use Analysis C-4 September 30, 2016

0
C2.3 Removal
The third alternative, comprehensive removal (Removal), included emissions from on-site
activities at both the ash pond location and the landfill site. The emissions from truck transport
between the sites were also evaluated. It was assumed for estimating purposes that the landfill
would be located 25 miles from the ash ponds. It was also assumed that the liner would be brought
from a facility located 100 miles from the landfill, and the cap material would be taken from an
adjacent land parcel approximately 1 mile from the landfill. The on-site activities at the ash pond
includes equipment similar to what is needed for the CIP alternative. At the landfill, the analysis
includes the activities required to construct the landfill, the operation of the landfill while ash is
being received, and the closure of the landfill. The durations were determined based on the amount
of material that would be transported during each phase. The analysis includes the direct emissions
from the various activities and truck transport plus the indirect GHG emissions, but does not
include fugitive dust emissions.
Appendix C — Air Emissions and Energy Use Analysis C-5 September 30, 2016

0
C3 ENERGY ANALYSIS
Energy consumption for the three remedial alternatives was evaluated. As described previously,
the energy analysis was restricted to the energy contained in the fuels combusted in various
engines. The fuel usage was determined using the data developed as part of the emissions analysis.
Additionally, typical fuel efficiency factors were taken from the USDOT Bureau of Transportation
Statistics as noted in the appended calculations. Each emission factor source is referenced in notes
below the emissions tables provided with this Appendix.
C3.1 Monitoring Only
For the NINA alternative, which consists of leaving the ash in place and periodically monitoring
the groundwater, it was assumed that the energy consumption would be negligible.
C3.2 Cap in Place (CIP)
For the CIP alternative, the energy consumption from the on-site activities plus the energy
consumed by trucks transporting the cap material to the site were evaluated. The on-site activities
consist of earth moving and compacting equipment, on-site trucks, a diesel generator, and the
personal vehicles used by workers to commute to and from the site. The duration of the project
was determined based on the amount of material needed to cap the ash ponds.
C3.3 Removal
The Removal alternative included energy consumption from on-site activities at both the ash pond
location and the landfill site. The energy consumed by truck transport between the sites were also
evaluated. For the truck energy usage, the same assumptions were made regarding the
transportation of ash, closure material, and liner as used in the Removal estimates. The on-site
activities at the ash pond includes equipment similar to what is needed for the CIP alternative. At
the landfill, the analysis includes the activities required to construct the landfill, the operation of
the landfill while ash is being received, and the closure of the landfill. The durations were
determined based on the amount of material that would be transported during each phase.
Appendix C — Air Emissions and Energy Use Analysis C-6 September 30, 2016

0
C4 RESULTS
The emission estimates for each alternative are shown in the attached table, along with any
assumptions and the sources of the emission factors. The results are also presented in the following
table. The PM10 and PM2.5 are combined as a single entry because the emission factor data does
not distinguish between them. It can be assumed that the majority of the PM emissions are actually
PM2.5, as they are they are the products of diesel fuel combustion, which primarily consists of
very fine particulates. The GHG emissions are shown on an annual emissions basis (ton/yr) and
cumulatively over the duration of the project, as their effects are cumulative unlike the criteria
pollutants for which the impact is much shorter in duration.
C4.1 Estimated Emissions
The air emissions from each of the sites and for both the CIP and Removal alternatives are
summarized in the table below:
As shown in the table, the NO. emissions from the CIP alternative are about 29 tons/yr for each
site, which is below the significance level of 40 tons/yr established in the federal Prevention of
Significant Deterioration (PSD) regulations. The emissions from the Removal alternative are
much more significant and are typically about 143 tons/yr for each site, well above the PSD
Threshold. Under the PSD rules, a project with emissions at this level would require an extensive
Appendix C — Air Emissions and Energy Use Analysis C-7 September 30, 2016
PM10/PM2.5
Cumulative CO2e
NO. Emissions
CO2e Emissions
Alternative
Emissions
Emissions
(tons/yr)
(tons/yr)
(tons/yr)
(tons)
3
Cap in Place
29.10
1.01
7,347
33,795
Removal
142.99
6.12
30,935
296,678
Cap in Place
29.26
1.01
7,396
68,784
Removal
143.01
6.12
30,942
656,544
o
Cap in Place
29.14
1.01
7,358
60,336
0
k
0
P4
Removal
143.00
6.12
30,939
795,005
,o
PSD Significant
40
15/10
NA
NA
Threshold
GHG Reporting
H
Threshold
NA
NA
25,000
NA
As shown in the table, the NO. emissions from the CIP alternative are about 29 tons/yr for each
site, which is below the significance level of 40 tons/yr established in the federal Prevention of
Significant Deterioration (PSD) regulations. The emissions from the Removal alternative are
much more significant and are typically about 143 tons/yr for each site, well above the PSD
Threshold. Under the PSD rules, a project with emissions at this level would require an extensive
Appendix C — Air Emissions and Energy Use Analysis C-7 September 30, 2016

0
permitting process, including air dispersion modeling to demonstrate that the emissions would not
cause an exceedance of the National Ambient Air Quality Standards.
The PMIO/PM2.5 emissions for the CIP alternative are less than the NOX emissions, but the PSD
significance thresholds are also much lower for this pollutant. As shown, the PMIO/PM2.5
emissions for each site from the CIP alternative are estimated to be about 1 ton/yr and from the
Removal alternative are about 6 ton/yr. It is important to remember that these values only include
particulate matter from fuel combustion. If the fugitive dust emissions from material handling and
unpaved roads were added, recognizing that some of this particulate matter would be larger than
10 microns, the total PMIO/PM2.5 emissions would be much higher.
Finally, the estimated GHG emissions from the Removal alternative is also fairly significant.
Although there are few regulations limiting GHG emissions at this time, USEPA has begun
requiring sources that emit 25,000 tons or more of CO2e annually to report those emissions to
USEPA. This effort is being pursued by USEPA in order to develop a database of major emitters
and in anticipation of future regulations. The annual GHG emissions for the CIP alternative (7,400
ton/yr for each site) are below this threshold, but the annual GHG emissions for the Removal
alternative (31,000 ton/yr for each site) exceed this threshold.
Based on the estimated air emissions and their comparisons with regulatory thresholds, it is
apparent that the air quality impact from the CIP alternative would be considerably higher than
NINA. The air emissions from Removal and transporting it to a landfill would be even more
substantial.
C4.2 Estimated Energy Consumption
The energy consumption annually and cumulatively across the duration of the projects for both the
CIP and Removal alternatives are summarized in the tables below:
Annual Energy Consumed
Alternative
Energy Consumed (MMBtu/yr)
Belews Creek
Marshall
Roxboro
Total
CIP
81,812
82,190
81,899
245,901
Removal
441,500
441,557
441,536
1,324,594
Appendix C — Air Emissions and Energy Use Analysis C-8 September 30, 2016

0
Cumulative Energy Consumed
Alternative
Total Energy Consumed (MMBtu)
Belews Creek
Marshall
Roxboro
Total
CIP
388,509
79208
709,604
1,890,801
Removal
3,588,214
7,965,004
9,977,837
21,531,054
Energy Consumption Comparison
Alternative
Equivalent Personal Vehicles (vehicles*)
Belews Creek
Marshall
Roxboro
Total**
CIP
1,800
1,800
1,800
5,400
Removal
9,700
9,700
9,700
29,000
*Personal vehicles commuting five days a week for the duration of the project
**Note that the projects have varying durations, and the Total only applies when all projects are occurring simultaneously
As shown, the CIP alternative would consume approximately 82,000 MMBtu/yr for each
individual site and about 246,000 MMBtu/yr collectively. For comparison, a personal vehicle
travelling 10 miles to work and back five days a week would consume about 45.6 MMBtu/yr in
gasoline. Therefore, the energy consumption for the CIP alternative for all three sites is equivalent
to about 5,400 personal vehicles commuting five days a week. The Removal alternative would
consume even more. As shown in the table above, Removal at each site would consume about
442,000 MMBtu/yr, which corresponds to about 1,325,000 MMBtu/yr, collectively. This is
equivalent to about 29,000 vehicles commuting 5 days a week.
Additionally, the table above also presents the energy consumed for the entire duration of each
project. As shown, the Removal alternative would consume about 21.5 million MMBtu's
cumulatively; whereas the CIP alternative would consume only about 1.9 million MMBtu's.
Appendix C — Air Emissions and Energy Use Analysis C-9 September 30, 2016

Table 1. Air Emissions and Energy Usage Summary
Appendix C - Air Emissions and Energy Use Analysis C-10 M6
REMOVAL
CIP
Site
NOx
PM10/PM2.5
Total GHG
Cumulative Total
Cumulative Energy
NOx
PMlo/PM2,5
Total GHG
Cumulative Total
Cumulative Energy
Emissions
Emissions
Emissions
GHG Emissions
Energy Usage
Usage
Emissions
Emissions
Emissions
GHG Emissions
Energy Usage
Usage
(tons/yr)
(tons/yr)
(tons CO2e/yr)
(tons CO2e)
(MMBtu/yr)
(MMBtu)
(tons/yr)
(tons/yr)
(tons CO2e/yr)
(tons CO2e)
(MMBtu/yr)
(MMBtu)
Belews
142.99
6.12
30,935
296,678
441,500
3,588,214
29.10
1.01
7,347
33,795
81,812
388,509
Marshall
143.01
6.12
30,942
656,544
441,557
7,965,004
29.26
1.01
7,396
68,784
82,190
792,688
Roxboro
143.00
6.12
30,939
795,005
441,536
9,977,837
29.14
1.01
7,358
60,336
81,899
709,604
Total
429.01
18.37
92,816
1,748,228
1,324,594
21,531,054
87.51
3.04
22,101
162,915
245,901
1,890,801
Thresholds
PSD
Significant
40
15/10
NA
NA
NA
NA
40
15/10
NA
NA
NA
NA
Threshold
GHG
Reporting
NA
NA
25,000
NA
NA
NA
NA
NA
25,000
NA
NA
NA
Threshold
Appendix C - Air Emissions and Energy Use Analysis C-10 M6

Table 2. Belews Creek Air Emissions Calculations
MNA Monitor Only
Since similar monitoring would be required for each option for the project duration, similar emissions are expected for each and the emissions are not included in this estimate. It is expected that the emissions contributions from
personal vehicles due to monitoring would be insignificant compared to the other emission sources.
CIP Cap in Place (CIP)
CIP Duration = 12 hr/day 270 day/yr 4.6 years 123323 truck trips carrying cap material
179 truck trips carrying liner material
Appendix C - Air Emissions and Energy Use Analysis C-11 (216
Usage
NOx
Emission Factors
PM10/PM2 5 Direct CO2
Direct CH4
Emissions
(tons/yr)
Cumulative Emissions
(tons CO2e)
Activity
Value Units
Value Units
Value Units
Value Units
Value Units
NOx
PM,dPMZ.s Direct GHG (CO2e)
Direct GHG
2 Dozers'
6480 hr/yr
2.0891 lb/hr
0.0858 lb/hr
239 Ib/hr
0.0234 lb/hr
6.77
0.28
776.26
3570.77
Tractor'
3240 hr/yr
0.4070 Ib/hr
0.0258 Ib/hr
66.8 Ib/hr
0.0055 Ib/hr
0.66
0.04
108.44
498.82
Wheeled Backhoe'
3240 hr/yr
0.4070 lb/hr
0.0258 lb/hr
66.8 lb/hr
0.0055 Ib/hr
0.66
0.04
108.44
498.82
Water Truck'
3240 hr/yr
1.3322 lb/hr
0.0459 lb/hr
260 Ib/hr
0.0164 lb/hr
2.16
0.07
421.86
1940.58
Vibratory Roller'
3240 hr/yr
0.5273 Ib/hr
0.0353 Ib/hr
67 Ib/hr
0.0071 Ib/hr
0.85
0.06
108.83
500.61
Tracked Excavator'
3240 hr/yr
0.6603 lb/hr
0.0332 lb/hr
120 Ib/hr
0.0089 Ib/hr
1.07
0.05
194.76
895.90
Maint/Service Truck'
3240 hr/yr
1.3322 Ib/hr
0.0459 Ib/hr
260 Ib/hr
0.0164 Ib/hr
2.16
0.07
421.86
1940.58
55 KVA Diesel Generator'
3240 hr/yr
0.6102 Ib/hr
0.0431 Ib/hr
77.9 Ib/hr
0.0073 Ib/hr
0.99
0.07
126.49
581.87
15 Personal Vehicles2,3,4,5,6
121500 miles/yr
0.95 g/mile
0.0045 g/mile
410 g/mile
0.0452 g/mile
0.13
0.00
55.10
253.46
Truck Transport - Cap Matedal''$'9'10
26809 truck trips/yr
459.55g/truck trip
10.75 g/truck trip
138000 g/truck trip
0.255 g/truck trip
13.58
0.32
4078.40
18760.65
Truck Transport - Liner Materia 17,8,9,10,11
39 truck trips/yr I
1838.20 g/truck trip
43.00 g/truck trip
552000 g/truck trip
1.02 g/truck trip
0.08
0.00
23.68
108.92
29.10
1.01
6,424.12
29,550.97
Appendix C - Air Emissions and Energy Use Analysis C-11 (216

Table 2. Belews Creek Air Emissions Calculations
Removal Excavation and Landfill
Landfill Construction Duration = 12 hr/day 300 day/yr 2.4 years 137 truck trips carrying liner material (construction & closure)
Excavation Duration = 12 hr/day 270 day/yr 22.4 years 604500 truck trips carrying ash
Closure Duration = 12 hr/day 270 day/yr 1.4 years 22107 truck trips carrying closure material
Appendix C - Air Emissions and Energy Use Analysis C-12 (1216
Usage
NOx
Emission Factors
PM10/PM2.5 Direct CO2
Direct CH,
Emissions
(tons/yr)
Cumulative Emissions
(tons CO2e)
Activity
Value Units
Value Units
Value Units
Value Units
Value Units
NOx
PmjO/PMZ.S Direct GHG (CO2e)
Direct GHG
EXCAVATION
2 Tracked Excavators'
6480 hr/yr
0.6603 lb/hr
0.0332 lb/hr
120lb/hr
0.0089 Ib/hr
2.14
0.11
389.52
8725.27
2 Dozers'
6480 hr/yr
2.0891 lb/hr
0.0858 lb/hr
239lb/hr
0.0234 lb/hr
6.77
0.28
776.26
17388.12
Wheeled Loader'
3240 hr/yr
0.7114 lb/hr
0.0375 lb/hr
109lb/hr
0.0089 Ib/hr
1.15
0.06
176.94
3963.47
2 Dump Trucks'
6480 hr/yr
0.0587 Ib/hr
0.0024 Ib/hr
7.6 Ib/hr
0.0008 Ib/hr
0.19
0.01
24.69
553.03
Water Truck'
3240 hr/yr
1.3322 lb/hr
0.0459 lb/hr
260lb/hr
0.0164 lb/hr
2.16
0.07
421.86
9449.76
Wheeled Backhoe'
3240 hr/yr
0.4070 lb/hr
0.0258 lb/hr
66.8 Ib/hr
0.0055 Ib/hr
0.66
0.04
108.44
2429.03
2 6-8" Pumps'
6480 hr/yr
0.3830 lb/hr
0.0239 lb/hr
49.6 lb/hr
0.0051 lb/hr
1.24
0.08
161.12
3609.02
55 KVA Diesel Generator'
3240 hr/yr
0.6102 lb/hr
0.0431 lb/hr
77.9 Ib/hr
0.0073 Ib/hr
0.99
0.07
126.49
2833.46
15 Personal Vehicles2'3,4,5
121500 miles/yr
0.95 g/mile
0.0045 g/mile
410 g/mile
0.0452 g/mile
0.13
0.00
55.10
1234.25
MATERIAL TRANSPORT
Truck Transport - Ash 7,8,9,10
26987 truck trips/yr
459.55 g/truck trip
10.75 g/truck trip
138000 g/truck trip
0.2550 g/truck trip
13.67
0.32
4105.37
91960.23
Truck Transport - Closure Materia 17,8,9,10
15791 truck trips/yr
18.38 g/truck trip
0.43 g/truck trip
5520 g/truck trip
0.0102 g/truck trip
0.32
0.01
96.09
134.52
Truck Transport - Liner Materia 17,8,9,10,11
36 truck trips/yr
1838.20 g/truck trip
43 g/truck trip
552000 g/truck trip
1.0200 g/truck trip
0.07
0.00
21.94
83.37
LANDFILL CONSTRUCTION
8 Tracked Excavators'
28800 hr/yr
0.6603lb/hr
0.0332lb/hr
120 Ib/hr
0.0089 Ib/hr
9.51
0.48
1731.20
6578.58
8 Dozers'
28800 hr/yr
2.0891 Ib/hr
0.0858 Ib/hr
239 Ib/hr
0.0234 Ib/hr
30.08
1.24
3450.02
13110.09
4 Vibratory Compactors'
14400 hr/yr
0.568 Ib/hr
0.0234 lb/hr
123 Ib/hr
0.0065 Ib/hr
4.09
0.17
886.77
3369.73
4 Wheeled Loaders'
14400 hr/yr
0.7114 Ib/hr
0.0375 Ib/hr
109 Ib/hr
0.0089 Ib/hr
5.12
0.27
786.40
2988.33
8 Dump Trucks'
28800 hr/yr
0.0587 Ib/hr
0.0024 Ib/hr
7.6 Ib/hr
0.0008 Ib/hr
0.85
0.03
109.73
416.97
4 Water Trucks'
14400 hr/yr
1.3322 lb/hr
0.0459 lb/hr
260 Ib/hr
0.0164 lb/hr
9.59
0.33
1874.95
7124.82
4 Wheeled Backhoes'
14400 hr/yr
0.4070lb/hr
0.0258 lb/hr
66.8 lb/hr
0.0055 Ib/hr
2.93
0.19
481.95
1831.41
8 6-8" Pumps'
28800 hr/yr
0.3830 lb/hr
0.0239 lb/hr
49.6 Ib/hr
0.0051 lb/hr
5.52
0.34
716.08
2721.09
4 Maint/Service Trucks'
14400 hr/yr
1.3322 Ib/hr
0.0459 Ib/hr
260 Ib/hr
0.0164 Ib/hr
9.59
0.33
1874.95
7124.82
4 55 KVA Diesel Generator'
14400 hr/yr
0.6102 lb/hr
0.0431 lb/hr
77.9 lb/hr
0.0073 Ib/hr
4.39
0.31
562.19
2136.34
100 Personal Vehicles2,3'4'5
900000 miles/yr
0.95 g/mile
0.0045 g/mile
410 g/mile
0.0452 g/mile
0.94
0.00
408
1550.98
LANDFILL FILLING
2 Dozers'
6480 hr/yr
2.0891 lb/hr
0.0858 lb/hr
239 Ib/hr
0.0234 lb/hr
6.77
0.28
776.26
17388.12
Tractor'
3240 hr/yr
0.4070 lb/hr
0.0258lb/hr
66.8lb/hr
0.0055 Ib/hr
0.66
0.04
108.44
2429.03
Wheeled Backhoe'
3240 hr/yr
0.4070 lb/hr
0.0258lb/hr
66.8 Ib/hr
0.0055 Ib/hr
0.66
0.04
108.44
2429.03
Water Truck'
3240 hr/yr
1.3322 lb/hr
0.0459 lb/hr
260lb/hr
0.0164 lb/hr
2.161
0.071
421.86
9449.76
Vibratory Roller' 1
3240 hr/yr
0.5273 lb/hr
0.0353lb/hr
67lb/hr
0.00711b/hr 1
0.851
0.061
3.08.831
2437.74
Appendix C - Air Emissions and Energy Use Analysis C-12 (1216

Table 2. Belews Creek Air Emissions Calculations
Notes:
1. South Coast Air Quality Management District Off -Road Model Mobile Source Emission Factors for a 2016 fleet average from http://www.agmd.gov/home/regulations/ceqa/air-quality-analysis-handbook/off-road-mobile-source-
emission-factors.
2. USEPA Center for Corporate Climate Leadership Greenhouse Gas Inventory Guidance: Direct Emissions from Mobile Combustion Sources Tier 1 Gasoline Light -Duty Truck emission factors (0.0452 g CH4/mile) from
https://www.epa.gov/sites/production/fi les/2016-03/documents/mobi leem issions_3_2016. pdf.
3. Personally Operated Vehicle use is estimated as:
-Excavation: 15 persons/day * 30 miles/person * 270 day/yr (it is assumed each person travels 15 -miles one-way to work);
-Landfill Construction: 25 persons/day * 30 miles/person * 270 day/yr.
4. USDOT Bureau of Transportation Statistics Average Fuel Efficiency of U.S. Light Duty Vehicles for calendar year 2014 (21.4 miles/gal) for POV CO2 emissions from
http://www. rita. dot.gov/bts/sites/rita.dot.gov. bts/fi les/publications/nationa I_transportation_statistics/html/ta ble_04_23. htm I.
5. 100 -yr GWP for CH4 (25 kg CO2e/kg CH4) from Intergovernmental Panel on Climate Change (IPCC), Fourth Assessment Report (AR4), 2007.
6. USEPA Office of Transportation and Air Quality Average Annual Emissions and Fuel Consumption for Gasoline -Fueled Passenger Cars and Light Trucks light-duty trucks emissions estimates for the in -use fleet as of 2008 based on
https://www3.epa.gov/otaq/consumer/42ofO8o24.pdf.
7. It is assumed that the landfill location is 25 miles away, so 1 truck trip carrying ash is 50 miles, and 20 -ton trucks are used. It is assumed that the landfill cap/closure material for Option 3 is taken from an adjacent land parcel, thus 1
truck trip carrying cap/closure material is taken to be 2 miles. It is assumed that the landfill cap/closure material for Option 2 is taken from a site 25 miles aways, so 1 truck trip carrying cap/closure material for Option 2 is taken to be
50 miles.
8. USEPA Office of Transportation and Air Quality Average In -Use Emissions from Heavy -Duty Trucks NOx and PM10/PM2.5 emission factors approximated as a diesel Heavy -Duty Vehicle Class Villa (33,001-60,000 Ib GVWR--since it is
for 20 ton (40,000 Ib) material + truck) --based on the in -use fleet from July 2008 from https://www3.epa.gov/otaq/consumer/42OfO8O27.pdf.
9. USEPA Center for Corporate Climate Leadership Emission Factors for Greenhouse Gas Inventories greenhouse gas emission factors approximated as heavy duty vehicles for 1960 -present from Table 4 of
https://www.epa.gov/sites/production/files/2015-12/documents/emission-factors_nov_2015.pdf, dated November 2015.
10. It is assumed that the weight of the vehicle + load is approximately 60,000 Ib (20 -ton load and 10 -ton truck). Diesel heavy duty combination truck CO2 emission factor for MY2014/Class 8/Day Cab is 92 g CO2/ton-mile taken from
https://www.gpo.gov/fdsys/pkg/FR-2011-09-15/pdf/2011-20740.pdf (EPA/DOT Federal Register Vol. 76, No. 179, 15 September 2011).
-92 g CO2/ton-mile * (30 ton*x mile)/truck trip = y g CO2/truck trip
11. It is assumed that the liner is transported 100 miles to the site/landfill on public roads and approximately 10 tons of liner are transported per trip (3240 Ib/roll * 1 ton/2000 Ib * 6 rolls/truck trip = 10 ton/truck trip).
Appendix C - Air Emissions and Energy Use Analysis C-13 September 30, 2016
Usage
NOx
Emission Factors
PM10/PM2,5 Direct CO2
Direct CH4
Emissions
(tons/yr)
Cumulative Emissions
(tons CO2e)
Activity
Value Units
Value Units
Value Units
Value Units
Value Units
NOx
PM10/PM2.5 Direct GHG (CO2e)
Direct GHG
Tracked Excavator'
3240 hr/yr
0.6603 Ib/hr
0.0332 Ib/hr
120 Ib/hr
0.0089 Ib/hr
1.07
0.05
194.76
4362.63
Maint/Service Truck'
3240 hr/yr
1.3322 Ib/hr
0.0459 Ib/hr
260 Ib/hr
0.0164 Ib/hr
2.16
0.07
421.86
9449.76
55 KVA Diesel Generator'
3240 hr/yr
0.6102 lb/hr
0.0431 lb/hr
77.9 lb/hr
0.0073 Ib/hr
0.99
0.07
126.49
2833.46
15 Personal Vehicles2'3,4,5,6
121500 miles/yr
0.95 g/mile
0.0045 g/mile
410 g/mile
0.0452 g/mile
0.13
0.00
55.10
1234.25
LANDFILL CLOSURE
2 Dozers'
6480 hr/yr
2.0891 lb/hr
0.0858 lb/hr
239 Ib/hr
0.0234 lb/hr
6.77
0.28
776.26
1086.76
Tractor'
3240 hr/yr
0.4070 Ib/hr
0.0258 Ib/hr
66.8 Ib/hr
0.0055 Ib/hr
0.66
0.04
108.44
151.81
Wheeled Backhoe'
3240 hr/yr
0.4070 lb/hr
0.0258 lb/hr
66.8 Ib/hr
0.0055 Ib/hr
0.66
0.04
108.44
151.81
Water Truck'
3240 hr/yr
1.3322 Ib/hr
0.0459 Ib/hr
260lb/hr
0.0164 Ib/hr
2.16
0.07
421.86
590.61
Vibratory Roller'
3240 hr/yr
0.5273 Ib/hr
0.0353 Ib/hr
67 Ib/hr
0.0071 Ib/hr
0.85
0.061
108.83
152.36
Tracked Excavator'
3240 hr/yr
0.6603lb/hr
0.0332lb/hr
120lb/hr
0.0089 Ib/hr
1.07
0.05
194.76
272.66
Maint/Service Truck'
3240 hr/yr
1.3322 Ib/hr
0.0459 Ib/hr
260 Ib/hr
0.0164 Ib/hr
2.16
0.07
421.86
590.61
55 KVA Diesel Generator'
3240 hr/yr
0.6102 lb/hr
0.0431 lb/hr
77.9 lb/hr
0.0073 Ib/hr
0.99
0.07
126.49
177.09
15 Personal Vehicles2'3,4,5,6
121500 miles/yr
0.95 g/mile
0.0045 g/mile
410 g/mile
0.0452 g/mile
0.13
0.00
55.10
77.14
142.99
6.12
23,990.30
246,581.30
Notes:
1. South Coast Air Quality Management District Off -Road Model Mobile Source Emission Factors for a 2016 fleet average from http://www.agmd.gov/home/regulations/ceqa/air-quality-analysis-handbook/off-road-mobile-source-
emission-factors.
2. USEPA Center for Corporate Climate Leadership Greenhouse Gas Inventory Guidance: Direct Emissions from Mobile Combustion Sources Tier 1 Gasoline Light -Duty Truck emission factors (0.0452 g CH4/mile) from
https://www.epa.gov/sites/production/fi les/2016-03/documents/mobi leem issions_3_2016. pdf.
3. Personally Operated Vehicle use is estimated as:
-Excavation: 15 persons/day * 30 miles/person * 270 day/yr (it is assumed each person travels 15 -miles one-way to work);
-Landfill Construction: 25 persons/day * 30 miles/person * 270 day/yr.
4. USDOT Bureau of Transportation Statistics Average Fuel Efficiency of U.S. Light Duty Vehicles for calendar year 2014 (21.4 miles/gal) for POV CO2 emissions from
http://www. rita. dot.gov/bts/sites/rita.dot.gov. bts/fi les/publications/nationa I_transportation_statistics/html/ta ble_04_23. htm I.
5. 100 -yr GWP for CH4 (25 kg CO2e/kg CH4) from Intergovernmental Panel on Climate Change (IPCC), Fourth Assessment Report (AR4), 2007.
6. USEPA Office of Transportation and Air Quality Average Annual Emissions and Fuel Consumption for Gasoline -Fueled Passenger Cars and Light Trucks light-duty trucks emissions estimates for the in -use fleet as of 2008 based on
https://www3.epa.gov/otaq/consumer/42ofO8o24.pdf.
7. It is assumed that the landfill location is 25 miles away, so 1 truck trip carrying ash is 50 miles, and 20 -ton trucks are used. It is assumed that the landfill cap/closure material for Option 3 is taken from an adjacent land parcel, thus 1
truck trip carrying cap/closure material is taken to be 2 miles. It is assumed that the landfill cap/closure material for Option 2 is taken from a site 25 miles aways, so 1 truck trip carrying cap/closure material for Option 2 is taken to be
50 miles.
8. USEPA Office of Transportation and Air Quality Average In -Use Emissions from Heavy -Duty Trucks NOx and PM10/PM2.5 emission factors approximated as a diesel Heavy -Duty Vehicle Class Villa (33,001-60,000 Ib GVWR--since it is
for 20 ton (40,000 Ib) material + truck) --based on the in -use fleet from July 2008 from https://www3.epa.gov/otaq/consumer/42OfO8O27.pdf.
9. USEPA Center for Corporate Climate Leadership Emission Factors for Greenhouse Gas Inventories greenhouse gas emission factors approximated as heavy duty vehicles for 1960 -present from Table 4 of
https://www.epa.gov/sites/production/files/2015-12/documents/emission-factors_nov_2015.pdf, dated November 2015.
10. It is assumed that the weight of the vehicle + load is approximately 60,000 Ib (20 -ton load and 10 -ton truck). Diesel heavy duty combination truck CO2 emission factor for MY2014/Class 8/Day Cab is 92 g CO2/ton-mile taken from
https://www.gpo.gov/fdsys/pkg/FR-2011-09-15/pdf/2011-20740.pdf (EPA/DOT Federal Register Vol. 76, No. 179, 15 September 2011).
-92 g CO2/ton-mile * (30 ton*x mile)/truck trip = y g CO2/truck trip
11. It is assumed that the liner is transported 100 miles to the site/landfill on public roads and approximately 10 tons of liner are transported per trip (3240 Ib/roll * 1 ton/2000 Ib * 6 rolls/truck trip = 10 ton/truck trip).
Appendix C - Air Emissions and Energy Use Analysis C-13 September 30, 2016

Table 3. Belews Creek Indirect Greenhouse Gas Emissions
MNA Monitor Only
Since similar monitoring would be required for each option for the project duration, similar emissions are expected for each and the emissions are not included in this estimate. It
is expected that the emissions contributions from personal vehicles due to monitoring would be insignificant compared to the other emission sources.
CIP Cap in Place (CIP)
CIP Duration = 12 hr/day 270 day/yr 4.6 years 123323 truck trips carrying cap material
179 truck trips carrying liner material
Activity
Number
of Units
Usage
Value Units
Annual Total
Energy Usage
Value Units
Total Project
GGE
Value Units
WTP (Indirect)
GHG Emissions5
Value Units
Project Indirect
GHG Emissions
Value Units
Dozers°
2
6480 hr/yr
18319.9 MMBtu/yr
152062.6 GGE/yr
308 tons CO2e/yr
1417 tons CO2e
Tractor
1
3240 hr/yr
2748.0 MMBtu/yr
22809.4 GGE/yr
46 tons CO2e/yr
213 tons CO2e
Wheeled Backhoe4
1
3240 hr/yr
2748.0 MMBtu/yr
22809.4 GGE/yr
46 tons CO2e/yr
213 tons CO2e
Water Truck
1
3240 hr/yr
9159.9 MMBtu/yr
76031.3 GGE/yr
154 tons CO2e/yr
708 tons CO2e
Vibratory Roller
1
3240 hr/yr
2198.4 MMBtu/yr
18247.5 GGE/yr
37 tons CO2e/yr
170 tons CO2e
Tracked Excavator.4
1
3240 hr/yr
3664.0 MMBtu/yr
30412.5 GGE/yr
62 tons CO2e/yr
283 tons CO2e
Maint/Service Truck
1
3240 hr/yr
9159.9 MMBtu/yr
76031.3 GGE/yr
154 tons CO2e/yr
708 tons CO2e
55 KVA Diesel Generator
1
3240 hr/yr
1080.9 MMBtu/yr
8971.7 GGE/yr
18 tons CO2e/yr
84 tons CO2e
Personal Vehicles'
15
121500 miles/yr
10 tons CO2e/yr
47 tons CO2e
Truck Transport - Cap Materia 12
N/A
26809 truck trips/yr
1340468 miles/yr
87 tons CO2e/yr
399 tons CO2e
Truck Transport - Liner Materia 12,3
N/A
39 truck trips/yr
7765 miles/yr
0.5 tons CO2e/yr
2 tons CO2e
923 tons CO2e/yr
4,244 tons CO2e
Appendix C - Air Emissions and Energy Use Analysis C-14 September 30, 2016

Table 3. Belews Creek Indirect Greenhouse Gas Emissions
Removal Excavation and Landfill
Landfill Construction Duration = 12 hr/day 300 day/yr 2.4 years 137 truck trips
Excavation Duration = 12 hr/day 270 day/yr 22.4 years 604500 truck trips
Closure Duration = 12 hr/day 270 day/yr 1.4 years 22107 truck trips
carrying liner material
carrying ash
carrying closure material
Activity
Number
of Units
Total Usage
Value Units
Annual Total
Energy Usage
Value Units
Total Project
GGE
Value Units
WTP (Indirect)
GHG Emissionss
Value Units
Project Indirect
GHG Emissions
Value Units
EXCAVATION
Tracked Excavators4
2
6480 hr/yr
7328.0 MMBtu/yr
60825.0 GGE/yr
123 tons CO2e/yr
2759 tons CO2e
Dozers4
2
6480 hr/yr
18319.9 MMBtu/yr
152062.6 GGE/yr
308 tons CO2e/yr
6899 tons CO2e
Wheeled Loader
1
3240 hr/yr
3206.0 MMBtu/yr
26611.0 GGE/yr
54 tons CO2e/yr
1207 tons CO2e
Dump Trucks4
2
6480 hr/yr
916.0 MMBtu/yr
7603.1 GGE/yr
15 tons CO2e/yr
345 tons CO2e
Water Truck
1
3240 hr/yr
9159.9 MMBtu/yr
76031.3 GGE/yr
154 tons CO2e/yr
3449 tons CO2e
Wheeled Backhoe4
1
3240 hr/yr
2748.0 MMBtu/yr
22809.4 GGE/yr
46 tons CO2e/yr
1035 tons CO2e
6-8" Pumps4
2
6480 hr/yr
3664.0 MMBtu/yr
30412.5 GGE/yr
62 tons CO2e/yr
1380 tons CO2e
55 KVA Diesel Generator
1
3240 hr/yr
1080.9 MMBtu/yr
8971.7 GGE/yr
18 tons CO2e/yr
407 tons CO2e
Personal Vehiclesl
15
121500 miles/yr
10 tons CO2e/yr
230 tons CO2e
MATERIAL TRANSPORT
Truck Transport - Ash
N/A
26987 truck trips/yr
1349330 miles/yr
87 tons CO2e/yr
1956 tons CO2e
Truck Transport - Closure Materia 12
N/A
15791 truck trips/yr
31581 miles/yr
2 tons CO2e/yr
3 tons CO2e
Truck Transport - Liner Materia 12,3
N/A
36 truck trips/yr
7199 miles/yr
0.5 tons CO2e/yr
2 tons CO2e
LANDFILL CONSTRUCTION
Tracked Excavators4
8
28800 hr/yr
32568.7 MMBtu/yr
270333.5 GGE/yr
548tons CO2e/yr
1314 tons CO2e
Dozers4
8
28800 hr/yr
81421.8 MMBtu/yr 1
675833.9 GGE/yr
1369 tons CO2e/yr
3285 tons CO2e
Appendix C - Air Emissions and Energy Use Analysis C-15 M6

Vibratory Compactors4
Wheeled Loaders°
Dump Trucks4
Water Trucks4
Wheeled Backhoes4
6-8" Pumps4
Maint/Service Trucks4
55 KVA Diesel Generators
Personal Vehicles'
LANDFILL FILLING
Dozers4
Tractor
Wheeled Backhoe4
Water Truck
Vibratory Roller
Tracked Excavator
Maint/Service Truck
55 KVA Diesel Generator'
Personal Vehicles'
LANDFILL CLOSURE
Dozers4
Wheeled Backhoe"
Water Truck
Vibratory Roller
Tracked Excavator
Maint/Service Truck
Table 3. Belews Creek Indirect Greenhouse Gas Emissions
Number
of Units
Total Usage
Value Units
4
14400 hr/yr
4
14400 hr/yr
8
28800 hr/yr
4
14400 hr/yr
4
14400 hr/yr
8
28800 hr/yr
4
14400 hr/yr
4
14400 hr/yr
100
900000 miles/yr
2
6480 hr/yr
1
3240 hr/yr
1
3240 hr/yr
1
3240 hr/yr
1
3240 hr/yr
1
3240 hr/yr
1
3240 hr/yr
1
3240 hr/yr
15
121500 miles
Annual Total
Energy Usage
Value F Units
9770.6 MMBtu/yr
14248.8 MMBtu/yr
4071.1 MMBtu/yr
40710.9 MMBtu/yr
12213.3 MMBtu/yr
16284.4 MMBtu/yr
40710.9 MMBtu/yr
4803.9 MMBtu/vr
18319.9 MMBtu/yr
2748.0 MMBtu/yr
2748.0 MMBtu/yr
9159.9 MMBtu/yr
2198.4 MMBtu/yr
3664.0 MMBtu/yr
9159.9 MMBtu/yr
1080.9 MMBtu/yr
Total Project
GGE
Value Units
81100.1 GGE/yr
118270.9 GGE/yr
33791.7 GGE/yr
337916.9 GGE/yr
101375.1 GGE/yr
135166.8 GGE/yr
337916.9 GGE/yr
39874.2 GGE/vr
152062.6 GGE/yr
22809.4 GGE/yr
22809.4 GGE/yr
76031.3 GGE/yr
18247.5 GGE/yr
30412.5 GGE/yr
76031.3 GGE/yr
8971.7 GGE/yr
WTP (Indirect)
GHG Emissionss
Value I Units
Project Indirect
GHG Emissions
Value I Units
164 tons CO2e/yr
394 tons CO2e
240 tons CO2e/yr
575 tons CO2e
68 tons CO2e/yr
164 tons CO2e
684 tons CO2e/yr
1643 tons CO2e
205 tons CO2e/yr
493 tons CO2e
274 tons CO2e/yr
657 tons CO2e
684 tons CO2e/yr
1643 tons CO2e
81 tons CO2e/yr
194 tons CO2e
76 tons CO2e/yr
183 tons CO2e
308 tons CO2e/yr
6899 tons CO2e
46 tons CO2e/yr
1035 tons CO2e
46 tons CO2e/yr
1035 tons CO2e
154 tons CO2e/yr
3449 tons CO2e
37 tons CO2e/yr
828 tons CO2e
62 tons CO2e/yr
1380 tons CO2e
154 tons CO2e/yr
3449 tons CO2e
18 tons CO2e/yr
407 tons CO2e
10 tons CO2e/vr
230 tons CO2e
2 6480 hr/yr
18319.9 MMBtu/yr
152062.6 GGE/yr
308 tons CO2e/yr
431 tons CO2e
1 3240 hr/yr
2748.0 MMBtu/yr
22809.4 GGE/yr
46 tons CO2e/yr
65 tons CO2e
1 3240 hr/yr
2748.0 MMBtu/yr
22809.4 GGE/yr
46 tons CO2e/yr
65 tons CO2e
1 3240 hr/yr
9159.9 MMBtu/yr
76031.3 GGE/yr
154 tons CO2e/yr
216 tons CO2e
1 3240 hr/yr
2198.4 MMBtu/yr 1
18247.5 GGE/yr
37 tons CO2e/yr
52 tons CO2e
1 3240 hr/yr
3664.0 MMBtu/yr
30412.5 GGE/yr
62 tons CO2e/yr
86 tons CO2e
1 3240 hr/yr
9159.9 MMBtu/yr
76031.3 GGE/yr
154 tons CO2e/yr
216 tons CO2e
Appendix C - Air Emissions and Energy Use Analysis C-16 September 30, 2016

Table 3. Belews Creek Indirect Greenhouse Gas Emissions
Activity
Number
of Units
Total Usage
Annual Total
Energy Usage
Total Project
GGE
WTP (Indirect)
GHG Emissionss
Project Indirect
GHG Emissions
Value Units
Value Units
Value Units
Value Units
Value Units
55 KVA Diesel Generator
1
3240 hr/yr
1080.9 MMBtu/yr
8971.7 GGE/yr
18 tons CO2e/yr
25 tons CO2e
Personal Vehicles'
15
121500 miles/yr
10 tons CO2e/yr
14 tons CO2e
6,944 Itons CO2e/yr
50,097 Itons CO2e
Notes:
1. Personally Operated Vehicle use is estimated as:
-Excavation: 15 persons/day * 30 miles/person * 270 day/yr (it is assumed each person travels 15 -miles one-way to work);
-Landfill Construction: 25 persons/day * 30 miles/person * 270 day/yr.
2. It is assumed that the landfill location is 25 miles away, so 1 truck trip carrying ash is 50 miles, and 20 -ton trucks are used. It is assumed that the landfill cap/closure material for
Removal alternative is taken from the adjacent borrow area parcel, thus 1 truck trip carrying cap/closure material is taken to be 2 miles. It is assumed that the landfill cap/closure
material for the CIP alternative is taken from a site 25 miles aways, so 1 truck trip carrying cap/closure material for the cap is taken to be 50 miles.
3. It is assumed that the liner is transported 100 miles to the site/landfill on public roads and approximately 10 tons of liner are transported per trip
(3240 Ib/roll * 1 ton/2000 Ib * 6 rolls/truck trip = 10 ton/truck trip).
4. U.S. Energy Information Administration, Energy Explained - Energy Units and Calculators, 2015. Used diesel energy content of 137,871 Btu/gal and
gasoline energy content of 120,476 Btu/gal from http://www.eia.gov/energyexplained/?page=about_energy_units.
5. GHG emission factors from Results created by ANL on 11/12/2015 using GREETI_2015 version, October 2015 release, Argonne National Laboratory, 2015.
Emission Factors Well -To -Pump (WTP )16
Diesel 59 g CO2e/mi 1837 g CO2e/gge
Gasoline (E10) 77 g CO2e/mi
6. Annual Total Energy Usage values taken from Energy Usage calculations.
7. Conversion factor used: 1 HP = 2544.43 Btu/hr
Abbreviations:
GHG = Greenhouse Gas.
WTP = "Well -to -Pump" (also called Well -to -Tank, or WTT), refers to processes and activities involved in producing a fuel through when that fuel reaches a fueling station. This
may include raw material extraction, transportation, fuel production, distribution, and storage. For the purposes of this study, only WTP GHG emissions are considered as indirect
emissions. Indirect emissions in the PTW (Pump -to -Wheels) stage, such as refueling and evaporation, are not included as indirect emissions.
Appendix C - Air Emissions and Energy Use Analysis C-17 September 30, 2016

MNA
Monitor Only
Table 4. Belews Creek Energy Usage Calculations
Since similar monitoring would be required for each option for the project duration, similar energy usages are expected for each and the energy usage is not included in this estimate. It is
expected that the energy usage contributions from personal vehicles due to monitoring would be insignificant compared to the other source of energy usage.
CIP Cap in Place (CIP)
CIP Duration = 12 hr/day 270 day/yr 4.6 years 123323 truck trips carrying cap material
179 truck trips carrying liner material
Activity
Number
of Units
Usage
Value Units
Value Units
Hourly per Unit
Energy Usage9
Value Units
Annual Total
Energy Usage
Value Units
Total Project Energy
Usage
Value Units
Estimated Engine Size
Dozers 1,7
2
6480 hr/yr
500 HP each
2.8 MMBtu/hr
18320 MMBtu/yr
84272 MMBtu
Tractors''
1
3240 hr/yr
150 HP each
0.8 MMBtu/hr
2748 MMBtu/yr
12641 MMBtu
Wheeled Backhoe 1,7
1
3240 hr/yr
150 HP each
0.8 MMBtu/hr
2748 MMBtu/yr
12641 MMBtu
Water Truck s'7
1
3240 hr/yr
500 HP each
2.8 MMBtu/hr
9160 MMBtu/yr
42136 MMBtu
Vibratory Rolled'7
1
3240 hr/yr
120 HP each
0.7 MMBtu/hr
2198 MMBtu/yr
10113 MMBtu
Tracked Excavators''
1
3240 hr/yr
200 HP each
1.1 MMBtu/hr
3664 MMBtu/yr
16854 MMBtu
Maint/Service Trucks'?
1
3240 hr/yr
500 HP each
2.8 MMBtu/hr
9160 MMBtu/yr
42136 MMBtu
55 KVA Diesel Generators''
1
3240 hr/yr
59 HP each
0.3 MMBtu/hr 1
1081 MMBtu/yr
4972 MMBtu
Fuel Usage
Personal Vehicles2'3'8
15
121500 miles/yr
5678 gal/yr
684 MMBtu/yr
15322 MMBtu
Truck Transport - Cap Materia 14,6,8
N/A
26809 truck trips/yr
1340468 miles/yr
231115 gal/yr
31864 MMBtu/yr
146575 MMBtu
Truck Transport - Liner Materia 14,5,6,8
N/A
39 truck trips/yr
7765 miles/yr
1339 gal/yr
185 MMBtu/yr
849 MMBtu
81,812 MMBtu/yr
1 388,509 MMBtu
Appendix C - Air Emissions and Energy Use Analysis C-18 September 30, 2016

Table 4. Belews Creek Energy Usage Calculations
Removal Excavation and Landfill
Landfill Construction Duration = 12 hr/day 300 day/yr 2.4 years
Excavation Duration = 12 hr/day 270 day/yr 22.4 years
Closure Duration = 12 hr/day 270 day/yr 1.4 years
137 truck trips carrying liner material
604500 truck trips carrying ash
22107 truck trips carrying closure material
Activity
Number
of Units
Total Usage
Value Units
Value Units
Hourly per Unit
Energy Usage9
Value Units
Annual Total
Energy Usage
Value Units
Total Project Energy
Usage
Value Units
EXCAVATION
Estimated Engine Size
Tracked Excavators 1,7
2
6480 hr/yr
200 HP each
1.1 MMBtu/hr
7328 MMBtu/yr
164146 MMBtu
Dozers 1,7
2
6480 hr/yr
500 HP each
2.8 MMBtu/hr
18320 MMBtu/yr
410366 MMBtu
Wheeled Loaded'7
1
3240 hr/yr
175 HP each
1.0 MMBtu/hr
3206 MMBtu/yr
71814 MMBtu
Dump Trucks 1,7
2
6480 hr/yr
25 HP each
0.1 MMBtu/hr
916 MMBtu/yr
20518 MMBtu
Water Truck 1,7
1
3240 hr/yr
500 HP each
2.8 MMBtu/hr
9160 MMBtu/yr
205183 MMBtu
Wheeled Backhoe""
1
3240 hr/yr
150 HP each
0.8 MMBtu/hr
2748 MMBtu/yr
61555 MMBtu
6-8" Pumpsl''
2
6480 hr/yr
100 HP each
0.6 MMBtu/hr
3664 MMBtu/yr
82073 MMBtu
55 KVA Diesel Generator 1,7
1
3240 hr/yr
59 HP each
0.3 MMBtu/hr
1081 MMBtu/yr
24212 MMBtu
Fuel Usage
Personal VehicleS2,3'8
15
121500 miles/yr
5678 gal/yr
684 MMBtu/yr
15321.8 MMBtu
MATERIAL TRANSPORT
Fuel Usage
Truck Transport - Ash 4,6,8
N/A
26987 truck trips/yr
1349330 miles/yr
232643 gal/yr
32075 MMBtu/yr
718474 MMBtu
Truck Transport - Closure Materia 14,6,8
N/A
15791 truck trips/yr
31581 miles/yr
5445 gal/yr
751 MMBtu/yr
1051 MMBtu
Truck Transport - Liner Materia 14,5,6,8
N/A
36 truck trips/yr
7199 miles/yr
1241 gal/yr
171 MMBtu/yr
650 MMBtu
LANDFILL CONSTRUCTION
Estimated Engine Size
Tracked Excavators 1,7
8
28800 hr/yr
200 HP each
1.1 MMBtu/hr
32569 MMBtu/yr
78165 MMBtu
Dozers 1,7
8
28800 hr/yr
500 HP each
2.8 MMBtu/hr
81422 MMBtu/yr
195412 MMBtu
Vibratory Compactors l''
4
14400 hr/yr
120 HP each
0.7 MMBtu/hr
9771 MMBtu/yr
23449 MMBtu
Wheeled Loaders 1,7
4
14400 hr/yr
175 HP each
1.0 MMBtu/hr
14249 MMBtu/yr
34197 MMBtu
Dump Trucks1'7
8
28800 hr/yr
25 HP each
0.1 MMBtu/hr
4071 MMBtu/yr
9771 MMBtu
Appendix C - Air Emissions and Energy Use Analysis C-19 September 30, 2016

Table 4. Belews Creek Energy Usage Calculations
Activity
Number
of Units
Total Usage
Value Units
Value Units
Hourly (per Unit)
Energy Usage9
Value Units
Annual Total
Energy Usage
Value Units
Total Project Energy
Usage
Value Units
Water Trucks l''
4
14400 hr/yr
500 HPeach
2.8 MMBtu/hr
40711 MMBtu/yr
97706 MMBtu
Wheeled Backhoesl"7
4
14400 hr/yr
150 HP each
0.8 MMBtu/hr
12213 MMBtu/yr
29312 MMBtu
6-8" Pumps'''
8
28800 hr/yr
100 HP each
0.6 MMBtu/hr
16284 MMBtu/yr
39082 MMBtu
Maint/Service Trucks'''
4
14400 hr/yr
500 HP each
2.8 MMBtu/hr
40711 MMBtu/yr
97706 MMBtu
55 KVA Diesel Generators'''
4
14400 hr/yr
591 HP each
0.3 MMBtu/hr
4804 MMBtu/yr
11529 MMBtu
Fuel Usage
Personal Vehicles2'3's
100
900000 miles/yr
42056 gal/yr
5067 MMBtu/yr
12160.2 MMBtu
LANDFILL FILLING
Estimated Engine Size
Dozers 1,7
2
6480 hr/yr
500 HP each
2.8 MMBtu/hr
18320 MMBtu/yr
410366 MMBtu
Tractor'''
1
3240 hr/yr
150 HP each
0.8 MMBtu/hr
2748 MMBtu/yr
61555 MMBtu
Wheeled Backhoe''?
1
3240 hr/yr
150 HP each
0.8 MMBtu/hr
2748 MMBtu/yr
61555 MMBtu
Water Truck l''
1
3240 hr/yr
500 HP each
2.8 MMBtu/hr
9160 MMBtu/yr
205183 MMBtu
Vibratory Roller 1,7
1
3240 hr/yr
120 HP each
0.7 MMBtu/hr
2198 MMBtu/yr
49244 MMBtu
Tracked Excavator'''
1
3240 hr/yr
200 HP each
1.1 MMBtu/hr
3664 MMBtu/yr
82073 MMBtu
Maint/Service Truck'''
1
3240 hr/yr
500 HP each
2.8 MMBtu/hr
9160 MMBtu/yr
205183 MMBtu
55 KVA Diesel Generator'''
1
3240 hr/yr
59 HP each
0.3 MMBtu/hr
1081 MMBtu/yr
24212 MMBtu
Fuel Usage
Personal Vehicle S2,3,11
15
121500 miles/yr
5678 gal/yr
684 MMBtu/yr
15321.8 MMBtu
LANDFILL CLOSURE
Estimated Engine Size
Dozers""
2
6480 hr/yr
500 HP each
2.8 MMBtu/hr
18320 MMBtu/yr
25648 MMBtu
Tractor'''
1
3240 hr/yr
150 HP each
0.8 MMBtu/hr
2748 MMBtu/yr
3847 MMBtu
Wheeled Backhoe'''
1
3240 hr/yr
150 HP each
0.8 MMBtu/hr
2748 MMBtu/yr
3847 MMBtu
Water Truck l''
1
3240 hr/yr
500 HP each
2.8 MMBtu/hr
9160 MMBtu/yr
12824 MMBtu
Vibratory Rolle r1,7
1
3240 hr/yr
120 HP each
0.7 MMBtu/hr
2198 MMBtu/yr
3078 MMBtu
Tracked Excavator 1''
1
3240 hr/yr
200 HP each
1.1 MMBtu/hr
3664 MMBtu/yr
5130 MMBtu
Maint/Service Truck'''
1
3240 hr/yr
500 HP each
2.8 MMBtu/hr
9160 MMBtu/yr
12824 MMBtu
55 KVA Diesel Generator'''
1
3240 hr/yr
59 HP each
0.3 MMBtu/hr
1081 MMBtu/yr
1513 MMBtu
Fuel Usage
Personal Vehicles2'3's
15
121500 miles/yr
5678 gal/yr
684 MMBtu/yr
957.6 MMBtu
441,500 MMBtu/yr
3,588,214 MMBtu
Appendix C - Air Emissions and Energy Use Analysis C-20 September 30, 2016

Table 4. Belews Creek Energy Usage Calculations
Notes:
1. South Coast Air Quality Management District Off -Road Model Mobile Source Emission Factors for a 2016 fleet average from http://www.agmd.gov/home/regulations/ceqa/air-quality-
analysis-handbook/off-road-mobile-source-emission-factors.
2. Personally Operated Vehicle use is estimated as:
-Excavation: 15 persons/day * 30 miles/person * 270 day/yr (it is assumed each person travels 15 -miles one-way to work);
-Landfill Construction: 25 persons/day * 30 miles/person * 270 day/yr.
3. USDOT Bureau of Transportation Statistics Average Fuel Efficiency of U.S. Light Duty Vehicles for calendar year 2014 U.S. light-duty vehicles ( 21.4 mi/gal) from
http://www.rita.dot.gov/bts/sites/rita.dot.gov.bts/files/publications/national_transportation_statistics/html/table_ 04_23.html.
4. It is assumed that the landfill location is 25 miles away, so 1 truck trip carrying ash is 50 miles, and 20 -ton trucks are used. It is assumed that the landfill cap/closure material for Option 3 is
taken from an adjacent land parcel, thus 1 truck trip carrying cap/closure material is taken to be 2 miles. It is assumed that the landfill cap/closure material for the CIP alternative is taken
from a site 25 miles aways, so 1 truck trip carrying cap/closure material for the CIP alternative is 50 miles.
5. It is assumed that the liner is transported 100 miles to the site/landfill on public roads and approximately 10 tons of liner are transported per trip
(3240 Ib/roll * 1 ton/2000 Ib * 6 rolls/truck trip = 10 ton/truck trip).
6. Oak Ridge National Laboratory Transportation Energy Data Book, Edition 34, September 2015. Class 7-8 average fuel economy (2013) is 5.8 mi/gal from
http://cta.ornl.gov/data/tedb34/Edition34_Chapter05.pdf.
7. USDOE Office of Energy Efficiency and Renewable Energy, Just the Basics Diesel Engine, 2003. Used estimated diesel engine efficiency of 45% from
http://wwwl.eere.energy.gov/vehiclesandfuels/pdfs/basics/jtb_diesel_engine.pdf.
8. U.S. Energy Information Administration, Energy Explained - Energy Units and Calculators, 2015. Used diesel energy content of 137,871 Btu/gal and
gasoline energy content of 120,476 Btu/gal from http://www.eia.gov/energyexplained/?page=about_energy_units.
9. Conversion factor used: 1 HP = 2544.43 Btu/hr
Appendix C - Air Emissions and Energy Use Analysis C-21 6, 2016

MNA
Monitor Only
Table 5. Marshall Air Emissions Calculations
Since similar monitoring would be required for each alternative for the project duration, similar emissions are expected for each and the emissions are not included in this estimate. It is expected that the emissions contributions
from personal vehicles due to monitoring would be insignificant compared to the other emission sources.
CIP Cap in Place (CIP)
CIP Duration = 12 hr/day 270 day/yr 9.3 years 252271 truck trips carrying cap material
366 truck trips carrying liner material
Appendix C - Air Emissions and Energy Use Analysis C-22 September 30, 2016
Usage
NOx
Emission Factors
PM10/PM2.5 Direct CO2
Direct CHQ
Emissions
(tons/yr)
Cumulative Emissions
(tons CO2e)
Activity
Value Units
Value Units
Value Units
Value Units
Value Units
NOx
PM10/PM2s Direct GHG (CO2e)
Direct GHG
2 Dozers'
6480 hr/yr
2.0891 Ib/hr
0.0858 Ib/hr
239 Ib/hr
0.0234 Ib/hr
6.77
0.28
776.26
7219.18
Tractor'
3240 hr/yr
0.4070 Ib/hr
0.0258 Ib/hr
66.8 Ib/hr
0.0055 Ib/hr
0.66
0.04
108.44
1008.48
Wheeled Backhoel
3240 hr/yr
0.4070 Ib/hr
0.0258 Ib/hr
66.8 Ib/hr
0.0055 Ib/hr
0.66
0.04
108.44
1008.48
Water Truck'
3240 hr/yr
1.3322 Ib/hr
0.0459 Ib/hr
260 Ib/hr
0.0164 Ib/hr
2.16
0.07
421.86
3923.34
Vibratory Roller'
3240 hr/yr
0.5273 Ib/hr
0.0353 Ib/hr
67 Ib/hr
0.0071 Ib/hr
0.85
0.061
108.83
1012.10
Tracked Excavator'
3240 hr/yr
0.6603 Ib/hr
0.0332 Ib/hr
120 Ib/hr
0.0089 Ib/hr
1.07
0.05
194.76
1811.27
Maint/Service Truck'
3240 hr/yr
1.3322 Ib/hr
0.0459 Ib/hr
260 Ib/hr
0.0164 Ib/hr
2.16
0.07
421.86
3923.34
55 KVA Diesel Generator'
3240 hr/yr
0.6102 Ib/hr
0.0431 Ib/hr
77.9 Ib/hr
0.0073 Ib/hr 1
0.99
0.07
126.49
1176.39
15 Personal Vehicles2'3,4,5'6
121500 miles/yr
0.95 g/mile
0.0045 g/mile
410 g/mile
0.0452 g/mile
0.13
0.00
55.10
512.44
Truck Transport - Cap Materia 17,8,1,10
27126 truck trips/yr
459.55 g/truck trip
10.75 g/truck trip
138000 g/truck trip
0.255 g/truck trip
13.74
0.32
4126.56
38377.01
Truck Transport - Liner Materia 17,8,9,10,11
39 truck trips/yr I
1838.20 g/truck trip I
3.00 g/truck trip
552000 g/truck trip
1.02 g/truck trip
0.08
0.00
23.95
222.71
29.26
1.01
6,472.55 1
60,194.72
Appendix C - Air Emissions and Energy Use Analysis C-22 September 30, 2016

Table 5. Marshall Air Emissions Calculations
Removal Excavation and Landfill
Landfill Construction Duration = 12 hr/day 300 day/yr 4.9 years 278 truck trips carrying liner material (construction & closure)
Excavation Duration = 12 hr/day 270 day/yr 50.7 years 1369500 truck trips carrying ash
Closure Duration = 12 hr/day 270 day/yr 2.8 years 45768 truck trips carrying closure material
Appendix C - Air Emissions and Energy Use Analysis C-23 (216
Usage
NOx
Emission Factors
PM10/PM2.5 Direct CO2
Direct CH4
Emissions
(tons/yr)
Cumulative Emissions
(tons CO2e)
Activity
Value Units
Value Units
Value Units
Value Units
Value Units
NOx
PM10/PM2.s Direct GHG (CO2e)
Direct GHG
EXCAVATION
2 Tracked Excavators'
6480 hr/yr
0.6603 Ib/hr
0.0332 Ib/hr
120 Ib/hr
0.0089 Ib/hr
2.14
0.11
389.52
19748.71
2 Dozers'
6480 hr/yr
2.0891 Ib/hr
0.0858 Ib/hr
239 Ib/hr
0.0234 Ib/hr
6.77
0.28
776.26
39356.15
Wheeled Loader'
3240 hr/yr
0.7114 Ib/hr
0.0375 Ib/hr
109 Ib/hr
0.0089 Ib/hr
1.15
0.06
176.94
8970.88
2 Dump Trucks'
6480 hr/yr
0.0587 Ib/hr
0.0024 Ib/hr
7.6 Ib/hr
0.0008 Ib/hr
0.19
0.01
24.69
1251.72
Water Truck'
3240 hr/yr
1.3322 Ib/hr
0.0459 Ib/hr
260 Ib/hr
0.0164 Ib/hr
2.16
0.07
421.86
21388.51
Wheeled Backhoe'
3240 hr/yr
0.4070 Ib/hr
0.0258 Ib/hr
66.8 Ib/hr
0.0055 Ib/hr
0.66
0.04
108.44
5497.84
2 6-8" Pumps'
6480 hr/yr
0.3830 Ib/hr
0.0239 Ib/hr
49.6 Ib/hr
0.0051 Ib/hr
1.24
0.08
161.12
8168.64
55 KVA Diesel Generator'
3240 hr/yr
0.6102 Ib/hr
0.0431 Ib/hr
77.9 Ib/hr
0.0073 Ib/hr 1
0.99
0.07
126.49
6413.23
15 Personal Vehicles2'3'4,5
121500 miles/yr
0.95 g/mile
0.0045 g/mile
410 g/mile
0.0452 g/mile
0.13
0.00
55.10
2793.60
MATERIAL TRANSPORT
Truck Transport - Ash 7,8,9,10
27012 truck trips/yr
459.55 g/truck trip
10.75 g/truck trip
138000 g/truck trip
0.2550 g/truck trip
13.68
0.32
4109.21
208336.71
Truck Transport - Closure Materia 17,8,9,10
16346 truck trips/yr
18.38 g/truck trip
0.43 g/truck trip
5520 g/truck trip
0.0102 g/truck trip
0.33
0.01
99.46
278.50
Truck Transport- Liner Materia 17,8,9,10,11
36 truck trips/yr
1838.20 g/truck trip
43 g/truck trip
552000 g/truck trip
1.0200 g/truck trip
0.07
0.00
21.97
169.16
LANDFILL CONSTRUCT.
8 Tracked Excavators'
28800 hr/yr
0.6603 Ib/hr
0.0332 Ib/hr
120 Ib/hr
0.0089 Ib/hr
9.51
0.48
1731.20
13330.27
8 Dozers'
28800 hr/yr
2.0891 Ib/hr
0.0858 Ib/hr
239 Ib/hr
0.0234 Ib/hr
30.08
1.24
3450.02
26565.18
4 Vibratory Compactors'
14400 hr/yr
0.568 Ib/hr
0.0234 Ib/hr
123 Ib/hr
0.0065 Ib/hr
4.09
0.17
886.77
6828.13
4 Wheeled Loaders'
14400 hr/yr
0.7114 Ib/hr
0.0375 Ib/hr
109 Ib/hr
0.0089 Ib/hr
5.12
0.27
786.40
6055.30
8 Dump Trucks'
28800 hr/yr
0.0587 Ib/hr
0.0024 Ib/hr
7.6 Ib/hr
0.0008 Ib/hr
0.85
0.03
109.73
844.91
4 Water Trucks'
14400 hr/yr
1.3322 Ib/hr
0.0459 Ib/hr
260 Ib/hr
0.0164 Ib/hr
9.59
0.33
1874.95
14437.13
4 Wheeled Backhoesl
14400 hr/yr
0.4070 Ib/hr
0.0258 Ib/hr
66.8 Ib/hr
0.0055 Ib/hr
2.93
0.19
481.95
3711.02
8 6-8" Pumps'
28800 hr/yr
0.3830 Ib/hr
0.0239 Ib/hr
49.6 Ib/hr
0.0051 Ib/hr
5.52
0.34
716.08
5513.79
4 Maint/Service Trucks'
14400 hr/yr
1.3322 Ib/hr
0.0459 Ib/hr
260 Ib/hr
0.0164 Ib/hr
9.59
0.33
1874.95
14437.13
4 55 KVA Diesel Generator'
14400 hr/yr
0.6102 Ib/hr
0.0431 Ib/hr
77.9 Ib/hr
0.0073 Ib/hr 1
4.39
0.31
562.19
4328.89
100 Personal Vehicles2'3'4'S
900000 miles/yr
0.95 g/mile
0.0045 g/mile
410 g/mile
0.0452 g/mile
0.94
0.00
408
3142.77
LANDFILL FILLING
2 Dozers'
6480 hr/yr
2.0891 Ib/hr
0.0858 Ib/hr
239 Ib/hr
0.0234 Ib/hr
6.77
0.28
776.26
39356.15
Tractor'
3240 hr/yr
0.4070 Ib/hr
0.0258 Ib/hr
66.8 Ib/hr
0.0055 Ib/hr
0.66
0.041
108.44
5497.84
Wheeled Backhoe'
1 3240 hr/yr
0.4070 Ib/hr
0.0258 Ib/hr
66.8 Ib/hr
0.0055 Ib/hr
0.66
0.041
108.44
5497.84
Water Truck'
I 3240 hr/yr
1.3322 Ib/hr
0.0459 Ib/hr
260 Ib/hr I
0.0164 Ib/hr 1
2.16
0.071
421.86
21388.51
Appendix C - Air Emissions and Energy Use Analysis C-23 (216

Table 5. Marshall Air Emissions Calculations
Notes:
1. South Coast Air Quality Management District Off -Road Model Mobile Source Emission Factors for a 2016 fleet average from http://www.agmd.gov/home/regulations/ceqa/air-quality-analysis-handbook/off-road-mobile-source-
emission-factors.
2. USEPA Center for Corporate Climate Leadership Greenhouse Gas Inventory Guidance: Direct Emissions from Mobile Combustion Sources Tier 1 Gasoline Light -Duty Truck emission factors (0.0452 g CH4/mile) from
https://www.epa.gov/sites/prod uction/fi les/2016-03/documents/mobi leem issions_3_2016. pdf.
3. Personally Operated Vehicle use is estimated as:
-Excavation: 15 persons/day * 30 miles/person * 270 day/yr (it is assumed each person travels 15 -miles one-way to work);
-Landfill Construction: 25 persons/day * 30 miles/person * 270 day/yr.
4. USDOT Bureau of Transportation Statistics Average Fuel Efficiency of U.S. Light Duty Vehicles for calendar year 2014 (21.4 miles/gal) for POV CO2 emissions from
http://www. rita. dot.gov/bts/sites/rita.dot.gov. bts/fi les/pu bl icati ons/national_tra nsportation_statistics/htm I/ta ble_04_23. html.
5. 100 -yr GWP for CH4 (25 kg CO2e/kg CH4) from Intergovernmental Panel on Climate Change (IPCC), Fourth Assessment Report (AR4), 2007.
6. USEPA Office of Transportation and Air Quality Average Annual Emissions and Fuel Consumption for Gasoline -Fueled Passenger Cars and Light Trucks light-duty trucks emissions estimates for the in -use fleet as of 2008 based on
httPs://www3.epa.gov/otaq/consumer/42OfO8O24.pdf.
7. It is assumed that the landfill location is 25 miles away, so 1 truck trip carrying ash is 50 miles, and 20 -ton trucks are used. It is assumed that the landfill cap/closure material for the Removal alternative is taken from an adjacent
land borrow area, thus 1 truck trip carrying cap/closure material is taken to be 2 miles. It is assumed that the landfill cap/closure material for the CIP alternative is taken from a site 25 miles aways, so 1 truck trip carrying cap/closure
material for the CIP alternative is taken to be 50 miles.
8. USEPA Office of Transportation and Air Quality Average In -Use Emissions from Heavy -Duty Trucks NOx and PM10/PM2.5 emission factors approximated as a diesel Heavy -Duty Vehicle Class Vllla (33,001-60,000 Ib GVWR--since it is
for 20 ton (40,000 Ib) material +truck) --based on the in -use fleet from July 2008 from https://www3.epa.gov/otaq/consumer/42OfO8O27.pdf.
9. USEPA Center for Corporate Climate Leadership Emission Factors for Greenhouse Gas Inventories greenhouse gas emission factors approximated as heavy duty vehicles for 1960 -present from Table 4 of
https://www.epa.gov/sites/production/files/2015-12/documents/emission-factors_nov_2015.pdf, dated November 2015.
10. It is assumed that the weight of the vehicle + load is approximately 60,000 Ib (20 -ton load and 10 -ton truck). Diesel heavy duty combination truck CO2 emission factor for MY2014/Class 8/Day Cab is 92 g CO2/ton-mile taken
from https://www.gpo.gov/fdsys/pkg/FR-2011-09-15/pdf/2011-20740.pdf (EPA/DOT Federal Register Vol. 76, No. 179, 15 September 2011).
-92 g CO2/ton-mile * (30 ton*x mile)/truck trip = y g CO2/truck trip
11. It is assumed that the liner is transported 100 miles to the site/landfill on public roads and approximately 10 tons of liner are transported per trip (3240 Ib/roll * 1 ton/2000 Ib * 6 rolls/truck trip = 10 ton/truck trip).
Appendix C - Air Emissions and Energy Use Analysis C-24 6, 2016
Usage
NOx
Emission Factors
PM10/PM2 s Direct CO2
Direct CH4
Emissions
(tons/yr)
Cumulative Emissions
(tons CO2e)
Activity
Value Units
Value Units
Value Units
Value Units
Value Units
NOx
PMlo/PMz.s Direct GHG (CO2e)
Direct GHG
Vibratory Roller'
3240 hr/yr
0.5273 Ib/hr
0.0353 Ib/hr
67 Ib/hr
0.0071 Ib/hr
0.85
0.06
108.83
5517.56
Tracked Excavator'
3240 hr/yr
0.6603 Ib/hr
0.0332 Ib/hr
120 Ib/hr
0.0089 Ib/hr
1.07
0.05
194.76
9874.35
Maint/Service Truck'
3240 hr/yr
1.3322 Ib/hr
0.0459 Ib/hr
260 Ib/hr
0.0164 Ib/hr 1
2.16
0.07
421.86
21388.51
55 KVA Diesel Generator'
3240 hr/yr
0.6102 Ib/hr
0.0431 Ib/hr
77.9 Ib/hr
0.0073 Ib/hr
0.99
0.07
126.49
6413.23
15 Personal Vehicles2'1,4,5,6
121500 miles r
/y
0.95 g/mile
0.0045 g/mile
410 g/mile
0.0452 g/mile
0.13
0.00
55.10
2793.60
LANDFILL CLOSURE
2 Dozers'
6480 hr/yr
2.0891 Ib/hr
0.0858 Ib/hr
239 Ib/hr
0.0234 Ib/hr
6.77
0.28
776.26
2173.52
Tractor'
3240 hr/yr
0.4070 Ib/hr
0.0258 Ib/hr
66.8 Ib/hr
0.0055 Ib/hr
0.66
0.04
108.44
303.63
Wheeled Backhoe'
3240 hr/yr
0.4070 Ib/hr
0.0258 Ib/hr
66.8 Ib/hr
0.0055 Ib/hr
0.66
0.04
108.44
303.63
Water Truck'
3240 hr/yr
1.3322 Ib/hr
0.0459 Ib/hr
260 Ib/hr
0.0164 Ib/hr
2.16
0.07
421.86
1181.22
Vibratory Roller'
3240 hr/yr
0.5273 Ib/hr
0.0353 Ib/hr
67 Ib/hr
0.0071 Ib/hr
0.85
0.06
108.83
304.72
Tracked Excavator'
3240 hr/yr
0.6603 Ib/hr
0.0332 Ib/hr
120 Ib/hr
0.0089 Ib/hr
1.07
0.05
194.76
545.33
Maint/Service Truck'
3240 hr/yr
1.3322 Ib/hr
0.0459 Ib/hr
260 Ib/hr
I 0.0164 Ib/hr
2.16
0.07
421.86
1181.22
55 KVA Diesel Generator'
3240 hr/yr
0.6102 Ib/hr
0.0431 Ib/hr
77.9 Ib/hr
0.0073 Ib/hr
0.99
0.07
126.491
354.18
15 Personal Vehicles2,s,4,5,6
121500 miles/yr
0.95 g/mile
0.0045 g/mile
410 g/mile
0.0452 g/mile
0.13
0.00
55.10
154.28
143.01
6.12
23,997.55 1
545,797.50
Notes:
1. South Coast Air Quality Management District Off -Road Model Mobile Source Emission Factors for a 2016 fleet average from http://www.agmd.gov/home/regulations/ceqa/air-quality-analysis-handbook/off-road-mobile-source-
emission-factors.
2. USEPA Center for Corporate Climate Leadership Greenhouse Gas Inventory Guidance: Direct Emissions from Mobile Combustion Sources Tier 1 Gasoline Light -Duty Truck emission factors (0.0452 g CH4/mile) from
https://www.epa.gov/sites/prod uction/fi les/2016-03/documents/mobi leem issions_3_2016. pdf.
3. Personally Operated Vehicle use is estimated as:
-Excavation: 15 persons/day * 30 miles/person * 270 day/yr (it is assumed each person travels 15 -miles one-way to work);
-Landfill Construction: 25 persons/day * 30 miles/person * 270 day/yr.
4. USDOT Bureau of Transportation Statistics Average Fuel Efficiency of U.S. Light Duty Vehicles for calendar year 2014 (21.4 miles/gal) for POV CO2 emissions from
http://www. rita. dot.gov/bts/sites/rita.dot.gov. bts/fi les/pu bl icati ons/national_tra nsportation_statistics/htm I/ta ble_04_23. html.
5. 100 -yr GWP for CH4 (25 kg CO2e/kg CH4) from Intergovernmental Panel on Climate Change (IPCC), Fourth Assessment Report (AR4), 2007.
6. USEPA Office of Transportation and Air Quality Average Annual Emissions and Fuel Consumption for Gasoline -Fueled Passenger Cars and Light Trucks light-duty trucks emissions estimates for the in -use fleet as of 2008 based on
httPs://www3.epa.gov/otaq/consumer/42OfO8O24.pdf.
7. It is assumed that the landfill location is 25 miles away, so 1 truck trip carrying ash is 50 miles, and 20 -ton trucks are used. It is assumed that the landfill cap/closure material for the Removal alternative is taken from an adjacent
land borrow area, thus 1 truck trip carrying cap/closure material is taken to be 2 miles. It is assumed that the landfill cap/closure material for the CIP alternative is taken from a site 25 miles aways, so 1 truck trip carrying cap/closure
material for the CIP alternative is taken to be 50 miles.
8. USEPA Office of Transportation and Air Quality Average In -Use Emissions from Heavy -Duty Trucks NOx and PM10/PM2.5 emission factors approximated as a diesel Heavy -Duty Vehicle Class Vllla (33,001-60,000 Ib GVWR--since it is
for 20 ton (40,000 Ib) material +truck) --based on the in -use fleet from July 2008 from https://www3.epa.gov/otaq/consumer/42OfO8O27.pdf.
9. USEPA Center for Corporate Climate Leadership Emission Factors for Greenhouse Gas Inventories greenhouse gas emission factors approximated as heavy duty vehicles for 1960 -present from Table 4 of
https://www.epa.gov/sites/production/files/2015-12/documents/emission-factors_nov_2015.pdf, dated November 2015.
10. It is assumed that the weight of the vehicle + load is approximately 60,000 Ib (20 -ton load and 10 -ton truck). Diesel heavy duty combination truck CO2 emission factor for MY2014/Class 8/Day Cab is 92 g CO2/ton-mile taken
from https://www.gpo.gov/fdsys/pkg/FR-2011-09-15/pdf/2011-20740.pdf (EPA/DOT Federal Register Vol. 76, No. 179, 15 September 2011).
-92 g CO2/ton-mile * (30 ton*x mile)/truck trip = y g CO2/truck trip
11. It is assumed that the liner is transported 100 miles to the site/landfill on public roads and approximately 10 tons of liner are transported per trip (3240 Ib/roll * 1 ton/2000 Ib * 6 rolls/truck trip = 10 ton/truck trip).
Appendix C - Air Emissions and Energy Use Analysis C-24 6, 2016

MNA
Monitor Only
Table 6. Marshall Indirect Greenhouse Gas Emissions
Since similar monitoring would be required for each option for the project duration, similar emissions are expected for each and the emissions are not included in this estimate. It is
expected that the emissions contributions from personal vehicles due to monitoring would be insignificant compared to the other emission sources.
CIP Cap in Place (CIP)
CIP Duration = 12 hr/day 270 day/yr 9.3 years 252271 truck trips carrying cap material
366 truck trips carrying liner material
Activity
Number
of Units
Usage
Value Units
Annual Total
Energy Usage
Value Units
Total Project
GGE
Value Units
WTP (Indirect)
GHG Emissionss
Value Units
Project Indirect
GHG Emissions
Value Units
Dozers4
2
6480 hr/yr
18319.9 MMBtu/yr
152062.6 GGE/yr
308 tons CO2e/yr
2864 tons CO2e
Tractor
1
3240 hr/yr
2748.0 MMBtu/yr
22809.4 GGE/yr
46 tons CO2e/yr
430 tons CO2e
Wheeled Backhoe4
1
3240 hr/yr
2748.0 MMBtu/yr
22809.4 GGE/yr
46 tons CO2e/yr
430 tons CO2e
Water Truck 4
1
3240 hr/yr
9159.9 MMBtu/yr
76031.3 GGE/yr
154 tons CO2e/yr
1432 tons CO2e
Vibratory Roller
1
3240 hr/yr
2198.4 MMBtu/yr
18247.5 GGE/yr
37 tons CO2e/yr
344 tons CO2e
Tracked Excavator4
1
3240 hr/yr
3664.0 MMBtu/yr
30412.5 GGE/yr
62 tons CO2e/yr
573 tons CO2e
Maint/Service Truck
1
3240 hr/yr
9159.9 MMBtu/yr
76031.3 GGE/yr
154 tons CO2e/yr
1432 tons CO2e
55 KVA Diesel Generator
1
3240 hr/yr
1080.9 MMBtu/yr
8971.7 GGE/yr
18 tons CO2e/yr
169 tons CO2e
Personal Vehicles'
15
121500 miles/yr
10 tons CO2e/yr
96 tons CO2e
Truck Transport - Cap Materia 12
N/A
27126 truck trips/yr
1356295 miles/yr
88 tons CO2e/yr
816 tons CO2e
Truck Transport - Liner Materia 12,3
N/A
39 truck trips/yr
7866 miles/yr
0.5 tons CO2e/yr
5 tons CO2e
924 tons CO2e/yr
8,590 tons CO2e
Appendix C - Air Emissions and Energy Use Analysis C-25 M6

Table 6. Marshall Indirect Greenhouse Gas Emissions
Removal Excavation and Landfill
Landfill Construction Duration = 12 hr/day 300 day/yr 4.9 years 278 truck trips
Excavation Duration = 12 hr/day 270 day/yr 50.7 years 1369500 truck trips
Closure Duration = 12 hr/day 270 day/yr 2.8 years 45768 truck trips
carrying liner material
carrying ash
carrying closure material
Appendix C - Air Emissions and Energy Use Analysis C-26 (0 6
Annual Total
Total Project
WTP (Indirect)
Project Indirect
Number
Total Usage
Energy Usage
GGE
GHG Emissions5
GHG Emissions
Activity
of Units
Value Units
Value Units
Value Units
Value Units
Value Units
EXCAVATION
Tracked Excavators4
2
6480 hr/yr
7328.0 MMBtu/yr
60825.0 GGE/yr
123 tons CO2e/yr
6246 tons CO2e
Dozers4
2
6480 hr/yr
18319.9 MMBtu/yr
152062.6 GGE/yr
308 tons CO2e/yr
15614 tons CO2e
Wheeled Loader
1
3240 hr/yr
3206.0 MMBtu/yr
26611.0 GGE/yr
54 tons CO2e/yr
2733 tons CO2e
Dump Trucks°
2
6480 hr/yr
916.0 MMBtu/yr
7603.1 GGE/yr
15 tons CO2e/yr
781 tons CO2e
Water Truck
1
3240 hr/yr
9159.9 MMBtu/yr
76031.3 GGE/yr
154 tons CO2e/yr
7807 tons CO2e
Wheeled Backhoe4
1
3240 hr/yr
2748.0 MMBtu/yr
22809.4 GGE/yr
46 tons CO2e/yr
2342 tons CO2e
6-8" Pumps4
2
6480 hr/yr
3664.0 MMBtu/yr
30412.5 GGE/yr
62 tons CO2e/yr
3123 tons CO2e
55 KVA Diesel Generator
1
3240 hr/yr
1080.9 MMBtu/yr
8971.7 GGE/yr
18 tons CO2e/yr
921 tons CO2e
Personal Vehicles'
15
121500 miles/yr
10 tons CO2e/yr
521 tons CO2e
MATERIAL TRANSPORT
Truck Transport - Ash
N/A
27012 truck trips/yr
1350592 miles/yr
87 tons CO2e/yr
4431 tons CO2e
Truck Transport - Closure Material2
N/A
16346 truck trips/yr
32691 miles/yr
2 tons CO2e/yr
6 tons CO2e
Truck Transport - Liner Materia 12,3
N/A
36 truck trips/yr
7228 miles/yr
0.5 tons CO2e/yr
4 tons CO2e
LANDFILL CONSTRUCTION
Tracked Excavators4
8
28800 hr/yr
32568.7 MMBtu/yr
270333.5 GGE/yr
548 tons CO2e/yr
2683 tons CO2e
Dozers4
8
28800 hr/yr
81421.8 MMBtu/yr
675833.9 GGE/yr
1369 tons CO2e/yr
6707 tons CO2e
Vibratory Compactors4
4
14400 hr/yr
9770.6 MMBtu/yr
81100.1 GGE/yr
164 tons CO2e/yr
805 tons CO2e
Appendix C - Air Emissions and Energy Use Analysis C-26 (0 6

Wheeled Loaders"
Dump Trucks4
Water Trucks4
Wheeled Backhoes4
6-8" Pumps4
Maint/Service Trucks4
55 KVA Diesel Generators4
Personal Vehicles'
LANDFILL FILLING
Dozers4
Tractor
Wheeled Backhoe4
Water Truck
Vibratory Roller
Maint/Service Truck"
55 KVA Diesel Generator
Personal Vehicles'
Number
of Units
4
8
4
4
8
4
4
100
2
1
1
1
1
1
1
1
15
Table 6. Marshall Indirect Greenhouse Gas Emissions
Total Usage
Value Units
14400 hr/yr
28800 hr/yr
14400 hr/yr
14400 hr/yr
28800 hr/yr
14400 hr/yr
14400 hr/yr
900000 miles/vr
6480 hr/yr
3240 hr/yr
3240 hr/yr
3240 hr/yr
3240 hr/yr
3240 hr/yr
3240 hr/yr
3240 hr/yr
121500 miles
Annual Total
Energy Usage
Value Units
14248.8 MMBtu/yr
4071.1 MMBtu/yr
40710.9 MMBtu/yr
12213.3 MMBtu/yr
16284.4 MMBtu/yr
40710.9 MMBtu/yr
4803.9 MMBtu/vr
18319.9 MMBtu/yr
2748.0 MMBtu/yr
2748.0 MMBtu/yr
9159.9 MMBtu/yr
2198.4 MMBtu/yr
3664.0 MMBtu/yr
9159.9 MMBtu/yr
1080.9 MMBtu/vr
Total Project
GGE
Value Units
118270.9 GGE/yr
33791.7 GGE/yr
337916.9 GGE/yr
101375.1 GGE/yr
135166.8 GGE/yr
337916.9 GGE/yr
39874.2 GGE/vr
152062.6 GGE/yr
22809.4 GGE/yr
22809.4 GGE/yr
76031.3 GGE/yr
18247.5 GGE/yr
30412.5 GGE/yr
76031.3 GGE/yr
8971.7 GGE/vr
WTP (Indirect)
GHG Emissionss
Value Units
240 tons CO2e/yr
68 tons CO2e/yr
684 tons CO2e/yr
205 tons CO2e/yr
274 tons CO2e/yr
684 tons CO2e/yr
81 tons CO2e/yr
76 tons CO2e/vr
Project Indirect
GHG Emissions
Value Units
1174 tons CO2e
335 tons CO2e
3353 tons CO2e
1006 tons CO2e
1341 tons CO2e
3353 tons CO2e
396 tons CO2e
373 tons CO2e
308
tons CO2e/yr
15614
tons CO2e
46
tons CO2e/yr
2342
tons CO2e
46
tons CO2e/yr
2342
tons CO2e
154
tons CO2e/yr
7807
tons CO2e
37
tons CO2e/yr
1874
tons CO2e
62
tons CO2e/yr
3123
tons CO2e
154
tons CO2e/yr
7807
tons CO2e
18
tons CO2e/yr
921
tons CO2e
10
tons CO2e/vr
521
tons CO2e
LANDFILL CLOSURE
Dozers4
2
6480 hr/yr
18319.9 MMBtu/yr
152062.6 GGE/yr
308 tons CO2e/yr
862 tons CO2e
Tractor
1
3240 hr/yr
2748.0 MMBtu/yr
22809.4 GGE/yr
46 tons CO2e/yr
129 tons CO2e
Wheeled Backhoe4
1
3240 hr/yr
2748.0 MMBtu/yr
22809.4 GGE/yr
46 tons CO2e/yr
129 tons CO2e
Water Truck
1
3240 hr/yr
9159.9 MMBtu/yr
76031.3 GGE/yr
154 tons CO2e/yr
431 tons CO2e
Vibratory Roller4
1
3240 hr/yr
2198.4 MMBtu/yr
18247.5 GGE/yr
37 tons CO2e/yr
103 tons CO2e
Tracked Excavator4
1
3240 hr/yr
3664.0 MMBtu/yr
30412.5 GGE/yr
62 tons CO2e/yr
172 tons CO2e
Maint/Service Truck
1
3240 hr/yr
9159.9 MMBtu/yr
76031.3 GGE/yr
154 tons CO2e/yr
431 tons CO2e
55 KVA Diesel Generator
1
3240 hr/yr
1080.9 MMBtu/yr
8971.7 GGE/yr
18 tons CO2e/yr
51 tons CO2e
Appendix C - Air Emissions and Energy Use Analysis C-27 (Z6

Table 6. Marshall Indirect Greenhouse Gas Emissions
Activity
Number
of Units
Total Usage
Annual Total
Energy Usage
Total Project
GGE
WTP (Indirect)
GHG Emissionss
Project Indirect
GHG Emissions
Value Units
Value Units
Value Units
Value Units
Value Units
Personal Vehicles'
15
121500 miles/yr
10 tons CO2e/yr
29 tons CO2e
6,945 tons CO2e/yr
110,747 tons CO2e
Notes:
1. Personally Operated Vehicle use is estimated as:
-Excavation: 15 persons/day * 30 miles/person * 270 day/yr (it is assumed each person travels 15 -miles one-way to work);
-Landfill Construction: 25 persons/day * 30 miles/person * 270 day/yr.
2. It is assumed that the landfill location is 25 miles away, so 1 truck trip carrying ash is 50 miles, and 20 -ton trucks are used. It is assumed that the landfill cap/closure material for
the Removal alternative is taken from an adjacent land parcel, thus 1 truck trip carrying cap/closure material is taken to be 2 miles. It is assumed that the landfill cap/closure
material for the CIP alternative is taken from a site 25 miles aways, so 1 truck trip carrying cap/closure material for the CIP alternative is taken to be 50 miles.
3. It is assumed that the liner is transported 100 miles to the site/landfill on public roads and approximately 10 tons of liner are transported per trip
(3240 Ib/roll * 1 ton/2000 Ib * 6 rolls/truck trip = 10 ton/truck trip).
4. U.S. Energy Information Administration, Energy Explained - Energy Units and Calculators, 2015. Used diesel energy content of 137,871 Btu/gal and
gasoline energy content of 120,476 Btu/gal from http://www.eia.gov/energyexplained/?page=about_energy_units.
5. GHG emission factors from Results created by ANL on 11/12/2015 using GREETI_2015 version, October 2015 release, Argonne National Laboratory, 2015.
Emission Factors Well -To -Pump (WTP)16
Diesel 59 g CO2e/mi 1837 g CO2e/gge
Gasoline (E10) 77 g CO2e/mi
6. Annual Total Energy Usage values taken from Energy Usage calculations.
7. Conversion factor used: 1 HP = 2544.43 Btu/hr
Abbreviations:
GHG = Greenhouse Gas.
WTP = "Well -to -Pump" (also called Well -to -Tank, or WTT), refers to processes and activities involved in producing a fuel through when that fuel reaches a fueling station. This may
include raw material extraction, transportation, fuel production, distribution, and storage. For the purposes of this study, only WTP GHG emissions are considered as indirect
emissions. Indirect emissions in the PTW (Pump -to -Wheels) stage, such as refueling and evaporation, are not included as indirect emissions.
Appendix C - Air Emissions and Energy Use Analysis C-28 6, 2016

MNA
Monitor Only
Table 7. Marshall Energy Usage Calculations
Since similar monitoring would be required for each option for the project duration, similar energy usages are expected for each and the energy usage is not included in this estimate. It is
expected that the energy usage contributions from personal vehicles due to monitoring would be insignificant compared to the other source of energy usage.
CIP Cap in Place (CIP)
CIP Duration = 12 hr/day 270 day/yr 9.3 years 252271 truck trips carrying cap material
366 truck trips carrying liner material
Activity
Number
of Units
Usage
Value Units
Value Units
Hourly (per Unit)
Energy Usage9
Value Units
Annual Total
Energy Usage
Value Units
Total Project Energy
Usage
Value Units
Estimated Engine Size
Dozers 1,7
2
6480 hr/yr
500 HP each
2.8 MMBtu/hr
18320 MMBtu/yr
170375 MMBtu
Tractors''
1
3240 hr/yr
150 HP each
0.8 MMBtu/hr
2748 MMBtu/yr
25556 MMBtu
Wheeled Backhoe 1,7
1
3240 hr/yr
150 HP each
0.8 MMBtu/hr
2748 MMBtu/yr
25556 MMBtu
Water Truck l''
1
3240 hr/yr
500 HP each
2.8 MMBtu/hr
9160 MMBtu/yr
85188 MMBtu
Vibratory Rollers'7
1
3240 hr/yr
120 HP each
0.7 MMBtu/hr
2198 MMBtu/yr
20445 MMBtu
Tracked Excavator l'7
1
3240 hr/yr
200 HP each
1.1 MMBtu/hr
3664 MMBtu/yr
34075 MMBtu
Maint/Service Trucks''
1
3240 hr/yr
500 HP each
2.8 MMBtu/hr
9160 MMBtu/yr
85188 MMBtu
55 KVA Diesel Generators''
1
3240 hr/yr
59 HP each
0.3 MMBtu/hr
1081 MMBtu/yr
10052 MMBtu
Fuel Usage
Personal VehicleS2'3'8
15
121500 miles/yr
5678 gal/yr
684 MMBtu/yr
34679 MMBtu
Truck Transport - Cap Materia 14,6,8
N/A
27126 truck trips/yr
1356295 miles/yr
233844 gal/yr
32240 MMBtu/yr
299835 MMBtu
Truck Transport - Liner Materia 14,5,6,8
N/A
39 truck trips/yr
7866 miles/yr
1356 gal/yr
187 MMBtu/yr
1739 MMBtu
82,190 MMBtu/yr
792,688 1MMBtu
Appendix C - Air Emissions and Energy Use Analysis C-29 M6

Table 7. Marshall Energy Usage Calculations
Removal Excavation and Landfill
Landfill Construction Duration = 12 hr/day 300 day/yr 4.9 years 278 truck trips carrying liner material
Excavation Duration = 12 hr/day 270 day/yr 50.7 years 1369500 truck trips carrying ash
Closure Duration = 12 hr/day 270 day/yr 2.8 years 45768 truck trips carrying closure material
Activity
Number
of Units
Total Usage
Value Units
Value Units
Hourly (per Unit)
Energy Usage9
Value Units
Annual Total
Energy Usage
Value Units
Total Project Energy
Usage
Value Units
EXCAVATION
Estimated Engine Size
Tracked Excavators 1,7
2
6480 hr/yr
200 HP each
1.1 MMBtu/hr
7328 MMBtu/yr
371527 MMBtu
Dozers 1,7
2
6480 hr/yr
500 HP each
2.8 MMBtu/hr
18320 MMBtu/yr
928819 MMBtu
Wheeled Loaded''
1
3240 hr/yr
175 HP each
1.0 MMBtu/hr
3206 MMBtu/yr
162543 MMBtu
Dump Trucks 1,7
2
6480 hr/yr
25 HP each
0.1 MMBtu/hr
916 MMBtu/yr
46441 MMBtu
Water Truck l''
1
3240 hr/yr
500 HP each
2.8 MMBtu/hr
9160 MMBtu/yr
464409 MMBtu
Wheeled Backhoe 1'7
1
3240 hr/yr
150 HP each
0.8 MMBtu/hr
2748 MMBtu/yr
139323 MMBtu
6-8" Pumpsl''
2
6480 hr/yr
100 HP each
0.6 MMBtu/hr
3664 MMBtu/yr
185764 MMBtu
55 KVA Diesel Generators''
1
3240 hr/yr
59 HP each
0.3 MMBtu/hr
1081 MMBtu/yr
54800 MMBtu
Fuel Usage
Personal Vehicles2'3'8
15
121500 miles/yr
5678 gal/yr
684 MMBtu/yr
34679.4 MMBtu
MATERIAL TRANSPORT
Fuel Usage
Truck Transport - Ash 4,6,8
N/A
27012 truck trips/yr
1350592 miles/yr
232861 gal/yr
32105 MMBtu/yr
1627710 MMBtu
Truck Transport - Closure Materia 14,6,8
N/A
16346 truck trips/yr
32691 miles/yr
5636 gal/yr
777 MMBtu/yr
2176 MMBtu
Truck Transport - Liner Materia 14,5,6,8
N/A
36 truck trips/yr
7228 miles/yr
1246 gal/yr
172 MMBtu/yr
1323 MMBtu
LANDFILL CONSTRUCTION
Estimated Engine Size
Tracked Excavators l''
8
28800 hr/yr
200 HP each
1.1 MMBtu/hr
32569 MMBtu/yr
159587 MMBtu
Dozers 1,7
8
28800 hr/yr
500 HP each
2.8 MMBtu/hr
81422 MMBtu/yr
398967 MMBtu
Vibratory Compactors l''
4
14400 hr/yr
120 HP each
0.7 MMBtu/hr
9771 MMBtu/yr
47876 MMBtu
Wheeled Loadersl''
4
14400 hr/yr
175 HP each
1.0 MMBtu/hr
14249 MMBtu/yr
69819 MMBtu
Dump Trucks 1,7
8
28800 hr/yr
25 HP each
0.1 MMBtu/hr
4071 MMBtu/yr
19948 MMBtu
Water Trucks l''
4
14400 hr/yr
5001 HP each
2.8 MMBtu/hr
40711 MMBtu/yr
199483 MMBtu
Appendix C - Air Emissions and Energy Use Analysis C-30 M6

Table 7. Marshall Energy Usage Calculations
Activity
Number
of Units
Total Usage
Value Units
Value Units
Hourly (per Unit)
Energy Usage9
Value Units
Annual Total
Energy Usage
Value Units
Total Project Energy
Usage
Value Units
Wheeled Backhoesl'7
4
14400 hr/yr
150 HP each
0.8 MMBtu/hr
12213 MMBtu/yr
59845 MMBtu
6-8" Pumpsl''
8
28800 hr/yr
100 HP each
0.6 MMBtu/hr
16284 MMBtu/yr
79793 MMBtu
Maint/Service Trucks 1,7
4
14400 hr/yr
500 HP each
2.8 MMBtu/hr
40711 MMBtu/yr
199483 MMBtu
55 KVA Diesel Generators 1,7
4
14400 hr/yr
59 HP each
0.3 MMBtu/hr
4804 MMBtu/yr
23539 MMBtu
Fuel Usage
Personal Vehicles2'3'$
100
900000 miles/yr
42056 gal/yr
5067 MMBtu/yr
24827.1 MMBtu
LANDFILL FILLING
Estimated Engine Size
Dozers 1,7
2
6480 hr/yr
500 HP each
2.8 MMBtu/hr
18320 MMBtu/yr
928819 MMBtu
Tractors''
1
3240 hr/yr
150 HP each
0.8 MMBtu/hr
2748 MMBtu/yr
139323 MMBtu
Wheeled Backhoe 1,7
1
3240 hr/yr
150 HP each
0.8 MMBtu/hr
2748 MMBtu/yr
139323 MMBtu
Water Truck 1,7
1
3240 hr/yr
500 HP each
2.8 MMBtu/hr
9160 MMBtu/yr
464409 MMBtu
Vibratory Rolled'7
1
3240 hr/yr
120 HP each
0.7 MMBtu/hr
2198 MMBtu/yr
111458 MMBtu
Tracked Excavators''
1
3240 hr/yr
200 HP each
1.1 MMBtu/hr
3664 MMBtu/yr
185764 MMBtu
Maint/Service Trucks''
1
3240 hr/yr
500 HP each
2.8 MMBtu/hr
9160 MMBtu/yr
464409 MMBtu
55 KVA Diesel Generators''
1
3240 hr/yr
59 HP each
0.3 MMBtu/hr
1081 MMBtu/yr
54800 MMBtu
Fuel Usage
Personal VehicleS2'3'8
15
121500 miles/yr
5678 gal/yr
684 MMBtu/yr
34679.4 MMBtu
LANDFILL CLOSURE
Estimated Engine Size
Dozers 1,7
2
6480 hr/yr
500 HP each
2.8 MMBtu/hr
18320 MMBtu/yr
51296 MMBtu
Tractors''
1
3240 hr/yr
150 HP each
0.8 MMBtu/hr
2748 MMBtu/yr
7694 MMBtu
Wheeled Backhoe 1,7
1
3240 hr/yr
150 HP each
0.8 MMBtu/hr
2748 MMBtu/yr
7694 MMBtu
Water Truck 1,7
1
3240 hr/yr
500 HP each
2.8 MMBtu/hr
9160 MMBtu/yr
25648 MMBtu
Vibratory Rollers''
1
3240 hr/yr
120 HP each
0.7 MMBtu/hr
2198 MMBtu/yr
6155 MMBtu
Tracked Excavators''
1
3240 hr/yr
200 HP each
1.1 MMBtu/hr
3664 MMBtu/yr
10259 MMBtu
Maint/Service Trucks''
1
3240 hr/yr
500 HP each
2.8 MMBtu/hr
9160 MMBtu/yr
25648 MMBtu
55 KVA Diesel Generators''
1
3240 hr/yr
59 HP each
0.3 MMBtu/hr
1081 MMBtu/yr
3026 MMBtu
Fuel Usage
Personal Vehicles2'3'8
15
121500 miles/yr
5678 gal/yr
684 MMBtu/yr
1915.2 MMBtu
441,557 MMBtu/yr
7,965,004 MMBtu
Appendix C - Air Emissions and Energy Use Analysis C-31 September 30, 2016

Table 7. Marshall Energy Usage Calculations
Notes:
1. South Coast Air Quality Management District Off -Road Model Mobile Source Emission Factors for a 2016 fleet average from http://www.agmd.gov/home/regulations/ceqa/air-quality-analysis-
handbook/off-road-mobile-source-emission-factors.
2. Personally Operated Vehicle use is estimated as:
-Excavation: 15 persons/day * 30 miles/person * 270 day/yr (it is assumed each person travels 15 -miles one-way to work);
-Landfill Construction: 25 persons/day * 30 miles/person * 270 day/yr.
3. USDOT Bureau of Transportation Statistics Average Fuel Efficiency of U.S. Light Duty Vehicles for calendar year 2014 U.S. light-duty vehicles ( 21.4 mi/gal) from
http://www.rita.dot.gov/bts/sites/rita.dot.gov.bts/fi les/publications/nationa I_transportation_statistics/htm I/table_04_23. htm I.
4. It is assumed that the landfill location is 25 miles away, so 1 truck trip carrying ash is 50 miles, and 20 -ton trucks are used. It is assumed that the landfill cap/closure material for the
Removal alternative is taken from an adjacent land parcel, thus 1 truck trip carrying cap/closure material is taken to be 2 miles. It is assumed that the landfill cap/closure material for the CIP
alternative is taken from a site 25 miles aways, so 1 truck trip carrying cap/closure material for the CIP alternative is taken to be 50 miles.
5. It is assumed that the liner is transported 100 miles to the site/landfill on public roads and approximately 10 tons of liner are transported per trip
(3240 Ib/roll * 1 ton/2000 Ib * 6 rolls/truck trip = 10 ton/truck trip).
6. Oak Ridge National Laboratory Transportation Energy Data Book, Edition 34, September 2015. Class 7-8 average fuel economy (2013) is 5.8 mi/gal from
http://cta.ornl.gov/data/tedb34/Edition34_Chapter05.pdf.
7. USDOE Office of Energy Efficiency and Renewable Energy, Just the Basics Diesel Engine , 2003. Used estimated diesel engine efficiency of 45% from
http://wwwl.eere.energy.gov/vehiclesandfuels/pdfs/basics/J`tb_diesel_engine.pdf.
8. U.S. Energy Information Administration, Energy Explained- Energy Units and Calculators, 2015. Used diesel energy content of 137,871 Btu/gal and
gasoline energy content of 120,476 Btu/gal from http://www.eia.gov/energyexplained/?page=about_energy_units.
9. Conversion factor used: 1 HP = 2544.43 Btu/hr
Appendix C - Air Emissions and Energy Use Analysis C-32 September 30, 2016

MNA
Monitor Only
Table 8. Roxboro Air Emissions Calculations
Since similar monitoring would be required for each option for the project duration, similar emissions are expected for each and the emissions are not included in this estimate. It is expected that the emissions contributions from
personal vehicles due to monitoring would be insignificant compared to the other emission sources.
CIP Cap in Place (CIP)
CIP Duration = 12 hr/day 270 day/yr 8.2 years 220436 truck trips carrying cap material
319 truck trips carrying liner material
Appendix C - Air Emissions and Energy Use Analysis C-33 (216
Usage
NOx
Emission Factors
PM10/PM2.5 Direct CO2
Direct CH4
Emissions
(tons/yr)
Cumulative Emissions
(tons CO2e)
Activity
Value Units
Value Units
Value Units
Value Units
Value Units
NOx
PM10/PM2.5 Direct GHG (CO2e)
Direct GHG
2 Dozers'
6480 hr/yr
2.0891 lb/hr
0.0858 lb/hr
239 Ib/hr
0.0234 lb/hr
6.77
0.28
776.26
6365.29
Tractor'
3240 hr/yr
0.4070 Ib/hr
0.0258 lb/hr
66.8 Ib/hr
0.0055 lb/hr
0.66
0.04
108.44
889.20
Wheeled Backhoe'
3240 hr/yr
0.4070 Ib/hr
0.0258 lb/hr
66.8 Ib/hr
0.0055 lb/hr
0.66
0.04
108.44
889.20
Water Truck'
3240 hr/yr
1.3322 Ib/hr
0.0459 lb/hr
260 Ib/hr
0.0164 lb/hr
2.16
0.07
421.86
3459.29
Vibratory Roller'
3240 hr/yr
0.5273 Ib/hr
0.0353lb/hr
67 Ib/hr
0.0071 lb/hr
0.85
0.06
108.83
892.39
Tracked Excavator'
3240 hr/yr
0.6603 Ib/hr
0.0332 lb/hr
120 Ib/hr
0.0089 lb/hr
1.07
0.05
194.76
1597.04
Maint/Service Truck'
3240 hr/yr
1.3322 Ib/hr
0.0459 Ib/hr
260 Ib/hr
0.0164 Ib/hr
2.16
0.07
421.86
3459.29
55 KVA Diesel Generator'
3240 hr/yr
0.6102 Ib/hr
0.0431 lb/hr
77.9 Ib/hr
0.0073 lb/hr
0.99
0.07
126.49
1037.25
15 Personal Vehicles2'3'4'5'6
121500 miles/yr
0.95 g/mile
0.0045 g/mile
410 g/mile
0.0452 g/mile
0.13
0.00
55.10
451.82
Truck Transport - Cap Materia 17,8,9,10
26882 truck trips yr
459.55 g/truck trip
trip
138000 g/truck trip
0.255 g/truck trip
13.62
0.32
4089.52
33534.07
Truck Transport - Liner Material''8'9'10'11
39 Itruck trips/yr I
r10.75.9/truck
1838.20 g/truck trip
43.00 g/truck trip
552000 g/truck trip
1.02 g/truck trip
0.08
0.00
23.67
194.11
29.14
1.01
6,435.241
52,768.94
Appendix C - Air Emissions and Energy Use Analysis C-33 (216

Table 8. Roxboro Air Emissions Calculations
Removal Excavation and Landfill
Landfill Construction Duration = 12 hr/day 300 day/yr 6.0 years 342 truck trips carrying liner material (construction & closure)
Excavation Duration = 12 hr/day 270 day/yr 63.8 years 1723000 truck trips carrying ash
Closure Duration = 12 hr/day 270 day/yr 3.5 years 56221 truck trips carrying closure material
Appendix C - Air Emissions and Energy Use Analysis C-34 (216
Usage
NOx
Emission Factors
PM10/PM2.5 Direct CO2
Direct CH4
Emissions
(tons/yr)
Cumulative Emissions
(tons CO2e)
Activity
Value Units
Value Units
Value Units
Value Units
Value Units
NOx
PM10/PM2.5 Direct GHG (CO2e)
Direct GHG
EXCAVATION
2 Tracked Excavators'
6480 hr/yr
0.6603 Ib/hr
0.0332 lb/hr
120 Ib/hr
0.0089 lb/hr
2.14
0.11
389.52
24851.43
2 Dozers'
6480 hr/yr
2.0891 lb/hr
0.0858 lb/hr
239 Ib/hr
0.0234 lb/hr
6.77
0.28
776.26
49525.09
Wheeled Loader'
3240 hr/yr
0.7114 Ib/hr
0.0375 lb/hr
109 Ib/hr
0.0089 Ib/hr
1.15
0.06
176.94
11288.80
2 Dump Trucks'
6480 hr/yr
0.0587 Ib/hr
0.0024lb/hr
7.6 Ib/hr
0.0008 lb/hr
0.19
0.01
24.69
1575.15
Water Truck'
3240 hr/yr
1.3322 lb/hr
0.0459 Ib/hr
260 Ib/hr
0.0164 lb/hr
2.16
0.07
421.86
26914.94
Wheeled Backhoe'
3240 hr/yr
0.4070 Ib/hr
0.0258 lb/hr
66.8 Ib/hr
0.0055 lb/hr
0.66
0.04
108.44
6918.39
2 6-8" Pumps'
6480 hr/yr
0.3830 Ib/hr
0.0239 Ib/hr
49.6 Ib/hr
0.0051 lb/hr
1.24
0.08
161.12
10279.27
55 KVA Diesel Generator'
3240 hr/yr
0.6102 Ib/hr
0.0431 lb/hr
77.9 Ib/hr
0.0073 lb/hr
0.99
0.07
126.49
8070.29
15 Personal Vehicles2'3'4'5
121500 miles/yr
0.95 g/mile
0.0045 g/mile
410 g/mile
0.0452 g/mile 1
0.13
0.00
55.10
3515.42
MATERIAL TRANSPORT
Truck Transport - Ash 7,8,9,10
27006 truck trips/yr
459.55 g/truck trip
10.75 g/truck trip
138000 g/truck trip
0.2550 g/truck trip
13.68
0.32
4108.36
262113.29
Truck Transport - Closure Materia 17,8,9,10
16063 truck trips/yr
18.38 g/truck trip
0.43 g/truck trip
5520 g/truck trip
0.0102 g/truck trip
0.33
0.01
97.74
342.11
Truck Transport - Liner Materia 17,8,9,10,11
36 truck trips/yr
1838.20 g/truck trip
43 g/truck trip
552000 g/truck trip
1.0200 g/truck trip
0.07
0.00
21.91
208.11
LANDFILL CONSTRUCT.
8 Tracked Excavators'
28800 hr/yr
0.6603 Ib/hr
0.0332 lb/hr
120 Ib/hr
0.0089 Ib/hr
9.51
0.48
1731.20
16446.44
8 Dozers'
28800 hr/yr
2.0891 lb/hr
0.0858 lb/hr
239 Ib/hr
0.0234 lb/hr
30.08
1.24
3450.02
32775.23
4 Vibratory Compactors'
14400 hr/yr
0.568 Ib/hr
0.0234 lb/hr
123 Ib/hr
0.0065 lb/hr
4.09
0.17
886.77
8424.32
4 Wheeled Loaders'
14400 hr/yr
0.7114 Ib/hr
0.0375 lb/hr
109 Ib/hr
0.0089 Ib/hr
5.12
0.27
786.40
7470.82
8 Dump Trucks'
28800 hr/yr
0.0587 Ib/hr
0.0024 lb/hr
7.6 Ib/hr
0.0008 lb/hr
0.85
0.03
109.73
1042.42
4 Water Trucks'
14400 hr/yr
1.3322 Ib/hr
0.0459lb/hr
260 Ib/hr
0.0164 lb/hr
9.59
0.33
1874.95
17812.04
4 Wheeled Backhoes'
14400 hr/yr
0.4070 Ib/hr
0.0258 Ib/hr
66.8 Ib/hr
0.0055 Ib/hr
2.93
0.19
481.95
4578.53
8 6-8" Pumps'
28800 hr/yr
0.3830 Ib/hr
0.0239 lb/hr
49.6 Ib/hr
0.0051 lb/hr
5.52
0.34
716.08
6802.72
4 Maint/Service Trucks'
14400 hr/yr
1.3322 Ib/hr
0.0459 Ib/hr
260 Ib/hr
0.0164 lb/hr
9.59
0.33
1874.95
17812.04
4 55 KVA Diesel Generator'
14400 hr/yr
0.6102 Ib/hr
0.0431 lb/hr
77.9 Ib/hr
0.0073 lb/hr
4.39
0.31
562.19
5340.84
100 Personal Vehicles2,3,4,5
900000 miles/yr
0.95 g/mile
0.0045 g/mile
410 g/mile
0.0452 g/mile
0.94
0.00
408
3877.45
LANDFILL FILLING
2 Dozers'
6480 hr/yr
2.0891 lb/hr
0.0858 lb/hr
239 Ib/hr
0.0234 lb/hr
6.77
0.28
776.26
49525.09
Tractor'
3240 hr/yr
0.4070 Ib/hr
0.0258 lb/hr
66.8 Ib/hr
0.0055 lb/hr
0.661
0.041
108.44
6918.39
Wheeled Backhoe'
3240 hr/yr
0.4070 Ib/hr
0.0258 lb/hr
66.8 Ib/hr
0.0055 lb/hr
0.661
0.041
108.44
6918.39
Water Truck'
3240 hr/yr
1.3322 Ib/hr
0.0459 lb/hr
260 Ib/hr
0.0164 lb/hr 1
2.161
0.071
421.86
26914.94
Vibratory Roller'
3240 hr/yr
0.5273 Ib/hr
0.0353lb/hr
67 Ib/hr
0.00711b/hr
0.85
0.06
108.83
6943.20
Appendix C - Air Emissions and Energy Use Analysis C-34 (216

Table 8. Roxboro Air Emissions Calculations
Notes:
1. South Coast Air Quality Management District Off -Road Model Mobile Source Emission Factors for a 2016 fleet average from http://www.agmd.gov/home/regulations/ceqa/air-quality-analysis-handbook/off-road-mobile-source-
emission-factors.
2. USEPA Center for Corporate Climate Leadership Greenhouse Gas Inventory Guidance: Direct Emissions from Mobile Combustion Sources Tier 1 Gasoline Light -Duty Truck emission factors (0.0452 g CH4/mile) from
https://www.epa.gov/sites/production/fi les/2016-03/documents/mobileem issions_3_2016. pdf.
3. Personally Operated Vehicle (POV) use is estimated as:
-Excavation: 15 persons/day * 30 miles/person * 270 day/yr (it is assumed each person travels 15 -miles one-way to work);
-Landfill Construction: 25 persons/day * 30 miles/person * 270 day/yr.
4. USDOT Bureau of Transportation Statistics Average Fuel Efficiency of U.S. Light Duty Vehicles for calendar year 2014 (21.4 miles/gal) for POV CO2 emissions from
http://www. rita.dot.gov/bts/sites/rita.dot.gov. bts/files/publications/national_tra nsportation_statistics/htmi/table 04_23.html.
5. 100 -yr GWP for CH4 (25 kg CO2e/kg CH4) from Intergovernmental Panel on Climate Change (IPCC), Fourth Assessment Report (AR4), 2007.
6. USEPA Office of Transportation and Air Quality Average Annual Emissions and Fuel Consumption for Gasoline -Fueled Passenger Cars and Light Trucks light-duty trucks emissions estimates for the in -use fleet as of 2008 based on
https://www3.epa.gov/otaq/consumer/42OfO8O24.pdf.
7. It is assumed that the landfill location is 25 miles away, so 1 truck trip carrying ash is 50 miles, and 20 -ton trucks are used. It is assumed that the landfill cap/closure material for the Removal alternative is taken from an adjacent
land parcel, thus 1 truck trip carrying cap/closure material is taken to be 2 miles. It is assumed that the landfill cap/closure material for the CIP alternative is taken from a site 25 miles aways, so 1 truck trip carrying cap/closure
material for the CIP alternative is taken to be 50 miles.
S. USEPA Office of Transportation and Air Quality Average In -Use Emissions from Heavy -Duty Trucks NOx and PM10/PM2.5 emission factors approximated as a diesel Heavy -Duty Vehicle Class Villa (33,001-60,000 Ib GVWR--since it
is for 20 ton (40,000 Ib) material +truck) --based on the in -use fleet from July 2008 from https://www3.epa.gov/otaq/consumer/42OfO8O27.pdf.
9. USEPA Center for Corporate Climate Leadership Emission Factors for Greenhouse Gas Inventories greenhouse gas emission factors approximated as heavy duty vehicles for 1960 -present from Table 4 of
https://www.epa.gov/sites/production/files/2015-12/documents/emission-factors_nov_2015.pdf, dated November 2015.
10. It is assumed that the weight of the vehicle + load is approximately 60,000 Ib (20 -ton load and 10 -ton truck). Diesel heavy duty combination truck CO2 emission factor for MY2014/Class 8/Day Cab is 92 g CO2/ton-mile taken
from https://www.gpo.gov/fdsys/pkg/FR-2011-09-15/pdf/2011-20740.pdf (EPA/DOT Federal Register Vol. 76, No. 179, 15 September 2011).
-92 g CO2/ton-mile * (30 ton*x mile)/truck trip = y g CO2/truck trip
11. It is assumed that the liner is transported 100 miles to the site/landfill on public roads and approximately 10 tons of liner are transported per trip (3240 Ib/roll * 1 ton/2000 Ib * 6 rolls/truck trip = 10 ton/truck trip).
Appendix C - Air Emissions and Energy Use Analysis C-35 September 30, 2016
Usage
NOx
Emission Factors
PMlo/PM2.5 Direct CO2
Direct CH,
Emissions
(tons/yr)
Cumulative Emissions
(tons CO2e)
Activity
Value Units
Value Units
Value Units
Value Units
Value Units
NOx
PM10/PM2.5 Direct GHG (CO2e)
Direct GHG
Tracked Excavator'
3240 hr/yr
0.6603 Ib/hr
0.0332 Ib/hr
120 Ib/hr
0.0089 Ib/hr
1.07
0.05
194.76
12425.72
Maint/Service Trucks
3240 hr/yr
1.3322 Ib/hr
0.0459 Ib/hr
260 Ib/hr
0.0164 Ib/hr
2.16
0.07
421.86
26914.94
55 KVA Diesel Generator'
3240 hr/yr
0.6102 Ib/hr
0.0431 Ib/hr
77.9 Ib/hr
0.0073 Ib/hr
0.99
0.07
126.49
8070.29
15 Personal Vehicles2,3,4'5'6
121500 miles/yr
0.95 g/mile
0.0045 g/mile
410 g/mile
0.0452 g/mile
0.13
0.00
55.10
3515.42
LANDFILL CLOSURE
2 Dozers'
6480 hr/yr
2.0891 lb/hr
0.0858 lb/hr
239 Ib/hr
0.0234 lb/hr
6.77
0.28
776.26
2716.89
Tractor'
3240 hr/yr
0.4070 Ib/hr
0.0258 lb/hr
66.8 Ib/hr
0.0055 Ib/hr
0.66
0.04
108.44
379.54
Wheeled Backhoe'
3240 hr/yr
0.4070 Ib/hr
0.0258 lb/hr
66.8 Ib/hr
0.0055 lb/hr
0.66
0.04
108.44
379.54
Water Truck'
3240 hr/yr
1.3322 Ib/hr
0.0459 Ib/hr
260 Ib/hr
0.0164 lb/hr
2.16
0.07
421.86
1476.52
Vibratory Roller'
3240 hr/yr
0.5273 Ib/hr
0.0353lb/hr
67 Ib/hr
0.0071 lb/hr
0.85
0.06
108.83
380.90
Tracked Excavator'
3240 hr/yr
0.6603 Ib/hr
0.0332 Ib/hr
120 Ib/hr
0.0089 Ib/hr
1.07
0.05
194.76
681.66
Maint/Service Truck'
3240 hr/yr
1.3322 Ib/hr
0.0459 Ib/hr
260 Ib/hr
0.0164 Ib/hr
2.16
0.07
421.86
1476.52
55 KVA Diesel Generator'
3240 hr/yr
0.6102 Ib/hr
0.0431 lb/hr
77.9 Ib/hr
0.0073 lb/hr
0.99
0.071
126.49
442.73
15 Personal Vehicles2,3,4,5'6
121500 miles/yr
0.95 g/mile
0.0045 g/mile
410 g/mile
0.0452 g/mile
0.13
0.00
55.101
192.85
143.00
6.12
23,994.921
684,258.66
Notes:
1. South Coast Air Quality Management District Off -Road Model Mobile Source Emission Factors for a 2016 fleet average from http://www.agmd.gov/home/regulations/ceqa/air-quality-analysis-handbook/off-road-mobile-source-
emission-factors.
2. USEPA Center for Corporate Climate Leadership Greenhouse Gas Inventory Guidance: Direct Emissions from Mobile Combustion Sources Tier 1 Gasoline Light -Duty Truck emission factors (0.0452 g CH4/mile) from
https://www.epa.gov/sites/production/fi les/2016-03/documents/mobileem issions_3_2016. pdf.
3. Personally Operated Vehicle (POV) use is estimated as:
-Excavation: 15 persons/day * 30 miles/person * 270 day/yr (it is assumed each person travels 15 -miles one-way to work);
-Landfill Construction: 25 persons/day * 30 miles/person * 270 day/yr.
4. USDOT Bureau of Transportation Statistics Average Fuel Efficiency of U.S. Light Duty Vehicles for calendar year 2014 (21.4 miles/gal) for POV CO2 emissions from
http://www. rita.dot.gov/bts/sites/rita.dot.gov. bts/files/publications/national_tra nsportation_statistics/htmi/table 04_23.html.
5. 100 -yr GWP for CH4 (25 kg CO2e/kg CH4) from Intergovernmental Panel on Climate Change (IPCC), Fourth Assessment Report (AR4), 2007.
6. USEPA Office of Transportation and Air Quality Average Annual Emissions and Fuel Consumption for Gasoline -Fueled Passenger Cars and Light Trucks light-duty trucks emissions estimates for the in -use fleet as of 2008 based on
https://www3.epa.gov/otaq/consumer/42OfO8O24.pdf.
7. It is assumed that the landfill location is 25 miles away, so 1 truck trip carrying ash is 50 miles, and 20 -ton trucks are used. It is assumed that the landfill cap/closure material for the Removal alternative is taken from an adjacent
land parcel, thus 1 truck trip carrying cap/closure material is taken to be 2 miles. It is assumed that the landfill cap/closure material for the CIP alternative is taken from a site 25 miles aways, so 1 truck trip carrying cap/closure
material for the CIP alternative is taken to be 50 miles.
S. USEPA Office of Transportation and Air Quality Average In -Use Emissions from Heavy -Duty Trucks NOx and PM10/PM2.5 emission factors approximated as a diesel Heavy -Duty Vehicle Class Villa (33,001-60,000 Ib GVWR--since it
is for 20 ton (40,000 Ib) material +truck) --based on the in -use fleet from July 2008 from https://www3.epa.gov/otaq/consumer/42OfO8O27.pdf.
9. USEPA Center for Corporate Climate Leadership Emission Factors for Greenhouse Gas Inventories greenhouse gas emission factors approximated as heavy duty vehicles for 1960 -present from Table 4 of
https://www.epa.gov/sites/production/files/2015-12/documents/emission-factors_nov_2015.pdf, dated November 2015.
10. It is assumed that the weight of the vehicle + load is approximately 60,000 Ib (20 -ton load and 10 -ton truck). Diesel heavy duty combination truck CO2 emission factor for MY2014/Class 8/Day Cab is 92 g CO2/ton-mile taken
from https://www.gpo.gov/fdsys/pkg/FR-2011-09-15/pdf/2011-20740.pdf (EPA/DOT Federal Register Vol. 76, No. 179, 15 September 2011).
-92 g CO2/ton-mile * (30 ton*x mile)/truck trip = y g CO2/truck trip
11. It is assumed that the liner is transported 100 miles to the site/landfill on public roads and approximately 10 tons of liner are transported per trip (3240 Ib/roll * 1 ton/2000 Ib * 6 rolls/truck trip = 10 ton/truck trip).
Appendix C - Air Emissions and Energy Use Analysis C-35 September 30, 2016

MNA
Monitor Only
Table 9. Roxboro Indirect Greenhouse Gas Emissions
Since similar monitoring would be required for each option for the project duration, similar emissions are expected for each and the emissions are not included in this estimate. It is
expected that the emissions contributions from personal vehicles due to monitoring would be insignificant compared to the other emission sources.
CIP Cap in Place (CIP)
CIP Duration = 12 hr/day 270 day/yr 8.2 years 220436 truck trips carrying cap material
319 truck trips carrying liner material
Activity
Number
of Units
Usage
Value Units
Annual Total
Energy Usage
Value Units
Total Project
GGE
Value Units
WTP (Indirect)
GHG Emissionss
Value Units
Project Indirect
GHG Emissions
Value Units
Dozers4
2
6480 hr/yr
18319.9 MMBtu/yr
152062.6 GGE/yr
308 tons CO2e/yr
2525 tons CO2e
Tractor
1
3240 hr/yr
2748.0 MMBtu/yr
22809.4 GGE/yr
46 tons CO2e/yr
379 tons CO2e
Wheeled Backhoe4
1
3240 hr/yr
2748.0 MMBtu/yr
22809.4 GGE/yr
46 tons CO2e/yr
379 tons CO2e
Water Truck 4
1
3240 hr/yr
9159.9 MMBtu/yr
76031.3 GGE/yr
154 tons CO2e/yr
1263 tons CO2e
Vibratory Roller
1
3240 hr/yr
2198.4 MMBtu/yr
18247.5 GGE/yr
37 tons CO2e/yr
303 tons CO2e
Tracked Excavator4
1
3240 hr/yr
3664.0 MMBtu/yr
30412.5 GGE/yr
62 tons CO2e/yr
505 tons CO2e
Maint/Service Truck
1
3240 hr/yr
9159.9 MMBtu/yr
76031.3 GGE/yr
154 tons CO2e/yr
1263 tons CO2e
55 KVA Diesel Generator
1
3240 hr/yr
1080.9 MMBtu/yr
8971.7 GGE/yr
18 tons CO2e/yr
149 tons CO2e
Personal Vehicles'
15
121500 miles/yr
10 tons CO2e/yr
84 tons CO2e
Truck Transport - Cap Materia 12
N/A
26882 truck trips/yr
1344122 miles/yr
87 tons CO2e/yr
713 tons CO2e
Truck Transport - Liner Materia 12,3
N/A
39 truck trips/yr
7792 miles/yr
0.5 tons CO2e/yr
4 tons CO2e
923 tons CO2e/yr
7,567 tons CO2e
Appendix C - Air Emissions and Energy Use Analysis C-36 September 30, 2016

Removal
Landfill Construction Duration =
Excavation Duration =
Closure Duration =
Table 9. Roxboro Indirect Greenhouse Gas Emissions
Excavation and Landfill
12 hr/day 300 day/yr
12 hr/day 270 day/yr
12 hr/day 270 day/yr
6 years 342 truck trips carrying liner material
63.8 years 1723000 truck trips carrying ash
3.5 years 56221 truck trips carrying closure material
LANDFILL CONSTRUCTION
Tracked Excavators 8 28800 hr/yr 32568.7 MMBtu/yr 270333.5 GGE/yr 548 tons CO2e/yr 3285 tons CO2e
Dozers4 8 28800 hr/yr 81421.8 MMBtu/yr 675833.9 GGE/yr 1369 tons CO2e/yr 8213 tons CO2e
Vibratory Compactors4 4 14400 hr/yr 9770.6 MMBtu/yr 81100.1 GGE/yr 164 tons CO2e/yr 986 tons CO2e
Appendix C - Air Emissions and Energy Use Analysis C-37 September 30, 2016
Annual Total
Total Project
WTP (Indirect)
Project Indirect
Number
Total Usage
Energy Usage
GGE
GHG Emissionss
GHG Emissions
Activity
of Units
Value Units
Value Units
Value Units
Value Units
Value Units
EXCAVATION
Tracked Excavators
2
6480 hr/yr
7328.0 MMBtu/yr
60825.0 GGE/yr
123 tons CO2e/yr
7860 tons CO2e
Dozers4
2
6480 hr/yr
18319.9 MMBtu/yr
152062.6 GGE/yr
308 tons CO2e/yr
19649 tons CO2e
Wheeled Loader
1
3240 hr/yr
3206.0 MMBtu/yr
26611.0 GGE/yr
54 tons CO2e/yr
3439 tons CO2e
Dump Trucks4
2
6480 hr/yr
916.0 MMBtu/yr
7603.1 GGE/yr
15 tons CO2e/yr
982 tons CO2e
Water Truck 4
1
3240 hr/yr
9159.9 MMBtu/yr
76031.3 GGE/yr
154 tons CO2e/yr
9824 tons CO2e
Wheeled Backhoe4
1
3240 hr/yr
2748.0 MMBtu/yr
22809.4 GGE/yr
46 tons CO2e/yr
2947 tons CO2e
6-8" Pumps4
2
6480 hr/yr
3664.0 MMBtu/yr
30412.5 GGE/yr
62 tons CO2e/yr
3930 tons CO2e
55 KVA Diesel Generator4
1
3240 hr/yr
1080.9 MMBtu/yr
8971.7 GGE/yr
18 tons CO2e/yr
1159 tons CO2e
Personal Vehicles'
15
121500 miles/yr
10 tons CO2e/yr
656 tons CO2e
MATERIAL TRANSPORT
Truck Transport - Ash
N/A
27006 truck trips/yr
1350313 miles/yr
87 tons CO2e/yr
5575 tons CO2e
Truck Transport - Closure Materia 12
N/A
16063 truck trips/yr
32126 miles/yr
2 tons CO2e/yr
7 tons CO2e
Truck Transport - Liner Materia 12,3
N/A
36 truck trips/yr
7194 miles/yr
0.5 tons CO2e/yr
4 tons CO2e
LANDFILL CONSTRUCTION
Tracked Excavators 8 28800 hr/yr 32568.7 MMBtu/yr 270333.5 GGE/yr 548 tons CO2e/yr 3285 tons CO2e
Dozers4 8 28800 hr/yr 81421.8 MMBtu/yr 675833.9 GGE/yr 1369 tons CO2e/yr 8213 tons CO2e
Vibratory Compactors4 4 14400 hr/yr 9770.6 MMBtu/yr 81100.1 GGE/yr 164 tons CO2e/yr 986 tons CO2e
Appendix C - Air Emissions and Energy Use Analysis C-37 September 30, 2016

Wheeled Loaders"
Dump Trucks4
Water Trucks4
Wheeled Backhoes4
6-8" Pumps4
Maint/Service Trucks4
55 KVA Diesel Generators4
Personal Vehicles'
LANDFILL FILLING
Dozers4
Tractor
Wheeled Backhoe4
Water Truck
Vibratory Roller
Maint/Service Truck"
55 KVA Diesel Generator
Personal Vehicles'
Number
of Units
4
8
4
4
8
4
4
100
2
1
1
1
1
1
1
1
15
Table 9. Roxboro Indirect Greenhouse Gas Emissions
Total Usage
Value Units
14400 hr/yr
28800 hr/yr
14400 hr/yr
14400 hr/yr
28800 hr/yr
14400 hr/yr
14400 hr/yr
900000 miles/vr
6480 hr/yr
3240 hr/yr
3240 hr/yr
3240 hr/yr
3240 hr/yr
3240 hr/yr
3240 hr/yr
3240 hr/yr
121500 miles
Annual Total
Energy Usage
Value Units
14248.8 MMBtu/yr
4071.1 MMBtu/yr
40710.9 MMBtu/yr
12213.3 MMBtu/yr
16284.4 MMBtu/yr
40710.9 MMBtu/yr
4803.9 MMBtu/vr
18319.9 MMBtu/yr
2748.0 MMBtu/yr
2748.0 MMBtu/yr
9159.9 MMBtu/yr
2198.4 MMBtu/yr
3664.0 MMBtu/yr
9159.9 MMBtu/yr
1080.9 MMBtu/vr
Total Project
GGE
Value Units
118270.9 GGE/yr
33791.7 GGE/yr
337916.9 GGE/yr
101375.1 GGE/yr
135166.8 GGE/yr
337916.9 GGE/yr
39874.2 GGE/vr
152062.6 GGE/yr
22809.4 GGE/yr
22809.4 GGE/yr
76031.3 GGE/yr
18247.5 GGE/yr
30412.5 GGE/yr
76031.3 GGE/yr
8971.7 GGE/vr
WTP (Indirect)
GHG Emissionss
Value Units
240 tons CO2e/yr
68 tons CO2e/yr
684 tons CO2e/yr
205 tons CO2e/yr
274 tons CO2e/yr
684 tons CO2e/yr
81 tons CO2e/yr
76 tons CO2e/vr
Project Indirect
GHG Emissions
Value Units
1437 tons CO2e
411 tons CO2e
4106 tons CO2e
1232 tons CO2e
1643 tons CO2e
4106 tons CO2e
485 tons CO2e
457 tons CO2e
308
tons CO2e/yr
19649
tons CO2e
46
tons CO2e/yr
2947
tons CO2e
46
tons CO2e/yr
2947
tons CO2e
154
tons CO2e/yr
9824
tons CO2e
37
tons CO2e/yr
2358
tons CO2e
62
tons CO2e/yr
3930
tons CO2e
154
tons CO2e/yr
9824
tons CO2e
18
tons CO2e/yr
1159
tons CO2e
10
tons CO2e/vr
656
tons CO2e
LANDFILL CLOSURE
Dozers4
2
6480 hr/yr
18319.9 MMBtu/yr
152062.6 GGE/yr
308 tons CO2e/yr
1078 tons CO2e
Tractor
1
3240 hr/yr
2748.0 MMBtu/yr
22809.4 GGE/yr
46 tons CO2e/yr
162 tons CO2e
Wheeled Backhoe4
1
3240 hr/yr
2748.0 MMBtu/yr
22809.4 GGE/yr
46 tons CO2e/yr
162 tons CO2e
Water Truck
1
3240 hr/yr
9159.9 MMBtu/yr
76031.3 GGE/yr
154 tons CO2e/yr
539 tons CO2e
Vibratory Roller4
1
3240 hr/yr
2198.4 MMBtu/yr
18247.5 GGE/yr
37 tons CO2e/yr
129 tons CO2e
Tracked Excavator4
1
3240 hr/yr
3664.0 MMBtu/yr
30412.5 GGE/yr
62 tons CO2e/yr
216 tons CO2e
Maint/Service Truck
1
3240 hr/yr
9159.9 MMBtu/yr
76031.3 GGE/yr
154 tons CO2e/yr
539 tons CO2e
55 KVA Diesel Generator
1
3240 hr/yr
1080.9 MMBtu/yr
8971.7 GGE/yr
18 tons CO2e/yr
64 tons CO2e
Appendix C - Air Emissions and Energy Use Analysis C-38 September 30, 2016

Table 9. Roxboro Indirect Greenhouse Gas Emissions
Activity
Number
of Units
Total Usage
Annual Total
Energy Usage
Total Project
GGE
WTP (Indirect)
GHG Emissionss
Project Indirect
GHG Emissions
Value Units
Value Units
Value Units
Value Units
Value Units
Personal Vehicles'
15
121500 miles/yr
10 tons CO2e/yr
36 tons CO2e
6,945 tons CO2e/yr
138,611 tons CO2e
Notes:
1. Personally Operated Vehicle use is estimated as:
-Excavation: 15 persons/day * 30 miles/person * 270 day/yr (it is assumed each person travels 15 -miles one-way to work);
-Landfill Construction: 25 persons/day * 30 miles/person * 270 day/yr.
2. It is assumed that the landfill location is 25 miles away, so 1 truck trip carrying ash is 50 miles, and 20 -ton trucks are used. It is assumed that the landfill cap/closure material for
the Removal alternative is taken from an adjacent land parcel, thus 1 truck trip carrying cap/closure material is taken to be 2 miles. It is assumed that the landfill cap/closure
material for the CIP alternative is taken from a site 25 miles aways, so 1 truck trip carrying cap/closure material for the CIP alternative is taken to be 50 miles.
3. It is assumed that the liner is transported 100 miles to the site/landfill on public roads and approximately 10 tons of liner are transported per trip
(3240 Ib/roll * 1 ton/2000 Ib * 6 rolls/truck trip = 10 ton/truck trip).
4. U.S. Energy Information Administration, Energy Explained - Energy Units and Calculators, 2015. Used diesel energy content of 137,871 Btu/gal and
gasoline energy content of 120,476 Btu/gal from http://www.eia.gov/energyexplained/?page=about_energy_units.
5. GHG emission factors from Results created by ANL on 11/12/2015 using GREETI_2015 version, October 2015 release, Argonne National Laboratory, 2015.
Emission Factors Well -To -Pump (WTP)16
Diesel 59 g CO2e/mi 1837 g CO2e/gge
Gasoline (E10) 77 g CO2e/mi
6. Annual Total Energy Usage values taken from Energy Usage calculations.
7. Conversion factor used: 1 HP = 2544.43 Btu/hr
Abbreviations:
GHG = Greenhouse Gas.
WTP = "Well -to -Pump" (also called Well -to -Tank, or WTT), refers to processes and activities involved in producing a fuel through when that fuel reaches a fueling station. This may
include raw material extraction, transportation, fuel production, distribution, and storage. For the purposes of this study, only WTP GHG emissions are considered as indirect
emissions. Indirect emissions in the PTW (Pump -to -Wheels) stage, such as refueling and evaporation, are not included as indirect emissions.
Appendix C - Air Emissions and Energy Use Analysis C-39 September 30, 2016

MNA
Monitor Only
Table 10. Roxboro Energy Usage Calculations
Since similar monitoring would be required for each option for the project duration, similar energy usages are expected for each and the energy usage is not included in this estimate. It is
expected that the energy usage contributions from personal vehicles due to monitoring would be insignificant compared to the other source of energy usage.
CIP Cap in Place (CIP)
CIP Duration = 12 hr/day 270 day/yr 8.2 years 220436 truck trips carrying cap material
319 truck trips carrying liner material
Activity
Number
of Units
Usage
Value Units
Value Units
Hourly per Unit
Energy Usage9
Value Units
Annual Total
Energy Usage
Value Units
Total Project Energy
Usage
Value Units
Estimated Engine Size
Dozers 1,7
2
6480 hr/yr
500 HP each
2.8 MMBtu/hr
18320 MMBtu/yr
150223 MMBtu
Tractors''
1
3240 hr/yr
150 HP each
0.8 MMBtu/hr
2748 MMBtu/yr
22533 MMBtu
Wheeled Backhoe 1,7
1
3240 hr/yr
150 HP each
0.8 MMBtu/hr
2748 MMBtu/yr
22533 MMBtu
Water Truck 1,7
1
3240 hr/yr
500 HP each
2.8 MMBtu/hr
9160 MMBtu/yr
75112 MMBtu
Vibratory Rolled''
1
3240 hr/yr
120 HP each
0.7 MMBtu/hr
2198 MMBtu/yr
18027 MMBtu
Tracked Excavators''
1
3240 hr/yr
200 HP each
1.1 MMBtu/hr
3664 MMBtu/yr
30045 MMBtu
Maint/Service Trucks''
1
3240 hr/yr
500 HP each
2.8 MMBtu/hr
9160 MMBtu/yr
75112 MMBtu
55 KVA Diesel Generators''
1
3240 hr/yr
59 HP each
0.3 MMBtu/hr
1081 MMBtu/yr
8863 MMBtu
Fuel Usage
Personal Vehicles2'3'8
15
121500 miles/yr
5678 gal/yr
684 MMBtu/yr
43640 MMBtu
Truck Transport - Cap Materia 14,6,8
N/A
26882 truck trips/yr
1344122 miles/yr
231745 gal/yr
31951 MMBtu/yr
261998 MMBtu
Truck Transport - Liner Materia 14,5,6,8
N/A
39 truck trips/yr
7792 miles/yr
1344 gal/yr
185 MMBtu/yr
1519 MMBtu
81,899 MMBtu/yr
709,604 MMBtu
Appendix C - Air Emissions and Energy Use Analysis C-40 September 30, 2016

Table 10. Roxboro Energy Usage Calculations
Removal Excavation and Landfill
Landfill Construction Duration = 12 hr/day 300 day/yr 6 years 342 truck trips carrying liner material
Excavation Duration = 12 hr/day 270 day/yr 63.8 years 1723000 truck trips carrying ash
Closure Duration = 12 hr/day 270 day/yr 3.5 years 56221 truck trips carrying closure material
Activity
Number
of Units
Total Usage
Value Units
Value Units
Hourly (per Unit)
Energy Usage9
Value Units
Annual Total
Energy Usage
Value Units
Total Project Energy
Usage
Value Units
EXCAVATION
Estimated Engine Size
Tracked Excavatorsl'7
2
6480 hr/yr
200 HP each
1.1 MMBtu/hr
7328 MMBtu/yr
467524 MMBtu
Dozers 1,7
2
6480 hr/yr
500 HP each
2.8 MMBtu/hr
18320 MMBtu/yr
1168809 MMBtu
Wheeled Loaded''
1
3240 hr/yr
175 HP each
1.0 MMBtu/hr
3206 MMBtu/yr
204542 MMBtu
Dump Trucks 1,7
2
6480 hr/yr
25 HP each
0.1 MMBtu/hr
916 MMBtu/yr
58440 MMBtu
Water Truck 1,7
1
3240 hr/yr
500 HP each
2.8 MMBtu/hr
9160 MMBtu/yr
584405 MMBtu
Wheeled Backhoe 1'7
1
3240 hr/yr
150 HP each
0.8 MMBtu/hr
2748 MMBtu/yr
175321 MMBtu
6-8" Pumpsl''
2
6480 hr/yr
100 HP each
0.6 MMBtu/hr
3664 MMBtu/yr
233762 MMBtu
55 KVA Diesel Generators''
1
3240 hr/yr
59 HP each
0.3 MMBtu/hr
1081 MMBtu/yr
68960 MMBtu
Fuel Usage
Personal Vehicles2'3'8
15
121500 miles/yr
5678 gal/yr
684 MMBtu/yr
43639.9 MMBtu
MATERIAL TRANSPORT
Fuel Usage
Truck Transport - Ash 4,6,8
N/A
27006 truck trips/yr
1350313 miles/yr
232813 gal/yr
32098 MMBtu/yr
2047860 MMBtu
Truck Transport - Closure Materia 14,6,8
N/A
16063 truck trips/yr
32126 miles/yr
5539 gal/yr
764 MMBtu/yr
2673 MMBtu
Truck Transport - Liner Materia 14,5,6,8
N/A
36 truck trips/yr
7194 miles/yr
1240 gal/yr
171 MMBtu/yr
1625 MMBtu
LANDFILL CONSTRUCTION
Estimated Engine Size
Tracked Excavators l''
8
28800 hr/yr
200 HP each
1.1 MMBtu/hr
32569 MMBtu/yr
195412 MMBtu
Dozers 1,7
8
28800 hr/yr
500 HP each
2.8 MMBtu/hr
81422 MMBtu/yr
488531 MMBtu
Vibratory Compactors l''
4
14400 hr/yr
120 HP each
0.7 MMBtu/hr
9771 MMBtu/yr
58624 MMBtu
Wheeled Loadersl''
4
14400 hr/yr
175 HP each
1.0 MMBtu/hr
14249 MMBtu/yr
85493 MMBtu
Dump Trucks 1,7
8
28800 hr/yr
25 HP each
0.1 MMBtu/hr
4071 MMBtu/yr
24427 MMBtu
Water Trucks l''
4
14400 hr/yr
5001 HP each
2.8 MMBtu/hr
40711 MMBtu/yr
244265 MMBtu
Appendix C - Air Emissions and Energy Use Analysis C-41 September 30, 2016

Table 10. Roxboro Energy Usage Calculations
Activity
Number
of Units
Total Usage
Value Units
Value Units
Hourly (per Unit)
Energy Usage9
Value Units
Annual Total
Energy Usage
Value Units
Total Project Energy
Usage
Value Units
Wheeled Backhoesl'7
4
14400 hr/yr
150 HP each
0.8 MMBtu/hr
12213 MMBtu/yr
73280 MMBtu
6-8" Pumpsl''
8
28800 hr/yr
100 HP each
0.6 MMBtu/hr
16284 MMBtu/yr
97706 MMBtu
Maint/Service Trucks 1,7
4
14400 hr/yr
500 HP each
2.8 MMBtu/hr
40711 MMBtu/yr
244265 MMBtu
55 KVA Diesel Generators 1,7
4
14400 hr/yr
59 HP each
0.3 MMBtu/hr
4804 MMBtu/yr
28823 MMBtu
Fuel Usage
Personal Vehicles2'3'$
100
900000 miles/yr
42056 gal/yr
5067 MMBtu/yr
30400.5 MMBtu
LANDFILL FILLING
Estimated Engine Size
Dozers 1,7
2
6480 hr/yr
500 HP each
2.8 MMBtu/hr
18320 MMBtu/yr
1168809 MMBtu
Tractors''
1
3240 hr/yr
150 HP each
0.8 MMBtu/hr
2748 MMBtu/yr
175321 MMBtu
Wheeled Backhoe 1,7
1
3240 hr/yr
150 HP each
0.8 MMBtu/hr
2748 MMBtu/yr
175321 MMBtu
Water Truck 1,7
1
3240 hr/yr
500 HP each
2.8 MMBtu/hr
9160 MMBtu/yr
584405 MMBtu
Vibratory Rolled'7
1
3240 hr/yr
120 HP each
0.7 MMBtu/hr
2198 MMBtu/yr
140257 MMBtu
Tracked Excavators''
1
3240 hr/yr
200 HP each
1.1 MMBtu/hr
3664 MMBtu/yr
233762 MMBtu
Maint/Service Trucks''
1
3240 hr/yr
500 HP each
2.8 MMBtu/hr
9160 MMBtu/yr
584405 MMBtu
55 KVA Diesel Generators''
1
3240 hr/yr
59 HP each
0.3 MMBtu/hr
1081 MMBtu/yr
68960 MMBtu
Fuel Usage
Personal VehicleS2'3'8
15
121500 miles/yr
5678 gal/yr
684 MMBtu/yr
43639.9 MMBtu
LANDFILL CLOSURE
Estimated Engine Size
Dozers 1,7
2
6480 hr/yr
500 HP each
2.8 MMBtu/hr
18320 MMBtu/yr
64120 MMBtu
Tractors''
1
3240 hr/yr
150 HP each
0.8 MMBtu/hr
2748 MMBtu/yr
9618 MMBtu
Wheeled Backhoe 1,7
1
3240 hr/yr
150 HP each
0.8 MMBtu/hr
2748 MMBtu/yr
9618 MMBtu
Water Truck 1,7
1
3240 hr/yr
500 HP each
2.8 MMBtu/hr
9160 MMBtu/yr
32060 MMBtu
Vibratory Rollers''
1
3240 hr/yr
120 HP each
0.7 MMBtu/hr
2198 MMBtu/yr
7694 MMBtu
Tracked Excavators''
1
3240 hr/yr
200 HP each
1.1 MMBtu/hr
3664 MMBtu/yr
12824 MMBtu
Maint/Service Trucks''
1
3240 hr/yr
500 HP each
2.8 MMBtu/hr
9160 MMBtu/yr
32060 MMBtu
55 KVA Diesel Generators''
1
3240 hr/yr
59 HP each
0.3 MMBtu/hr
1081 MMBtu/yr
3783 MMBtu
Fuel Usage
Personal Vehicles2'3'8
15
121500 miles/yr
5678 gal/yr
684 MMBtu/yr
2394.0 MMBtu
441,536 MMBtu/yr
9,977,837 MMBtu
Appendix C - Air Emissions and Energy Use Analysis C-42 September 30, 2016

Table 10. Roxboro Energy Usage Calculations
Notes:
1. South Coast Air Quality Management District Off -Road Model Mobile Source Emission Factors for a 2016 fleet average from http://www.agmd.gov/home/regulations/ceqa/air-quality-analysis-
handbook/off-road-mobile-source-emission-factors.
2. Personally Operated Vehicle use is estimated as:
-Excavation: 15 persons/day * 30 miles/person * 270 day/yr (it is assumed each person travels 15 -miles one-way to work);
-Landfill Construction: 25 persons/day * 30 miles/person * 270 day/yr.
3. USDOT Bureau of Transportation Statistics Average Fuel Efficiency of U.S. Light Duty Vehicles for calendar year 2014 U.S. light-duty vehicles ( 21.4 mi/gal) from
http://www.rita.dot.gov/bts/sites/rita.dot.gov.bts/fi les/publications/nationa I_transportation_statistics/htm I/table_04_23. htm I.
4. It is assumed that the landfill location is 25 miles away, so 1 truck trip carrying ash is 50 miles, and 20 -ton trucks are used. It is assumed that the landfill cap/closure material for the
Removal alternative is taken from an adjacent land parcel, thus 1 truck trip carrying cap/closure material is taken to be 2 miles. It is assumed that the landfill cap/closure material for the CIP
alternative is taken from a site 25 miles aways, so 1 truck trip carrying cap/closure material for the CIP alternative is taken to be 50 miles.
5. It is assumed that the liner is transported 100 miles to the site/landfill on public roads and approximately 10 tons of liner are transported per trip
(3240 Ib/roll * 1 ton/2000 Ib * 6 rolls/truck trip = 10 ton/truck trip).
6. Oak Ridge National Laboratory Transportation Energy Data Book, Edition 34, September 2015. Class 7-8 average fuel economy (2013) is 5.8 mi/gal from
http://cta.ornl.gov/data/tedb34/Edition34_Chapter05.pdf.
7. USDOE Office of Energy Efficiency and Renewable Energy, Just the Basics Diesel Engine , 2003. Used estimated diesel engine efficiency of 45% from
http://wwwl.eere.energy.gov/vehiclesandfuels/pdfs/basics/jtb_diesel_engine.pdf.
8. U.S. Energy Information Administration, Energy Explained - Energy Units and Calculators, 2015. Used diesel energy content of 137,871 Btu/gal and
gasoline energy content of 120,476 Btu/gal from http://www.eia.gov/energyexplained/?page=about_energy_units.
9. Conversion factor used: 1 HP = 2544.43 Btu/hr
Appendix C - Air Emissions and Energy Use Analysis C-43 September 30, 2016

EPS
APPENDIX D
Human Health Risk Analysis
Appendix D — Human Health Risk Analysis D-1 September 30, 2016

0
DI INTRODUCTION
Potential impacts to humans in contact with chemicals in environmental media were estimated for
30 years after implementation of the three remedial alternatives (Monitored Natural Attenuation
(MNA), Cap -in -Place with MNA (CIP), and Removal with MNA Removal). A current condition
(i.e., year 2015-2016) risk assessment was conducted for each site. These risk assessments formed
the basis of estimating the risks' in the future for the three different remedial alternatives. It is
important to note that the purpose of this analysis is to compare the three different remedial
alternatives for each site. The purpose is not to accurately determine the actual expected risk for
each alternative.
The current condition risk assessments evaluated the following environmental media: (Area of
Wetness (AOW)/seep soil, AOW/seep water, groundwater, sediment, surface water and fish tissue.
The receptors evaluated included a commercial/industrial worker, construction worker, trespasser,
boater, swimmer, wader, recreational fisher and subsistence fisher. One exposure alternative and
one chemical were excluded from this risk evaluation for the Net Environmental Benefit Analysis
(NEBA). Fish consumption was excluded because the risk assessment for this alternative
presented in the Corrective Action Plan (CAP) documents was not based on fish tissue data and
the assessment as presented was overly -conservative and not representative of the true risk. Lead
was excluded because the risks due to lead are calculated differently than for other chemicals and
they are not additive with other chemicals.
There were two considerations in extrapolating the current risk assessment to the future condition.
The first was to forward project into the future (30 years from implementation/completion of the
corrective action). The second was to project the changes due to each corrective action.
The information available for each site varied. Accordingly, for some environmental media
different techniques were used to estimate the projected potential risks.
1 Note, in risk evaluations calculations are performed differently for carcinogenic and non -carcinogenic chemicals.
The Hazard Index (HI) is the measurement used to determine the hazard of non -carcinogens. The Excess Lifetime
Cancer Risk (ELCR) is the measurement used for carcinogenic chemicals. For the purpose of the text of this document
the term "risk" is used to generically represent both the cancer risk and hazard. However, the associated tables do
differentiate between ELCR and non -carcinogenic hazard HI.
Appendix D — Human Health Risk Analysis D-2 September 30, 2016

0
D2 AOW SOIL AND AOW WATER
This evaluation was conducted the same for each site. It was assumed that the concentrations (and,
thus, risk) for the AOWs would not change from now to 30 years in the future. For the MNA
alternative it was assumed that the risk would be the same as the current risk. The CAPS indicate
that most if not all AOWs would not be present under the CIP alternative. However, to be
conservative it was assumed that 75% of the AOWs would be removed. Accordingly, the projected
MNA risk would be 25% of the current risk. Under the Removal alternative all contaminants in
soil would be removed, thus there would be no contaminants in any future AOWs. Accordingly,
there is no projected Removal risk. The calculation of the projected risks for the AOW/seep Soil
and Water, are shown in Table I and Table 2, respectively.
Appendix D — Human Health Risk Analysis D-3 September 30, 2016

0
D3 GROUNDWATER
Groundwater modeling was conducted for each site projecting concentrations in groundwater into
the future for the three different alternatives. However, different amounts and types of information
were provided for the groundwater model output for each site. Accordingly, the projection of risks
due to groundwater into the future for each alternative for each site was conducted differently.
D3.1 Belews and Marshall
The CAP Part 2 report for Belews and Marshall presented results of a groundwater model
predicting concentrations under the NINA and Cap alternative, but did not include the excavation
alternative. However, the groundwater model included in the CAP Part 1 report did include the
Removal alternative. The ratio of the excavation model to the MNA model from the CAP Part 1
report was used to estimate the Removal alternative concentrations based on the MNA model
results from the CAP Part 2 report.
The reports contained graphs showing concentrations of each of the chemical under each
alternative for specific wells at the compliance boundary for many years. The concentrations for
these wells for 30 -years into the future (after the action is taken) was estimated from the graphs.
The results from all the wells presented were averaged to determine estimated groundwater
concentrations 30 years after each corrective action was completed. These concentrations were
then multiplied by the Risk Based Concentrations (RBC) from the risk assessment (included in the
CAP Part 2) to determine the projected risk 30 years in the future for each alternative. Not all
chemicals included in the risk assessment were evaluated in the groundwater model. For these
chemicals, the concentrations 30 years into the future were estimated by multiplying the current
groundwater concentrations in the risk assessment by a ratio, which was based on the future
modeled groundwater concentrations for the modeled chemicals divided by the groundwater
concentrations used in the risk assessment. The the risk calculations for the future alternatives are
presented in Table 3A and 3B for Belews and Marshall, respectively. The only receptor with
exposure to groundwater is the construction worker.
D3.2 Roxboro
The output from the groundwater model for Roxboro was presented as a series of figures depicting
the extent of the plume at different dates for each alternative. The risk for the MNA alternative
was estimated by multiplying the current risk by 1.5. The risk for the Cap alternative was estimated
by multiplying the MNA risk by 0.25. The risk for the Removal alternative was estimated by
multiplying the Cap risk by 0.1. A summary of the results is presented in Table 3C.
Appendix D — Human Health Risk Analysis D-4 September 30, 2016

EPS
D4 SEDIMENT AND SURFACE WATER -
ON-SITE
The on-site sediment and surface water exposure pathways were evaluated the same way for all
sites. It was assumed that the concentrations (and, thus, risk) for on-site sediment and surface
water would not change from now to 30 years from now. For MMA it was assumed that the risk
is the same as in the current risk assessment. Under the CIP and Removal alternatives there is
minimal if any risk into the future. However, to be conservative for the CIP alternative it was
assumed that the risk is 25% of the MMA risk. It assumed there is no risk under the Removal
alternative. The projected risk calculations for on-site soil and on-site surface water are shown in
Tables 4 and 5, respectfully.
Appendix D — Human Health Risk Analysis D-5 September 30, 2016

0
D5 SEDIMENT - OFF-SITE
The off-site sediment exposure pathway was evaluated the same way for all sites. It was assumed
that the concentrations (and, thus, risk) for off-site sediment would not change from now to 30
years from now. For MNA it was assumed that the risk is the same as in the current risk
assessment. Under CIP and Removal there is minimal if any risk into the future. However, to be
conservative it was assumed that the risk under CIP would be 25% of the MNA risk and the risk
under Removal would be 10% of the MNA risk. The projected risk calculations for off-site
sediment are shown in Table 6.
Appendix D — Human Health Risk Analysis D-6 September 30, 2016

0
D6 SURFACE WATER - OFF-SITE
D6.1 Belews and Marshall
The CAP Part 2 Report for Belews and Marshall presented surface water mixing models that
estimated the current surface water concentrations based on the current modeled groundwater
concentrations. The estimated groundwater concentrations presented in Table 3A and 3B were
used as input to the surface water model to estimate surface water concentrations 30 years from
implementation of the three different alternatives. These surface water concentrations were then
multiplied by the RBCs from the risk assessments for each site to estimate the risk of the different
alternatives in the future. A summary of these calculations is presented in Table 7A and Table 7B
for Belews and Marshall, respectively.
D6.2 Roxboro
The Roxboro CAP Part 2 Report did not include a surface water model. In order to project the risk
for each alternative in the future, the ratios from current year to 2030 for MNA (1.05) and for
MNA to Cap (0.96) or Excavate (0.94) were estimated from the surface water models from the
other sites. The results of the projects for Roxboro are shown in Table 7C.
Appendix D — Human Health Risk Analysis D-7 September 30, 2016

0
D7 SUMMARY
The combined risks for each alternative where the risk for each medium is summed to determine
the total risk for each receptor is shown in Tables 8A and 8B. This information is further
summarized in Table 9 where the maximum risk for on-site exposure (maximum risk between
commercial/industrial worker, construction worker and trespasser) and maximum risk for off-site
exposure (boater, swimmer and wader) is presented. Following Table 9, graphs depicting the
combined risks for each receptor in each alternative compared to acceptable risk criteria (HI of 1
and 3 and ELCR of lE-5 and 1E-4) are provided.
Appendix D — Human Health Risk Analysis D-8 September 30, 2016

Table 1. AOW/Seep Soil
1 Concentrations for current scenario updated from the original Risk Assessment (see Table 113)
-- Not Applicable
30 -year MNA: same as current risk assessment
30 -year CIP: 0.25 x 30 -year MNA
30 -year Removal: 0
Appendix D - Human Health Risk Analysis D-9 September 30, 2016
Hazard Index
ELCR
Current Risk
30 -year
30 -year 30 -year
Current Risk
30 -year
30 -year 30 -year
Site
Receptor
Assessment
MNA
CIP Removal
Assessment
MNA
CIP Removal
Belews
Commerical/Industrial Worker
0.073
0.073
0.018 --
4.9E-06
4.9E-06
1.2E-06 --
Construction Worker
0.038
0.038
0.0095 --
1.5E-07
1.5E-07
3.8E-08 --
Trespasser
0.024
0.024
0.006 --
6.1E-07
6.1E-07
1.5E-07 --
Boater
--
--
--
Swimmer
--
--
-- --
--
Wader
--
--
--
Marshall
Commerical/Industrial Worker
0.059
0.059
0.015 --
1.5E-06
1.5E-06
3.8E-07 --
Construction Worker
0.011
0.011
0.0028 --
4.4E-08
4.4E-08
1.1E-08 --
Trespasser
0.019
0.019
0.0048 --
1.8E-07
1.8E-07
4.5E-08 --
Boater
--
--
--
Swimmer
--
--
-- --
--
Wader
--
--
--
Roxboro'
Commerical/Industrial Worker
0.10
0.100
0.025 --
3.0E-06
3.0E-06
7.5E-07 --
Construction Worker
0.08
0.080
0.020 --
9.0E-08
9.0E-08
2.3E-08 --
Trespasser
0.04
0.040
0.010 --
4.0E-07
4.0E-07
1.0E-07 --
Boater
--
--
--
Swimmer
--
--
-- --
--
Wader
I --
--
--
1 Concentrations for current scenario updated from the original Risk Assessment (see Table 113)
-- Not Applicable
30 -year MNA: same as current risk assessment
30 -year CIP: 0.25 x 30 -year MNA
30 -year Removal: 0
Appendix D - Human Health Risk Analysis D-9 September 30, 2016

Table 2. AOW/Seep Water
-- Not Applicable
30 -year MNA: same as current risk assessment
30 -year CIP: 0.25 x 30 -year MNA
30 -year Removal: 0
Appendix D - Human Health Risk Analysis D-10 September 30, 2016
Hazard Index
ELCR
Current Risk
30 -year
30 -year 30 -year
Current Risk
30 -year
30 -year 30 -year
Site
Assessment
MNA
CIP Removal
Assessment
MNA
CIP Removal
Belews
Commerical/Industrial Worker
0.0024
0.0024
0.0006 --
2.3E-09
2.3E-09
5.8E-10 --
Construction Worker
--
--
-- --
--
Trespasser
0.10
0.10
0.025 --
6.5E-08
6.5E-08
1.6E-08 --
Boater
--
--
--
Swimmer
--
--
-- --
--
Wader
--
--
--
Marshall
Commerical/Industrial Worker
0.0092
0.0092
0.0023 --
--
--
-- --
Construction Worker
--
--
-- --
--
--
-- --
Trespasser
0.27
0.27
0.068 --
1.4E-06
1.4E-06
3.5E-07 --
Boater
--
--
--
Swimmer
--
--
-- --
--
Wader
--
--
--
Roxboro
Commerical/Industrial Worker
0.0030
0.0030
0.00075 --
5.0E-08
5.0E-08
1.3E-08 --
Construction Worker
--
--
-- --
--
--
-- --
Trespasser
0.090
0.090
0.023 --
1.0E-06
1.0E-06
2.5E-07 --
Boater
--
--
--
Swimmer
--
--
-- --
--
Wader
I --
--
--
-- Not Applicable
30 -year MNA: same as current risk assessment
30 -year CIP: 0.25 x 30 -year MNA
30 -year Removal: 0
Appendix D - Human Health Risk Analysis D-10 September 30, 2016

Table 3A. Belews Groundwater Risk
1 Not included in groundwater model. Concentrations estimated based on ratio of modeled analytes to current concentrations used in risk assessment.
2 Average of modeled concentrations from wells included in the model (which were all at the compliance boundary)
3 Modeled groundwater concentration / HI RBC
4 Modeled groundwater concentration / ELCR RBC x 1E-04
RBC: Risk-based concentration from risk assessement
Appendix D - Human Health Risk Analysis D-11 September 30, 2016
Const Wkr
Const Wkr
30 Year Modeled Groundwater 2
30 Year Estimated HI 3
30 Year Estimated ELCR 4
MNA
CIP
Removal
MNA
CIP
Removal
MNA
CIP Removal
Analyte
HI RBC ELCR RBC
µg/L
µg/L
µg/L
Aluminum
1
96000000
16064
15534
1941
1.7E-04
1.6E-04
2.0E-05
Antimony
i
17000
6.2
6.0
0.7
3.6E-04
3.5E-04
4.4E-05
Arsenic
29000
450000
13
12
13
4.4E-04
4.1E-04
4.4E-04
2.8E-09
2.7E-09 2.8E-09
Beryllium
480000
0.5
0.4
0.0
9.9E-07
7.8E-07
0.0E+00
Boron
19000000
5938
4500
452
3.1E-04
2.4E-04
2.4E-05
Cadmium
1
10000
2.0
1.9
0.2
2.0E-04
1.9E-04
2.4E-05
Chromium (total)
8600000
8.7
8.2
1.3
1.0E-06
9.5E-07
1.5E-07
Chromium VI
28000
76000
3.9
3.4
3.3
1.4E-04
1.2E-04
1.2E-04
5.2E-09
4.5E-09 4.3E-09
Cobalt
330000
106
94
69
3.2E-04
2.8E-04
2.1E-04
Manganese
i
2200000
18359
17753
2219
8.3E-03
8.1E-03
1.0E-03
Molybdenum
1
480000
57
55
6.9
1.2E-04
1.2E-04
1.4E-05
Vanadium
1
960000
71.1
68.8
8.6
7.4E-05
7.2E-05
9.0E-06
Zinc
1
31000000
126
122
15
4.1E-06
3.9E-06
4.9E-07
Total for Construction Worker
0.0105
0.0100
0.0019
8.0E-09
7.1E-09 7.1E-09
1 Not included in groundwater model. Concentrations estimated based on ratio of modeled analytes to current concentrations used in risk assessment.
2 Average of modeled concentrations from wells included in the model (which were all at the compliance boundary)
3 Modeled groundwater concentration / HI RBC
4 Modeled groundwater concentration / ELCR RBC x 1E-04
RBC: Risk-based concentration from risk assessement
Appendix D - Human Health Risk Analysis D-11 September 30, 2016

Table 3B. Marshall Groundwater Risk
1 Not included in groundwater model. Concentrations estimated based on ratio of modeled analytes to current concentrations used in risk assessment.
2 Average of modeled concentrations from wells included in the model (which were all at the compliance boundary)
3 Modeled groundwater concentration / HI RBC
4 Modeled groundwater concentration / ELCR RBC x 1E-04
RBC: Risk-based concentration from risk assessement
Appendix D - Human Health Risk Analysis D-12 September 30, 2016
Const Wkr
Const Wkr
30 Year Modeled Groundwater 2
30 Year Estimated HI 3
30 Year Estimated ELCR 4
MNA
CIP
Removal
MNA
CIP
Removal
MNA
CIP Removal
Analyte
HI RBC ELCR RBC
µg/L
µg/L
µg/L
Aluminum 1
96000000
504
73
504
5.3E-06
7.6E-07
5.3E-06
Antimony
17000
0.76
0.79
0.29
4.5E-05
4.6E-05
1.7E-05
Arsenic
29000
450000
4.2
4.1
0.8
1.4E-04
1.4E-04
2.6E-05
9.3E-10
9.2E-10 1.7E-10
Barium
5000000
133
133
127
2.7E-05
2.7E-05
2.5E-05
Beryllium
480000
1.6
2.0
0.0
3.3E-06
4.2E-06
0.0E+00
Boron
19000000
710
480
191
3.7E-05
2.5E-05
1.0E-05
Chromium (total)
8600000
8.4
7.4
0
9.8E-07
8.6E-07
0.0E+00
Chromium VI
28000
7.60E+04
1.0
1.1
0.7
3.6E-05
3.8E-05
2.4E-05
1.3E-09
1.4E-09 9.0E-10
Cobalt
330000
2.9
2.4
0.13
8.7E-06
7.1E-06
3.9E-07
Manganese i
2200000
164
24
164
7.4E-05
1.1E-05
7.4E-05
Molybdenum 1
480000
4.9
0.7
4.9
1.0E-05
1.5E-06
1.0E-05
Selenium
480000
5.6
5.1
10
1.2E-05
1.1E-05
2.1E-05
Strontium i
1.90E+08
414
60
414
2.2E-06
3.1E-07
2.2E-06
Vanadium
960000
3.1
3.1
3.3
3.3E-06
3.2E-06
3.4E-06
Zinc 1
31000000
2.2
0.3
2.2
7.0E-08
1.0E-08
7.0E-08
Total for Construction Worker
0.00041
0.00032
0.00022
2.2E-09
2.3E-09 1.1E-09
1 Not included in groundwater model. Concentrations estimated based on ratio of modeled analytes to current concentrations used in risk assessment.
2 Average of modeled concentrations from wells included in the model (which were all at the compliance boundary)
3 Modeled groundwater concentration / HI RBC
4 Modeled groundwater concentration / ELCR RBC x 1E-04
RBC: Risk-based concentration from risk assessement
Appendix D - Human Health Risk Analysis D-12 September 30, 2016

Table 3C. Roxboro Groundwater Risk
1 30 -year MNA = Current Risk Assessment x 1.5
2 30 -year Cap = 30 -year MNA x 0.25
2 30 -year Cap = 30 -year MNA x 0.1
-- Not applicable
Appendix D - Human Health Risk Analysis D-13 September 30, 2016
Hazard Index
ELCR
Current Risk 30 -year 30 -year 30 -year
Current Risk 30 -year 30 -year 30 -year
Receptor
Assessment MNA1 Capt Excavate3
Assessment MNAl Ca P2 Excavate3
Construction Worker
2.00E-03 0.0030 0.00075 0.0003
-- - -- -
1 30 -year MNA = Current Risk Assessment x 1.5
2 30 -year Cap = 30 -year MNA x 0.25
2 30 -year Cap = 30 -year MNA x 0.1
-- Not applicable
Appendix D - Human Health Risk Analysis D-13 September 30, 2016

Site
Receptor
Belews
Commerical/Industrial Worker
30 -year
CIP
Construction Worker
0.000099
0.0017
Trespasser
0.000075
0.0010
Boater
0.000019
0.00025
Swimmer
Wader
Marshall
Commerical/Industrial Worker
Construction Worker
Trespasser
Boater
Swimmer
Wader
Roxboro
Commerical/Industrial Worker
Construction Worker
Trespasser
Boater
Swimmer
Wader
Table 4. On -Site Sediment
-- Not Applicable
30 -year MNA: same as current risk assessment
30 -year CIP: 0.25 x 30 -year MNA
30 -year Removal: 0
30 -year Current Risk
Removal Assessment
-- 5.7E-09
-- 5.5E-08
ELCR
30 -year
MNA
5.7E-09
5.5E-08
30 -year
CIP
1.4E-09
1.4E-08
30 -year
Removal
Appendix D - Human Health Risk Analysis D-14 September 30, 2016
Hazard Index
Current Risk
Assessment
30 -year
MNA
30 -year
CIP
0.000099
0.0017
0.000099
0.0017
0.000025
0.00043
0.000075
0.0010
0.000075
0.0010
0.000019
0.00025
-- Not Applicable
30 -year MNA: same as current risk assessment
30 -year CIP: 0.25 x 30 -year MNA
30 -year Removal: 0
30 -year Current Risk
Removal Assessment
-- 5.7E-09
-- 5.5E-08
ELCR
30 -year
MNA
5.7E-09
5.5E-08
30 -year
CIP
1.4E-09
1.4E-08
30 -year
Removal
Appendix D - Human Health Risk Analysis D-14 September 30, 2016

Table 5. On -Site Surface Water
-- Not Applicable
30 -year MNA: same as current risk assessment
30 -year CIP: 0.25 x 30 -year MNA
30 -year Removal: 0
Appendix D - Human Health Risk Analysis D-15 September 30, 2016
Hazard Index
ELCR
Current Risk
30 -year
30 -year 30 -year
Current Risk 30 -year 30 -year 30 -year
Site
Receptor
Assessment
MNA
CIP Removal
Assessment MNA CIP Removal
Belews
Commerical/Industrial Worker
0.00010
0.000096
0.000024 --
-- -- -- --
Construction Worker
--
--
-- --
-- -- -- --
Trespasser
0.0047
0.0047
0.0012 --
-- -- -- --
Boater
--
--
--
Swimmer
--
--
-- --
--
Wader
--
--
--
Marshall
Commerical/Industrial Worker
0.00037
0.00037
0.000093 --
-- -- -- --
Construction Worker
--
--
-- --
-- -- -- --
Trespasser
0.013
0.013
0.0033 --
-- -- -- --
Boater
--
--
--
Swimmer
--
--
-- --
--
Wader
--
--
--
Roxboro
Commerical/Industrial Worker
--
--
-- --
-- -- -- --
Construction Worker
--
--
-- --
-- -- -- --
Trespasser
--
--
-- --
--
Boater
--
--
--
Swimmer
--
--
-- --
-- -
Wader
--
--
--
-- Not Applicable
30 -year MNA: same as current risk assessment
30 -year CIP: 0.25 x 30 -year MNA
30 -year Removal: 0
Appendix D - Human Health Risk Analysis D-15 September 30, 2016

Table 6. Off -Site Sediment
-- Not Applicable
30 -year MNA: same as current risk assessment
30 -year CIP: 0.25 x 30 -year MNA
30 -year Removal: 0.1 x 30 -year MNA
Appendix D - Human Health Risk Analysis D-16 September 30, 2016
Hazard Index
ELCR
Current Risk
30 -year
30 -year
30 -year
Current Risk
30 -year
30 -year
30 -year
Site
Receptor
Assessment
MNA
CIP
Removal
Assessment
MNA
CIP
Removal
Belews
Commerical/Industrial Worker
--
--
--
--
--
--
--
--
Construction Worker
--
--
--
--
--
--
--
--
Trespasser
--
--
--
--
--
Boater
0.00078
0.00078
0.00020
7.8E-05
3.5E-08
3.5E-08
8.8E-09
3.5E-09
Swimmer
0.0061
0.00610
0.0015
6.1E-04
3.6E-07
3.6E-07
9.0E-08
3.6E-08
Wader
0.0042
0.0042
0.0011
4.2E-04
1.4E-07
1.4E-07
3.5E-08
1.4E-08
Marshall
Commerical/Industrial Worker
--
--
--
--
--
--
--
--
Construction Worker
--
--
--
--
--
--
--
--
Trespasser
--
--
--
--
--
Boater
0.0003
0.00029
0.000073
2.9E-05
--
--
--
--
Swimmer
0.0031
0.0031
0.00078
3.1E-04
--
--
--
--
Wader
0.0031
0.0031
0.00078
3.1E-04
--
--
--
--
Roxboro
Commerical/Industrial Worker
--
--
--
--
--
--
--
--
Construction Worker
--
--
--
--
--
--
--
--
Trespasser
--
--
--
--
--
Boater
0.007
0.007
0.0018
7.0E-04
--
--
--
--
Swimmer
0.007
0.007
0.0018
7.0E-04
--
--
--
--
Wader
0.007
0.007
0.0018
7.0E-04
--
--
--
--
-- Not Applicable
30 -year MNA: same as current risk assessment
30 -year CIP: 0.25 x 30 -year MNA
30 -year Removal: 0.1 x 30 -year MNA
Appendix D - Human Health Risk Analysis D-16 September 30, 2016

Table 7A. Off -Site Surface Water: Belews
1 Not included in surface water model. C,j... based on 1/2 of typical detection limits.
Csw = (QewxCew + 4i e XC'med / (Qgw + Q'i-)
QGW (cfs) 1.151
Q'i_(efs) 40.44
Model C,W from Table 36
Receptor
Analyte
2046 MNA
30 Year Surface Water
MNA CIP Removal
µg/L µg/L µg/L
2046
CIP
2046 Removal
MNA CIP Removal
Analyte
Criver
Model Csw
CSW chronic
Model Csw
CSW chronic
Model Csw
Csw chronic
1.4E-06
(µg/L)
(µg/L)
(µg/L)
(µg/L)
(µg/L)
(µg/L)
(µg/L)
Aluminum
251
16064
469
15534
454
1941
78
Boron
25
5938
106
18359
_
3.19
513
4500
149
452
37
Cobalt 0.25
94 2.84
69
2.15
Manganese 51
17753
496
2219
66
Zinc
0.0051
126
3.50
122
3.38
15
0.427
1 Not included in surface water model. C,j... based on 1/2 of typical detection limits.
Csw = (QewxCew + 4i e XC'med / (Qgw + Q'i-)
QGW (cfs) 1.151
Q'i_(efs) 40.44
Model C,W from Table 36
Receptor
Analyte
HI RBC ELCR RBC
30 Year Surface Water
MNA CIP Removal
µg/L µg/L µg/L
30 Year Estimated HI 1
30 Year Estimated ELCR 2
MNA CIP Removal
MNA CIP Removal
Boater
Boater
Aluminum
Boron
5.6E+07
I.1E+071
469
0.00
454
149
78
37
8.4E-06
8.1E-06
1.4E-06
-
-
-
0.0E+00 1.4E-05
7.6E-05 6.8E-05
1.7E-03 1.6E-03
1.2E-07 1.2E-07
3.3E-06
5.1E-05
2.1E-04
1.5E-08
Boater
Cobalt 4.2E+04 -- 3.19 3 2
Boater Manganese 3.IE+051 513 496 66
Boater Zinc 2.8E+07 3.50 3 0
Total
1.7E-03
1.7E-03
2.7E-04
Swimmer
Aluminum
1.1E+06 -
469
454
78
4.3E-04
4.1E-04
7.1E-05
-- --
Swimmer
Boron
2.2E+05
0.00
149
37
0.0E+00
6.8E-04
1.7E-04
-- --
Swimmer
Cobalt
3.5E+02 -
3.19
3
2
9.1E-03
8.1E-03
6.2E-03
-- --
Swimmer
Swimmer
Manganese
Zinc
4.1E+04
3.4E+05 -
513
3.50
496
3
66
0
1.3E-02
1.0E-05
1.2E-02
9.9E-06
1.6E-03
1.3E-06
-
Total
2.2E-02
2.1E-02
8.0E-03
-- --
Wader
Wader
Aluminum
Boron
1.2E+06
2.4E+051
469
0.00
454
149
78
37
3.9E-04
0.0E+00
3.8E-04
6.2E-04
6.5E-05
1.5E-04
-
-- -- --
Wader
Cobalt
3.6E+02
3.19
3
2
8.9E-03
7.9E-03
6.0E 03
-- -- --
Wader
Manganese
9.OE+041
513
496
66
5.7E-03
5.5E-03
7.4E-04
-- -- -
Wader
Zinc
3.6E+05
3.50
3
0
9.7E-06
9.4E-06
1.2E-06
-- -- -
Total
1.5E-02
1.4E-02
6.9E-03
- -- --
1 Modeled surface water concentration / HI RBC
2 Modeled surface water concentration / ELCR RBC x 1E-04
RBC: Risk-based concentration from risk assessement
Appendix D - Human Health Risk Analysis D-17 September 30, 2016

Table 7B. Off -Site Surface Water: Marshall
1 Not included in surface water model. Cr;,,ef based on 1/2 of typical detection limits.
These calculations are for Suck Creek, whichis more sensitive than the Broad River.
C"=(QGWXCGW+`*ups[r XCupstream)/(Q,+`-/r Wpstream)
QGW (cfs) 0.362
Q1pS1fe,m (cfs) 753
Model CGw from Table 3B
Receptor
Analyte
2046 MNA
HI RBC ELCR RBC
2046
CIP
2046 Removal
Analyte
Cupstream
Model Caw
CSW Chronic
Model Caw
CSW Chronic
Model Caw CSW chronic
25
25
0.3
5
0.01
(µg/L)
(µg/L)
(µg/L)
(µg/L)
(µg/L)
(µg/L) (µg/L)
Aluminum
251
504
25
73
25
504 25
Boron
25
710
3
25
0.3
480
25
191 25
Cobalt 0.25
2 0.3
0.1 0.2
Manganese
51
1_64
5
24
5
164 5
Zinc
0.0051
2
0.01
0
0.01
2 0.01
1 Not included in surface water model. Cr;,,ef based on 1/2 of typical detection limits.
These calculations are for Suck Creek, whichis more sensitive than the Broad River.
C"=(QGWXCGW+`*ups[r XCupstream)/(Q,+`-/r Wpstream)
QGW (cfs) 0.362
Q1pS1fe,m (cfs) 753
Model CGw from Table 3B
Receptor
Analyte
HI RBC ELCR RBC
30 Year Surface Water
30 Year Estimated HI 1
30 Year Estimated ELCR 2
MNA CIP Removal
µg/L µg/L µg/L
MNA CIP Removal
MNA CIP Removal
Boater
Boater
Boater
nater
Boater
Aluminum
Boron
Cobalt
Manganese
g
Zinc
5.6E+07
1.1E+07
4.2E+04
+
2.8E+07
25
25
0.3
5
0.01
25
25
0.3
5
0.01
25
25
0.2
5
0.01
4.5E-07
4.5E-07
4.5E-07
-
-
2.3E-06 2.3E-06
2.3E-06
6.0E-06 6.0E-06
6.0E-06
1.6E-05 1.6E-05
2.2E-10 1.8E-10
1.6E-05
2.2E-10
Total
2.5E-05
2.5E-05
2.5E-05
- -
Swimmer
Swimmer
Aluminum
Boron
1.1E+06 -
2.2E+051
25
25
25
25
25
25
2.3E-05
1.2E-04
2.3E-05
1.1E-04
2.3E-05
1.1E-04
-- --
Swimmer
Cobalt
3.5E+02
0.3
0.3
0.2
7.2E-04
7.2E-04
7.1E-04
-- --
Swimmer
Manganese
4.1E+04 -
5
5
5
1.2E-04
1.2E-04
1.2E-04
- -- -
Swimmer
Zinc
3.4E+05
0.01
0.01
0.01
1.8E-08
1.5E-08
1.8E-08
--
Total
9.8E-04
9.8E-04
9.7E-04
--
Wader
Wader
Aluminum
Boron
1.2E+06
2.4E+05
25
25
25
25
25
25
2.1E-05
1.1E-04
2.1E-05
1.1E-04
2.1E-05
1.0E-04
--
-- -- --
Wader
Cobalt
3.6E+02
0.3
0.3
0.2
7.0E-04
7.0E-04
6.9E-04
-- -- -
Wader
Manganese
9.0E+04 -
5
5
5
5.6E-05
5.6E-05
5.6E-05
-- -- -
Wader
Zinc
3.6E+05 --
0.01
0.01
0.01
1.7E-08
1.4E-08
1.7E-08
-- --
Total
8.8E-04
8.8E-04
8.8E-04
- -- --
1 Modeled surface water concentration / HI RBC
2 Modeled surface water concentration / ELCR RBC x 1E-04
RBC: Risk-based concentration from risk assessement
Appendix D - Human Health Risk Analysis D-18
September 30, 2016

Table 7C. Off -Site Surface Water: Roxboro
1 30 -year MNA = Current Risk Assessment x 1.05
2 30 -year CIP = 30 -year MNA x 0.96
2 30 -year CIP = 30 -year MNA x 0.94
Factors were determined by projecting the results of the surface water model into the future for each scenario for the analytes used in the surface water model,
which were not the COPCs for surface water.
Appendix D - Human Health Risk Analysis D-19 September 30, 2016
Hazard Index
ELCR
Current Risk 30 -year 30 -year 30 -year
Current Risk 30 -year 30 -year 30 -year
Receptor
Assessment MNAI CIP2 Removal3
Assessment MNAI CIP2 Removal3
Boater
0.004 0.0042 0.0040 0.0039
Swimmer
0.06 0.063 0.060 0.059
Wader
1 0.04 0.042 0.040 0.039
1 30 -year MNA = Current Risk Assessment x 1.05
2 30 -year CIP = 30 -year MNA x 0.96
2 30 -year CIP = 30 -year MNA x 0.94
Factors were determined by projecting the results of the surface water model into the future for each scenario for the analytes used in the surface water model,
which were not the COPCs for surface water.
Appendix D - Human Health Risk Analysis D-19 September 30, 2016

Table 8A. Total Hazard Index for Each Receptor and Scenario
Appendix D - Human Health Risk Analysis D-20 September 30, 2016
30 -Year Removal - HI
30 -Year MNA - HI
AOW AOW Groundwater On -Site On -Site Off -Site Off -Site
Total
Site
Receptor
AOW
AOW
Groundwater
On -Site
On -Site
Off -Site
Off -Site
Total
Stu ftwilotar
Soil
Water
Trespasser
Sediment Surface Water
Sediment
Surface Water
HI
Belews Commerical/Industrial Wkr
7.3E-02
2.4E-03
Swimmer
9.9E-05
9.6E-05
Wader
7.6E-02
Construction Worker
3.8E-02
Commerical/Industrial Wkr
1.0E-02
0.0E+00
Construction Worker
2.2E-04
4.8E-02
Trespasser
2.4E-02
1.0E-01
0.0E+00
1.7E-03
4.7E-03
2.9E-05 2.5E-05
5.4E -OS
1.3E-01
Boater
3.1E-04 9.7E-04
1.3E-03
Wader
3.1E-04 8.8E-04
7.8E-04
1.7E-03
2.5E-03
Swimmer
0.0E+00
Construction Worker
3.0E-04
3.0E-04
6.1E-03
2.2E-02
2.8E-02
Wader
Boater
7.0E-04 3.9E-03
4.6E-03
4.2E-03
1.5E-02
1.9E-02
Marshall Commerical/Industrial Wkr
5.9E-02
9.2E-03
4.0E-02
7.5E-05
3.7E-04
6.9E-02
Construction Worker
1.1E-02
4.1E-04
1.1E-02
Trespasser
1.9E-02
2.7E-01
1.0E-03
1.3E-02
3.0E-01
Boater
2.9E-04
2.5E-05
3.2E-04
Swimmer
3.1E-03
9.8E-04
4.1E-03
Wader
3.1E-03
8.8E-04
4.0E-03
Roxboro Commerical/Industrial Wkr
1.0E-01
3.0E-03
1.0E-01
Construction Worker
8.0E-02
3.0E-03
8.3E-02
Trespasser
4.0E-02
9.0E-02
1.3E-01
Boater
7.0E-03
4.2E-03
1.1E-02
Swimmer
7.0E-03
6.3E-02
7.0E-02
Wader
7.0E-03
4.2E-02
4.9E-02
Appendix D - Human Health Risk Analysis D-20 September 30, 2016
30 -Year Removal - HI
30 -Year CIP - HI
AOW AOW Groundwater On -Site On -Site Off -Site Off -Site
Total
Site
Receptor
AOW
AOW
Groundwater
On -Site
On -Site
Off -Site
Off -Site
Total
Site Receptor
Soil
Water
Trespasser
Sediment Surface Water
Sediment
Surface Water
HI
Belews Commerical/Industrial Wkr
1.8E-02
6.0E-04
Swimmer
2.5E-05
2.4E-05
Wader
1.9E-02
Construction Worker
9.5E-03
Commerical/Industrial Wkr
1.0E-02
0.0E+00
Construction Worker
2.2E-04
2.0E-02
Trespasser
6.0E-03
2.5E-02
0.0E+00
4.3E-04
1.2E-03
2.9E-05 2.5E-05
5.4E -OS
3.3E-02
Boater
3.1E-04 9.7E-04
1.3E-03
Wader
3.1E-04 8.8E-04
2.0E-04
1.7E-03
1.9E-03
Swimmer
0.0E+00
Construction Worker
3.0E-04
3.0E-04
1.5E-03
2.1E-02
2.3E-02
Wader
Boater
7.0E-04 3.9E-03
4.6E-03
1.1E-03
1.4E-02
1.5E-02
Marshall Commerical/Industrial Wkr
1.5E-02
2.3E-03
4.0E-02
1.9E-05
9.3E-05
1.7E-02
Construction Worker
2.8E-03
3.2E-04
3.1E-03
Trespasser
4.8E-03
6.8E-02
2.5E-04
3.3E-03
7.6E-02
Boater
7.3E-05
2.5E-05
9.7E-05
Swimmer
7.8E-04
9.8E-04
1.8E-03
Wader
7.8E-04
8.8E-04
1.7E-03
Roxboro Commerical/Industrial Wkr
2.5E-02
7.5E-04
2.6E-02
Construction Worker
2.0E-02
7.5E-04
2.1E-02
Trespasser
1.0E-02
2.3E-02
3.3E-02
Boater
1.8E-03
4.0E-03
5.8E-03
Swimmer
1.8E-03
6.0E-02
6.2E-02
Wader
1.8E-03
4.0E-02
4.2E-02
Appendix D - Human Health Risk Analysis D-20 September 30, 2016
30 -Year Removal - HI
AOW AOW Groundwater On -Site On -Site Off -Site Off -Site
Total
Site
Receptor
Soil Water Sediment Surface Water Sediment Surface Water
HI
Belews
Commerical/Industrial Wkr
0.0E+00
Construction Worker
1.9E-03
1.9E-03
Trespasser
0.0E+00
Boater
7.8E-05 2.7E-04
3.5E-04
Swimmer
6.1E-04 8.0E-03
8.6E-03
Wader
4.2E-04 6.9E-03
7.4E-03
Marshall
Commerical/Industrial Wkr
0.0E+00
Construction Worker
2.2E-04
2.2E-04
Trespasser
0.0E+00
Boater
2.9E-05 2.5E-05
5.4E -OS
Swimmer
3.1E-04 9.7E-04
1.3E-03
Wader
3.1E-04 8.8E-04
1.2E-03
Roxboro
Commerical/Industrial Wkr
0.0E+00
Construction Worker
3.0E-04
3.0E-04
Trespasser
0.0E+00
Boater
7.0E-04 3.9E-03
4.6E-03
Swimmer
7.0E-04 5.9E-02
6.0E-02
Wader
7.0E-04 3.9E-02
4.0E-02
Appendix D - Human Health Risk Analysis D-20 September 30, 2016

Table 8B. Total ELCR for Each Receptor and Scenario
Site Receptor
30 -Year Removal - ELCR
Total
ELCR
30 -Year MNA - ELCR
Total
ELCR
AOW AOW Groundwater On -Site On -Site Off -Site Off -Site
Soil Water Sediment Surface Water Sediment Surface Water
Belews Commerical/Industrial Wkr
Construction Worker
Trespasser
Boater
Swimmer
Wader
4.9E-06
1.5E-07
6.1E-07
2.3E-09
6.5E-08
5.7E-09
8.0E-09
5.5E-08
3.5E-08
3.6E-07
1.4E-07
4.9E-06
1.6E-07
7.3E-07
3.5E-08
3.6E-07
1.4E-07
Marshall Commerical/Industrial Wkr
Construction Worker
Trespasser
Boater
Swimmer
Wader
1.5E-06
4.4E-08
1.8E-07
1.4E-06
2.2E-09
1.5E-06
4.6E-08
1.6E-06
Roxboro Commerical/Industrial Wkr
Construction Worker
Trespasser
Boater
Swimmer
Wader
3.0E-06
9.0E-08
4.0E-07
5.0E-08
1.0E-06
1.3E-08
2.5E-07
3.1E-06
9.0E-08
1.4E-06
3.5E-07
Site Receptor
30 -Year Removal - ELCR
Total
ELCR
30 -Year CIP - ELCR
Total
ELCR
AOW AOW Groundwater On -Site On -Site Off -Site Off -Site
Soil Water Sediment Surface Water Sediment Surface Water
Belews Commerical/Industrial Wkr
Construction Worker
Trespasser
Boater
Swimmer
Wader
1.2E-06
3.8E-08
1.5E-07
5.8E-10
1.6E-08
1.4E-09
7.1E-09
1.4E-08
8.8E-09
9.0E-08
3.5E-08
1.2E-06
4.5E-08
1.8E-07
8.8E-09
9.0E-08
3.5E-08
Marshall Commerical/Industrial Wkr
Construction Worker
Trespasser
Boater
Swimmer
Wader
3.8E-07
1.1E-08
4.5E-08
3.5E-07
2.3E-09
3.8E-07
1.3E-08
4.0E-07
Roxboro Commerical/Industrial Wkr
Construction Worker
Trespasser
Boater
Swimmer
Wader
7.5E-07
2.3E-08
1.0E-07
1.3E-08
2.5E-07
7.6E-07
2.3E-08
3.5E-07
Site Receptor
30 -Year Removal - ELCR
Total
ELCR
AOW AOW Groundwater On -Site On -Site Off -Site Off -Site
Soil Water Sediment Surface Water Sediment Surface Water
Belews Commerical/Industrial Wkr
Construction Worker
Trespasser
Boater
Swimmer
Wader
7.1E-09
3.5E-09
3.6E-08
1.4E-08
7.1E-09
3.5E-09
3.6E-08
1.4E-08
Marshall Commerical/Industrial Wkr
Construction Worker
Trespasser
Boater
Swimmer
Wader
1.1E-09
1.1E-09
Roxboro Commerical/Industrial Wkr
Construction Worker
Trespasser
Boater
Swimmer
Wader
Appendix D - Human Health Risk Analysis D-21 September 30, 2016

Table 9. Summary of Risks for Each Scenario
Belews
Marshall
Hazard Index
ELCR
On -Site Off -Site
On -Site Off -Site
MNA
0.1 0.03
5E-06 4E-07
CIP
0.03 0.02
1E-06 9E-08
Removal
1 0.002 0.009
7E-09 4E-08
Marshall
Roxboro
Hazard Index
ELCR
On -Site Off -Site
On -Site Off -Site
MNA
0.3 0.004
2E-06 --
CIP
0.08 0.002
4E-07 --
Removal
1 0.0002 0.001
1E-09 --
Roxboro
On-Site: Maximum of commercial/industrial worker,
construction worker and trespasser
Off -Site: Maximum of boater, swimmer and wader
Appendix D - Human Health Risk Analysis D-22 September 30, 2016
Hazard Index
ELCR
On -Site Off -Site
On -Site Off -Site
MNA
0.1 0.07
3E-06 --
CIP
0.03 0.06
8E-07 --
Removal
10.0003 0.06
-- --
On-Site: Maximum of commercial/industrial worker,
construction worker and trespasser
Off -Site: Maximum of boater, swimmer and wader
Appendix D - Human Health Risk Analysis D-22 September 30, 2016

3
2.5
2
1.5
1
0.5
0
3
2.5
2
1.5
1
0.5
0
Belews - HI - 30 Yr
MNA CIP Removal
■ Commerical/Industrial Wkr ■ Construction Worker ■ Trespasser Boater ■ Swimmer ■ Wader
Marshall - HI - 30 Yr
MNA CIP Removal
■ Commerical/Industrial Wkr ■ Construction Worker ■ Trespasser Boater ■ Swimmer ■ Wader
Appendix D - Human Health Risk Analysis D-23 September 30, 2016

2.S
1.5
0.5
Roxboro - HI - 30 Yr
MNA CIP Removal
■ Commerical/Industrial Wkr ■ Construction Worker 0 Trespasser Boater ■ Swimmer ■ Wader
Appendix D - Human Health Risk Analysis D-24 September 30, 2016

1.00E-04
8.00E-05
6.00E-05
4.00E-05
2.00E-05
0.00E+00
1.00E-04
8.00E-05
6.00E-05
4.00E-05
2.00E-05
0.00E+00
Belews - ELCR - 30 Yr
MINA CIP Removal
■ Commerical/Industrial Wkr ■ Construction Worker w Trespasser Boater ■ Swimmer ■ Wader
Marshall - ELCR - 30 Yr
MINA CIP Removal
■ Commerical/Industrial Wkr ■ Construction Worker ■ Trespasser Boater ■ Swimmer ■ Wader
Appendix D - Human Health Risk Analysis D-25 September 30, 2016

1.00E-04
8.00E-05
6.00E-05
4.00E-05
2.00E-05
0.00E+00 —
l
Roxboro - ELCR - 30 Yr
MNA CIP Removal
■ Commerical/Industrial Wkr ■ Construction Worker ■ Trespasser Boater ■ Swimmer ■ Wader
Appendix D - Human Health Risk Analysis D-26 September 30, 2016

[EN
APPENDIX E
Ecological Habitat Service Analysis
Appendix E — Ecological Habitat Service Analysis E-1 September 30, 2016

m
El ECOLOGICAL HABITAT SERVICE
ANALYSIS
The purpose of this evaluation was to understand how the CIP and Removal alternatives might
affect ecological habitat values associated with the Belews Creek, Marshall, and Roxboro Steam
Station sites. As stated in Section 3.5 of the report, the ecological habitat service analysis for each
site consisted of three main steps as follows:
The first step was to identify the major habitat types existing within the areas that would
be impacted by the remedial alternatives at each site and to estimate the surface area of
each major habitat type.
2. The second step was to develop assumptions regarding the timing and level of impact (i.e.,
projected change in ecological service value over time) that implementation of each
alternative would have on the habitat types evaluated.
3. The third step was to estimate the change (i.e., loss) in the net present value (NPV) of
ecological habitat services that would be projected to occur given the habitats, acreages,
and assumptions developed as part of Steps 1 and 2.
Each of these steps are discussed, in turn, in the following sections.
E1.1 Habitat Types and Areas
This step used a combination of existing geographic information system (GIS) habitat polygon
boundary information, aerial photography reviews, site visit observations, and GIS analysis to
understand the general distribution of the habitat types and their respective surface areas at each
of the four sites. The GIS files for the habitats at the Belews Creek and Marshall Steam Station
sites were provided by Duke Energy. In addition, I conducted site visits at all three sites during the
June 7-10, 2016, time period. For the Roxboro site, GIS habitat files were not available. Therefore,
habitat polygons were developed through GIS analysis based upon the site visits and review of
Google Earth aerial photography. The GIS polygons for the Belews Creek, Marshall, and Roxboro
Steam Station sites are presented in Figures E1 -E3, respectively. Land habitat types were assigned
to the following major categories:
Terrestrial Habitats
• Forest (included pine, hardwood, bottomland and mixed forest habitats)
• Shrub Scrub/ Early Successional
• Grass/open mowed field
Appendix E — Ecological Habitat Service Analysis E-2 September 30, 2016

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Wetlands and Surface Water
• Combined emergent wetland, forested wetland and open water habitats
I focused on the major habitat types that would be affected by the remedial alternatives. It should
be noted that parking areas, roads, water treatment facility basins, and barren ash areas (non-
vegetated) were excluded from the analysis.
Through the above GIS polygon analysis, the surface area of each habitat type that was projected
to be impacted by either the CIP or Removal alternative was determined for each site, including a
30 -foot work zone buffer around each basin that would be affected by each alternative. The GIS
polygon data for each site were grouped by major habitat type for the purposes of the evaluation
(Table E1). The focus was on how the major terrestrial and wetland/surface water habitats would
be affected given implementation of the alternatives.
Table E1. Acreage of the selected major habitat types under the current site condition
that would be physically impacted through implementation of the CIP or Removal
alternatives (rounded to nearest acre)
Site
Belews
Marshall
Roxboro
Terrestrial
Early Successional/Scrub
0.06
30
10
Forest
19
95
45
Open Field -Grass
13.4
157
159
Wetland and Surface Water
227
203
117
Total Acreage of Habitats
Evaluated
260
486
330
The evaluation area includes only those areas that were projected to be
impacted by the remedial actions, including a 30 foot buffer around the
outside of each basin. Areas with roads, water treatment facilities, and
barren ash were not included in the analysis.
E1.2 Ecological Habitat Service Methodology and Assumptions
Ecosystems provide a variety of services to humans. These services have been classified as
supporting, provisioning, regulating, and cultural services as part of the Millennium Ecosystem
Assessment (2005). Habitats serve as the supporting structure from which provisioning, regulating,
and cultural services flow and hence provide value. That is, many human use services (bird
watching, recreational fishing, etc.) are provided by the presence of the ecological habitat services.
For example, state game lands provide recreational hunting and birdwatching activities that would
otherwise not be present if the ecology and habitat was not in place. Thus, actions adversely
affecting ecological habitat services can result in significant human use service losses while actions
Appendix E — Ecological Habitat Service Analysis E-6 September 30, 2016

m
that enhance habitats can result in increased human use service value. The focus of this section is
the quantification of the ecological habitat services that are projected to be impacted (either lost or
gained) by the CIP and Removal remedial alternatives.
Importantly, the net environmental benefits have been assessed using the current status of the
environment (the project baseline) against which the potential change in environmental condition
is measured. As such, projected changes in ecological habitat service values associated with
implementation of the CIP and Removal alternatives is compared to the current status of the
habitats on-site.
E1.2.1 Environmental Metric and Discounting
Since ecological habitat impacts can occur over varying time frames, they can be normalized to
their net present value (NPV) using a time discount rate. The discount rate is the rate at which the
public is indifferent to consuming goods now or sometime in the future. An estimate of the NPV
of the losses in ecological habitat value were developed through the use of the Habitat Equivalency
Analysis (HEA) methodology. In this case, projected habitat alterations (e.g., removal,
displacement of habitat) were used to directly assess changes in ecological habitat quality and
resulting value. My evaluation included both the major direct on-site and off-site habitat impacts.
Indirect impacts associated with alternative implementation were not estimated. Therefore, my
estimation of impacts is conservative (i.e., underestimates projected losses).
Because many ecological habitat services are not traded in the marketplace, they may not have a
direct monetary value and therefore, value can be expressed using non -monetary metrics. The HEA
approach is a service quantification approach that evaluates ecological habitat service losses or
gains based on non -monetary metrics over time. It is important to recognize that ecosystem
services are not static measurements but represent a flow of benefits over time. As such, the HEA
approach uses an environmental metric to measure changes to ecological habitat services and
focuses on quantifying the area (e.g., acres) and level of impact over time in units typically
represented as service -acre -years (SAY'S). For this evaluation, I used the HEA methodology to
quantify the relative habitat service losses associated with the CIP and Removal alternatives.
Ecological service losses and gains can be measured using a variety of indicator metrics and units.
In many cases, the quantification of changes in ecological service flows is based upon selecting or
developing an indicator (can be one or more metrics) that acts as a surrogate to represent the
ecological service flows provided over time by the habitat and expressing the changes in services
(for that indicator) under the different alternatives as a percentage change from a baseline or
reference condition.
Ecosystem studies, literature -based information, professional experience, or a combination
thereof, can be used to estimate how ecosystem services may change given an action. The metrics
or indicators are selected based upon the site, habitats, and professional judgment. The metric(s)
are typically developed to represent the flow of value (e.g., loss or gain of services) over time.
As stated earlier, the ecological service calculations also involve a discount rate that allows for the
gains and losses to be evaluated from an NPV standpoint. Within the HEA methodology,
calculations of ecological service losses and gains associated with a project are computed over
Appendix E — Ecological Habitat Service Analysis E-7 September 30, 2016

0
time and represent time accumulated service flows. In these cases, the units are typically displayed
as a discounted service acre year (dSAY) which represents an ecological habitat value that takes
into account the time value of the habitat services. I used a 3% discount rate, this rate commonly
used in NRDA cases within the United States.
In evaluating ecological habitat service flows, applications of the HEA methodology must account
for the absolute difference in the flow of services from the ecological resources resulting from an
action and how those services are distributed over time. In addition, for any given action, it is
likely that the ecological habitat service loss or gain may not always be constant over time. An
assessment as to how ecological habitat service flows may change over time is thus necessary.
Quantifying the ecological service value of a given action can be conducted prior to project
implementation through the use of projected metrics based on scientific data and professional
judgment. Use of the HEA methodology has been upheld in U.S. federal court' as an appropriate
method to evaluate changes in ecological habitat services associated with actions that affect the
environment and has also been incorporated into the European Union Environmental Liabilities
Directive (Nicolette et al. 2013).
The analysis of ecological habitat services was conducted by examining how changes to the
existing habitats would occur given implementation of the CIP and Removal alternatives. It should
be recognized that the approach taken in the ecological analysis was to approximate the parameter
values for each of the alternatives based upon consistent assumptions where applicable. As such,
the parameter estimates are approximate values and not intended to be exact, but robust enough to
identify impacts and differences between alternatives to a reasonable degree of certainty.
My analysis focused on the major terrestrial and aquatic habitats. A discussion of the analysis of
the ecological habitat service value associated with the terrestrial and aquatic habitats is provided
in the following sections
E1.2.2 Assumptions
For the terrestrial analysis, ecological habitat service flows were modeled for each site per major
habitat type (forest, shrub scrub/early successional, and mowed grass). Changes in terrestrial
habitat value were compared to the baseline terrestrial habitat condition at the sites.
Baseline "Current" Condition
For the baseline terrestrial condition at each site, the following general assumption was made:
• The flow of ecological service value is consistent with the above -ground biomass of the
terrestrial habitats and increases as the terrestrial system moves through successional
stages. That is, as the vertical structure and complexity of the terrestrial vegetation
increases, so does the ecological habitat service value. In forest ecosystems, post -
disturbance biomass accumulation provides an index of carbon sequestration and the
United States 1997. United States v. Melvin Fisher. United States District Court for the Southern District of Florida, Key West Division Case
Numbers 92-10027-CIV-DAVIS, and 95-10051-CIV-DAVIS. Decided 30 July 1997, Filed 30 July 1997. 977 F. Supp. 1193; 1997 U.S. Dist.
LEXIS 16767.
United States 2001. United States of America and Internal Improvement Trust Fund v. Great Lakes Dredge and Dock Company. United States
District Court for the Southem District of Florida D. C. Docket No. 97 -02510 -CV -EBD.
Appendix E — Ecological Habitat Service Analysis E-8 September 30, 2016

0
reestablishment of biological control over a variety of ecosystem processes, such as those
controlling nutrient cycling (Johnson et al. 2000). A functional form of this relationship is
presented in Figure E5 (adapted from McMahon et al. 2010). The rate and asymptote of
this pattern of biomass recovery can differ across stands because of nutrient availability
and species composition; however, the functional form of this response remains similar
across forest types and regions (McMahon et al. 2010).
Ecological succession is the process of change in the species composition of an ecological
community over time. The process begins with relatively few pioneering plants and animals that
develop through increasing complexity until the ecological community becomes stable as a climax
stage community. Vertical and horizontal structural habitat complexity has been shown to drive
biodiversity by creating a greater variety of microclimates and microhabitats, which in turn
produce more diverse food and cover for a more diverse group of species (Verschuyl et al. 2008).
In addition, a positive relationship between tree species richness and above -ground productivity
has often been found (Parrotta 2012).
One study has also shown that old growth forests (50-250 years of age) serve as a stronger sink
for CO2 than a younger growth forest (i.e., 14 years of age), thus indicating a higher carbon
sequestration value as the forest gets older (Law et al. 2001). The value of forest habitat in
protecting biodiversity and ecosystem service values has also been demonstrated (e.g., Gibson et
al., 2011). Greenpeace (2016) also states that "Protecting forests will not only preserve biodiversity
and defend the rights of forest communities, it's also one of the quickest and cost effective ways
of halting climate change".
The curve used to depict the flow of ecological habitat service value is presented in Figure E4 and
was kept constant among all terrestrial habitats at all sites and was selected to serve as a standard
to which changes in terrestrial habitat at the sites can be evaluated and compared.
Appendix E — Ecological Habitat Service Analysis E-9 September 30, 2016

100
0
V)
v
U
j 75
L
Q�
CU
U
W 50
_O
O
U
LU +-
25
L
O
LL
EPS
011 1 1 1 1 1
0 50 100 150 200 250
Years
Figure E4. Graphic showing the relationship between above -ground biomass (AGB) (used as
a surrogate for ecological service value) and stand age of multiple forest plots in a
temperate deciduous forest in Edgewater, MD. Adapted from McMahon et al. (2010).
For calculation purposes, the percent (%) service value at various points along the curve was
estimated as depicted in Figure ET Yearly percent habitat service estimates were generated
through linear interpolation between the identified points presented in Figure E5.
Interpolated from Graph
s
0 50 100 ISO 200 250
Stand age (years)
Figure E5. Interpolation of service values used in calculations.
Years
AGB
%
0
0
0.00%
5
5
1.01%
10
45
9.09%
15
80
16.16%
20
110
22.22%
25
140
28.28%
30
165
33.33%
35
185
37.37%
40
205
41.41%
451
225
45.45%
50
245
49.49%
60
275
55.56%
70
305
61.62%
80
330
66.67%
90
355
71.72%
100
375
75.76%
125
415
83.84%
150
445
89.90%
175
475
95.96%
200
495
100.00%
Appendix E — Ecological Habitat Service Analysis E-10 September 30, 2016

MO
The baseline ecological service value for forest habitat at the Belews Creek site is depicted in
Figure E8. Note that the value estimate starts at an approximate age of 25 years for the on-site
forest stands being evaluated. This assumption was also held for offsite areas where forest habitat
would be impacted. This is conservative in estimating the baseline value as the tree stands are
likely older on average than 25 years of age both on- and off-site. Additionally, the flow of value,
for all sites and scenarios was calculated over a 200 -year period (2016-2216).
For shrub-scrub/early successional habitat, the start time on the successional curve was adjusted
to 5 years to approximate the average age of the vegetation assigned to this habitat type.
The conceptual model under which the forest dSAY value (330) for the Belews Creek Steam
Station was calculated (at a 3% discount rate) is presented in Figure E6. This represents the current
service value projected into the future of the on-site 19.0 acres of forest habitat. The on-site shrub
scrub/early successional habitat and the on-site grass/open field habitats would convert to a mowed
grass habitat under the CIP alternative, or regenerate to forest under the Removal alternative. Off-
site forest habitats that are impacted were assumed to reach a similar level of service value as their
pre -impact condition.
A similar process of calculating the projected changes in the flow of terrestrial ecological service
value was conducted for all four sites adjusting for the timing of implementation and the projected
level of impact to the habitat.
Wetland and surface water habitat was evaluated by projecting the change in the current condition
of the wetland and surface water habitat (the baseline). It was assumed that implementation of both
the CIP and Removal alternatives would result in a 100% (complete) loss of both the wetland and
surface water habitat on-site.
Appendix E — Ecological Habitat Service Analysis E-11 September 30, 2016

0
100-
F
N
v
v 75
L
On-site baseline value (19.0 acres) 330 dSAYs
M
LJ 50
0 Current age
of tree Baseline forest ecological
LU stands services projected into future
vii 25
N
L
0
LL
0
0 12016 12216 50 100 150 200 250
Years
Figure E6. Ecological service flow framework used as a standard to evaluate service flow
changes on forest habitats at the Belews Creek Steam Station — depicts baseline of ecological
service flows projected into the future.
My general assumptions for estimating the change in ecological service values for both the
terrestrial and aquatic habitats, given the CIP and Removal alternatives and their on-site and off-
site impacts, is detailed in Table E2 on the following page.
Appendix E — Ecological Habitat Service Analysis E-12 September 30, 2016

EPS.
Table E2. General assumptions used in evaluating changes in habitat values between
alternatives.
There are many factors that can influence the staging and timing of the construction work that would be required for the
implementation of the CIP and Removal alternatives at a site. These factors include: weather conditions, contractor availability,
economics, material availability, permitting, community acceptance, etc. As such, the habitat values (i.e., dSAYs) represented
are based upon general assumptions with the recognition that site specific conditions and influencing factors will dictate the
1
ultimate staging and timing of the actions associated with alternative implementation. The general assumptions were kept
consistent between the alternatives where applicable for the purposes of providing a comparison of the alternatives. The
ecological habitat estimates are approximate and not intended to be exact, but are robust enough to identify impacts and
evaluate and compare the alternatives with a reasonable degree of certainty.
2
The time frames for project implementation and completion are based upon the information presented in Appendix A.
The flow of ecological service value is consistent with the above -ground biomass of the terrestrial habitats and increases as the
3
terrestrial system moves through successional stages. That is, as the vertical structure and complexity of the terrestrial
vegetation increases, so does the ecological habitat service value.
4
Current on-site and off-site forest habitats were assumed to be 25 years of age.
5
Current scrub scrub habitats were assumed to be 5 years of age.
For both the removal and CIP alternatives, on-site habitat impacts to each terrestrial habitat type were assumed to initiate
upon implementation of the field construction activities and be completed in the first year of construction. With the CIP
6
alternative, the impacted terrestrial habitat area would eventually be converted to a mowed grass cover. With the Removal
alternative, those same impacted habitat areas would eventually be managed to encourage regrowth of forest habitat, that
would occur once the removal action was complete in that area and the work area developed to final grade.
For both the CIP and Removal alternatives, 100% of the on-site wetland and surface water habitat services would be lost over a
7
3 year period (linear) starting with initiation of construction as water is drawn out of the basin(s) to allow for capping,
Removal, and water management.
8
A 3% discount rate was used in calculating habitat values.
The Removal alternative necessitates the development of a new offsite landfill to store the removed ash. It was assumed that
9
the area where the offsite landfill would be placed would be a forest habitat. This forest habitat would be lost into perpetuity
and converted to a mowed grass cover upon completion of the landfill.
In addition, an off-site borrow area would be required to provide material for the new landfill under the Removal alternative as
10
well as for the CIP alternative.
Offsite areas serving as either borrow or landfill area were assumed to be forest habitat. This assumption was based on the
"Letter Reports" prepared by Amec Foster Wheeler for each of the sites, where they show the vast majority of potentially
11
suitable sites for landfill and borrow areas involved land that is presently forested (Amec Foster Wheeler 2015a, 2015b, and
2015c).
On -Site Habitat Conversion: Conversion of both the terrestrial and wetland areas onsite would be staggered with recovery of
12
50% of the area initiating at 50% project completion, regardless whether CIP or Removal alternative. The remaining 50% of the
area would initiate recovery at project completion, regardless whether the CIP or Removal alternative.
On -Site Habitat Conversion: All wetland and surface water impacted habitats currently on-site will be lost into perpetuity
13
(converted to either grass or forest).
The on-site CIP and offsite landfill cap areas result in a mowed grass cover. It was assumed that newly planted grass (cap cover)
would mature in a linear fashion over 5 years, starting once the cap was complete, and reach a maximum service value of 10%
14
(and continue at this rate into perpetuity). That is, mature grass habitat was assumed to generate 1/10 the value of the forest
habitat at maximum value at maturity.
Existing mowed grass habitats currently provide a constant 10% service value (as compared to the maximum forest habitat
15
value at maturity.
Offsite forest habitat removal at the new off-site landfill location will occur to 50% of the acreage during the first year of
construction for the Removal alternative. Subequently, the remaining 50% of forest will be removed halfway through the
16
projected project duration. Grass cap regeneration of the area where 50% of forest was initially removed for the landfill will
initiate halfway through project completion with the remaining 50% initiating recovery at project completion.
Offsite removal of forest at the borrow area location for the Removal alternative would occur at the following rate: 10% would
be removed upon project initiation, 45% would be removed at 40% completion and the remaining 45% of the acreage would
17
be removed at the 80% completion stage. Forest regeneration of these areas would occur with 50% of the impacted acreage
initiating at 50% project completion and the remaining 50% of impacted acreage initiating recovery at project completion.
Offsite forest habitat removal at the borrow area location will occur to 50% of the acreage during the first year of construction
for the CIP alternative. Subequently, the remaining 50% of forest will be removed halfway through the projected project
18
duration. Forest regeneration of the area where 50% of forest was initially removed for the landfill will initiate halfway through
project completion with the remaining 50% initiating recovery at project completion.
Appendix E — Ecological Habitat Service Analysis E-13 September 30, 2016

0
E1.2.3 Ecological Habitat Service Analysis Results
The detailed results of the analysis, by site and remedial alternative, are presented in Table E3.
Forest, scrub shrub/early successional, and grass habitat values (terrestrial habitats) were combined
and presented in Table E3. The forest and scrub shrub/early successional habitats fall along the
same successional curve, and grass habitats were quality adjusted to the forest and scrub
shrub/early successional habitats, as such, their dSAY values are directly comparable given the
assumptions made.
For my analysis, I calculated the wetland/surface water values separate within the table. However,
since all of the wetland and surface water features will be lost as a result of both the CIP and
Removal alternatives, these areas will be subsequently converted to either mowed grass (CIP
alternative) or forest (Removal alternative).
It should be recognized that ecological habitat service values (i.e., dSAYs) between different
habitat types (e.g., wetlands and forest) may not be equivalent. Thus, care must be taken when
combining dSAYs between different habitat types. A recent study of the ecosystem service values
between various ecological biomes indicates that wetlands are significantly more valuable than
temperate forest/woodlands (estimates ranged from about 11-15 times more valuable, based on
median values) (de Groot et al. 2012). That same study also indicated that lakes and river habitats
were more valuable than temperate forest/woodland habitat (estimates ranged from about 2.6 — 3.5
times more valuable, based on median values). Wetland habitat was about 4 times more valuable
when compared to lake and river habitats in the de Groot study (2012).
In order to put the dSAY values into perspective, for a specific habitat such as a wetland or forest
functioning at 100% of its service value into perpetuity, 1 acre of that habitat is equivalent to about
34 dSAY's at a 3% discount rate. Therefore, one can infer the impact of the lost dSAYs, for each
habitat type at each site by dividing the total lost dSAYs for that site by 34.2. In addition, for the
purposes of comparing the change in value between the CIP and Removal alternatives, I set the
wetland/surface water dSAY value to be equivalent to the dSAY value of the existing forest habitat
value. This is a conservative estimate (i.e., underestimates the true impacts of both the CIP and
Removal alternatives) since the wetland/surface area ecological service value is higher than the
forest ecological service value.
As such and as presented in Table E3, the CIP and Removal alternatives each would result, given
the calculations herein, in the permanent removal of about 750 and 510 acres of old growth climax
forest habitat value into perpetuity, respectively. Based on the conservatism in the analysis, these
losses are likely higher.
Appendix E — Ecological Habitat Service Analysis E-14 September 30, 2016

EPS.
Table E3. Summary of ecological habitat service values between alternatives by site, habitat
type, and on-site versus off-site impacts.
ONSITE LOSSES and GAINS
Belews Creek
Marshall
Roxboro
Habitat Type by Site
Acres
dSAYs
Acres
dSAYs
Acres
dSAYs
ONSITE LOSSES
Terrestrial
Early Successional/Scrub
0.06
(1)
30
(349)
10
(112)
Forest
19
(330)
95
(1,651)
45
(773)
Mowed -Grass
13
(46)
157
(539)
159
(544)
Terrestrial Total
32
(376)
283
(2,539)
213
(1,429)
Wetland and Surface Water
227
(7,440)
203
(6,641)
117
(3,839)
Total Losses Onsite'
(7,816)
(9,181)
(5,268)
ONSITE GAINS
Terrestrial
Cap -in -Place (CIP) - Grass Cap
260
734
486
1,259
330
881
Removal Alternative - Forest Regeneration
260
1,643
486
1,710
330
890
NET ONSITE LOSSES
Cap -in -Place (CIP) -Total On -Site dSAY Loss'
(7,082)
(7,922)
(4,386)
Removal -Total On -Site dSAY Loss'
(6,172)
(7,471)
(4,378)
Total Acreage of Onsite Habitats Evaluated
260
486
330
OFFSITE LOSSES AND GAINS
Belews Creek
Marshall
Roxboro
Habitat Type by Site
Acres
cISAYs
Acres
dSAYs
Acres
dSAYs
Terrestrial
OFFSITE LOSSES
Cap -in -Place (CIP) - Borrow Area - Forest
168
(2,825)
335
(5,475)
294
(4,740)
Removal Alternative - Borrow Area - Forest
64
(804)
127
(1,091)
154
(1,105)
Removal Alternative - Offsite Landfill Location
162
(2,444)
293
(3,741)
350
(4,232)
OFFSITE GAINS
Cap -in -Place (CIP) - Borrow Area - Forest Regeneration
168
1,527
335
2,787
294
2,520
Removal Alternative - Borrow Area - Forest Regeneration
64
405
127
438
154
415
Removal Alternative -Offsite Landfill Location (Grass Cap)
162
320
293
324
350
298
NET OFFSITE LOSSES
Cap -in -Place (CIP) - Net Off -Site Net Loss
(1,298)
(2,688)
(2,220)
Removal - Net Off -Site Net Loss
(2,523)
(4,070)
(4,624)
CIP -Total Acreage of Offsite Habitats Evaluated
168
335
294
Removal -Total Acreage of Offsite Habitats Evaluated
226
420
504
CIP -Total Acreage Evaluated
428
821
624
Removal -Total Acreage Evaluated
486
906
834
NET LOSSES - TERRESTRIAL AND WETLAND/SURFACE WATER
Cap -in -Place -Total Net Terrestrial Losses
(940)
(3,969)
(2,767)
Cap -in -Place -Total Net Wetland/Surface Water Losses
(7,440)
(6,641)
(3,839)
Removal -Total Net Terrestrial Losses
(1,255)
(4,899)
(5,163)
Removal -Total Net Wetland/Surface Water Losses
(7,440)
(6,641)
(3,839)
OVERALL NET LOSSES
Cap -in -Place (CIP) Overall Net cISAY Loss 2
(8,380)
(10,610)
(6,607)
Removal - Overall Net dSAY Loss 2
(8,695)
(11,540)
(9,002)
PUTTING LOSSES INTO PERSPECTIVE
Cap -in -Place (CIP) - Overall - Acres of Fully Functioning Climax
Forest that would be Lost into Perpetuity 2 (minimum)
245
310
193
Removal - Overall - Acres of Fully Functioning Climax Forest
that would be Lost into Perpetuity 2 (minimum)
254
337
263
1 Assumes that onsite habitats are affected similarly at initiation of the construction for both the Cap -in -Place and Removal alternatives.
2Assumes that the wetland and terrestrial dSAYs are equivalent, an assumption that underestimates ecological losses. Wetlands and surface water
can be 10-20 times the value of forest habitat (DeGroot et al. 2012).
Appendix E - Ecological Habitat Service Analysis E-15 September 30, 2016

J�K
E2 HUMAN RECREATIONAL SERVICES
For this evaluation, since the sites are retained under private property, human recreational on-site
services were not considered. However, it should be recognized that game land areas can provide
significant human use value. In addition, as no off-site impacts were identified, off-site human
recreational service values were not evaluated.
Appendix E — Ecological Habitat Service Analysis E-16 September 30, 2016

0
E3 REFERENCES
Amec Foster Wheeler, 2015a. Letter Report — Waste Strategy Analysis — Belews Creek Steam
Station. Prepared for Duke Energy March 12, 2015.
Amec Foster Wheeler, 2015b. Letter Report — Waste Strategy Analysis (Revised) Marshall Steam
Station. Prepared for Duke Energy July 22, 2015.
Amec Foster Wheeler, 2015c. Letter Report — Waste Strategy Analysis, (Revised) Roxboro Steam
Station — Ash Basin Closure Response. Prepared for Duke Energy March 25, 2015.
de Groot, R., Brander, L., van der Ploeg, S., Costanza, R., Bernard, F., Braat, L., Christie, M.,
Crossman, N., Ghermandi, A., Hein, L., Hussain, S., Kumar, P., McVittie, A., Portela, R.,
Rodriguez, L.C., ten Brink, P., van Beukering, P., 2012. Global estimates of the value of
ecosystems and their services in monetary units. Ecosyst. Serv. 1, 50-61.
Gibson, L., Lee, T., Koh, L., Brook, B., Gardner, T., Barlow, J., Peres, C., Bradshaw, C., Laurence,
W., Lovejoy, T. and Sodhi, N.S. 2011. Primary forests are irreplaceable for sustaining
tropical biodiversity. Nature 478: 378-381.
Greenpeace. Web Accessed June 23, 2016.
http://www. rg eenpeace.org/international/en/campaigns/forests/solutions/
Johnson C., Zarin D., and A. Johnson. 2000. Post -disturbance aboveground biomass accumulation
in global secondary forests. Ecology 81:1395-1401.
Law, B., Thornton, J., Anthoni, P. and S. Van Tuyl. 2001. Carbon storage and fluxes in ponderosa
pine forests at different developmental stages. Global Change Biology. 7, pp. 755-777
McMahon, S. M., Parker, G. G., and Miller, D. R. 2010. Evidence for a recent increase in forest
growth. PNAS, Edited by William H. Schlesinger, Institute of Ecosystem Studies,
Millbrook, NY, February 23, 2010, Vol. 107, No. 8, 3611-3615.
Millennium Ecosystem Assessment. Ecosystems and Human Well-being: Full Report; Island
Press: Washington, DC, USA, 2005.
Nicolette, J., Burr, S., and Rockel, M. 2013. A Practical Approach for Demonstrating
Environmental Sustainability and Stewardship through a Net Ecosystem Service Analysis.
Sustainability 2013, 5, 2152-2177; doi:10.3390/su5052152, Published May 10, 2013.
Parrotta, J. 2012. Understanding Relationships between Biodiversity, Carbon, Forests and People:
The Key to Achieving REDD+ Objectives. A Global Assessment Report. Prepared by the
Global Forest Expert Panel on Biodiversity, Forest Management, and REDD+. Wildburger
& Stephanie Mansourian (eds.) IUFRO World Series Volume 31. Vienna. 161 p. ISBN
978-3-902762-17-7, ISSN 1016-3263
Appendix E — Ecological Habitat Service Analysis E-17 September 30, 2016

0
Thompson, I.D., Mackey, B., McNulty, S. and Mosseler, A., 2009. Forest resilience, biodiversity,
and climate change. A synthesis of the biodiversity/resilience/stability relationship in forest
ecosystems. Technical Series no. 43. Montreal: Secretariat of the Convention on Biological
Diversity.
United States 1997. United States v. Melvin Fisher. United States District Court for the Southern
District of Florida, Key West Division Case Numbers 92-10027-CIV-DAVIS, and 95-
10051-CIV-DAVIS. Decided 30 July 1997, Filed 30 July 1997. 977 F. Supp. 1193; 1997
U.S. Dist. LEXIS 16767.
United States 2001. United States of America and Internal Improvement Trust Fund v. Great Lakes
Dredge and Dock Company. United States District Court for the Southern District of
Florida D. C. Docket No. 97 -02510 -CV -EBD.
Verschuyl, J., Hansen, A., McWethy, D., Sallabanks, R., and R. Hutto. 2008. Is the effect of forest
structure on bird diversity modified by forest productivity? Ecological Applications, 18(5),
pp. 1155-1170.
Appendix E — Ecological Habitat Service Analysis E-18 September 30, 2016

0
APPENDIX F
Joseph Nicolette CV
Appendix F — Joseph Nicolette CV F-1

Joseph Nicolette
Fields of Competence
Risk management and net environmental benefit
analysis (NEBA)
Natural resource damage assessment (NRDA)
Ecosystem service valuation
Site remediation alternatives analysis
Ecological and human health risk assessment evaluation
CERCLA project coordination
Oil spill response and planning
Aquatic ecology
Experience Summary
Expertise: Joseph Nicolette has over 30 years of
experience in the environmental consulting field with a
focus on NRDA, NEBA, ecosystem service valuation,
site risk management, remediation alternatives analysis,
project coordination and agency relations, and aquatic
ecology. He is a Senior Principal and Ecosystem
Services Practice Leader at Environmental Planning
Specialists, Inc. (EPS).
Joe has made demonstrated contributions both nationally
and internationally in developing what is known as the
net environmental benefits analysis (NEBA) or net
ecosystem service analysis (MESA) approaches. He co-
authored the first formalized NEBA framework
recognized by the United States Environmental
Protection Agency (USEPA), the USEPA Science
Advisory Board (USEPA SAB), the National Oceanic
and Atmospheric Administration (NOAA). Joe has
focused on NEBA applications to site risk management
and decision-making, incorporating ecosystem service
valuation, over the past 24 years.
He provides strategic advice and oversight for projects
to help balance the risks, benefits and tradeoffs
associated with competing alternatives (e.g., remediation
actions, mitigation and restoration, oil spill response, site
restoration, and decommissioning actions). He has
contributed to multiple environmental assessments
associated with oil and chemical releases, and has
managed NEBA, NRDA and CERCLA issues on behalf
of the responsible party. His role has been to provide
technical direction and assist the client in coordination
with Natural Resource Trustee Agencies (State and
Federal), the United States Environmental Protection
Agency (USEPA), state agencies, and other stakeholders
in the risk management and NRDA processes.
Joseph has participated in NRDA projects since 1990.
He is recognized for his NRDA experience and role in
pioneering NRDA injury and restoration ecological
Appendix F - Joseph Nicolette CV
economics approaches such as habitat equivalency
analysis (HEA). He has been involved in the conduct of
impact assessments for over 50 hazardous releases and
has led projects on behalf of the client, including agency
negotiations. These include assessments associated with
oil and chemical releases (including petroleum products,
PCB's, DDT, dioxin, metals, etc.) and damage
assessments associated with releases under US NRDA
regulations and the EU Environmental Liabilities
Directive (ELD). He has contributed to multiple
environmental assessments associated with oil releases
from the Exxon Valdez up to and including the
Deepwater Horizon Incident. Mr. Nicolette has managed
over 50 NRDA related projects. His services include
client strategy development regarding natural resource
injury and environmental assessment; ecological and
human health risk characterization; mitigation and
remedial planning, restoration valuation and planning,
allocation modeling, agency negotiations, technical
assessment design, and technical data review,
assessment, and interpretation.
Joseph has also worked with several law firms to provide
expert witness and litigation support for multiple NRDA
related environmental cases. He has provided written
affidavits to support his technical findings and provided
testimony through deposition by the Department of
Justice.
He has also served as the Project Coordinator and/or risk
management lead on behalf of the responsible party at
multiple Superfund (CERCLA) sites. He has experience
with sites in EPA Regions 2, 3, 4, 5, 6, 8 and 10. These
sites were primarily related to polychlorinated biphenyls
(PCBs), metals, dioxin, and TCE releases to a variety of
media such as soil, sediment, surface water and
groundwater. These projects involved the assessment of
ecological and human health risks and the feasibility of
various remedies to manage potential risks.
Mr. Nicolette has also provided PRP identification and
remedial/NKDA liability allocation support for
industrial clients. He has developed and reviewed
allocation models for specific sites, determining
estimates of the portion of remedial and NKDA liability
associated with various PRP's at the site.
Joseph is also trained in hierarchical relational scientific
database design, structuring and management.
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Joseph Nicolette
Credentials
M.S. Fisheries Management, 1983. University of
Minnesota - related fields: statistics, computer
applications, and aquatic invertebrates
B.S. Environmental Resources Management, 1980.
Pennsylvania State University
Certifications
Certified Fisheries Scientist, no. 2,042, since 1992
Career
2016 -Present
Senior Principal and Ecosystem Service Practice
Director
Joes role is to provide strategic consultation for projects
directed at managing client environmental liabilities
(e.g., NEBA, NRDA, oil spill response, offshore
decommissioning, remediation, risk management) and
assets, including natural resource valuations of land
parcels.
2009-2016
Principal, Global Ecosystem Services Director,
Ramboll Environ
Provided strategic consultation for projects directed at
managing client environmental liabilities (e.g., NEBA,
NRDA, oil spill response, offshore decommissioning,
remediation, risk management) and assets, including
natural resource valuations of land parcels.
1999-2009
Vice President, Natural Resource Liability and Asset
Management, C112M HILL
Provided strategic consultation for projects
directed at managing client environmental
liabilities (e.g., NEBA, NRDA, oil spill response,
offshore decommissioning, remediation, risk
management) and assets, including natural
resource valuations of land parcels.
1998-1999
President, Nicolette Environmental, Inc.
NRDA Project Strategy, Management, and
Negotiations
Appendix F - Joseph Nicolette CV
1990-1998
Senior Consultant, ENTRIX Inc.
Oil Spill Response and Damage Assessment Advisor
1984-1990
Operations Supervisor, Adirondack lakes Survey
Corporation Oversight of field operations, data
management, and QA/QC
1983-84
North Carolina State University
Acid Deposition Program. Database Manager.
Developed the Fish Information Network as part of acid
deposition studies in the United States.
Professional Affiliations
USGS sponsored ACES (a community of ecosystem
services) — Steering/Planning Committees 2008 -present
Net Environmental Benefits Analysis
Joe's contributions to the development of NEBA
approaches, aside from co-authoring the first
formalized NEBA framework, includes the conduct of
national and international presentations and workshops
(Brazil, Canada, Germany, Great Britain, Italy,
Malaysia, Norway, Scotland, South Africa, Sweden,
Thailand, United States, etc.) related to ecosystem
service valuation, benefits assessment (i.e., NEBA),
risk management, project development, resource
equivalency, oil spill response and planning, site
remediation and damage assessment.
Joes success in this area also includes:
✓ Recognition of, and incorporation of the formalized
NEBA framework by the USEPA in a report by the
USEPA Science Advisory Report entitled "Valuing
the Protection of Ecological Systems and
Services", (2009).
✓ A chapter regarding NEBA that was integrated into
Interstate Technical Regulatory Council Guidance
(2006).
✓ Pilot studies evaluating appropriate metrics for
NEBA for site cleanup, restoration, and
remediation on behalf of the US Environmental
Protection Agency (2008).
✓ Guidance for the London Energy Institute (2009
and 2010, London) on the Environmental Liability
Directive and on establishing ecological baselines
F, D

N
N
I
Joseph Nicolette
(pre -incident) using NEBA concepts.
NEBA support for the Oil and Gas Producers
(2015-2016) (OGP) Joint Industry Group (JIP)
related to oil spill response and planning in the
Arctic.
He was the lead author of a book chapter
(published in March of 2013 by the Oxford Press)
that provided an overview of the U.S. natural
resource damage assessment regulations and the
development of resource equivalency analysis
approaches. The book was entitled "The E.U.
Liability Directive: A Commentary". He led
Chapter 9 that was entitled "Experience with
Restoration of Environmental Damage". The
chapter also discusses the similarities and
differences of the U.S. NRDA rules in relation to
the ELD.
Led the first NEBA studies for decommissioning of
offshore oil and gas platforms in Australia and the
North Sea (2014 -Present).
Multiple published papers and reports related to
NEBA and ecosystem service valuation.
Multiple client projects using NEBA and
ecosystem service valuation approaches to address
remedial risk issues and manage costs
Joseph has served on the Planning and Steering
committees for the ACES Conferences (A
Community of Ecosystem Services), working with
the United States Geological Survey Conference
leaders since 2008.
Participated in the conduct of numerous
environmental assessments associated with the
development of restoration and remedial decisions.
This includes the ecosystem service valuation of
compensatory restoration projects related to NRDA
or other resolutions.
Example Projects
Armstrong World Industries CERCLA OU -1 Site,
Macon, Georgia. Joe served as the EPA Project
Coordinator on behalf of AWI and provided oversight of
Operable Unit 1 (OU -1) evaluations, including the
development of the environmental engineering/cost
analysis (EE/CA), remedial design/remedial action, Post -
Closure, NRDA/NEBA considerations, and supporting
field sampling. He assisted in negotiations with the
USEPA and State agencies and coordinated OU -1
CERCLA activities, on behalf of AWI, with the USEPA
and GAEPD. The primary contaminant of concern was
PCBs. He provided oversight of the site characterization
efforts including the development of study plans, the
Appendix F - Joseph Nicolette CV
ecological and human health risk assessments, and the site
remedy with a focus on the managing potential PCB risks.
BP Deepwater Horizon. Joe served as a Project Technical
Lead related to selected damage assessment (NRDA)
issues associated with the Deepwater Horizon Gulf of
Mexico oil release.
Crab Orchard National Wildlife Refuge, PCB
CERCLA/NRDA Site, Marion, Illinois. Joe led PCB site
characterization, remedial alternatives analysis through
NEBA, remediation implementation, and NRDA liability
management). Joseph served as the CERCLA Project
Coordinator jointly working with two PRP's
(Schlumberger and the USFWS). He helped negotiate
environmental remedial and NRDA associated liabilities
related to historical PCB releases at the site. In serving as
the Project Coordinator, he coordinated closely with the
federal (USFWS, USEPA) and state (IL DNR, IL EPA)
regulatory agencies. This was a unique case in that the
USFWS was a PRP and at the same time, a trustee for
natural resources. Innovative risk management data
collection and analysis approaches were used to support
risk management decision-making and included
incremental sampling study design and surface weighted
area concentration (SWAG) analysis A NEBA-based
approach using resource equivalency analysis was used as
part of the remedial and damage assessment resolution,
saving the client over $10 million dollars.
Edwards Air Force Base (EAFB) and NASA CERCLA
Site, California. NRDA and remedial NEBA
negotiations. Joe provided NRDA and remedial NEBA
support to EAFB as the responsible party at this site.
Joseph developed an overarching CERCLA NRDA and
NEBA strategy to EAFB and participated in agency
negotiations. Major issues were related to groundwater
and surface soil contamination. A NEBA was used to
demonstrate that the presumptive pump and treat remedy
would provide no net benefit to the public. A less
intrusive NINA alternative was instituted and reduced
project costs by $65 million.
USEPA OSWER NEBA Studies, Colorado and Florida
Joe served as the Principle Investigator for a project
evaluating the metrics that can be used to evaluate changes
in ecosystem services associated with site remediation and
local development. This work was conducted for the
F. D

Joseph Nicolette
USEPA OSWER group as it relates to evaluating the net
environmental benefit (NEBA) associated with remedial
actions at superfund sites. The USEPA was evaluating the
use of NEBA to help demonstrate the benefits and
environmental stewardship associated with site
remediation and in the selection of site management
alternatives. These studies were conducted for the USEPA
at Rocky Mountain Arsenal, Colorado, and Homestead
AFB, Florida. This project was directed at a "real world"
evaluation of metrics that can be used to evaluate changes
in ecosystem service values associated with site cleanup
decision making. This project was titled "Demonstrating
the Net Environmental Benefit of Site Cleanup; An
Evaluation of Ecological and Economic Metrics at Two
Superfund Sites" was conducted for the USEPA
Superfund group as it relates to evaluating the net
environmental benefit associated with remedial actions at
Superfund sites and appropriate metrics. This work was
developed to be consistent with the Millennium
Assessment ecological service categorization.
Texas: For Region 6 USEPA, Joe supported the conduct
of NEBAs to evaluate remedial alternatives at two
orphan sites in Texas. The NEBAs were used to
demonstrate the benefitslimpacts associated with
remediation. These are described below.
NEBA for USEPA: Jasper Creosoting Company
Superfund Site, Texas: An ecological risk assessment
(ERA) for a wetland indicated low to medium risks
for benthic invertebrates and a subset of upper trophic
level receptors associated with exposure to dioxin and
polycyclic aromatic hydrocarbons in sediment. Joe
supported the development of a NEBA for USEPA
Region 6 to quantify the net present value of the
ecological services associated with no further action
and six remedial alternatives involving monitoring,
phytoremediation and combinations of full removal,
partial removal and wetland enhancement. The
NEBA demonstrated that monitored natural
attenuation coupled with phytoremediation would
provide the greatest net environmental benefit at the
least cost and decrease ecological risks over time. The
cost of this alternative was estimated to be more than
$2 million less than the most intrusive remedy.
Appendix F - Joseph Nicolette CV
NEBA for USEPA: State Marine Superfund Site,
Texas: Joe supported the development of a NEBA for
the USEPA to evaluate remedial alternatives for
marginal ecological risks to benthic invertebrates
identified in intertidal sediments. The baseline level
of ecological service associated with no further action
and monitored natural attenuation was evaluated as
well as the net change in ecological services that
would be expected with a sediment removal action.
The NEBA results indicated that the loss of
ecological services associated with no further action
would be minor, if injury was occurring, and that the
intrusive remedy would create a greater net
ecological service loss because of impacts to habitat.
In this case, no further action was selected as the
preferred alternative as the NEBA demonstrated that
expenditure of more than $6 million on sediment
removal would not be protective of the environment.
Army Base Realignment and Closure (BRAC) Strategy
Studies Joe served as the Principal Investigator for the
U.S. Department of the Army of four studies designed to
understand site development and reuse strategies and
integration of natural resource values to maximize the
benefits associated with site natural resources and
remedial strategies. For these studies, potential site
remedial alternatives were evaluated in conjunction with
potential reuse scenarios to reflect the interdependencies
between remediation and property reuse. The goal for
each site was to identify the combination of remedial
action and re -use that would provide for the protection of
human health and the environment while providing the
greatest net ecological and human use value. This series
of studies conducted over two years and included the
following four Army BRAC sites: Camp Bonneville,
Washington; Savanna Army Depot, Illinois; Fort Ord,
California; and Fort McClellan, Alabama. The
Department of the Army used the information from these
analyses to develop preferred land management and
remedial actions for each site that minimize remedial costs
while maximizing natural resource values to the public.
Passaic River, New Jersey. Joe developed a preliminary
example NEBA evaluation for Passaic River remedial
alternatives (large scale sediment dredging) as proposed
by the USEPA. The overall goal was to demonstrate the
F, D

Joseph Nicolette
environmental and human health cost/benefit of proposed
intrusive remediation.
Tennessee EIS Support Eco Asset Valuation:
Comparing Economic Development and Conservation
of over 300 Land Parcels
Joe was the technical lead for a land eco -valuation project
for a confidential client. In partnership with the client's
Resource Stewardship Division, Joseph led a Land
Valuation Pilot for 14,000 acres that surrounded a
reservoir in Tennessee. This project was conducted as a
NEBA in support of the client's NEPA documentation
(e.g., supporting the preferred alternative) that will drive
the management of properties surrounding the reservoir.
As part of this work, he evaluated and compared the
environmental (e.g., natural resource) value and real estate
(e.g., "highest and best" land use) value associated with
the parcels located within the project area given the three
proposed land use alternative scenarios (e.g. no -action,
balanced conservation and recreation, and balanced
development and recreation). This analysis resulted in the
development of a 4th preferred alternative that maximized
ecosystem service values (ecological and human use) back
to the public.
Brownfield Site NEBA Options Analysis. Joe provided
oversight of the incorporation of a NEBA framework for
a large brownfield site. He collaboratively worked with
the City of Milwaukee, the public, regulatory agencies and
prospective developers as part of the City of Milwaukee's
Menomonee Valley Industrial Center Redevelopment
Program to create a sustainability -focused brownfield's
success. Through the use of a NEBA framework, he was
able to evaluate the development plans for the Brownfield
site and modify/tweak the designs to maximize ecological
and human use values to the public. We were able to
demonstrate that the revised plan for site restoration and
remediation activities created ecological, recreational and
aesthetic creation/enhancement benefits estimated at over
$120MM of value to the public. In addition, the NEBA
also assisted in identifying over $25MM in value -
engineered cost savings and new-found revenue streams
from the beneficial re -use of materials.
NEBA for PCB Related Dam Removal at Lake Hartwell,
South Carolina. Joe assisted a client in evaluation of the
ecological impacts associated with the removal of two
Appendix F - Joseph Nicolette CV
dams in South Carolina. The dam removals were being
conducted as part of an NRDA settlement associated with
PCB releases. Joe evaluated ongoing fish tissue PCB
concentrations associated with MMA activities.
Lower Passaic River, PRP Group NRDA Negotiations
and Strategy Advisement, New Jersey. Joe supported a
group of Cooperating PRP's in developing a strategy and
negotiating with the State and federal trustees regarding
the Lower Passaic River NRDA. Joseph directly
interfaced with the Companies and the State and federal
Trustees. His role was to assist the PRP's in developing a
strategy to manage their NRDA liability at the site. He
assisted with conducting preliminary evaluations of
ecological and human use injury and compensatory
restoration project identification.
LCP CERCLA Site, Brunswick, Georgia, PCB releases.
Joe provided remedial NEBA analysis and NRDA support
associated with PCB releases for a client in Brunswick,
GA. His role was to evaluate ecological risk data for the
purposes of integrating select areas of the estuary into a
NEBA sediment management approach. In addition, he
also evaluated injury assessment data and developed
potential compensatory restoration options as part of this
project. He participated in agency meetings and
discussions regarding remedial and NRDA issues.
Delaware River, Pennsylvania, PCBs. Joe supported a
PRP on ecological risk and NRDA issues associated with
historical PCB releases at the Metals Bank site.
Specifically, he evaluated potential impacts of PCBs on
aquatic invertebrates, fish, and birds. A resource
equivalency analysis approach was used as part of the
damage assessment. Joe evaluated agency impact analyses
and developed appropriate compensatory restoration.
Kalamazoo River, Michigan, PCBs. Joe assisted a client
on the Kalamazoo River in the evaluation of historical
PCB concentrations, potential impacts to fish and
terrestrial biota, development of appropriate SWAC
concentrations, and remedial alternative evaluations. Joe
evaluated fish tissue PCB concentrations and examined
trends of PCBs in fish along the river.
Sediment PCB Remedial NEBA Evaluation.
Confidential Client, Portland, Oregon. Joe provided
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Joseph Nicolette
technical and strategic support to a client on the
Willamette River to settle its NRDA mitigation liability.
Wisconsin Tissue, Fox River PCBs. Joe provided
technical and strategic advice to Wisconsin Tissue
regarding the Fox River NRDA and participated in trustee
negotiations on behalf of Wisconsin Tissue.
Confidential Client, Calumet River CERCLA,
Allocation, Remedial, and NADA Support. Joe
represented a potentially responsible party (PRP) with
remedial and NRDA liabilities associated with historical
PCBs, metals, etc. releases. In this context, Joe reviewed
allocation issues, HEA model runs, sediment ecological
and water toxicity data, and sediment and water column
concentration data to assist the client in responding to
demands of the natural resource trustees and other PRPs.
Allocation Modeling. Confidential Clients, New York,
New Jersey, and Indiana: Joe has provided PRP
identification and remedial liability allocation support for
two major industrial clients in the states of New York,
New Jersey, and Indiana. The overall purpose of these
projects was to identify potential PRPs and rank them by
estimated contribution in relation to one another. Based
upon the information gathered during this work (e.g.,
volumes released, parameter toxicity, geographic
location), supported the development of allocation models
and the approach for determining estimates of the portion
of remedial liability associated with each PRP.
Colonial Pipeline Company. Senior NRDA Advisor
(1993 -Present). Oil spill response, planning and
assessment. Joe's responsibilities included overall project
management (of oil release impact assessments, including
participation in company planning and drills) for Colonial
from a technical and administrative aspect, including
project strategy, coordination with the governmental
regulatory agencies, management of contractors, cost
control and management, task management, field study
coordination, risk management, technical expertise, and
report generation. In addition, he provides overall
management and oversight of necessary compensatory
restoration required as part of a spill settlement, if any.
Appendix F - Joseph Nicolette CV
Example emergency releases Joe has responded to and/or
provided expertise for environmental assessments include
the following:
o BP, Deepwater Horizon, Gulf of Mexico
o BP barge release, Elizabeth River, VA
o Sugarland Run, Potomac River
o Darling Creek, Louisiana
o Lookout Mountain, Tennessee
o Tennessee River/Goose Creek, Knoxville
o Reedy River, South Carolina
o San Jacinto River, Texas
o Pine Bend, Tennessee
o Simpsonville, South Carolina
o Sun Oil, barge release, Delaware River, DE
o Maritrans, tug barge release, Mississippi River, MN
o Amoco Pipeline, pipeline release, Whiting, Illinois
o Southern Pacific Railroad, tanker car (release of
metum sodium, Sacramento River, CA)
o Buckeye Pipeline release, Allegheny River, PA
o Buckeye Pipeline release, Quinnipiac River, CT
o EXXON, tanker, Prince William Sound, Valdez, AK
o Plantation Pipeline, pipeline release, Rich Fork, NC
o Plantation Pipeline, pipeline release, Ward Road, GA
o Conoco. Calcasieu Estuary, Louisiana
o Unocal, Guadalupe, CA
o Union Pacific Railroad, 7 train derailment releases,
UT, CO
o Petrobras, pipeline release, Brazil Rainforest
o CITGO, pipeline release, Texas
o Multiple smaller releases
Alabama, Marshall Space Flight Center. NRDA, NEBA,
and site remediation of groundwater contamination at
NASA Marshall Space Flight Center CERCLA Site in
Alabama. Joe was retained to provide oversight of a
NRDA for the NASA Marshall Space Flight Center in
Huntsville, Alabama. Joseph assisted in coordinating the
assessment with the natural resource trustees and provided
technical support for determining the potential levels of
injury and potential scale of compensatory restoration.
This project also entailed the use of NEBA to evaluate
potential remedial alternatives associated with the site.
D

Joseph Nicolette
Koch Site, Hastings, Minnesota Using natural resource
economics -based approaches, Joe supported an
assessment of the value to the public of converting a land
asset along the Mississippi River to a public recreational
use to obtain a consent decree, facilitate site closure, and
generate substantial goodwill with the public. The fair
market value of the property was $215,000 and the
recreational value, given the transfer scenario, was
approximately $30 million (see following press release).
"Plans Announced for Koch Riverfront Park; City to
Complete Bike Trail, Develop Park with Koch Petroleum
Group's Gift of Land, April 20, 2000 5:46 PM EDT
HASTINGS, Minn., April 20 /PRNewswire/ -- At a
ceremony held today on the west bank of the Mississippi
River, the City of Hastings and Koch Petroleum Group
unveiled a joint initiative to develop a bike trail and a
community park on riverfront property currently owned
by Koch. David Robertson, president of Koch Petroleum
Group, announced the company's donation of 43 acres of
Mississippi riverfront land to the city. Hastings Mayor
Mike Werner also announced that the city will name the
area Koch Riverfront Park. The announcement ceremony,
hosted by Werner and Robertson, was held at the
riverfront site immediately northwest of downtown
Hastings. "We sincerely hope that generations of area
families will enjoy the park, and that it will serve as a
gathering place that will connect community members to
each other and to the river, " said Robertson. The
appraised market value of the land is $215,000; its
potential recreation value to the public is estimated at $30
million based on a recent study... "
RMC, Troutdale Superfund Site, Oregon — CERCLA,
NEBA, CWA, NRDA. Joe provided strategic advice
regarding the evaluation of remediation options for
RMC's 16 -acre NPDES process water pond ("Company
Lake"). Regulatory agencies stated a desire to declare the
pond a Water of the State. Such a determination would
have eliminated RMC's ability to use the pond as part of
the plant's NPDES wastewater management system. This
would have required closing the plant or constructing a
replacement storm water treatment system. Joseph
supported a collaborative negotiation process that resulted
in integrating pond remediation, continued pond use for
NPDES purposes, plant storm water system upgrades, and
an informal settlement of NRD claims. Direct savings to
RMC in reduced project scope are estimated at more than
Appendix F - Joseph Nicolette CV
$1 million. Indirect savings associated with retaining use
of Company Lake are believed to exceed $10 million.
Land Transfer and Restoration Strategy, Confidential
Client, Utah Joe contributed to a study whose purpose was
to determine the status of real estate, contamination and
natural resource conditions for a large and complex
industrial site in Utah. This analysis served to develop a
path forward to demonstrate and maximize the value of a
site by integrating site cleanup with site reuse and future
development. This study considered and integrated
Property Reuse Alternatives, Alternative Remedial
Approaches, Natural Resource Assets, and Liability
Transfer Options. The results of the study provided the
high-level framework to establish a reasonable
performance target for the eventual reuse of the site and
helped the client to maximize the overall ecological and
human use values that the site could provide under various
reuse scenarios. For most large, complex sites there is an
initial degree of uncertainty associated with defining
environmental remediation and the potential impact on the
real estate and ecological assets of the site. The study
process was developed to establish high-level
opportunities for value enhancement through the
development of a proactive strategy to reduce this
uncertainty and effectively reposition the property for sale
and future site reuse. This study was a key step in the
process to ensure that the site is proactively repositioned,
sold and redeveloped. The study also reduced the
uncertainty associated with existing environmental
remediation and restoration and provides insight into the
environmental issues associated with site reuse.
Tactical Oil Response Plans. Joe has led the development
of tactical response plans for Colonial Pipeline for
multiple locations in the SE United States. These plans
have been developed with NEBA concepts in mind to
assist Colonial in managing response efforts in the event
of a release. Joe supports Colonial in annual spill drill
events. His role is to help Colonial Pipeline manage
environmental impacts and liabilities during an event,
including NEBA considerations in OSRP.
Pipeline Mitigation Projects Joe led a NEBA to evaluate
the mitigation requirements for a pipeline expansion
project in Louisiana. This project demonstrated that the
compensatory restoration was 60% less than that
F• D

Joseph Nicolette
requested by the USACE. This reduced the client project
costs substantially. The results were published in the Oil
and Gas Pipeline Magazine.
For the same client, Joe led a NEBA to evaluate the
mitigation requirements for a pipeline expansion project
in Texas. This project demonstrated that the compensatory
restoration was significantly less (greater than 50% less)
than what was estimated to be requested by the USACE.
This analysis incorporated the resource equivalency
approaches and consideration of socioeconomic benefits
Mitigation Bank Prospectus Development and Financial
Cash Flow Analysis For a confidential client, Joe led the
evaluation of the remedial liability and buffer land
wetland and stream mitigation banking value associated
with the clients property. Based on the evaluation,
ENVIRON staff calculated the credit values for both the
wetland and stream banking opportunities and developed
a mitigation bank prospectus that was negotiated with the
US Army Corps of Engineers. As with any mitigation
banking project, the primary uncertainties in determining
the cost and return of a project include: the quantity of
credits that can be realized, the market available for the
credits, the sale price of the credits and the cost of
restoration or creating the credits. Joe conducted an
analysis to understand the mitigation banking
uncertainties and minimize these uncertainties. A
financial cash flow analysis was conducted to bound the
project uncertainties.
The mitigation bank cash flow financial analysis was
conducted based upon our understanding of the credit
values, demand and potential site uplift (i.e., number of
credits to be allocated). This analysis provided our client
with the information necessary to evaluate the business
case for the bank as more refined information became
available. As such, it provided an "off ramp" should any
information arise that would make the mitigation bank
non -desirable from a financial perspective. The cash flow
analysis was a critical step to determine viability of the
project. The cost and returns were predicted under
conservative, likely and aggressive scenarios.
Confidential Railroad, Litigation Support (Utah,
Nevada, Colorado). Joe was retained by a major railroad
to support a major litigation case. Joe Nicolette served as
Appendix F - Joseph Nicolette CV
a technical expert for the railroad providing expertise
related to the environmental effects of chemical releases
to the environment (tanker car releases associated with
derailments along multiple sites: diesel and sulfuric acid
releases) and the NRDA process. He evaluated multiple
sites regarding NRDA liability and provided strategic
advice to the client regarding potential liabilities. This
case was settled prior to deposition.
Confidential Paper Company: Private and Public
Interest Property Valuation Joe led a study for a large
paper company to evaluate the natural resource value
associated with buffer properties surrounding a mill that
was scheduled for closure. The client was looking to
capture eco -asset values not typically considered in fair
market valuations. The evaluation considered multiple
land parcels for several hundred acres of property and
provided an assessment of the "private" and "public'
interest value associated with the property. Using this
information, the client was able to negotiate the sale of the
property, manage site liabilities, and capture value greater
than a fair market value. This project included an
evaluation of wetland and stream mitigation banking
value including calculation and estimation of potential
credit values and potential cash-flow for the site. The eco -
asset valuation estimated the minimum private interest
value (based on the ranges developed in this
memorandum) was estimated to be about $7,500,000. The
FMV of the property was in the range of $400,000. The
overall public interest value was estimated to be
$5,200,000. Client used this analysis to inform
negotiations regarding the sale of their property.
Confidential Client, Los Angeles Harbor, California —
NRDA. Joe assisted in an in-depth statistical analysis of
sediment toxicity PCB and DDT concentrations. This
project entailed a thorough analysis of sediment
concentration threshold data and the applicability of these
data to represent thresholds in sediments of the Los
Angeles Harbor area. This analysis was conducted to
provide a sound scientific basis to refute the apparent
effects threshold (AET) levels developed by a NOAA
expert witness.
Statistical Analysis, Lower Bayou d7nde and Calcasieu
River Estuary. Joe examined the spatial and temporal
trends of hexachlorobenzene, and hexachlorobutadiene
F, D

Joseph Nicolette
(HCB and HCBD, respectively), PCBs, and mercury in
sediments and biological tissues in these waterways.
Evaluated trend data in response to National Oceanic and
Atmospheric Administration (NOAA) comments
regarding analysis of the data. These data will be used in
creating a proposed restoration -based compensation
approach for the site using NEBA, HEA, and ROA.
American Petroleum Institute Aquatic Toxicity Studies.
Joe participated in a study to evaluate the toxicity of
petroleum products on fish, invertebrates, algae, and
zooplankton for use in NRDA's. The purpose of the
project was to conduct a critical review of toxicity values
for the purposes of identifying potential risks associated
with released oil. This study screened about 8,000
references published on the fate and effects of petroleum
in the environment. The study evaluated and compared
toxicity values for a range of petroleum substances from
crude oil to petroleum products. This analysis identified
the large disparity between acute (LC50) values for a
given compound for the same species and identified the
likely causes associated with methods used to derive
toxicity values.
Conoco, Clooney Loop, Louisiana. Assisted in
development of a net environmental benefits analysis to
demonstrate that a less intrusive remedy for ethylene
dichloride coupled with wetlands restoration resulted in
greater environmental benefit than dredging remedy.
Resulted in a cost savings of $19 million to Conoco.
Exxon Valdez, Alaska. When the supertanker Exxon
Valdez struck a rock reef and spilled approximately 11
million gallons of crude oil into Prince William Sound,
Joe participated in a project to evaluate the impacts of the
oil release on invertebrate populations in selected Prince
William Sound areas. The purpose of the work was to
collect data to contribute to a NEBA. Data were collected
to describe the epifauna and epiflora, cryptic fauna, and
infauna of oiled and reference beaches and to relate the
composition, numbers, and vertical distribution of infauna
to the amounts of subsurface oil.
International Project Examples
Landmark Enforcement Case, U.K. Joe provided
technical oversight (2013) for a recent landmark
Appendix F - Joseph Nicolette CV
enforcement undertaking in the U.K. for a water pollution
offence. This was the first enforcement undertaking
accepted by the environment agency for a pollution
incident. Joe led the technical effort for the client's
external legal representation in assessing suitable actions
to compensate for the environmental impacts of a river
pollution incident. The technical basis for the resolution
was the use of a resource equivalency analysis approach
(i.e., habitat equivalency analysis — HEA). The
Environment Agency accepted an enforcement
undertaking as a practical alternative to a prosecution and
fine. This was the first case in the U.K. to use this
approach.
Lago Maggiore, Italy Joe led a Comparative Analysis
(CA) (e.g. a NEBA) to provide a formal quantification of
the change in key ecosystem service values that would be
associated with the implementation of a remedial action
and compares those changes to costs and predicted
changes in risk. The goal of a CA is to provide information
to support the selection of remedial alternatives that
maximize benefits to the public, while managing site risks
and costs.
Offshore Decommissioning O&G platforms and
FPSO's in the North Sea and Western Australia
Confidential Clients Joe was the Principal Investigator
leading NEBA efforts associated with the
decommissioning of offshore O&G platforms and FPSO's
(Australia and the North Sea). These NEBA projects entail
an understanding of the environmental conditions of the
site; subsea infrastructure design, removal alternatives that
can be considered for the site, ROV analysis, fate and
transport of potential chemical releases and baseline
conditions, ecological and human risk assessment
evaluations for both potential chemical (NORM,
petroleum, mercury, etc.) releases and physical impacts
associated with removal alternative implementation;
associated GHG emissions of removal alternatives;
human use evaluation of the sites (e.g., commercial,
recreational fisheries); Marine life and CITES
evaluations; baseline and predictive impact assessment;
and worker health and safety.
Arctic NEBA, Oil and Gas Industry. Joe worked as part
of an integrated team to develop a NEBA tool for oil spill
response and planning for the Oil and Gas Producers

Joseph Nicolette
(OGP) Joint Industry Group (JIP) related to oil spill
response and planning in the Arctic. The overall goal of
the Phase 2 Project is to help evaluate oil spill response
technologies, their application in the Arctic environment,
and develop a decision-making tool to limit environmental
and social impacts in the event of an oil release.
Ecosystem Services Analysis of Chlorpyrifos Use in
Citrus Production, Spain Joe led an analysis of the effects
on ecosystem services (ES) of using an agricultural
insecticide (chlorpyrifos) in citrus orchards in south-
eastern Spain to identify risk management actions and
understand the consequences of the hypothetical situation
of discontinued use of chlorpyrifos. Farmers rely on
chlorpyrifos to limit the occurrence of skin blemishes on
the surface of citrus fruit caused by scale insects. Citrus
fruit is graded for sale based on size, shape and lack of
skin blemishes under European marketing regulations;
farmers only make a profit when unblemished fruit is sold
in Europe. ES, including income, were compared for the
current status and the hypothetical scenario. The study
concluded that discontinuation of chlorpyrifos use would
result in significant economic losses for the region when
only a small change in current orchard management, such
as using a vegetated conservation area for risk mitigation,
could offset potential ecological impacts while
maintaining farmer's income and the recreational value of
orchards to local people. The study informed advocacy
discussions between the client, scientists and policy
makers responsible for pesticide authorisation in Europe.
Ecosystem Services Analysis of an Agricultural
Molluscicide used in the UK Joe led an analysis of the
effects on ecosystem services (ES) of using an agricultural
molluscicide in winter wheat and oilseed rape production
in the UK. These are key crops and farmers in north-
western Europe rely on the control of slugs using pelleted
molluscicides for crop protection. The study compared
marketing leading molluscicides and presented the costs
and benefits of each across a range of ecosystem services,
including crop production, habitat services (e.g. indicator
farmland species), soil and drinking water services. The
findings informed advocacy discussions with pesticide
regulators at a national level and had implications for other
environmental policies, such as the European Water
Framework Directive.
Appendix F - Joseph Nicolette CV
Ecosystem Services Analysis of 1,3-Dichloropropene
(1,3-D) Use in Tomato Production, Italy The use of 1,3-
D as a soil fumigant for the control of damaging nematode
pests in tomato production in Southern Italy and Sicily
was evaluated using an ecosystem services approach. 1,3-
D is currently approved for emergency use in Italian
tomato cultivation, although its use is widespread and well
established amongst growers. A field visit and interviews
with farmers underpinned the socio-economic aspects of
the study. The findings compared traditional chemical
controls (1,3-D) with perceived `green' approaches to
cultivation, such as soil solarisation (covering soil with
plastic) and biofumigation (use of biological fumigants).
The study provided an analysis of the costs and benefits to
the environmental and socio-economic services for each
alternative, which could be used to inform policy makers.
Database Design and Structuring Examples
Gulf of Mexico Baseline Database System Development
- Deepwater Horizon (2010-2015). Based on his
experience in NRDA combined with his large scale
relational database training, design, and management,
Joseph was assigned to serve as technical lead for the
development of a baseline information management
system incorporating ecological, chemical, physical,
socioeconomic, and GIS mapping data in the Gulf of
Mexico. This database system was used to evaluate the
potential for natural resource damages associated with
ecological and human use services in the Gulf of Mexico,
and incorporated data from Florida, Alabama, Louisiana,
Mississippi, and Texas.
North Carolina Acid Deposition Program: USEPA Acid
Deposition and Fisheries Populations in the Northeast
U.S. Joe designed this database system that contains
chemical, physical and biological data on fish populations
potentially impacted by acidic deposition. The
development of this complex database required
integration and coordination of multiple databases across
multiple U.S. states and development of a database
structure to allow data transfer. The database was used by
the USEPA in evaluating acid deposition.
Adirondack Lakes Acid Deposition Data Management
System. This is a nationally recognized database which
incorporated physical, biological and chemical data

Joseph Nicolette
associated with over 1,700 lakes in New York State. The
database was funded by the State of New York
Department of Environmental Conservation (NYDEC)
and the Empire State Electric Energy Corporation
(ESEERCO). The Adirondack Lake database was used
primarily for acid deposition assessment by the EPA and
the National Acid Precipitation Assessment Program
(NAPAP).
Selected Publications and Project Reports
Deacon, S., Norman, S., Nicolette, J., Reub, G., Greene,
G., Osborn, R., and Andrews, P. 2015. Integrating
ecosystem services into risk management decisions:
Case study with Spanish citrus and the insecticide
chlorpyrifos. Science of the Total Environment.
Elsevier publishing. 505 (2015) 732-739.
http://dx.doi.org/10.1016/j.scitotenv.2014.10.034
Nicolette, J., Burr, S., and Rockel, M. 2013. A Practical
Approach for Demonstrating Environmental
Sustainability and Stewardship through a Net
Ecosystem Service Analysis. Sustainability 2013, 5,
2152-2177; doi:10.3390/su5052152, Published May
10, 2013.
Nicolette, J., Goldsmith, B., Wenning, R., Barber, T.,
and Colombo, Fabio. 2013, Experience with
Restoration of Environmental Damage. Chapter 9 of
the book entitled "The E.U. Liability Directive: A
Commentary", edited by L. Berkamp and B.
Goldsmith. Published March 14, 2013, Oxford Press.
Pages 181-219.
Colombo, F., Nicolette, J., Wenning, R., and M.
Travers. 2012. Incorporating Ecosystem Service
Valuation in the Assessment of Risk and Remedy
Implementation. Chemical Engineering Transactions,
28, 55-60 DOI: 10.3303/CET1228010
Nicolette, J. Rockel, M. and D. Pelletier. 2011.
Incorporating Ecosystem Service Valuation into
Remedial Decision -Making: Net Ecosystem Service
Analysis. American Bar Association. Superfund and
Natural Resource Damage Litigation Committee
Newsletter, December 2011, Vol. 7. No. 1.
S. Deacon, A. Goddard, N. Eury, and J. Nicolette. 2010.
Assessing risks to ecosystems: Using a net
Appendix F - Joseph Nicolette CV
environmental benefit analysis framework to assist
with environmental decision-making. In Restoration
and Recovery: Regenerating Land and Communities.
British Land Reclamation Society. Whittles
Publishing, Scotland, U.K. pages 164-175.
A. Campioni, J. Nicolette and V. Magar. 2010.
Riparazione danno ambientale: valutazione
tecnica/economica. Rifiuti e bonifiche:
www.ambientesicurezza.ilsole24ore.com. Pages 57-
60.
S. Deacon, N. Eury, J. Nicolette, and M. Travers. 2010.
The European Environmental Liability Directive and
Comparisons with U.S. Natural Resource Damage
Assessment Regulations. Air and Waste Management
Association.
Nicolette, J. 2008. Contributing Author. Use of net
environmental benefit analysis to demonstrate the
Net Benefit of Site Cleanup Actions: An Evaluation
of Ecological and Economic Metrics at Two
Superfund Sites. US. EPA Pilot Studies Report.
Nicolette, J. 2003-2004 Contributing Author.: Net
environmental benefit analyses (NEBA) for 4 Army
BRAC Sites: Fort McClellan, AL, Savanna Army
Depot, IL and Camp Bonneville, WA. Four separate
technical study reports). Technical Reports.
Efroymson, R., Nicolette, J. and Suter, G. 2004. A
Framework for net environmental benefit analysis for
remediation or restoration of contaminated sites.
Environmental Management. September 2004. Vol.
34: (3): pp 315-331.
Efroymson, R.A., Nicolette, J. and Suter II, G.W.
(2003). A Framework for Net Environmental Benefit
Analysis for Remediation or Restoration of
Petroleum -Contaminated Sites. Oak Ridge National
Laboratory (TM -2003/17), Oak Ridge, Tennessee.
Nicolette, J., Rockel, M. and Kealy M. 2001.
Quantifying ecological changes helps determine best
mitigation. Pipeline and Gas Industry Magazine.
September 2001.

Joseph Nicolette
CH2MHILL/Marstel-Day, Inc. Contributing Author
(2003-2004): Net environmental benefit analyses
(NEBA) for Fort McClellan, AL, Savanna Army
Depot, IL and Camp Bonneville, WA. Technical
Reports.
CH2MHILL. Contributing Author (2003-2004): Net
environmental benefit analyses for OU6 and OU1 at
Edwards Air Force Base, CA. Technical Reports.
CH2M Hill. 2000. Environmental Assessment and
Closure Report, Goose Creek, Knoxville, Tennessee
Release Site. Prepared for the Tennessee Department
of Environmental Conservation on Behalf of Colonial
Pipeline Company, Inc.
CH2M Hill. 2000. Draft Response Action Plan.
Terminal Road Site, Newington, Virginia. Prepared
for the Plantation Pipeline Company. February 4.
CH2M Hill. 2000. Contributing Author. Benthic
Macroinvertebrate Sampling Plan, Rich Fork
Release, North Carolina. Prepared for the Plantation
Pipeline Company.
CH2M Hill. 2000. Contributing Author. Evaluation of
the Koch Hastings terminal Site with Regards to an
NRDA. Prepared for Koch Petroleum.
CH2M Hill. 1999-2001. Contributing Author. Quarterly
Monitoring Reports aor the Darling Creek, Louisiana
Site. Prepared for Colonial Pipeline Company, Inc.
Quarterly Reports Beginning in First Quarter of 1999
Through 2000.
CH2M Hill. 1999. Contributing Author. Net
Environmental Benefits Analysis of Treatability
Studies. Prepared for NASA (Marshall Space Flight
Center) Superfund Site.
CH2M Hill and Peacock, B. 1999. Contributing Author.
Final Restoration Plan and Environmental
Assessment. Prepared for Colonial Pipeline and the
Natural Resource Trustees. Final Restoration Plan for
the Sugarland Run Oil Spill, NRDA case.
Appendix F - Joseph Nicolette CV
CH2M Hill 1999. Contributing Author. Preliminary
Natural Resources Asset and Liability Management
Study. Prepared for Pacific Gas and Electric
Company (PG&E).
Entrix, Nicolette Environmental, Inc., and Peacock, B.
1998. Draft Restoration Plan and Environmental
Assessment. Prepared for Colonial Pipeline and the
Natural Resource Trustees. Draft Restoration Plan
(for public review) for the Sugarland Run Oil Spill,
NRDA case.
Entrix and Nicolette Environmental, Inc. 1998c. Reedy
River Fisheries Population Assessment. Conducted as
Part of the Natural Resource Damage Assessment,
Report (Volumes I and II). Prepared for the Natural
Resource Trustees and Colonial Pipeline Company,
Inc. Project Number 773712. Draft. April 3.
Entrix and Nicolette Environmental, Inc. 1998d. Reedy
River Ecological Assessment Studies: Conducted as
part of the Reedy River NRDA. Prepared for the
Natural Resource Trustees and Colonial Pipeline
Company, Inc.
Entrix. 1998a. Contributing Author. Water Quality
Assessment: Conducted in Response to the Reedy
River Incident. Prepared for the Natural Resource
Trustees and Colonial Pipeline Company, Inc. Project
Number 773712. Draft April 3.
Entrix. 1998b. Contributing Author. Reedy River
Aquatic Macroinvertebrate Assessment: Conducted
as Part of the Natural Resource Damage Assessment.
Prepared for the Natural Resource Trustees and
Colonial Pipeline Company, Inc. Project Number
773712. Draft April 3.
Entrix. 1998c. Contributing Author. Preliminary
Recreational Lost Use and Compensatory Restoration
Assessment: Conducted as Part of the Natural
Resource Damage Assessment. Prepared for the
Natural Resource Trustees and Colonial Pipeline
Company, Inc. Project Number 773712. Draft April
3.
Entrix and Nicolette Environmental, Inc. 1998a. Reedy
River Corbicula Population and PAH
Bioaccumulation Assessment: Conducted as Part of

Joseph Nicolette
the Natural Resource Damage Assessment. Prepared
for the Natural Resource Trustees and Colonial
Pipeline Company, Inc. Project Number 773712.
Draft. April 3.
Entrix and Nicolette Environmental, Inc. 1998b. Reedy
River Crayfish Population and PAH Bioaccumulation
Assessment — Oct 1996 and Sep 1997: Conducted as
Part of the Natural Resource Damage Assessment.
Prepared for the Natural Resource Trustees and
Colonial Pipeline Company, Inc. Project Number
773712. Draft. Apr 3.
Entrix and Nicolette Environmental, Inc. 1997. Quality
Assurance Project Plan for the Reedy River Incident.
Entrix. 1996a. Contributing Author. Reedy River
Natural Resource Damage Assessment: Current
Status and Proposed Approach. Prepared for the
Natural Resource Trustees and Colonial Pipeline
Company, Inc. Project Number 773712. Draft
September 11.
Entrix. 1996b. Contributing Author. Assessing Potential
Injury to Wildlife Along the Reedy River: A
discussion Prepared as Part of the Natural Resource
Damage Assessment. Prepared for the Natural
Resource Trustees and Colonial Pipeline Company,
Inc. Project Number 773712. Draft October 15.
Entrix. 1996. Contributing Author. Natural Resource
Credit Analysis for a Confidential Site. Based upon
the Habitat Equivalency Analysis Framework.
Confidential Client.
Markarian, R.K., J.P. Nicolette, T. Barber, and L.
Giese. 1995. A Critical Review of Toxicity Values
and an Evaluation of the Persistence of Petroleum
Products for Use in Natural Resource Damage
Assessments. American Petroleum Institute (API)
Publication Number 4594. January.
Nicolette, J.P., T.R. Barber, R.K. Markarian, T.W.
Cervino, and D.V. Pearson. 1995. A Cooperative
Natural Resource Damage Assessment (NRDA) case
study: Coloial pipeline release, Reston, Virginia.
Proceedings: Toxic Substances in Water
Environments. Assessment and Control: Water
Environment Federation. Pp. 7-21 to 7-32. May.
Entrix. 1995. Contributing Author. Analytical
Chemistry Results: Oyster and Sediment Samples
from the Quinnipiac River, Connecticut. Prepared for
Buckeye Pipeline Company and the Connecticut
State Department of Agriculture.
Entrix. 1995.c Contributing Author. Habitat
Equivalency Analysis: Overview, Definition of
Terms, and Debit Calculations for Sugarland Run,
NRDA. Prepared for Colonial Pipeline Company and
the Natural Resource Trustees.
Entrix. 1994. Contributing Author. Addendum to the
Fisheries Injury Assessment for Sugarland Run.
Conducted as Part of the Natural Resource Damage
Assessment. Prepared for Colonial Pipeline
Company, Inc. and the Natural Resource Trustees.
Entrix, 1994. Contributing Author. Mass Balance of
Spilled Diesel: Simulation Modeling. Conducted as
Part of the Natural Resource Damage Assessment.
Prepared for Colonial Pipeline Company, Inc. and the
Natural Resource Trustees.
Entrix. 1994. Contributing Author. Fish Population
Survey and Injury Assessment for Sugarland Run:
Conducted as Part of the Natural Resource Damage
Assessment. Prepared for Colonial Pipeline
Company, Inc. and the Natural Resource Trustees.
Entrix. 1994. Contributing Author. Benthic
Macroinvertebrate Survey of Sugarland Run, Broad
Run, and the Potomac River: Conducted as Part of
the Natural Resource Damage Assessment. For
Colonial Pipeline Company, Inc. and the Natural
Resource Trustees.
Entrix. 1994. Contributing Author. Corbicula PAH
Bioaccumulation Study for Sugarland Run and the
Potomac River: Conducted as Part of the Natural
Resource Damage Assessment. For Colonial Pipeline
Company, Inc. and the Natural Resource Trustees.
Entrix. 1994. Contributing Author. Preliminary Survey:
Analytical Chemistry Data Analysis for Sugarland
Run and the Potomac River: Conducted as Part of
the Natural Resource Damage Assessment. Prepared
Appendix F - Joseph Nicolette CV F -14i

Joseph Nicolette
for Colonial Pipeline Company, Inc. and the Natural
Resource Trustees.
Entrix. 1994. Contributing Author. Vegetation Survey
and Natural Communities of the Potomac River from
Lowes Island to Chicamuxen Creek. Prepared for
Colonial Pipeline Company, Inc., the USEPA, and
the Natural Resource Trustees.
Entrix. 1993. Contributing Author. NRDA Study Plan
and Status: Sugarland Run and the Potomac River:
Prepared for Colonial Pipeline Company, Inc. and the
Natural Resource Trustees.
Entrix. 1993. Contributing Author. Response Action
Plan for Remediation of Spilled Diesel. Prepared for
Colonial Pipeline Company, Inc.
Entrix. 1993. Contributing Author. Quality Assurance
Project Plan. Supplement to the Response Action
Plan. Specific action to address Section 10.1 of the
EPA Unilateral Order. Prepared for the Colonial
Pipeline Company, Inc.
Entrix. 1993. Contributing Author. Preliminary Survey
Plan for Sugarland Run and the Potomac River in
response to the EPA Administrative Order regarding
the Sugarland Run oil spill. Prepared for Colonial
Pipeline Company, Inc. and the NR Trustees.
Entrix. 1993. Contributing Author. Sediment and Water
Quality Toxicity Tests for Sugarland Run. Conducted
as part of the Natural Resource Damage Assessment.
Prepared for Colonial Pipeline Company, Inc. and the
Natural Resource Trustees.
Entrix. 1992. Contributing Author. Oil Spill Response
and Impact Assessment Report for British Petroleum
(BP). Norfolk, Virginia Crude Oil Release.
Entrix. 1992. Oil and Oil Product Toxicity Database
User's Guide for OILTOX. Prepared for the
American Petroleum Institute.
Entrix. 1991. Contributing Author. Instream Flow
Study and Gravel Enhancement on the White Salmon
Appendix F - Joseph Nicolette CV
River, Washington. FERC Relicensing Agency
Review Document.
Entrix. 1990. Contributing Author. Biological Data
Report on the Intertidal Communities of Prince
William Sound. Prepared for Exxon. Part of an
evaluation of the environmental costs associated with
oil cleanup in Prince William Sound as a result of the
Exxon Valdez Oil Spill.
EA Engineering, Science and Technology, Inc. 1989.
Contributing Author. Pilot Study Report -Predation
by Piscivorous Fish in the Lower Tuolumne River,
1989. 1991. Report for the Turlock -Modesto
Irrigation District.
EA Engineering, Science and Technology, Inc. 1989.
Contributing Author. An Evaluation of the Effect of
Gravel Ripping on Redd Distribution in the Lower
Tuolumne River. Report for the Turlock -Modesto
Irrigation District.
EA Engineering, Science and Technology, Inc. 1989.
Contributing Author. Tuolumne River Summer Flow
Study. Report for the Turlock -Modesto Irrigation
District.
EA Engineering, Science and Technology, Inc. 1989.
Contributing Author. Chinook Salmon Redd
Excavations. Report for the Turlock -Modesto
Irrigation District.
EA Engineering, Science and Technology, Inc. 1989.
Contributing Author. Adirondack Lakes Study:
1984-1987: An Evaluation of Fish Communities and
Water Chemistry. Adirondack Lakes Survey Corp.,
NY. Final Report.
Nicolette, J.P. and G.R. Spangler. 1986. Contributing
Author. Population Characteristics of Adult Pink
Salmon in Two Minnesota Tributaries to Lake
Superior. Journal of Great Lakes Research.
12(4):237-250.
Bagdovitz, M., W. Taylor, J. Nicolette, and G.R.
Spangler. 1986. Contributing Author. Pink Salmon
Populations in the U.S. Waters of Lake Superior,

Joseph Nicolette
1981-1984. Journal of Great Lakes Research.
12(1):72-81.
Nicolette, J.P. 1984. Contributing Author. A Three -
Year -Old Pink Salmon In An Odd -Year Run in Lake
Superior." North American Journal of Fisheries
Management. Vol. 4(1):130-132.
Baker, J, Harvey, T. and J.P. Nicolette. 1984.
Contributing Author. Compilation of Available Data
on the Status of Fish Populations in Regions of the
Eastern U.S. Final Report to the Environmental
Protection Agency, Corvallis, OR.
Nicolette, J.P. 1983. Contributing Author. Population
Dynamics of Pink Salmon in Two Minnesota
Tributaries to Lake Superior. M.S. Thesis. University
of Minnesota, St. Paul, MN. 94 p.
Appendix F - Joseph Nicolette CV F-16