20150041 Ver 1_Add Info 20150605 to USACE_20150605

��earWater
Cleamater ETivironrnentrO Consukants, Inc.
June 5, 20,15 www.cvvenv.com
Mr, Craig Brown
US Army Corps of Engineers
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
RE: Response to Corps Comments
Brickhaven and Sanford Mines
Chatham and Lee County, North Carolina
Action ID SAW-2014-02254.; DWR Project # 15-0041 and 42
Dear Mr. Brown,
Please reference the letter dated May 6, 2015 (Attachment A) sent by the US Army Corps
of Engineers (Corps) in response to the permit application submitted by ClearWater
Environmental Consultants, Inc. (CEC), on behalf of Green Meadow, LLC represented
by Mr. Charles Price. The pen-nit application requested written authorization for the
impacts associated with disposal of coal ash at the Brickhaven and Sanford Mines, The
con-nnents provided by the Corps arc listed and discussed below.
Comment #1 — "This prqjecl does not need to be located within waters ofthe U.S. in
order to sati & your Purpose and Need stateinent. As required by the 404(b)(1)
Guidelines (40 CFR Fart 230) other practicable alternatives must be evaluated to ensure
that the Least Environmentall y Damaging Praclicable Alternative (LE PA) is identified..
Please elaborate on the criteria used to evaluate other urine sites, iden4fy the mines that
were consid�red, and an ewlVana lion a these alternative urine sites were deterinined
.f w h�y
to be unsuitable as, it applies to Purpose and Need."
Charah utilized a multi-phased analysis for identification of feasible mine sites.
Phase I comprised a review of the Division of Energy, Mineral, and Land
Resources' (DEMLR) rnine site inventory database. 'The database search
identified, 848 existing mine sites in the State of North Carolina, These 848 mine
sites were ranked based on commodity (the type of'resource extracted during the
mining process). Commodities are an important factor to consider due to the
geology surrounding rn, inc sites with certain commodities and constituents in the
raw material being mined. For example, sites that are mined for rock, stone, and
sand most likely contain fractured rock which increases the potential for
preferential pathways to the groundwater table. Elimination of sites with this type
of underlying geology reduces the likelihood for changes in existing groundwater
conditions. As another example, monitoring wells near phosphate and lithium
mines tend to have an increase in phosphate and lithium concentrations because of
224 South Grove Stre(`L, 511 it(� 1;
f lendersoiwille, NC 28792
t,129-698-98001 0
828-6199-9003 Rix

W Craig Brown
06,05.15
Page 2 of' 14
the presence of these commodities. Due to the potential forty confusion of the
origins of high concentrations of phosphate and lithium (mine vs. coal ash), mines
with these commodities were eliminated, Clay mines that are conducive to the
liner system requirements contained in both Coal Ash Management Act of 2014
(CAMA14) and Coal Combustion Residuals (CCR) rules were given highest
rankings. These mines contain natural materials ('clay) that have a low to
moderate capability of transmitting water.
Phase 1 of the analysis also included a search for "active" vs. "inactive" mine
sites. Inactive mines were considered to be already reclaimed; therefore, inactive
mine sites would not be suitable candidates for structural fill reclamation projects.
At the completion of Phase 1, 38 mines remained for analysis under Phase 2, The
38 mine alternatives, are listed in the table included for review (Attachment B).
Phase 2 of the analysis involved reviewing the remaining 38 mine sites for
specific location criteria consisting of.
(1) Proximity to Rail — Due to the volume: of ash removal, and disposal that is
required by CA1 A14, the ability to move large amounts of ash efficiently is
of vital importance. Trains are one of the most efficient transportation
methods, According to the Rocky Mountain Institute, an independent
research organization, trains can move four times more ton-miles per gallon
than trucks and typically at a lower cost, Moving ash by rail reduces the
number of trucks in use; therefore, reducing and/or eliminating hauling on
state maintained roads. The following criteria was considered when choosing
a suitable mine site as it relates to rail proximity:
a, Commercial rail line within approximately I mile of the mine site; and
b. Practical construction of a rail spur after consideration of existing
crossing constraints (existing highways, rivers, etc.), environmental
conditions, and potential procurement of casements.
(2) Trucking Access — Truck access is important in both the construction phase
and the operational phase of the site. In the construction phase, truck access is
vital so that all the equipment and material necessary to construct the site can
be easily transported to the site. During the operation of the site, truck access
allows for equipment to be brought in as necessary. Additionally, trucking
ash will be used as a contingency to rail in the event rail service is temporarily
disrupted, Although not all-inclusive, the following criteria was considered
when choosing a suitable mine site as it relates to trucking access:
a. Weight limits on bridge crossings;
b. Presence of school zones; and
c. Presence of residential zones and high density population.

Mr. 0-dig Brown
0610.15
Page 3 of 14
(3) Proximity to Duke Energy's Existing Steam Stations ­., Although not as critical
as proximity to rail and trucking access, proximity to existing steam stations was
considered. The closer an existing steam station is to the mine site, the less time
is required to remove, transport, and dispose oaf f ash. Due to the volume of ash
removal and disposal that is required by CAMA14, the ability to move large
amounts of ash efficiently is of vital importance,
The table provided in Attachment B indicates the reasons why specific mine alternatives
were dismissed from consideration. Of the 38 mine sites evaluated, 12 were selected for
Phase 3 of analysis. These mine sites include: General Shale Brick, Inc. (5 sites), Boral
Bricks, Inc. (3 Sites), Triangle Brick Company (2 sites), CEMEX Construction Materials
(I site), and Lee Brick & Tile (I site). Of these 12 sites, three sites owned by General
Shale Brick, Inc. were available for acquisition. Brickhaven Mine 42 (proposed), Colon
Mine (proposed, identified as the Sanford Mine in the permit application), and Sanford
Mine (not proposed, located less than 1.5 mile from downtown Sanford). The other 9
mine sites were not available for acquisition per communication with site ownership.
The Sanford Mine (located near downtown Sanford) was eliminated due to proximity to
existing high density residential areas. Therefore, Brickhaven Mine #2 and Colon Mine
(identified as the Sanford Mine in the permit application) were secured by Green
Meadow, LLC for the development of the coal ash structural fill and mine reclamation
prof ects,
Comment #2 — "In the alternatives analysis of your application, ii stales that coal ash
can be used in cement and asphalt concrete. One cement companY, currently accel)(s coal
ashfi-otn Duke power plants for this purpose. Please provide, detailed information as to
jjRky soine or all of the coal ash cannot be used in this manner."
Coal fly ash has been successfully used in Portland cement concrete (PCQ as a
mineral admixture, and more recently as a component of blended cement, for
nearly 60 years. As an admixture, fly ash functions as either a partial replacernent
for, or an addition to, Portland c=ent,. Fly ash is added directly into ready-inix
concrete at the batch plant. Fly ash can. also be inter-ground with cement clinker
or blended with Portland cement to produce blended cements,.
The quality of fly ash for use in PCC is extremely important. Fly ash used in
concrete should be as consistent and uniform as possible. In addition, specific
criteria regarding particle size, carbon content (loss on ignition), and constituent
make-up (iron. and mercury) are critical in qualifying the coal ash for potential use
in concrete manufacturing, When used in blended cement or as as partial
replacement for PC C in ready-mix concrete, fly ash must be in a dry form. When
used as a raw feed material for the production of PCC, either dry or conditioned
(ponded) ash can be used if the quality meets specifications (typically, the amount
of alumina and/or silica present in the ash). The net result of all these restrictions
is that only a relatively low percentage (25 to 30 percent) of all the coal fly ash
produced annually is potentially suitable for use in these applications.

Mr. Craig Brown
06,05,15
Page 4 of 14
An extremely large inventory of ponded ash is available for reclamation and
potential sale into the concrete markets. Of that volume, only a small percentage
meets the quality specifications necessary for engaging these markets. The
applicant has identified 6 locations capable of utilizing ponded ash that are also
within the feasible transportation radius of Duke Energy facilities. These
locations offer approximately 330,000 to 430,000 tons per year of available
capacity. All of this capacity is within utility markets neighboring the concrete
manufacturing facilities and is highly competitive; therefore, opportunities to
transport ash from Sutton and Riverbend to other concrete manufacturers is
limited.
As stated in the permit application, Duke Energy is already sending
approximately 25,000 tons of coal ash per month to the Roanoke Cement
Company for their use in cement manufacturing and plans to send approximately
115,000 tons (10,000 tons per month) of coal ash as a part of ash removal from
the ash stacks at Riverbend. The amount of coal ash they can use is directly
related to demand for their product (cement). At this time, the Roanoke Cement
Company cannot accept additional ash from Duke Energy.
Comment #3 — "In .your application f6r this project, you utilize the ternz, Phase 1. Please
providu clarfzcation as to what activities are specificallY involved in Phase L In, addition,
please elaborate on any.ffiture phases and their potential impacts to the Waters of the
United States (WOUS). Besides impacts to WO US at the Brickhaven and Sw#brd Mines,
please identq other impacts to WOUS at offivite locations resultingfirom the transfer of
coal ash to the Brickhaven and Saqford Mines. This would include improvements to
transportation and handlingfiacilitie.s, at the Riverbend and Sutton Power Plants, as well
as other, known loeations that will be eont•ibuting coal ash to these sites."
As the application states, ash excavation at the Riverbend and Sutton has been
phased in accordance with the proposed ash excavation plans submitted to the NC
Department of Environment and Natural Resources (DENR) for approval. Phase
I focuses on the removal of ash above the groundwater table. Typically, this
phase includes the construction oaf f haul roads, load-out areas, and the excavation
of dry ash stacks. Additional ash excavation within the ash basins at these
facilities is further phased (Phases 2+) as the ash depths in the basins are
advanced to reach the bottom of each existing ash pond. Phases 2+ use existing
infrastructure constructed for Phase 1. Plans for the ash basin and ash stack
excavations (Phase 1) at each station have been prepared and are currently under
permit review with the State. No "OUS impacts have been identified within the
work area for these excavations; therefore, coal ash excavation areas were not
included in the 4041401 permit application. Rail load-out, truck load-out, and
transportation routes have also been identified at the steam stations. As with the
excavations, no WOUS impacts were identified for infrastructure improvements
at the steam station sites. Plans for these improvements arc underway as a part of
the ash basin excavation plans as noted above. WOO S impacts at the mine sites

W Craig Brown
06J,05A
Page 5 (if 14
have been identified and were included in the permit application currently under
review. There are no known impacts to WOUS in subsequent phases.
Comment 94 — "The application slates that "The putpose qflhe proposed project is to
close ash basins at the Riverhend Steam Station and the Sialon Electric Plant 1ry,41tgusl
of 2019 cis required 4y the Coal Ash Management Act of 2014 (CAAW4). " This Project
PwTose is defused too broad4, and does not have any direct relation to the activityfir
ivhich you are seeking a Clean, Water. Act Section 404 permit. Therejbru, ive ivould
recoinmend that it he revised to state, something to the affect ,fect of- "The propose of the
proposed project is to dispose of coal ash in a suitabl e manner and in an environmentally
sound location, The long -lean disposal of coal ash in suitable locations will.facilitate the
closing of coal ash basins across North Carolina, as required �y the CAMA 14."
The applicant has redefined the project purpose as rcconiniended. The purpose of
the proposed project is to dispose of coal ash in a suitable manner, using the best
available technology, and in an environmentally sound location. The long-term
disposal of coal ash in suitable locations will facilitate the closing of coal ash
basins across North Carolina, as required by CAMA14.
Comment #5 — "yaps supplied with the application indicate that there is an "Arch
Culvert "' on one oJ'the streams at the Saqfo•d Alfine, and two "',Spanning Structures " at
the Brick-haven Mine crossing a stream and a wetland. While these proposals do not
result in a direct loss ref jurisdictional feawres, they are known to have an adverse impact
upon aquatic resources and will require carnpensato)�y mitigation for their indirect
impacts to jurisdictional waters. Based on our experience with these types e?f structures
and depending on the quality of the aquatic resource, lve have required compensato,�V
inifigation at a half the ratio that would be required of the stream were to be culverted."
The Sanford Mine contains one Crossing identified as an "arch culvert" on the
northwest portion of the property. The arch culvert would have indirect impacts
to 0.02 acre of wetland. The wetland is in an existing dirt road and is of poor
quality, a typical mitigation ratio for direct impacts would be 1:1. Indirect
impacts are generally mitigated at half the full ratio. The proposed mitigation at
the Sanford Mine will be increased by 0.01 acre (a 0.5:1 ratio for indirect impact
associated with the arch culvert).
The Brickbaven Mine contains two crossings on the Moncure Holdings site
identified as "spanning structures". The spanning structure crossing the wetland
will be a true bridge; therefore, no mitigation would be required for the crossing.
The spanning structure crossing, the stream will be an arch culvert. The arch
culvert would have indirect impacts on 90 linear feet of stream. The stream is of
good quality and a typical mitigation ratio for direct impacts would be 2:1.
Indirect impacts are generally mitigated at half the full ratio. The proposed
mitigation at the Brickliavcn Mine will be increased by 90 linear feet (a 1: 1 ratio
for indirect impact associated with the arch culvert),

mr, cruig Bra V4,11
06.05.15
Page 6 of 14
The impact tables in Section 5. 1 of the permit application have been updated to
reflect indirect impacts and are attached for review (Attachment C). The impacts
have also been updated on the attached permit maps (Fi grure I a and I b).
Proposed mitigation has been updated to reflect the following changes:
1. Mitigation for indirect impacts associated with Impact #25 at the Sanford
Mine.
2. Mitigation for indirect impacts associated with Impact #12 at the
Brickhaven Mine.
1 Impact #2 and #13 at Brickhaven will be mitigated for at a 2:1 ratio to
allow "out of HUC" mitigation as approve by the Corps on May 14, 2015.
A mitigation table has been provided for review (Attachment D). Updated
acceptance letters from the Division of Mitigation Services (DDS) are also
included for review (Attachment E).
Comment #6 — "'A cemetery I'" pr to be the Zion Hill Coinetety ") is located at the
Sari ,/b rd site. Please explain w m
hat easures will be taken to preserve and protect this
cemelety and allow public access."
Cemeteries and grave sites are protected from defacing and desecration by State
Statutes 14-148 and 14-149, The Zion Hill Cemetery, located in the northeast
comer of the Sanford Mine site, is also subject to these state statutes. Its location
has been added to the attached permit map (Figure la) and a 50-foot buffer has
been applied. No construction traffic or work will occur within 50 feet of the
cemetery and the cemetery site will be permanently fenced and gated. No
improvement or maintenance to the cemetery is planned at this time.
Public access to the cemetery will be provided with consent as required by State
Statute 65-101. In the interest of public safety, all visitors must be escorted to and
from the cemetery location. Green Meadow, LLC and its on-site representatives
will require a minimum of 48 hours of notice to prepare for and provide access as
noted. Access without consent is not available.
Coniment #7 — "The U.S. Fish and Wildlife Service {US FICS) and the public have
expressed concerns about the transportation ql'coal ash to the two project areas. Much
of these concerns were addressed on page 17 of 'the application pack-age. Please clarif
y
it,hat steps Charah, Inc. will be taking to ininimize loss of coal ash during transport and
storage at the proposed disposal location.'"
As stated in the permit application, coal ash must be collected and transported in, a
manner that will prevent nuisances and hazards to public health and safety (NCGS
130A-.309.216(a)(2)). The transport of ash will be achieved primarily by rail
using covered gondola cars. Each rail car will be covered with a fiberglass, cover
that is fitted and clamped to the car. Coal ash will be moisture conditioned to

Mr. Craig Brown
06,05. 15
Page 7 of 14
20% and ash contained in rail cars will be sprayed with a water absorbent to
contain any water that may rise to the surface during transport.
Unloading operations at the structural fill sites will involve the removal of car
covers, and the removal of coal ash from the cars using straddle carrier excavators,
The excavators will place the moisture conditioned ash directly into Artie off-road
dump trucks for transport to the structural fill site for placement. No interim ash
storage or double-handling of ash is anticipated. Taking ash directly from the
load-out area to the structural fill site for placement minimizes the possibility for
loss of ash from a load-out area. The load-out area will be paved and located
above a liner system designed to contain. any spillage, of ash or contact water,
Additionally, any ash spillage will be collected with a vacuum truck and taken to
the structural fill for placement. Any contact water from the load-out area will be
collected in a sump and pumped directly into the leachate collection, system.
As stated in the permit application, NCGS 130A-309.216(a)(9) requires sufficient
dust control measures to minimize airborne emissions and prevent dust from
becoming a nuisance or safety hazard. The primary potential source of dust
emissions on site is the top-deck area and active area of structural fill placement.
These areas are at higher risk for producing dust due to vehicular and equipment
traffic and earthwork -like construction. Exterior slopes are less of a dust control
concern,, as they have interim soil cover which is vegetated. Dust emission can be
controlled through a variety of methods. These methods may be characterized as
products and/or applications, structural wind breaks and/or covers, and
operational methods. Dust control methods for the facility include- watering,
establishing vegetative cover, mulching, wind breaks, temporary coverings (i.e.
tarps), spray applied dust suppressants, calcium chloride, soil stabilizers, interim
and operational soil cover, and modification of the active working area and
operations during dry and windy conditions. The site operator may use, and is not
limited to, combinations of these dust control methods or any method that is
technically sound to control dust for specific site conditions. The effectiveness of
the dust control methods implemented will be evaluated through visual
observation of dust prone areas. Equipment operators will continuously observe
the active face and other active construction areas for dust emissions. If fugitive
dust emissions are observed and observations indicate dust control measures are
not achieving their intended purpose, then appropriate corrective actions will be
taken. Dust control measures would be reapplied,, repaired, or added as necessary
to control dust emissions. The site operator will construct, install, apply, and/or
repair dust control measures prior to the end of each work day to control dust
emissions during non-operating hours. The site operator will also implement dust
control measures as preventative controls rather than in response to fugitive dust
emissions. A wheel wash system will be used if necessary to minimize dust
tracking outside of the facility.

Mr. Craig Drawn
06,05.15
Page 8 col` 14
Comment #8 — "There ivere several public coinivents expressi rig concern about possible
groundwaler containinationfi-om coal ash at these two reclarnation site.,,?. Although .you
will address concerns related to water quality and groundivater monitoring through the
Alorth Carolina Division ql'Water Resources and the 401 process, ive re,
.fer thefiollowing
representative cominentsfior reference:"
Comment #8a - "The Southern Environmental Law Center (SELC), hl a comment letter
to the USA CE dated March 23, 2015, recommended that two monitoring wells, be added
tit both reclamation sites, . In addition, they have recornmended that monthly monitoring
qf grow ndwa,ter elevations be required .for the.11irst year in order to verify assu mptions
about seasonal high water levety and that back-groundsainpling should be conducted on
a quarterly basis for the_ rst year in order to evaluate possible seasonal variation in
water quality,,"
A complete Water Quality Monitoring Plan was included in the Structural Fill
permit application submitted to DENR. Groundwater and surface water
monitoring is being performed in accordance with CAMA14 and CCR rule
requirements. A sufficient number of wells have been sited at each of the mine
sites as required by the Division of Waste Management through implementation
of CAMA14 and Subtitle D standards. Ground water levels have been tinder
review since July of 2013 for the sites and will continue to be monitored during
construction of each cell within the limits of the structural fill boundary.
Adjustments will be made as needed to maintain the required separation to
groundwater. Baseline water quality conditions for the inine site's are being
established as specified in the CCR rules through the implementation of 8
sampling events, with at least one event occurring prior to the placement of coal
ash as specified in the permit application for the projects. By establishing the
baseline water quality condition for the site, the projects' water quality standards
are set and can be used as a comparison for effluent waters (groundwater and
surface water) leaving the site.
Comment #8b — "The Haw River Assembly, an a comment letter to the USACE dated
April 2, 2015, asked ff there was a "plan.ffir baseline monitoring ttf neighbors' drinking
water wells in (in area surrounding the inines? " The concel•17 with contaminated
drinking vvater was also addressed ky other members of the public during the comment
period,"
At this time, Charah and Green Meadow, LLB have no plans to monitor drinking
water wells on adjacent properties. DENR has the ability and the legislative
support to perform a well water quality assessment for properties surrounding the
mine sites should they feel it is warranted. Charab has noted publicly that it
would sample the well water of neighboring properties upon request. This well
sampling will be conducted by a third party at no cost to the property owner. As
stated above, baseline water quality conditions for the mine sites are being
established as specified in the CAMA14 and CCR rules. As long as the baseline
water quality standard for each of the mine sites is maintained, there would be no
effect on down-gradient properties including drinking water wells.

Mr. Cmig Brom
06.05�. 15
Page 9 of 14
Comment #8c — "In a petition signed 1av 110 residents q/' Chatham Couqv, and
submitted to our office via email on April (5, 2015, concerns ivere expre.Ysed about coal
ash containing high levels qfheaij metals such as arsenic, lead,' mercury, and other
toxic substances, it,hich requires utmost precautions and protections or handling
transporting, and disposal. ' This, petition and a number of other coinmentors expressed
concerns about the disposal of leachate, and questioned whether numicipal wasteivaler
treatment plants would be able to handle, hemy metals and other toxins contained in coal
ash. Many commenters were also concerned that the liners lining! the coal ash pits i'vould
eventual�y deteriorate and toxic substances would be released into the streams, wetlands
and groundwater. Tease address concerns about heavy metals and other toxic
substances in the coal ash including: the precautions and ,protections or handling,
transporting, and disposal oftoal ash to insure that heaiy metals and other toxins do not
escape into the environment; the adequacy of municipal wastewater treatments plants to
handle these substances in the leachate; and the potential of heai-y metal and leachate
entering the watershed because qj"deterioratinq liners,"
As discussed in the response to Comment #7, transport of ash will be achieved
primarily by rail using covered gondola cars. The cover systern minimizes the
opportunities for loss, of ash or contact water through the use of containment in
the bed, absorbents placed in the bed with the ash, and covers intended to contain
and seal the bed while in transport. Within the structural fill boundary, a
composite liner system will be used. Specifically formulated geocomposite clay
liners (GCL) treated with polymers needed to be chemically resistive to coal ash
will be installed along the entire base of the structural fill limits. High density
polyethylene (HI PE) flexible membrane liners will be placed on top of and in
direct contact with the GCL to provide an additional barrier against the coal, ash
constituent migration into the environment. Several industry studies have been
conducted throughout the years that prove the HDPE liners are chemically
resistant to types of constituents that can be found in coal ash. These same liners
have been used for years to contain both municipal solid waste as well as
hazardous waste across the country. Several reports have been performed by the
Geosynthetic Institute (G I) that have determined the resistivity of manufactured
liners, as, well as predicted the lifespan of these materials. Based on the
environmental conditions in which the liners will reside with regard to the coal
ash materials, G testing indicates a lifespan of more than 400 years for HDPE
liners (Attachment F). The contact waters or leachate that is generated by the
handling and placement of the coal ash will dissipate over a period of I to 2 years
after the structural fill has been closed. Coal ash will reach a state: defined as
terminal, moisture content and will cease to release any leaebatc or contact waters.
Charah continues to work with the City of Sanford to secure an industrial
discharge permit allowing for the discharge of leachate into the public sewer
system. To determine the options available for discharge, Charah and the City are
collaborating to perform a waste characterization for the leachate as well as a
treatability assessment for the treatment plant,, While the assessment with the

Mr. Craig Brown.
06.05J 5
Page 10 of 14
it of Sanford continues, Charah has contracted a private wastewater treatment
provider to safely and effectively treat leachate at the mine sites.
Commen't #9 — "The lVorth Carolina Wildlife Resources Commission (NOITC), in as
cointnent letter to the USA CE dated April 2, 2'015, recommended ".-a mininnim 200-
fbot
undisturbed, native,fibrested hqf .fer alon 9
perem?ial streams, and a 10(J -fbot bqI
,P,)- along
intermittent streams and ivellantis is advised. " Further stating drat Maintaining
tin disturbad, forested bqffers along these areas will tninirnize impacts to aquatic and
terrestrial wildlife resources, ivater quality and aquatic habitat both within and
dou,nstrea?n of the project area. In addition, forested riparian bqffiers protect, water
qualit
y y swath zing sireenn banics antl filtering slormwater rung/ '" Meaty q the puhhe
comments received �y the USACE also expressed concerns as out protecting existing
stretunsfi-am pollutants and sedimentiltiring stormy events at the project sites. In light of
these comments, please, evaluate and care meni on the NCff7RCs reconnnendationfior
X1111 -foot bufftrs on perennialstreanis and 100-
fibot bt,!f
ftrs along interinittent streams
and ivetlands.
Named and unnamed tributaries on both sites are classified by the Division of
Water Resources as "WS-IV". According to 15A NCAC 02B.0216, a minimum
30-foot vegetative buffer for development is required along all perennial waters.
Additionally, CAMA14 130A-309,216(c) restricts placement of coal ash within
50 horizontal feet of the top of the bank of a perennial strearn or other surface
water bodies. Undisturbed streams (perennial and intermittent) on both sites will
have a 50-foot undisturbed woody buffer which complies with both state rules.
Buffers beyond what is required by CAMA14 and 15A NCAC 0213.0216 within
proximity of the working limits of 'the structural fill sites are not feasible.
Considering the large scope of the project which is necessary to meet the
regulatory requirements for construction and operation of the projects, stream
buffers beyond what is required by state rules cannot be accommodated.
Requiring larger buffers would require significant changes to the site plan
including relocation of stormwater basins and reconfiguration of the coal ash
cells. Significant efforts have been undertaken to avoid streams and wetlands at
the mine sites. As noted in the application, 75% of strearns have been avoided at
the Sanford and Brickhaven Mines.
Corry ment #10 — "The NCWRC recommended relocation of "...streams using natural
channel design methods. Y'streains cannot be relocated, stream channels should he
diverted to Prevent suftiee watersfirom coming into contact with disposed materials. "
The loss of'flow ftom impacts to upstream tributaries could negatively impact stream
quality downstream, cis well cis base flmvs. Please evaluate the potential for stream
relocation, and the downstream impacts fi•oin losses to upstream TFOUS, as wall as
qffbrts to prevent sue faace watersfioin coming into contact with disposed materials."

mr.,Craig Brown
&05AS
Page I I of 14
Stream relocation is not feasible for impacted strearn segments at the Sanford and
Bfickhaven Mine sites as there is no practical location for relocation. Generally,
relocated stream segments are relocated within their, same valley or topographic
crenulation. Because the fill cells and associated basins impact stream channels
and upland areas surrounding the stream channels, there will be no available land
adjacent to impacted streams for relocation.
No change,; to existing, drainage patterns or watershed boundaries will occur as a
result of the proposed projects. Erosion and sediment controls will be installed as
required by regulatory standards to protect the water quality of down-gradient
drainage features. The proposed projects include stormwater management
systems comprised of slope drains, culverts, perimeter ditches, sto,rmwater basins,
etc. Stormwater and runoff (non-contact water) that would normally enter the
streams and wetlands would he collected by the stormwater management system
(during all phases of the project). Stonnwater and runoff would be directed to
stormwater basins for treatment and subsequently discharged to the unnamed
tributaries and wetlands adjacent to the fill areas. Storinwater and runoff in the
watershed will remain in the watershed and continue to provide hydrology to the
stream channels and wetlands. Stonnwater and runoff from the site will be
observed to determine if conditions of drainage remain in their current state or are
improved. Base flows in tributaries downstream from the st-Uctural fill sites
should remain equal to their current state.
Comment #11 — "The Chathani Coun(y petition also states that the heavy flow 0
track and train traffic ivill increase sqfety issues, i.e. accidents, spillage, fly ash, noise,
and air polhelion. Numerous other comments, received at our ollice, Rain both Chathain
and Lee Counties, expressed similar concerns. In light of these concerns, please address,
the precautions (speed calllv: accidents, spillage and noise) taken in the transporlofcoal
ash at these two sites."
Based upon the existing train traffic in the area as defined by CSX, the,
community will not experience a significant increase in train traffic. A train
comprised of approximately 110 cars will travel to the sites an average of every 3
days transporting approximately 7,740 tons of coal ash. As noted in the response
to Comment #7, the transport of ash will be achieved primarily by rail using
covered gondola cars which would minimize spillage from train cars,
Additionally, Charah has an Emergency Action Plan in the event ash is spilled
from rail cars. All rail transportation routes will be managed by CSX; therefore,
all transportation of coal ash by rail will be performed in accordance with Code of
Federal Register (CFR), Title 49, Subtitle B, Chapter 11 (Federal Railroad
Administration) standards. 'Train personnel are trained, and tested in accordance
with CFR 49.2,42.119 (Training) and 49.242.121 (Knowledge Testing).
Operational performance is monitored and documented by local CSX
management staff as required by CFR 49.242.123 (Monitoring Operational
Perfbimance) which mandates monitoring the conduct of certified conductors by
performing, unannounced operating rules compliance tests. Track infrastructure is

Mr, Craig Brown
06.05,15
Frig e E of 14
inspected and maintained as specified in CFTC 49.213 (Track Safety Standards)
and all signal systems that govern train movement are maintained as outlined in
CFTC. 49.233 (Signal 'System Reporting Requirements). Train noise is regulated
by CFR 49.2l fl (Railroad Noise EmiSSIOD Compliance Regulations).
Trucking ash will be used as a contingency to rail in the event rail service is
temporarily disrupted,. Truck operators are required to be properly licensed and
insured per State standards, attend Charah Safety Orientation, and remain
compliant with all applicable Charah safety rules, Drivers and their trucks are
subject to inspection and shall be monitored by Charah site management while
on-site and traveling over the road. Copies of safety training and inspection
documents shall be maintained on-site by Charah site management. Additionally,
Charah has an Emergency Action Plan in the event ash is spilled from trucks.
Comment #12 — "The Chatham Count), petitionfurther states that the "Transport and
storage ql'Coal Ash at adversely q#ct the econoinies o
flhe communiVIcoumy.
Numerous other comments, received at our qffice, fi-om both Chatham and Lee Counties,
expressed similar concerns. In addition, several commenters are concerned that the
proxitnity of their properties to the mine, sites will result in a devaluation qf their
Properties. In light of these concerns, please address how the transport anel storage Qf
coal ash will ajfeci the economies of the host communities1counties, including property
values near the mine s and within the two counties, "
Charah has contracted Haley & Aldrich, Inc. to conduct an Environmental Justice
and Economic Analysis review of current and future effects of the project on
surrounding communities. The report includes, but is not limited to, the
following: establishment of a study area, discussion of 'transportation,
identification of existing disamenities, discussion of benefits to reclamation,
property value evaluations, and a discussion of enviromilental Justice. The report
entitled "Qualitative Analysis Relevant to Socioeconornics and Environmental
Justice Issues for the Colon Mine and Brickhaven Mine Reclamation Projects" is
included for review (Attachment G).
Comment 413 — "List ajy other authorizations required far thisprqject."
Below is a list of additional authoti7ations required for the proposed projects:
Permit Type Permit #
Mine Permit 19-25 (Brickhaven)
Permit 53-05 {Sanford)
NPD S Permit NCG020354 (Brickhaven)
� 11,ennit NCG020854 (Sanford)
Status
Received 01/23115
Received 01/23/15
Received 12/16/14
Received 12116/14

Mr- Craig Brown
06.05.15
Page 13 of 14
Ero%ion and Sediment Control
CSX Rail
Structural Fill
DEMLR Permit 2015-011 (Sanford - North Tract) Received
Chadiam County (Brickhaven Rail) Pending
Rail Approval (Brickhaven)
Rail Approval (Sanford)
Permit Sir O14 -3. (Brickhaven)
Permit SW014-5306 (Sanford)
Pending
Pending
Pending
Pending.
Comment 14# - "lls you mc�y be aware, in accordance with Executive Order 12898, we
tire responsible Jbr identi oing and addressing disproportionately high and adverse
horn an health or environmenial efficis on ininorio, and low-income populations. Based
on an initial review of available census data qf the pate ntialtv af fecte conities, " e
have determined that there is potentially a disproportionate impact to a local ininority
population. We will need to continue to evaluate this issue during permitting rev i ew
process."
Charali has contracted Haley & Aldrich, Inc, to conduct an Environmental Justice
and Economic Analysis review of current and future effects of the project on
surrounding communities. The report includes, but is not limited to, the
following: establishment of a study area, discussion of transportation,
identification of existing disamenities, discussion of benefits to reclarnation,
property value evaluations, and a discussion of environmental justice. The report
entitled "Qualitative Analysis Relevant to Sociocconomics and Environmental
Justice Issues for the Colon Mine and Brickhaven Mine Reclamation Projects" is
included for review (Attachment G).
Modification to Permit Application
After additional evaluation and design, the rail spur at the Brickhaven Mine has been
realigned. Original plans showed the rail line entering the Brickhaven site and taking an
irnmediate turn to tile northeast. It was determined that as the rail line passed beneath
Duke Energy's existing transmission line, the rail line would be at an elevation that
would cause rail cars to touch the hanging transmission lines, The realignment eliminates
this situation. The realignment includes one additional wetland impact of 88 square feet
or 0,002 acre (Impact #13); all other impact will remain the same. The: area around the
realigned rail spur will be used as a stock pile area and rail side support area. The impact
map (Figure lb), impact table (Attachment C),, and mitigation table (Attachment D) have
all been updated to reflect the above change.

Mr- Craig Brown
06.05.15
Page 14 of 14
The applicant believes the infonnation submitted in this package addresses all issues set
forth by the Corps in their letter dated May 6, 2015. Responses to additional agency
comments will be submitted under a separate cover by July 1, 2015. Should you have
any questions or comments conQerning this project please do not hesitate to contact me at
828-698-9800.
Sincerely,
Rebekah L. Newton R. Cl
Project Biologist Principal
Cc: NC Division of Water Resources - Jennifer Burdette

Attacbment A
Corps Comments
(dated May 6, 2015)

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
LAY"
Regulatory Division/1200A
Action 11). SAW-2014-02254
Mr, Charles Price
Green Meadows, LLC
12601 Plantside Drive
Louisville, Kentucky 40299
Dear Mr. Price,
May 06, 2015
Rererence our March 5, 2015, Public Notice for die proposed mine reclamation project
located at the Brickhaven and Sanford Mines. The Brickhaven Mine is located off Moncure-
Flatwood Road approximately 2 miles east of MonCUre, in Chatham County, North Carolina.
The Sanford Mine is located off Brickyard Road approximately I mile northeast of Sanford,
in Lee County, North Carolina,
The project would perinanently impact a total of 4,166 linear feet of warm water stream,
and 1.14 acres of non-isolated wetlands. Specifically, jurisdictional impacts at the
Brickhaven site would impact, 2,450, linear feet of stream channel, 0.05 acre of non-isolated
wetlands, and 0.5 acre of isolated wetlands, The jurisdictional impacts for the S,anford site
would impact 1,,716 linear feet of stream channel and 1.09 acres of wetlands. The non -
isolated wetlands and unnamed tributaries at the Brickhaven site flow into Gulf and Shaddox
Creek, while at the Sanford site, the non-isolated wetlands and unnamed tributaries flow into
Roberts Creek. Both of these Creeks are in the Cape Fear Basin (8-Digit Cataloging Unit
03030004 and 03030003, respectively).
To help us with our review of this proposal, some additional information is required as
listed below;
1. This project does not need to be located within waters of the U.S. in order to
satisfy your Purpose and Need statement, As required by the 404(b)(1) Guidelines (40 CFR
part 230) other practicable alternatives must be evaluated to ensure that the Least
Environmentally Damaging Practicable Alternative (LEDPA) is identified.
Ptintad an is Ro CYC100 papef

Please elaborate on the criteria used to evaluate other inine sites, identify the mines that were
considered, and an explanation of why these alternative mine sites were determined to be
unsuitable as it applies to Purpose and Need.
2, In the altcrnatives, analysis of your application, it states that coal ash can be used
in cement and asphalt concrete. One cernent company currently accepts coal ash From Duke
power plants for this purpose. Please provide detailed information as to why some or all of
the coal ash cannot be used in this manner.
3. In your application for this project, you utilize the term, Phase I , Please provide
clarification as to what activities are, specifically involved in Phan o 1. In addition, please
elaborate on any future phases and their potential impacts to the Waters of the United States
(W US). Besides impacts to WOUS at the Brickhaven and Sanford Mines, please identify
other impacts to WOUS at offsite locations resulting from the transfer of coal ash to the
Brickhaven and Sanford Mines, This would include improvements to transportation and
handling facilities at the Riverbend and Sutton Power Plants, as well as other, known
locations that will be contributing coal ash to these sites.
4. The application states that "The purpose of the proposed project is to close ash
basins at the Rive•bend Steam Station and the Sutton Electric Plant by August of 2019 as
required by the Coal Ash Management Act of 2014 (CAMA 14)." This Project Purpose is
defined too broadly and docs not have any direct relation to the activity for which you are
seeking a Clean Water Act Section 404 permit. Therefore, we would recommend that it be
revised to state something to the effect of. "The purpose of the proposed project is to dispose
of coal ash in a suitable manner and in an environmentally sound location. The long-term
disposal of coal ash in suitable locations will facilitate the closing of coal ash basins across
North Carolina, as required by the CAMA 14. "
5. Maps supplied with the application indicate that there is an "Arch Culvert" on one
of the streams at the Sanford Mine, and two "Spanning Structures" at the Brickhaven Mine
crossing as stream and a wetland. While these proposals do not result in a direct loss of
jurisdictional features, they are known to have an adverse impact upon aquatic resources and
will require compensatory mitigation for their indirect impacts to Jurisdictional waters.
Prinluden G) poryded Npur

W
Based on our experience with these types of structures and depending on the quality of the
aquatic resource, we have required cornpensatoi-y mitigation at a half the ratio that would be
required if the stream were to be CUlverted.
6. A cernetery ("presurned to be the Zion Hill Cemetery") is located at the Sanford
site. Please explain what measures will be taken to preserve and protect this cemetery and
allow public access.
7. The U.S. Fish and Wildlifb Service (USFWS) and the public have expressed
concerns about the transportation of coal ash to the two project areas. Much of these
concerns were addressed on page 17 of the application package. Please clarify what steps
Charah, Inc. will be taking to minimize loss of coal ash during transport and storage at the
proposed disposal location.
8, There were several public comments expressing concern about possible
groundwater contamination from coal ash at these two reclamation sites. Although you will
address concerns related to water quality and groundwater monitoring through the North
Carolina Division of Water Resources and the 401 process, we refer the following
representative comments for reference:
(a) The Southern Environmental Law, Center (SELC), in a comment letter to the
USACE dated March 23, 2015 (copy enclosed), recommended that two monitoring wells be
added at both reclamation sites. In addition, they have recommended that monthly
monitoring of groundwater elevations be required for the first year in order to verify
assumptions about seasonal high water levels and that background sampling should be
conducted on a quarterly basis for the first year in order to evaluate possible seasonal
variation in water quality.
(b) The Haw River Assembly, in a comment letter to the L1 ACE dated
April 2, 2015 (copy enclosed), asked if there was a ` "plan for baseline monitoring of
neighbors' di-iriking water wells in an area surrounding, the mines?" The concern with
contaminated drinking water was also addressed by other members of the public during the
conunent period.
FrInted Dn 0 A ocyd od Papor

M
(c) In a petition signed by I 10 resident,-, of Chatham County, and submitted to our
office via email on April 8, 2015 (copy enclosed), concerns were expressed about coal ash
containing "... high levels of heavy metals such as arsenic, lead, mercury, and other- toxic
Substances, which requires utmost precautions, and protections for handling, transporting, and
disposal," `17his petition and a number of other corninentois expressed, concerns about the
disposal of leachate, and questioned whether municipal wastewater treatment plants would
be able to handle heavy metals and other toxins contained in coal ash. Many commenters
were also concerned that the liners lining the coal ash pits would eventually deteriorate and
toxic substances would be released into the streams, wetlands and groundwater. Please
address concerns about heavy metals and other toxic substances in the coal ash including:
the precautions and protections for handling, transporting, and disposal ofcoal ash to insure
that heavy metals and other toxins do not escape into the environment;, the adequacy of
municipal wastewater treatments plants to handle these substances in the leachate; and the
potential of heavy metal and leachate entering the watershed because of deteriorating liners.
9, The North Carolina Wildlife Resources Commission (NCWRQ, in a comment
letter to the 'USACE dated April 2, 2015 (copy enclosed), recommended "—a minimum 200-
foot undisturbed, native, forested buffer along perennial streams, and a I 00-foot buffer along
intermittent streams and wetlands, is advised."' Furdier stating that "Maintaining
undisturbed, forested buffers, along these areas will minimize impacts to aquatic and
terrestrial wildlife resources, water quality and aquatic habitat both within and downstream
of the project area, In addition, forested riparian buffers protect water quality by stabilizing
strearn banks and filtering stormwater runoff." Many of the public comments received by
the USACE also expressed concerns about protecting existing streams from pollutants and
sediment during storm events at the project sites. In light of these comments, please evaluate
and comment on the NCVIRC's recommendation for 200-foot buffers on perennial streams
and l00 -foot buffers along intermittent streams and wetlands,.
Prfrue-d on 19 Pi dod Paper

M
10. Ilie NCWRC recommended relocation of ". –streanis using natural channel
design methods, If strearns cannot be relocated, stream channels should be diverted to
prevent surface waters from coming into contact with disposed materials." The loss of flow
from impacts to upstream tributaries could negatively impact stream quality downstream, as
well as base flows. Please evaluate the potential for stream. and the downstream
impacts from losses to upstream WOUS, as well as efforts to prevent surface waters from
coming into contact with disposed materials.
I I , The Chatham County petition also states that "—the heavy flow of truck and train
traffic will increase safety issues, i.e. accidents, spillage, fly ash, noise, and air pollution."
Numerous other comments received at our, office, from both Chatham and Lee Counties,
expressed similar concerns, In light of these concerns, please address the precautions
(specifically: accidents, spillage and noise) taken in the transport of coal ash at these two
sites.
12. The Chatham County petition further states that the "Transport and storage of
Coal Ash would adversely affect the economics of the community/county." Numerous other
comments received at our office, from both Chatham and Lee Counties, expressed similar
concerns. In addition, several commenters are concerned that the proximity of their
properties to the mine sites will result in a devaluation of their properties, In light of these
concerns, please address how the transport and storage of coal ash will affect the economies
of the host conununitics/countics, including property values near the mines, and within the
two counties.
13. List any other authorizations required for this prqject.
14. As you may be aware, in accordance with Executive Order 12898, we are
responsible for identifying and addressing disproportionately high and adverse human health
or environmental effects on minority and low-income populations. Based on an initial
review of available census data of the potentially affected communities, we have determined
that there is potentially a disproportionate impact to a local minority Population. We will
need to continue to evaluate this issue during permitting review process.
PrIded ors @ ReUded Paper

Yow response to these comments are important to our review of your pr -oposal and,
should lie provided by June 5, 2015, to avaid delays in the review of your application. If you
have questions or comments, please contact Mr. Craig Brown at the Raleigh Regulatory
Field Office address, telephone [phone] ext. 35.
Siriccrely,
Jean B. Gibby
Chief", Raleigh Regulatory
Field Office
Enclosures: (as stated)
cc: (with enclosures):
Jennifer 13-urdette
NCDT!-,N-R, Division of Water ResOLIXOS
Water Quality Programs
1617 Mail Service Center
Raleigh, North Carolina 27604
NONA MI G nocyded Fapof

Your response to these comments are important to our review of your proposal and
should be provided by June 5, 2015, to avoid delays in the review of your application. If you
have questions or comments, please contact Nfr, Craig Brown at the Raleigh Regulatory
Field Office address, telephone [phone] ext. 35,
Sincerely,
FILE NA,ME:SAW-2014-0225Chai-aliCoaI Ash Disposal L(r.doe
CESAW-RG-R/CB/jat
CESAW-RG-R/FILE
CESAW-RG-R/MAIL105/06/15
Jean B. Libby
Chief, Raleigh Regulatory
Field Office
Enclosures: (as stated)
cc: (with enclosures):
Jennifer Burdette
NCDENR, Division of Water Resources
Water Quality Programs,
1617 Mail Service Center
Raleigh, North Carolina 27604
FdMed an 19 Recycjed� Paper

Attachment B
Mine Alternatives Table

Reason for Dismissal of Alternative
Phase I
Phase 2
Phase 3 Notes
Proximity to
Trucking
Proximity to
Available for
Operator
Mine Name
County
Inactive
Rail
Access
Duke Stearn
Acquisition
Stations
,Boral Bricks Inc
Panther Creek Mine
Rowan
. ..... X
Boral Bricks Inc 1
Thomas Mine
Rowan
x
Boral Bricks, Inc V
Gold Hill Mine
Ran
ow
X
CEMEX Construction Materials
I
Eden Quarry
Rockingham
Cunningham Brick Coiaap any
Beck Mine
Chatham
X
Cunningham Brick Company
Davidson II Mine
Davidson
General Shale Brick, Inc.
Brickhaven Mine No. I
Chatham
General Shale Brick, Inc.
Brickhaven Mine No. 2,
Chatham
Available
General Shale Brick, Inc.
Gulf Mine
Chatham
X
General Shale Brick, Inc.
Colon Mine-
Lee
�Available
General Shale Brick, Inc.
Sanford M in
Available but Disrrtissed (see response letter)
Harmnill Construction Co Inc
Zion ChMine
Rowan
X
Hanson Brick East, LLC
Anson County Mine
Anson
X
'Hanson Brick East LLC I
Howell Mine Nos I & 2
Anson
X
I Hanson Brick East LLC 1
Gulf Mine No. 3
Chatham
X
Brick East LLC
Pleasant Garden Plant #1
Guilford
x
-Hanson
Hanson Brick East LLC
Plant #3
Guilford
Hanson Brick East LLC
PG Farm Mine
Guilford
X
Hanson Brick East LLC
Sampson Mine II
Sampson
Hanson Brick East LLC
Kendrick Mine
Union
X
Lee Brick & Tile
Sanford Mine
Lee
X
:Nash Brick Company
Ita Mine
Halifax
x
Pine Hall Brick Company, Inc.
Madison Pomona Mine
Rockingham
X
Pine Hall Brick Company, Inc.
Young Webb Mine
Rockingham
Pine Hall Brick Company, Inc.
Chilton Van Noppen
Rockingham
X
jPine Hall Brick Company, Inc.
Dr. Martin Mine
. .... ... .
Rockingham
X
I
. Pine Hall Brick Company, Inc.
Galloway Mine
Rockingham
X
jPine Hall Brick Company, Inc.
Kluttz Mine
Stokes
X
Pine HaII Brick Compan
y, Inc.
Pipe Plant Mine
Stokes
IStatesville Brick Co
'fredell Pit No. 2
Iredell
IStatesville Brick Co
Gold Hill Mine
Rowan
1
x
I Statesville Brick Company
Statesville Brick 11 Mine
Iredell
ITaylor Clay Products
Candor Mine
Montgomery
X
Taylor Clay Products Inc
Clearwater Mine
Rowan
Triangle Brick Company
Wadesboro Mine
Anson
X
Triangle Brick Company
Merry.Caks Site I
Chatham
X
Triangle Brick Company
Merry Oaks Site #2
Chatham
Triangle Brick Company
, Durham Mine
Durham
X
*All mines listed above have been evaluted for commodity as a part of Phase I analysis.
"Mine sites must pass the Phase I before being analyzed in Phase 2.
Mine sites must pass
Phase 2 before being analyzed in Phase 3.

Attachment C
Updated Impact Table
(Section 5.1 of the Pennit Application)

,r'he proposed project includes the following stream and w(-,,tland impacts at the Sanford and
Brickhaven Mines (Figures la and lb),:
Impact #
3
6
10
13
15
21
22
23
2,4
Total
Impacts per site;
Sanford - Streams
Linear Feet
I Type of Impact
405
Fill Cell and SEC Structure
201
Fill Cell and SEC Structure
660
Fill Cell and SEC Structure
217
Fill Cell and SEC Structure
96
Fill Cell
23
Fill Cell
2
Road Crossing
100
Railroad
2
Road Crossing
10
Road Crossing
1,716
12
Brickhaven - Streams
Impact #
Linear Feet
Type of npact
1
320
SEC' Structure
3
906
Stockpile Yard and SEC
Structure
4
913
Stockpile Yard and SEC
Structure
5
311
SEC Structure
12*
90
Arch Culvert
Total
2,540
SEC Structure
*new impact added
Sanford - Wetlands (non-isolated)
Impact #
Acres
Typc of Impact
1
0,005
SEC Structure
7
OJI
SEC Structure
4
4.
0.03
Fill Cell
5
O.14
Fill Cell
7
0.1,9
SEC Structure
8
U9
SEC Structure
9
0.07
SEC Structure
12
0.02
Fill Cell
14
0.04
Fill Cell
16
0,10
Fill Cell
17
0.24
Railroad
18
10.03
Railroad
19
OM
Railroad
20
0.004
Railroad
25*
0.02
Arch Culvert
Total
1.11
Brickhaven - Wetlands (non-isolated)
Impact # Acres Type of Impact
2 0.04 SEC Structure
10 0.01 SEC Structure
13* 0.002 Railroad
Total 0.05
Brickhaven - Wetlands (isolated)
Impact #
Acres
Type of Impact
6
0.08
Fill Cell
7
0.01
Fill Cell
8
0.29
Fill Cell
9
0.10
Fill Cell.
11
0.02
SEC Structure
Total
0.50

Total impacts (for Sanford Mine and Brickhaven Mine):
Strearus
Sanford 1,716
Brickhaven 2,540
Total Streams 4,256
Wetlands (non-isolated)
Sanford
Brickhaven Q 0.05
Total Wetlands (no.n-isolated) Q 1.16
Wetlands (isolated)
Sanford 0
Brickhaven 0.50
Total Wetlands (isolated) 0.50

Attachment D
Mitigation Table

Sanford - Streams
Impact #
Linear Feet
Mitigation Ratio (x.1)
Basic Mitigation Requirement
HUC Notes
3
405
1
405
CF04
Total
6
1 201
1
201
CF04
CF02
10
660
1
660
LCF04
Brickhaven
11
217
217
CF04
-o
13
96
1
I
96
CF04
15
23
1
23
CF04-
21
2
1.
2
CF04
22
A, 100
1
100
CF04
23
2
1
2
CF04
24
10
10
Total
1,716
1,716
Sanford - Wetlands
Impact#
Acres
Mitigation Ratio (x:1)
Basic Mitigation Requirement
HUC
Notes
1
0,005
1 1
0.005
CF04
2
0.11
1
0.11
CF041
4
0.03
1
a03
CF04
5
0.14
1 1
014
0104
7
0.19
1
0,19
CF04
8
0�09
1
0.09
CF
9
0.07
1
0.07
CF04
12
0.02
1
OX2
=04
14
0,,04
1
0.04
1 CF04
16
0.10
1
0.1
CF04
17
0.24
1
0.24
CF04
18
0.03
1
0.03
CF04
19
0,02
1
0.02
CF04
20
U04
1
0,004
CF041
25*
0,02
03
0.01
CF04
arch crulvert - indirect impacts (Ralf of 1:1 ratio)
Total
1.11
L
1.10
*newly added
mitigation
lBrirkhaven - Streams
Impact
Linear Feet
Mitigation Ratio (x:1)
Basic Mitigation Requirement
UC
HUC Notes
1
320
1
320
CF02
3
906
1
9015
F02
4
913
1
913
CF02
5
311
1
312
1 CF02
12*
90
1
-
90
CFO culvert indirect impacts (half 2:1-ratio)
E
Total
2,540
2,njarch
540
*newly added
mitigation
Brickhaven - Wetlands
Impact
Impact #
Ac res
Mitigation Ratio (x.:l)
Basic Mitigation Requirement
I HUC INotes
2
OV
2
0.08
t.!�F02 adding to CF04 -'"out of HUC" (double of 1:1 ratio)
6
0.09
0,08
LSLD4
7
0L01
0,01
CF04,
8
0.29
C FLO 4,
0
9
mo
DAG
LCF041
10
0.01
1
0,01
CF04
11
0.02
1
0.02
CF04
13*
0.002
2
0.0,04
LSEE adding to CF04 - "out of HUC" (double of 1:1. ratio)
Total
0.55
0.59
L-1
*newly added mitigation
Total Mitigation Required by HUC- Stream (LF)
15anford
CF04 I CF02 Grand Total
11,716
0
Bricki Javen
0
[1H,716t2a,54
2,540
Total
0 4,2�6
Total Mitigation Required by HUC- Wetland (AC)
CF04
CF02
Grand Total
Sanford
1.10
0
Brickhaven
0.59
0
Total
1-69
-o
1.69

Attachment E
DMS Modified Acceptance Letter
(dated June 4, 2015)

RENEVR
North Carolina Department of Environment and Natural Resources
Charles Price
Green Meadows, LLC
12601 Plantside Drive
Louisville, KY 40299
Project: Brickhaven and Sanford Mines
Ecosystem Enhancement Program Donald: R. van der Vaart
Secretary
June 4, 2015
Expiration of Acceptance: December 4, 2015
County: Chatham/Lee
The purpose of this letter is to notify you that the North Carolina Ecosystem Enhancement Program (NCEEP) is willing to accept
payment for compensatory mitigation for impacts associated with the above referenced project as indicated in the table below. Please
note that this decision does not assure that participation in the NCEEP will be approved by the permit issuing agencies as mitigation
for project impacts. It is the responsibility of the applicant to contact these agencies to determine if payment to the NCEEP will be
approved. You must also comely with all other state. federal or local government vermits. reiaulations or authorizations associated
with the vroposed activity including SL 2009-337: An Act to Promote the Use of Compensatory Mitigation Banks as amended by
S.L. 2011-343.
This acceptance is valid for six months from the date of this letter and is not transferable. If we have not received a copy of the
issued 404 Permit/401 CertificationtCAAIA permit within this time frame, this acceptance will expire. It is the applicant's
responsibility to send copies of the permits to NCEEP. Once NCEEP receives a copy of the permits) an invoice will be issued based
on the required mitigation in that permit and payment must be made prior to conducting the authorized work. The amount of the In-
Lieu Fee to be paid to NCEEP by an applicant is calculated based upon the Fee Schedule and policies listed at www,nceep.net.
Based on the information supplied by you in your request to use the NCEEP, the impacts that may require compensatory mitigation
are summarized in the following table. The amount of mitigation required and assigned to NCEEP for this impact is determined by
permitting agencies and may exceed the impact amounts shown below.
River Basin CU Stream (feet) Wetlands (acres) Buffer I Buffer 11
i LocationI Cold Cool Warm Riparian Non-Riparian Marsh (Sq. Ft.)
Coastal
Impact Cape Fear 1 03030002 1 0 0 2,540 0 0 1 0 p 0 0
Upon receipt of payment, EEP will take responsibility for providing the compensatory mitigation. The mitigation will be performed
in accordance with the N.C. Department of Environment and Natural Resources' Ecosystem Enhancement Program In-Lieu Fee
Instrument dated July 28, 2010.
Thank you for your interest in the NCEEP. If you have any questions or need additional information, please contact Kelly Williams at
[phone].
Sincerely,
James. B, S 117
Asset Management Supervisor
cc: Craig Brown, USAGE- Raleigh
Rebekah Newton, agent
1652 Mail Service Center, Raleigh, North Carolina 27699-1652
Phone: [phone] Internet: www,nceep.net
An Equal Opportunity h Affirmative Action Employer — Made in part from recycled paper

North A&DENR
w Department of Environment and Natural „
Charles Price
Green Meadows, LLC
12601 Plantside Drive
Louisville, KY 40299
Project: Brickhaven and Sanford Mines
Ecosystem Enhancement Program Donald R. van der Vaart
Secretary
June 4, 2015
Expiration of Acceptance: December 4, 2015
County: Chatham/Lee
The purpose of this letter is to notify you that the North. Carolina Ecosystem Enhancement Program (NCEEP) is willing to accept
payment for compensatory mitigation for impacts associated with the above referenced project as indicated in the table below. Please
note that this decision does not assure that participation in the NCEEP will be approved by the (permit issuing agencies as mitigation
for project impacts. It is the responsibility of the applicant to contact these agencies to determine if payment to the NCEEP will be
approved. You must also comoly with all other state. federal or local government hermits, regulations or authorizations associated.
with the vrovosed activity including SL 2009 -337: An Act to Promote the Use of Comnensatory Mitigation Banks as amended by
S.L. 2011 -343.
This acceptance is valid for six months from the date of this letter and is not transferable. If we have not received a copy of the
issued 404 Permit/401 Certification/CAMA permit within this time frame, this acceptance will expire. It is the applicant's
responsibility to send copies of the permits to NCEEP. Once NCEEP receives a copy of the permit(g) an invoice will be issued based
on the required mitigation in that permit and payment must be made prior to conducting the authorized work. The amount of the In-
Lieu Fee to be paid to NCEEP by an applicant is calculated based upon the Fee Schedule and policies listed at www.nceep.net.
Based on the information supplied by you in your request to use the NCEEP, the impacts that may require compensatory mitigation
are summarized in the following table. The amount of mitigation required and assigned to NCEEP for this impact is determined by
permitting agencies and may exceed the impact amounts shown below.
Cut Stream feet - Wetlands (acres) Buffer I Buffer 11
River Basin Location ( ) I (Sq. Ft.) (Sq. FL)
Impact Ca a Fear 03030004 GoOId I Cool I Warm � Riparian 2 I Nan- �parian I Coastal Marsh
p
! 0
Upon receipt of payment, EEP will take responsibility for providing the compensatory mitigation. The mitigation will be performed
in accordance with the N.C. Department of Environment and Natural Resources' Ecosystem Enhancement Program In -Lieu Fee
Instrument dated July 28, 2010.
Thank you for your interest in the NCEEP. If you have any questions or need additional information, please contact Kelly Williams at
(919) 707 -8915.
Sincerely,
/0 5C
Jame Stanfill 1,-) C -,—N
Asset Management Supervisor
cc: Craig Brown, USACE- Raleigh
Rebekah Newton, agent
1552 Mail Service Center, Raleigh, North Carolina 27699 -1652
Phone. 919 - 707 -8976 t Internet: wuww.nceep.net
An Equal Opportunity 1 Affirmative Action Employer— Made in part (torn recycled paper

Attachment F
GRI White Paper, #6
(dated February 8,' 11

Geosynthetie Institute GRI
475 1.edron Avenue GEE GII
1~'olso �, PA 19033 -1208 USA
TEL [phone]
FAX [phone] CAI Cl�l
G I White Paper 46
�
Unexposed and Exposed Conditions
Robert A Koerner, Y. Grace Plsnan and George R. Koerner
Gensynthetic Institute
475 Kedron Avenue
I ammgmImi'�lf� 1
Phone [phone]
P'nx (610) 522 -8441
E rails:
robert. koernerg;coe.drexal.edu.
grace Irsu n coe.drexel.edu
gkm+erner @dca.net
Original: June 7, 2005

Geoinembrane Lifetime Prediction: Unexposed and Exposed Conditions
LO Introduction
Without any hesitation the most frequently asked question we have had over the past
thirty years' is "how long will a particular geomembrane last".* The two-part answer to the
question, largely depends on whether the geo membrane is covered in a timely manner or left
exposed to the site-specific environment. Before starting, however, recognize that the answer to
either covered or exposed geornembrane lifetime prediction is neither easy, nor quick, to obtain.
Further complicating the answer is the fact that all geomembranes are fort-nulated materials
consisting of (at the minimum), (i) the resin from which the name derives, (ii) carbon black or
colorants, (iii) short-term, processing stabilizers, and (iv) long-term antioxidants. If the
formulation changes (particularly the additives), the predicted lifetime will also change. See
Table I for the most cornmon types of geornembranes and their approximatc formulations.
Table 1 - Types of commonly used geornembranes and their approximate formulations
(based on weight percentage)
Type
Resin Plasticizer
Fillers,
HDPE
95-98 0
0
LLDPE
94-96 0
0
fpp
85-98 0
-13
PVC
50-70 25-35
0-110
CSPE
40-60 0
40-50
EPDM
25-30 0
20-40
HDPE
high density polyethylene
PVC
LLDPE
= linear low density polyethylene CSPE
fpp
= flexible polypropylene
EPDM
Carbon Black Additives
2-3 0.25-1
2-3 0,25-3
2-4 025-2
2-5 2-5
5-10 5-15
20-40 1-5
= polyvinyl, chloride (plasticized)
= chlorsulfonated. polyethylene
= ethylene propylene diene terpolymer
. More recently, the some question has arisen but focused on geotextiles, geogrids, geopipe, turf reinforcernent mats,
fibers of GCI.s, etc. This White Paper, however, is focused completely on eomembranes due to [lie tremendous
'time and expense of providing such information for all types of geosynthetics.

The possible variations being obvious, one must also address the degradation
mechanisms which might occur. They are as follows accompanied by some generalized
commentary.
0 Ultraviolet Light - This occurs only when the geosynthetic is exposed; it will be the focus
of the second part of this communication.
a Oxidation - This occurs in all polymers and is the major mechanism in polyolefins
(polyethylene and polypropylene) under all conditions.
a Ozone - This occurs in all polymers that are exposed to the environment. The site-
specific environment is critical in this regard.
a Hydrolysis - This is the primary mechanism in polyesters and polyamides.
0 Chemical - Can occur in all polymers and can vary from writer (least aggressive) to
organic solvents (most aggressive).
a Radioactivity -"phis is not a factor unless the geomembrane is exposed to radioactive
materials of sufficiently high intensity to cause chain. scission., eg., high level radioactive
'waste materials,
a Biological - This is generally not a factor unless biologically sensitive additives (such as
low molecular weight plasticizers) are included in the formulation.
a Stress State — This is a complicating factor which, is site-specific and should be
appropriately modeled in the incubation process but, 'for long -term testing, is very
difficult and expensive to acheive.
a Temperature - Clearly, the higher the temperature the more rapid the degradation of all of
the above mechanisms; temperature is critical to lifetime and furthermore is the key to
.2-

time-tempei*,,itu-re-supei-positioti which is the basis of the laboratory incubation methods
which will be followed.
2.0 Lifetime Prediction. Unexposed Conditions
Lifetime prediction studies at GRI began at Drexel 'University under U. S, EPA contract
from 1991 to 1997 and was continued under GSI consortium funding until ca. 2002. Focus to
date has been on HDPE geornernbranes placed beneath solid waste landfills due to its common
-use in this particular challenging application. Incubation of the coupons has been in landfill
simulation cells (see Figure 1) maintained at 85, 75, 65 and 55'C. The specific conditions, within
these cells are oxidation beneath, chemical (water) from above, and the equivalent of 50 in of
solid waste mobilizing compressive stress. Results have been forthcoming cover the years insofar
as three distinct lifetime stages; see Figure 2.
Stage A - Antioxidant Depletion Time
Stage B - Induction Time to the Onset of Degradation
Stage C - Time to Reach 50% Degradation (i.e., the Halflife)
2.1 Stage A - Antioxidant Depletion Time
The dual purposes of antioxidants are to (i) prevent polymer degradation during
processing, and (ii) prevent oxidation reactions from taking place during Stage A of service life,
respectively. Obviously, there can only be a given amount of antioxidants in any fonnulation,
Once the antioxidants are depleted, additional oxygen diffusing into the geomembrane will begin
to attack the polymer chains, leading to subsequent stages as shown in Figure 2. The duration of
the antioxidant depletion stage depends on both the type and amount of the various antioxidants,
i.e., the precise formulation.
N

10
-4, mew. ter
Load
EMM=
WFAM M '1010��W 41%,11aw
Seomembrane
sample under
compression
Figure 1. Incubation schematic and photograph of multiple cells maintained at various
constant temperatures,
Q.
Insulation
\ \ /
hew tape
{/
Vz
,
EMM=
WFAM M '1010��W 41%,11aw
Seomembrane
sample under
compression
Figure 1. Incubation schematic and photograph of multiple cells maintained at various
constant temperatures,
Q.

A = anfioxidant depletion 11me
A C a - Induction time
100 C = 50% property degradation
' time (I he *half-flfia")
Irne (I 11*h lf-lila"�_
V
cc j
T55
EL T75
t 0 t 85 t75 f65 f6s
Aging Time (" scale)
Figure 2. Three individual stages in the aging of most geomembranes.
The depiction of antioxidants is the consequence of two processes: (i) chemical reactions
with the oxygen diffusing into the geo membrane, and (J) physical loss of antioxidants from the
geomembrane, 'The chemical process involves two main ftinctions; the scavenging of free
radicals converting them into stable molecules, and the reaction 'with unstable hydroperoxide
(ROOFT) forining a more stable, substance. Regarding physical loss, the process involves the
distribution of antioxidants in die geomembrane and their volatility and extractability to the site
specific environment.
Hence, the rate of depletion of antioxidants is related to the type and amount of
antioxidants, the service temperature, and the nature of the site-specific environment. See Hsuan
and Koerner (1998) for, additional details.
2.2 Stage B - Induction Time to Onset of Degradation
In a pure polyolefin resin, ie,, one without carbon black and antioxidants, oxidation
occurs extremely slowly at the beginning, often at an immeasurable rate. Eventually, oxidation
occurs more rapidly. The reaction eventually decelerates and once again becomes very slow,
IRS

This progression is illustrated by the S-shaped curve of Figure 3(a), The initial portion of the
curve (before measurable degradation takes place) is called the induction period (or induction
time) of the polymer. In the induction period, the polymer reacts with oxygen forming
hydroperoxide (ROOH), as indicated in Equations (1)-(3), However, the amount of ROOH in
this stage is very small and the hydroperoxide does not further decompose into other free radicals
which inhibits the onset of the acceleration stage.
In a stabilized polymer such as one with antioxidants, the accelerated oxidation stage
takes an even longer time to be reached. The antioxidants create an additional depletion time
stage prior to the onset of the induction time, as shown in Figure 3(1.x).
R d
Induction
period
Acceleration tl
period
Deceleration
period
(a) Pure unstabilized polyethylene
Antioxidant Induction I Acceleration I Deceleration
depletion time I period period period,
_01a -.04 13—
Aging Time
(b) Stabilized polyethylene
Figure 3. Curves illustrating various stages of oxidation.
-6-

RH--->R@+H a (1)
(aided by energy or catalyst residues in the polymer)
R - + 02 —> ROO o (2)
ROO * + RH —> ROOH + R a (3)
In the above, RH represents the polyethylene polymer chains, and the symbol "a" represents free
radicals, which are highly reactive molecules.
2.3 Stage C - Time to Reach 50% Degradation (Halflife)
As oxidation Qontinues, additional ROOH molecules are being formed. Once the
concentration of ROOH reaches a critical level, decomposition of ROOH begins, leading to a
substantial increase in the amount, of free radicals, as indicated in Equations (4) to (6,). The
additional free radicals rapidly attack other polyrner chains, resulting in an accelerated chain
reaction, signifying the end of the induction period,, Rapopport and Zalkov (1986). This
indicates that the concentration of ROOH has a critical control on the duration of the induction
period.
ROOT) -4 RO a OH * (aided by energy) (4)
RO * + RH —> :ROH + R * (5)
01-1 a + RH --> H20 + R o (6)
A series of oxidation reactions produces a, substantial amount of free radical polymer chains
(Re), called alkyl radicals, which can proceed to further reactions leading to either cross-linking
or chain scission in the polymer. As the degradation of polymer continues, the physical and
mechanical properties of the polymer start to change. The most noticeable change in physical
properties is the melt index, since it relates to the molecular weight of the polymer. As for
mechanical properties, both tensile break stress (strength) and break strain (elongation) decrease.
-7-

Ultimately, the degradation becomes so severe that all tensile properties start to change (tear,
puncture, burst, etc.) and the engineering performance is jeopardized. This signifies the end of
the, so-called "service life" of the geomembrane.
Although quite arbitrary, the limit of service life of polymeric materials is often selected,
as a 50% reduction in a specific design property. niis is commonly referred to as the halflife
time, or simply the "halflife". It should be noted that even at halflife, the material still exists and
can function, albeit at a decreased performance level with a factor-of-safety lower than the initial
design value.
2.4 Summary of Lifetime Research -to- Date
Stage A, that of antioxidant depletion for HDPE geomembranes as required in the GRI-
GM 13 Specification, has been well established by our own research and corroborated by others,
e.g., Sangram and Rowe (2004). The GRI data for standard and high pressure Oxidative
Induction Time �OIT) is given in Table 2. The values are quite close to one another. Also, as
expected, the lifetime is strongly dependent on the service temperature; with the higher the
temperature the shorter the lifetime.
Table 2 - Lifetime prediction of HDPE (nonexposed) at various field temperatures
In Service
Stage "A" (years)
Stage "B"
Stage "C'
Total
Temperature
Standard High Press.
Average
Prediction*
('11)
OIT OIT
OIT
(years)
(years)
(years)
20
200 215
208
30
208
446
25
135 144
140
25
100
265
30
95 98
97
20
49
166
35
65 67
66
15
25
106
40
45 47 y
46
10
13
69
*Total — Stage A (average) + Stage B + Stage C
Stage "B", that of induction time, has been obtained by comparing 30-year old
polyethylene water and milk containers (containing no tong-term antioxidants) with currently
M

produced containers, The data shows that degradation is just beginning to occur as evidenced by
slight changes in break strength and elongation, but not in yield strength and elongation. The
lifetime for this stage is also given in Table 2,
Stage "C", the time for 50% change of mechanical properties is given in Table 2 as well.
The data depends on the activation energy, or slope of the Arrhenius curve, which is very
sensitive to material and experimental techniques. The data is from Gedde, et al, (1994) which is
typical of the HDPE resin used for gas pipelines and is similar to Martin and Gardner (1983).
Summarizing Stages A, B, and C, it is seen in Table 2 that the halflife of covered HDPE
geon-icnibranes (formulated according to the current GRI-GM13 Specification) is estimated to be
449-years at 20'C. This, of course, brings into question the actual temperature for a covered
geomembrane such as beneath a solid waste landfill. Figure 4 presents multiple thermocouple
monitoring data of a municipal waste landfill 11-ner in Pennsylvania for over 10-years, Koerner
and Koerner (2005), Note that for 6-years the temperature was approxii-nately 20'C. At that
time and for the subsequent 4-years the temperature increased to approximately 30'C. Thus, the
halflife of this geomembrane is predicted to be from 166 to 446 years within this temperature
range. The site is still being monitored, see Koerner and Koerner (2005).
In

Dry Cell Liner Temperatures
40
35
30
25
m 20
L
rE 15
L
CL 10
H 5
0
0 1000
I 1 I 1 4
2000 3000 4000 5000 8000
Lapsed Time days)
Figure 4. Long -term monitoring of an HDPE liner beneath a municipal solid waste landfill in
Pennsylvania.
2.5 Lifetime of Other Covered Geomembranes
By virtue of its widespread use as liners for solid waste landfills, HDPE is by far the
widest studied type of geomembrane. Note that in most countries (other than the U.S.), HDPE is
the required geomembrane type for solid waste containment. Some commentary on other -than
HDPE geomembranes (recall. Table 1) follows:
2.5.1 Linear Low Density Polyethylene (LLDPE) geomembranes
The nature of the LLDPE resin and its formulation is very similar to HDPE. The
fundamental difference is that LLDPE is a lower density, hence lower crystallinity, than HDPE;
e.g., 10% versus 50 %. This has the effect of allowing oxygen to diffuse into the polymer
structure quicker, and likely decreases Stages A and C. How much is uncertain since no data is
available, but it is felt that the lifetime of LLDPE will be somewhat reduced with respect to
HDPE,
-10-

2.5.2 Plasticizer inigTation in PVC geornembranes
Since PVC geomembranes necessarily have plasticizers in their f"bri-nulations so as to
provide flexibility, the migration behavior must be addressed for this material. In PVC the
plasticizer bonds to the resin and the Ai-en gth of this bonding versus liquid-to-resin bonding is
significant. One of the key parameters of a stable long-lasting plasticizer is its molecular weight.
The higher the molecular weight of the plasticizer in a PVC formulation, the more durable will
be the material. Conversely, low molecular weight plasticizers have resulted in field failures
even under covered conditions. See Miller, et al. (1991), Hammon, et al. . (1993), and Giroud and
Tisinger (1994) for more detail in this regard, At present there is a considerable difference (and
cost) between PVC geornernbranes made in North America versus Europe. This will be apparent
in the exposed study of durability in the second part of this )White Paper.
2.5.3 Crosslinking in EPDM and CSPE geomernbriiaes
The EPDM geomernbranes mentioned in Table I are crosslinked thermoset materials.
The oxidation degradation of EPDM takes place in either ethylene or propylene fraction of the
co-polymer via free radical reactions, as expressed in Figure 5, which are described similarly by
Equations (4) to (6).
EPDM ROOH---o -OH RO&
+ EPDM + EPDM
Figure 5. Oxidative degradation of crosslinked EPDM geomembranes, (Wang and Qu, 2003).
For CSPEgeome-mbranes, the degradation inechanisin is dehydrochlorination by losing chlorine
and generating carbon-carbon double bonds in the main polymer chain, as shown in Figure 6.
-I]-

The carbon-carbon double bonds become the preferred site for further then-nodegradation or
cross-linking in the polymer, leading to eventual brittleness of the geomenibrane.
I I
ut bu2cl
W
IwCH2—CH2� CH =CH I—, CH,—CH�,— +HCI
Y 1
S020
Figure 6. Dechlorination degradation of crosslinked CSPE geomembranes (Chailan, et al., 1995).
Neither EPDM nor CSPE has had a focused laboratory study of the type described for HDPE
reported in the open literature. Most of lifetime data for these gcomembrancs is antidotal by
virtue of actual field performance. Under covered conditions, as being considered in this section,
there have been no reported failures by either of these thermoset polymers to our knowledge.
3.0 Lifetime Prediction-, Exnosed Conditions
Lifi time prediction of exposed geomembrancs have taken two very different pathways;
(i) prediction from anecdotal feedback and field performance, and (ii) from laboratory
weathering device predictions.
WE=
There is a large body of anecdotal information available on field feedback of exposed
geomembranes. It comes form two quite different sources, i.e., dams in Europe and flat roofs in
the USA.
Regarding exposed geomembranes in dams in Europe, the original trials were using 2.0
mm thick polyisobutylene bonded directly to the face of the dai-n. There were numerous
problerns encountered as described by Scuero (1990). Similar experiences followed using PVC
Ili

geornernbranes. In 1980, a geoconiposite was first used at Lago Nero whicli had a 2,00 g/m2
nonwoven geotextile bonded to the PVC geomernbrane. This proved quite successftil and led to
the now-accepted strategy of requiring drainage behind the geomembranc. In addition to thick
nonwoven geotextiles, geonets, and goonet composites have been successful. Currently over 50
concrete and masonry dams have been rehabilitated in this manner and are proving successful for
over 3fl -years of service life. The particular type of PVC plasticized geomernbranes used for
these dams is proving to be quite durable. Tests by the dam owners on residual properties show
only norninal changes in properties, Cazzuffi (1998). As indicated in Miller, et a]. (1991) and
Hammond, et al. (1993), however, different PVC materials and formulations result in very
different behavior; the choice of plasticizer and the material's thickness both being of paramount
importance. An excellent overview of field performance is recently available in which 2,50 darns
which have been waterproofed by geomernbrancs is available from ]COLD (2010).
Regarding exposed geomembranes in flat roofs, past practice in the USA is almost all
with EPDM and C'SPE and, more recently, with fPP, Manufacturers of thosc geornembranes
regularly warranty their products for 20-years and such warrants appear to be justified. EPDM
and CSPE, being thermoset or elastorneric polymers, can be used in dams without the necessity
of having scams by using vertical attachments spaced at 2 to 4 m centers, see Scuero and
Vaschetti (1996). Conversely, fPP can be seamed by a number of thermal fusion methods. All
of these geomembrane types have good conformability to rough substrates as is typical of
concrete and masonry dam rehabilitation. It appears as though experiences (both positive and
negative) with geo-membranes in flat roofs, should be transferred to all types of waterproofing in
civil engineering applications.
M

3.2 Laboratory Wcatherometer Predictions
For an accelerated situ iulation of direct ultraviolet light, high temperature, and moisture
using a laboratory weatherometer one usually considers a worst-case situation which is the solar
maximum condition, This condition consists, of global, noon sunlight,, on the summer solstice, at
normal incidence. ft should be recognized that the UV-A range is the target spectrum for a
laboratory device to simulate the naturally occurring phenomenon, see Hsuan and Koerner
(1993), and Suits and Hsuan (2001).
The Xenon Arc weathering device (ASTM 1 4355) was introduced in Germany in 1954.
There are two important features; the type of filters and the irradiance settings. Using a quartz
inner and borosilicate outer filter (quartz/boro) results in excessive low frequency wavelength
degradation, The more common borosilicate inner and outer filters (boro/boro) shows a good
correlation with solar maximum conditions, although there is an excess of energy below 300 nin
wavelength. Irradiance settings are important adjustments in shifting the response although they
do not eliminate the portion. of the spectrum below 300 mn frequency. Nevertheless, the Xenon
Arc device is commonly used method for exposed lifetime prediction of all types of
geosynthetics.
UV Fluorescent devices (ASTM D7238) are an alternative type of accelerated laboratory
test device which, became available in the early 1970's. They reproduce the ultraviolet portion of
the sunlight spectrum but not the full spectrum as in Xenon Are weatherometers. Earlier FS 40
and UVB-313 lamps give reasonable short wavelength output in comparison to solar maximum.
The UVA-340 lamp was introduced in 1 987 , and its response is seen to reproduce ultraviolet light
quite well. This device (as well as other types of weatherometers) can handle elevated
temperature and programmed moisture on the test specimens.
so

Research at the Geosynthetic Institute: (G I') has actively pursued both. Xenon and UV
Fluorescent devices on a wide range of geomembranes. Table 3 gives the geomembranes that
were incubated and the number of hours of exposure as of 12 July 2005.
Table 5 - Details of the G laboratory exposed w,eatherometer study on various types of
geomernbranes
Geomernbrane
Thickness
UV Fluorescent
Xenon
Type
(111m)
Exposure*
Exposure*
L HDPE (GM 13)
1.50
800,0 hrs.
6600 lags.
2. LLDPE (GIVII 7)
1.00
8000
6600
3. PVC (No. Amer.)
0.75
8000
6600
4. PVC (Europe)
2.50
7500
6600
5. fPP (BuRec)
I .00
2745**
4416"
6, fPP-R (Texas)
0.191
100
100
7. fPP (No. Amer.)
1.00
7500
6600
*As of 12 July 200,5 exposure
is ongoing
"Light time to reach
halflife of break and elongation
3.3 Laboratory Weatherometer Acceleration Factors
Comment
Basis of GRI-Gill 13 Spec
Basis of GR1-GM- 17 Spec
Low Mot. Wt. Plasticizer
High Mot, Wt. Plasticizer
Field Failure at 26 mos.
Field Failure at 8 years
Expected Good Performance
The key to validation of any laboratory study is to correlate results to actual field
performance. For the nonexposed geomernbranes of Section 2 such correlations will take
hundreds of years for properly formulated products, For the exposed geomembranes, of Section
3, however, the lifetimes are significantly shorter and such correlations are possible. In
particular, Geomembrane #5 (flexible polypropylene) of Table 3 was an ,admittedly poor
geornembrane formulation which failed in 26 months of exposure at El Paso, Texas, USA. The
reporting of this failure is available in the literature, Comer, et al. (1998). Note that for both UV
Fluorescent and Xenon Arc laboratory incubation of this material, failure (halflife to 50%
reduction in strength and elongation) occurred at 2745 and 4416, hours, respectively. The
comparative analysis of laboratory and field for this case history allows for the obtaining of
acceleration factors for the two incubation devices.
-15-

33.1 Cornparison'between field and UV Fluorescent weathering
The light source used in the UV fluorescent weathering device is UVA with 'wavelengths
from 295-400 nm. In addition, the intensity of the radiation is controlled by the Solar Eye
irradiance control system. The UV energy output throughout the test is 68.25 W/-m2,
The time of exposure to reach 50% elongation at break was as follows:
= 2745 hr. of light
= 9,882,000 seconds
Total energy in MJ/rn2 = 68.25 W/m2 x 9,882,000
= 6 74.4 M. /M2
The field site was located at El Paso, "Texas. The UVA radiation energy (295-400 mn) at this site
is estimated based on data collected by the South Florida Testing Lab in Arizona (which is a
similar atmospheric location). For 26 months of exposure, the accumulated UV radiation energy
is 724 Mj/M2 which is very close to that generated from the LJV fluorescent weatherometer.
"Merefore, direct comparison of the exposure time between field and UV fluorescent is
acceptable.
Field time vs. Fluorescent LJV light time: Thus, the acceleradon factor is 6.8.
26 Months = 3.8 Months
3.3.2 Comparison between field and Xenon Arc weathering
The light source of the Xenon Are weathering device simulates almost the entire sunlight
spectrum frorn 250 to 800 nm. Depending of the age of the light source and filter, the solar
energy ranges from 340.2 to 695.4' /m2, with the average value being 517.8 W/M2.
The time of exposure to reach 50% elongation at break
4416 hr. of light
15,897,600 seconds
Total energy in Mj/1-n2 = 517.8 W/rn' x 15,897,600
= 9232 MJ/m2
-16-

The solar energy in the field is again estimated based on data collected by the South 'Florida
Testing Lab in Arizona. For 26 months of exposure, the accumulated solar energy (295-800 nm)
is 15,800 MI/M2, which is much higher than that from the UV Fluorescent device. Therefore,
direct comparison of halflives obtained from the field and Xenon Arc device is not anticipated to
be very accurate. However, for illustration purposes the acceleration factor based Oil Xenon Are
device would be as follows,:
Field vs, Xenon Are : Thus, the acceleration factor is 4.3.
= 26 Months = 6.1 Months
The ravulting conch4vion qj' this coinparison q/' weathering devices is that the UV
Fluorescent device is certain v reasonable to rase for long-terin incubations. When considering
the low cost qI'the device, its low maintenance, its inexpensive buths, and ease oftepair it (the
UV Iquorescent device) ivill be used exclusively v GSI.f6r long-term incubation starches.
33.3 Update of exposed lifetime predictions
There are presently (2011) four field failures of flexible polyprol-,iylene geornernbranes and
using unexposed archived samples from these sites their responses in laboratory UV Fluorescent
devices per AST'M 1 7328 at 70 °C are shown in Figure 5. From. this information we deduce that
the average correlation factor is approximately 1.200 light hours — ones ))ear in a heat clirnale.
This value will be used accordingly for other geomembranes.
M

IM11FAM=
120 F- i fP'P-R2 (OM mm)
ME,
80
A fPP-R3 (0.91 mm)
60
. ....... . ...... . . .
20
0
-20
0 2000 4000 6000 80DO 10000 12000 14000 16000
Light Hours
(b), Two Sites in So. Calif
Figure 5. Four field failures of fPP and fPP-R exposed geomembranes.
-18-
Lab-to-Field Correlation Factors
(AS "M D723,8 @ 70-C)
iod
Thickness
Field Location
Lab
Factor
(mm)
(Yrs.)
(It. hr.)
(It. bars. /1.0 yr.)
-1
LOO
—2 W. exas
1800
900
RI
1.14
—8 W. Texas
8200
1025
R—)
0.91
—2 So, Calif,
2500
1250
R3
0.91
—8 So. Calif
11200
1400
1140*
WO It.
hr. = 1.0 year in
hot climates
Figure 5. Four field failures of fPP and fPP-R exposed geomembranes.
-18-

Exposure of a number of different types of geomembranes, in laboratory UV Fluorescent
devices per ASTM D7238 at 70'C has been ongoing for the six years (between 2005 and 2011)
since this White Paper was first released. Included arc the following geomembranes:
e Two black 1.0 mm (4,0 mil) unreinforced flexible polypropylene geomernbranes
formulated per GRI-GM 18 Specification; see Figure 6a.
a Two black unreinforced polyethylene geomembranes, one 1.5 mrn (60 mil) high density
per GRI-CTM 13 Specification and the other 1.0 mm, (40 mil) linear low density per GRI-
GM 17 Specification; see Figure 6b.
0 One 1.0 (40 mil) black ethylene polypropylene diene terpolymer geomembrane per GRI-
GM21 Specification; see Figure 6c.
a Two polyvinyl chloride geomembranes, one black 1.0 mm (40 mil) formulated in North
America and the other grey 1.5 min (60 mil) 1'b nnulated in Europe; see Figure 6d.
Ur 140
a S 120
IL
1 Q sw
ao I—*— PP-2 per GM 18 at 70C
60 i . M-1- fPP-3 per GM 18 at 70C
. . . . ... . ........ .
w 40
20 .... . .........
IL 0
0 1000,0 20000 30000 40000 50000
Light Hours,
Figure 6a. Flexible polyethylene (fPP) geomembrane behavior.
-'19-

0 10000 20000 30000 40000 50000
Light Hours
Light Hours
HDPE (1.50 mm per
GMI 3) at 70C
LLDPE-1 (1,00mm per
GMI 7) at 70C
--*--HDPE (1.50 mm per
GM1 3) at 70C
--a -, LLDPE-1(1.00mm per
GM17') at 70C
Figure 6b. Polyedlylene (HDPE and LLDPE) geomernbranc, behavior.
-2o-

rr
X
10000 20000 30000
Light Hours Exposure
Figure 6c. Ethylene polypropylene diene terpolymer (EPDM) g,eo,membrane.
m

From the response curves of the various geomembranes shown in Figure 6a-d, the 50% reduction
value in strength or elongation (usually elongation) was taken a's being the "halflife". This value
is customarily used by the polymer industry as being the materials lifetime prediction value. We
have done likewise to develop Table 6 which is our predicted values for the designated exposed
geomembrane lifetimes, to date.
Table 6 — Exposed lifetime prediction results of selected geornembranes to date
Type
HDPE
LLDPE
EPDM
fPP-2
fPP-3
?VC-N.A.
PVC-Eur.
Specification
GRI-GM]3
GRI-GM 17
GRI-GM21
GRI-GM 18
GRI-GMIS
(see FGI)
proprietary
Prediction Lifetime in a Dry and Arid Climate
> 36 years (ongoing)
— 36, years (halflife)
> 27 years ('Ongoing)
— 30 years (halflife)
> 27 years (ongoing)
— 18 years (halflife)
> 32 years (ongoing)
4.0 Conclusions and Recommendations
This White Paper is bifurcated into two very different palls; covered (or buried) lifetime
prediction of HDPE geomembranes and exposed (to the atmosphere) lifetime prediction of a
number of geornermbrane types. In the covered geomembrane study we chose the geomembrane
type which has had the majority of usage, that being HDPE as typically used in waste
containment applications. Invariably whether used in landfill liner or cover applications the
geomeynbrane is covered, After ten-years of research Table 2 (repeated here) was developed
which is the conclusion of the covered geomernbrane research program. Here it is seen that
HDPE decreases its predicted lifetime (as measured by its halflife) from 446-years at 20'C, to
69-years at 40'C, Other geornembrane types (LLDPE, fPP, EPDM and PVC) have had
-22-

essentially no focused effort on their covered lifetime prediction of the type described herein.
"That said, all are candidates for additional research in this regard.
Table 2 - lifetime prediction of HDPE (nonexposed) at various field temperatures
In Service
Stage "C"
Stage "A" (years)
Temperature
Standard
I High Press.
Average
(OC)
OIT
OIT
IT
20
200
215
208
25
135
1,44
1,40
30
95
98
97
35
65
67
66
40
45
47
46
*Total = Stage A (average) + Stage B + Stage C
Stage "B"
Stage "C"
Total
Prediction*
(years)
(years)
(years)
30
208
446
25
1,00
265
20
49
166
15
25
106
10
13
69
E.-rposeii geomembrane ItOetinie was addressed from the perspective of field performance
which is very unequivocal. Experience in Europe, mainly with relatively thick PVC containing
high molecular weight plasticizers, has given 25-years of service and the geomembranes are still
in use. Experience in the USA with exposed geomembranes on flat roofs, mainly with EPDM
and CSPE, has given 20"-years of service, The newest geomembrane type in such applications is
fPP which currently carries similar warranties.
Rather than using the intricate laboratory setups of Fig-ure 1 which are necessary for
covered geomembranes, exposed geomembrane lifetime can be addressed by using accelerating
laboratory weathering devices. Here it was shown that the UV fluorescent device (per ASTM
D7238 settings) versus the Xenon Arc device (per ASTM D 4355) is equally if not slightly more
intense in its degradation capabilities, As a result, all further incubation has been using the UV
fluorescent devices per D7238 at 7I1 °C.
Archived flexible polypropylene geomembranes at four field 'failure sites resulted in a
correlation factor of 1200 light hours equaling one -year performance in a hot climate. Using this
'91-

value on the incubation behavior of seven commonly used geomembranes has resulted in the
following conclusions (recall Figure 6 and Table 6)
a FIDPE geomembranes (per GPI-GM13) are predicted to have lifictimes greater than 36-
years; testing is ongoing.
• LLDP,E geomembranes (per GRI-GM17) are predicted, to have lifetimes of approximately
36-years.
• EPDM geomembranes (per GRI-GM21) are predicted to have lifetimes of greater than
27-years; testing is ongoing.
• fPP geomembranes (per GRI-GMI 8) are predicted to have lifetimes of approximately 30-
am
0 PVC geomembranes are very dependent on their plascitizer types and amounts, and
probably thicknesses as well. The North American formulation has a lifetime of
approximately I 8-years, while the European formulation is still ongoing after 32-years.
Regarding continued and future recommendations with respect to lifetime prediction, G is
currently providing the following:
(i) Continuing the exposed lifetime incubations of HDPE, EPDM and PVC (European)
gcomembranes at 70'0.
(ii) Beginning the exposed lifetime incubations of HDPE, LLDPE, WP, EPDM and both
P'VC's at 601C and 80'C incubations.
(iii)With data from these three incubation temperatures (60, 70 and 80'C), time- temperature-
superposition plots followed by Arrhenius modeling will eventually provide information
such as Table 2 for covered geomembranes., This is our ultimate goal.
no

(iv) Parallel lifetime studies are ongoing at GSI for four types of geogrids and three types of
turf reinforcement mats at 60, 70 and 801C,
('v) G does not plan to duplicate the covered geomembrane study to other than the HDPE
provided herein. In this regard, the time and expense that would be necessary is
prohibitive.
(vi)The above said, GS1 is always interested in field lifetime behavior of geomembranes (and
other geosynthetics as well) whether covered or exposed,
Acknowledacments
The financial assistance of the U. S. Environmental Protection Agency for the covered HDPE
lifetime study and the member organizations of the Geosynthetic Institute and its related
institutes for research, information, education, accreditation and certification is sincerely
appreciated. Their identification and contact member, inforniation is available on the Institute's
web site at <<gcosyiitlietic-instituteorg>>,
References
Cazzuffl, D., "Long-Term Performance of Exposed Gcomembranes on Dams in the Italian
Alps,"' Proc. 6 ch Intl. Conf. on Geosynthetics, IFAI, 1998, pp. 1107 -1114W
Chailan, J.-F,, Boiteux, C., Chauchard, J'., Pinel, B. and Seytre, G., "Effect of Thermal
Degradation on the Viscoelastic and Dielectric Properties of Chlorostilfonated Polyethylene
(CSPE) Compounds," Journal of Polymer Degradation and Stability, Vol. 48, 1995, pp. 61-
65.
Comer, A. I., Hsuaji, Y. G. and Konrath, L., "The Performance of Flexible Polypropylene
Geomembranes in Covered and Exposed Environments," 6"" International Conference on
Geosynthetics, Atlanta, Georgia, USA, March, 1999, pp. 359-364.
Gedde, U. W., Viebke, J., Leijstrom, H. and If arson, M.., "Long-Term Properties of flot-Water
Polyalefin Pipes - A Review," Polymer Erigineering and Science, Vol, 34, No. 24, 1994, pp,
1773-1787.
Giroud, J.-P. and Tisinger, L. G., "The Influence of Plasticizers on the Perfon-nance of PVC
Geoniernbranes," PVC GRI- 17 Conference, IFAI, Roseville, N4N, 1994, pp. 169-196.
Hammon, K, Hsuan, G., Levin, S. B. and Mackey, R. E., "The Re-examination of a Nine-Year-
Old PVC Geomembrane Used in a Top Cap Application," `11" Annual SWANA Conference,
San Jose, CA, 1.993, pp. 93-108.
-25-

lisuan, Y. G. and Guan, Z., "Evaluation of the Oxidation Behavior of Polyethylene
Geomembranes Using Oxidative Induction Time Tests," ASTM STP 1326, Riga and
Patterson, Eds., ASTM, 1997, pp. 138-149.
Hsuan, Y, G. and Koerner, R. M., "Can. Outdoor Degradation be Predicted by Laboratory
Acceleration Weathering?," GFR, November, 1993, pp. 12-16.
Hsuan, Y. G. and Koerner, R. M,, "Antioxidant Depiction Lifetime in High Density Polyethylene
Geomembranes," Jour. Geotech. and Geoenviro.n. En r., ASCE, Vol., 124, No. , 1998, pp.
532-54,1.
ICOLD (2010), "Geomembrane Seating Systems for Dams: Design Principles and Return of
Experience,," Intl. Committee on Large Dams, Bulletin, 135, Paris, France.,
Koerner, G. R. and Koe!mer. R. M., "In-Situ Temperature 'Mon itoring of Geomembranes," Proc.
GRI-I 8 Conf. at GeoFrontiers, Austin, TX, 2005, 6 pgs.
Martin, J. R. and Gardner, R, J. (1983), "Use of Plastics in Corrosion Resistant Instrumentation,"
1983 Plastics Seminar, NACE, October 2,4-27.
Miller, L. V., Koerner, R. M., Dewyea, J. and Mackey, R. E., "Evaluation of a 30 mil PVC Liner
and Leachate Collection System," Proc. 29"' Annual GRCDAJSWANA Conf, Cincinnati,
01-1,1991.
Mijeller, W. and Jakob, I., "'Oxidative Resistance of High-Density Polyethylene
Geomenibranes," Jour, Polymer Degradation and Stability," Elsevier Publ. Co,, No. 79,
2003, pp. 161-172.
Rapoport, N. Y. and Zaikov, G. E., "Kinetics and Mechanisms of the Oxidation of Stressed
Polymer," Developments in Polymer Stabilization-4, G. Scott, Ed., Applied Science
Publishers Ltd., London, U.K., 1986, pp. 207-258.
Sangam, H. P. and Rowe, R. K., "Effects of Exposure Conditions on the Depletion of
Antioxidants from HDPE Geomernbranes", Canadian Geotechnical Journal, Vol. 39, 2002,
pp� 1221-1230.
Scuero, A., "The Use ot'Geocomposites for the Rehabilitation of Concrete Danis," Proc. d' Intl.
Conf. on Geosynthetics, The Hague, Balkerna Publ. Co., 1990, pg. 474.
Scuero, A. M. and Vaselie,tti, G. L., "Geomembranes for Masonry and Concrete Dams: State-of-
the-Art Report,"' Proc. Geosynthetics Applications, Design and Construction, M. B. deGroot,
et al., Eds., A. A. Balkerna, 1996, pp. 889-898.
Suits, L. D. and I-Isuan, Y. G., "'Assessing the Photo Degradation of Geosyntheties by Outdoor
Exposure and Laboratory Weatherometers," Proc. GRI-15 Conference, Hot Topics in
,Geosynthetics II, Gil Publ., Folsom, PA, 2001, pp.. 67 -279.
Wang, W. and Qu, B., "Photo and Thermo- Oxidative Degradation of Photoerosslinked Ethylene-
Propylene-Diene Terpolymer," Journal of Polymer Degradation and Stability, Vol. 81, 2003,
pp.531-537.
M

Attachment G
Qualitative Analysis Relevant to Socioeconomics and Environmental Justice
Issues for the Colon Mine and Brickhaven Mine Reclamation Projects
(dated Ma , 2015)

' """'g
�L-�E41CH
REPORT ON
mcmgm���
QUALITATIVE ANALYSIS RELEVANT TO SOCIOECONOMICS AND
ENVIRONMENTAL JUSTICE ISSUES FOR THE COLON MINE AND
BRICKHAVEN MINE RECLAMATION PROJECTS
by Haley & Aldrich, Inc.
Bedford, New Hampshire
for
Charah, Inc.
File No. 41844-022
June 2015

ff., 1 1.1 RT * 0i 1119 4'Z k
�m
List of Tables iii
List of Figures iv
1. Introduction 1
2. Socioeconomic Ana,lysis 2
8
2.1 STUDY AREA: COLON MINE LOCATION
2
21.1 Transportation of CCPs
2
2.1.2 Existing Disamenities
3
2.1.3 Population and Demographics
3
2.1.4 Employment and Median Household Income
4
12 STUDY AREA: BRICKHAVEN MINE LOCATION
4
2.2.1 Transportation of CCP,5
5
2.2.2 Existing Disamenitles
5
2.2.3 Population and Demographics
6
2.2.4 E mployme nt a nd Median Household I ncome
6
23 MARKET AND NOWMARKET BENEFITS ASSOQATED WITH RECLAMATION
6
3.
Property Value Impacts
9
4.
Environmental Justice Analysis
11
4,1 MINORITY POPULATION ANALYSIS
11
41.1 Colon Mine
11
41.2 Brickhaven Mine
12
4.2 POVERTY LEVEL ANALYSIS
12
42.1 Colon Mine
12
4.2.2 Brickhaven Mine
12
4.3 SENSITIVE RECEPTORS
12
4.4 SUMMARY OF POTENTIAL ADVERSE ENVIRONMENTAL AND HUMAN HEALTH EFFECTS
AND ANALYSIS OF THE POTENTIAL FOR DISPROPORTIONATELY HIGH AND ADVERSE
EFFECTS
13
4,4.1 Increased truck and rail traffic impacts
13
4.4.2 Potential releases of CCPs to the environment
13
5.
Conclusions
16
6.
References
18
8

Page
Tables
Figures

X, Mr.%?=
Table No. Title
Demographic Statistics for Census Tracts in the Vicinity of the Colon Mine
Employment Statistics for Census Tracts in the Vicinity of the Colon M ine
Income Statistics for Census Tracts in the Vicinity of the Colon Mine
4 Demographic Statistics for Census Tracts in the Vicinity of the Brickhaven M ine
5 Employment Statistics for Census Tracts in the Vicinity of the Brickhaven Mine
6 Income Statistics for Census Tracts in the Vicinity of the Brickhaven Mine
7 Race and Ethnicity Data for Census Block Groups within a 5-Mile Radius of the
Bricichaven and Colon Facilities
Poverty Data for Census block Groups within a 5-Mile Radius of the BrIckhaven
and, Colon Mines
9 Summary of Census Block Groups and Potential Environmental Justice
Communities within a 5-Mile Radius of the Brickhaven and Colon Facilities
HAkRICH'

List of Figures
Figure No. Title
1
Location of Brownfields within Lee County
2A
Abandoned General Shale Plant Site
2B
C&D Debris Remaining On-Site
3
Census Tracts within a 5-Mile Radius of the Colon Mine
4A
Wood Products Manufacturing Plant
4B
Truck/Rail Traffic along Corinth Road
5
Census Tracts within a 5-Mile Radius of the Brickhaven Mine
6
Census Block Groups within a 5-Mile Radius, of the Colon Mine
7
Census Block Groups within a 5-Mile Radius of the Brickhaven Mine
8
Sensitive Receptors within a 5-Mile Radius of the Colon Mine
9
Sensitive Receptors within a 5-Mile Radius of the Brickhaven Mine
10
North Carolina Rail System
11
Railroads and Stations in the Vicinity of the Colon and Brickhaven Mines
iv

VINEEK =1. MTO oMt
Green Meadow LLC and Charah, Inc. (Charah) have submitted an application to obtain permits to
construct structural fill projects at the Brickhaven No,2 Mine Tract "A" in Chatham County, North
Carolina, and at the Colon Mine Site in Lee County, North Carolina. As described in the Permit
Application, coal ash, or coal combustion products (CCP), will be used as structural fill to close the open-
pit clay mines and return the land to beneficial re-use for industrial or other purposes.
The Brickhaven and Colon projects are fully regulated by the North Carolina Department of Environment
and Natural Resources (DENR) under the North Carolina Coal Ash Management Act of 2014 (CAMA14)
(codified at North: Carolina General Statues (NC GS) 130A Subpart 3, Use of Coal Combustion Products as
Structural Fill), Including a rigorous permit application submission, review, and approval process, under
the DENR Division of Energy, Mineral and Land Resources..
The structural fill projects have been designed to fully comply with these regulations. The base liner at
each site will use a composite liner design which will consist of three components, a geomembrane liner
installed above and in uniform contact with a geosynthetic clay liner, which overlies a compacted clay
liner, The general leachate management system includes the collection, storage, treatment, and disposal
of the leachate generated. A cover will then be placed over the structural fill which will consist of a six
foot thick system of layers for the top slopes and a four foot thick system of layers for the sideslopes. A
storm water drainage system and high density polyethylene (HDPE) geomembrane will be integrated
into the cover to prevent storm water contact wiith structural fill and to prevent migration of dust from
structural MI. Thus, the installation of a three component liner system, the employment of the leachate
collection system, and the installation of the cover system will effectively sequester the CCPs from the
surrounding environment.
As part of the permit review process, the Army Corps of Engineers (ACOE) has provided: comments on
the permits, The purpose of this report is to address two of those comments, provided below.
Comment 12: The Chatham County petition further states that the "Transport and storage of
Coal Ash would adversely affect the economics of the community/county." Numerous other
comments received at our office, from both Chatham and Lee Counties, expressed similar
concerns. In addition, several commenters; are concerned that the proximity of their properties
to the mine sites will result In a devaluation of their properties. In light of these concerns, please
address how the transport and storage of coal ash will affect the economies of the host
communities/counties, including property values near the mines and within the two counties.
Comment 14: As you may be aware, in accordance with Executive Order 12898, we are
responsible for identifying and addressing disproportionately high and adverse human health or
environmental effects on minority and low-income populations. Based on an initial review of
available census data of the potentially affected communities, we have determined that there is
potentially a disproportionate impact to a local minority population. We will need to continue to
evaluate this issue during permitting review process.
This report provides a detailed demographic analysis relevant to socioeconomics and environmental
justice and a qualitative evaluation of potential impacts.
1 11111RERICH

This study examined the socioeconomic factors present in a five-mile radius surrounding the Colon and
Brickhaven mine sites. This five-mile radius is defined as the study area and encompasses the
geographical areas, potentially impacted by the projects. Demographic data was taken from the United
States (U.S.) Census American Community Survey. The American Community Survey is an ongoing survey
that provides community data every year at the state, county, census tract, census block group, and
census block levels. For some of the demographic data, five-year averages were used while other
demographic data relied on single year estimates.
The Colon mine is located in Lee County at 1600 Colon Road, approximately five miles northeast of the
city of Sanford, NC. The site is a former General Shale Brick Inc, clay mine that was originally permitted
in 1972, and although still permitted as an active mine, the operations went dormant due to lack of
demand for brick in 2008. The permit was transferred to Green Meadow LLC in early 2015. Tice site is
bordered by a mix of wooded, agricultural and rural residential properties. The mine is not visible from
right -of -ways within: the county. The five-mile area surrounding the mine site is characterized by densely
forested areas, numerous industrial and manufacturing facilities, and farmland interspersed with rural
residential housing., A portion of the residential and commercial areas in the city of Sanford are within
the five-mile radius of the mine.
South and west of the Colon mine are industrial and manufacturing areas. This area is also characterized
by older buildings and structures (some abandoned), demolished building sites, and cleared land with
some rural residential housing. Some of the larger industries/companies within five miles of the Colon
mine Include:
0 Lee Brick & Tile plant
0 Pfizer Pharmaceutical manufacturing plant
6 Heritage Concrete
0 Romatic Manufacturing
a Lee Iron & Metal Co. scrap yard
2.1.1 Transportation of CCPs
CCPs will be transported by rail after the completion of a rail! spur to connect to the existing rail line that
runs directly south of the mine site. There are two major (Class I1) freight railroad companies that
operate in North Carolina —CSC( Transportation (CSXT) and Norfolk Southern (NS). Both CSXT and NS
have freight rail lines that run just south of the Colon mine site (see Figure 10). The NS rail (line runs from
Greensboro into Colon (north of Sanford) and on to Brickhaven. Once the rail spur is complete, CCPs will
be delivered by train, with one train (comprised of 110 rail cars) delivery every three days. This is not
expected, to negatively impact, traffic along the rail lines, based on freight volume statistics for the lines
(Federal Railroad Administration, 2015; List et al., 2008). Figure 11 shows railroads and stations In the
vicinity of the Colon mine. The rail traffic to the Colon mine will be temporary, and once the mine
structural fill project is completed in accordance with the structural fill permit application, the rail traffic
would cease.
2 J�q � p
, RE b""'A'

2.1.2 Existing Disamenities
There are several disamenities that are associated with the dormant mine and in the surrounding area
which, affect the residential community. Disamenitie5 are features that detract from the attractiveness,
safety, livability, or convenience of an area and influence housing values. Disamenitles associated with
dormant clay surface mine site include:
Highwalls and potentially unstable slopes
Barren soil and lack of vegetative cover
Construction and manufacturing debris
Lack of drainage and associated undesirable surface water bodies
These disamerittles will be remedied by the Colon mine reclamation project, The structural fill will bring
the elevation up to just slightly above original grade, which will not be visible from the surrounding
residential areas. The structural fill will correct potentially hazardous slopes and improve drainage
surrounding the site. Engineering controls installed include geolsyntbetic liners, leachate collection
system, and groundwater monitoring wells. A vegetative cover will make the site amenable for industrial
or commercial development, agricultural use, or green space. This provides the opportunity for future
socioeconomic benefits without clearing of forested land. Moreover, putting CCPs into beneficial use for
this, project obviates the need to disturb virgin lands to provide structural fill, thereby conserving natural
resources, that would otherwise need to be obtained through other mining activity, and avoiding the
energy expenditures and emissions associated with that mining.
Disamenities not associated with the project include undeveloped brownfields in the immediate area,
abandoned industrial sites, and neglected commercial and residential structures. Figure I shows the
location of brownfields within Lee County relative to the Colon mine site, which are clustered within the
city limits of Sanford. Brownfield mapping was obtained from Lee County geographic information
system (GIS) data. it is important to note that cleanup and redevelopment of a brownfield can remedy a
disa men ity,
Directly across from the Colon mine along Brickyard Road is the abandoned General Shale industrial site.
With lower demand for brick products, General Shale consolidated area operations in 2008, resulting in
the razing of facilities across from the mine which border Brickyard Road and Colon Road. As a result,
there is a large dormant area with construction and demolition (C&D) debris directly across the street
from the entrance to the Colon mine (Figures, 2A,,B).
wM
The census tracts within the vicinity of the Colon mine are shown in Figure 3, which also shows the one-
mile and five-mile distance radius from the site. The population of Lee County, as reported in the 2010
U.S. Census of Population, is 58,735. Census Tract 307'.01, which includes the Colon mine site, has a
population of 4,588, with 79.5% of the population 18 years and older. Census Tract 302, which includes
a portion of the city of Sanford, has a population of 3,988, with 70,.71% over the age of 18. Table 1 shows
the population: of Lee County by census tract.
1" IREMICH

Lee County has an overall minority population of 41% but some census blocks in the study area have
significantly higher (over 50%) minority populations, as shown in Table 1. The impact on minority
communities is discussed in further detail in Section 4.0 Environmental Justice.
E03��w
Within Lee County, 55.9% of the population over the age of 16 is employed. In the census tracts within
the study area, employment ranges from a low of 31.9% in Census Tract 303 (within Sanford city limits)
to 63.5% in Census Tract 301.02, located southwest of the Colon mine site. Census Tract 307.01, which,
includes the Colon mine site, has S8.5% employment rate. The majority of the employed population
works in, manufacturing (22.7%), reflecting the importance of this industry to the local economy.
Another 19.9% work in educational and health services and 12.7% are employed in retail trade.
Employment statistics for the census tracts, are listed in Table 2.
The median household income in Lee County is $44,819; this is below the national average of $53,1346.
There is wide disparity in household income among census tracts near the mine location, from a high of
$74,457 median income in Census Tract 306.01 to a low of $19,279 in Census Tract 303. Census Tract
307.01, which, includes the Colon mine site, has a median household income of $46,413. Nearly 60% of
the househoids in Census Traict 303 earn less than $25,0GO per year. The income statistics for the census
tracts in the study area are summarized in Table 3.
Note that the census tract with the highest minority composition is one of the furthest from the Colon
mine, on the south side of Sanford (Census Tract 303), and that the census tract with the highest median
income is one closest to the mine (Census Tract 306.01).
2.2 STUDY AREA: BRICKHAVEN MINE LOCATION
The Brickhaven mine site is located in southern Chatham County near Shearon Harris Lake and the city
of Moncure, The mine site is co-located with an active General Shale Brick linc. clay mine. Both mines,
were permitted in 1985, and the permit for Tract A was transferred to, Green Meadow LLC in early 2015.
The mine is accessed via Moncure-Flatwood Road frorn Corinth Road, which is paved. Past the rive site,
Moncure-Flatwood Road turns to gravel. The only structures visible from Moncure-Flatwood Road
leadingto the site are a dirt road leading into the mine and a large mound that is on the active General
Shale property, The mine site is surrounded by dense forest /trees on all sides and is quite secluded.
The area within five miles of the mine site is heavily forested and rural, but also is home to several major
manufacturing plants and industrial sites including:
AraucoPly lumber manufacturing plant
Boise Cascade plywood manufacturing plant
Arclin resin manufacturing plant
General Shale brick manufacturing facility
Triangle Brick Company Merry Oaks brick manufacturing facility
Duke Energy Shearon Harris nuclear plant
Duke Energy Cape Fear Power Plant (retired in 2012)
01
4 64 6WgM icti

2.2.1 Transportation of CCPs
Initially CCPs, will be transported by trucks, accessing the mine via Moncure-Flatwood Road from Corinth
Road, Trucks will travel to the mine site via US Highway I (US-1) to Old US Highway 1 to Corinth Road,
'The intersection of Corinth Road along Old US Highway I is approximately 3,5 miles from the US-1 exit
that is used by freight trucks. US-1 is a six-la,ne divided highway that currently accommodates significant
truck traffic. Because of the heavy industry already in the area, truck traffic is common along Old US
Highway 1 and Corinth Road. The stretch of Corinth Road that trucks would travel Is mainly industrial,
with the AarucoPly plant, Boise Cascade plant, Arclin plant, and Duke Energy Cape Fear Power Plant
located directly along the trucking route, An RV park and a few residential homes are located near the
intersection of Corinth Road and Moncure-Flatwood Road. Trucks transporting, CCPs will be traveling
only along the paved section of Moncure-Flatwood Road. The estimated truck traffic is expected to be
approximately 100-130 trucks per day until the rail spur is complete. This is equivalent to 12 — 16 trucks
per hour during normal business operating hours. The truck traffic will follow a route that is commonly
used by the aforementioned industrial facilities in the study area. The trucks will not be traveling
through the commercial or residential areas of the city of Moncure. Thus, because of the trucking route,
and the fact that truck transportation will cease once the rail spur is complete, the truck traffic is not
expected to have significant transportation- related impacts on the residents of Chatham County.
Both CSXT and NS have freight rail lines in the vicinity of the Brickhaven mine, with the CSXT line north
of the mine site parallel to Old US Hwy 1, and the NS line south of the mine site (see Figure 11). Once a
rail spur is complete, CCPs will be delivered by train only, with one train (comprised, of 110 rail cars)
delivery approximately every three days. This is not expected to disrupt freight traffic along the rail lines,
based on freight volume statistics for the lines (Federal Railroad Administration, 2015; List et al., 2008).
Figure 11 shows railroads and stations in the vicinity of the Brickhaven mine. The truck and rail traffic to
the Brickhaven mine will be temporary, and once the mine structural fill project is completed in
accordance with the permit application, the truck and rail traffic would cease.
2.2.2 Existing Disamenitles
There are several disamenities that are associated with the abandoned mine and in the surrounding
area which affect the community. Disamenitles are features that detract from the attractiveness, safety,
livability or convenience of an area and influence, housing values. Disamenitles associated with the
unused portion of the Brickhaven clay surface mine include:
0 Highwalls and potentially unstable slopes
a Barren soil and lack of vegetative cover
0 Construction and manufacturing debris
0 Lack of drainage and associated undesirable surface water bodies
These disamenities will be remedied by the Brickhaven mine reclamation project. The structural fill will
bring the elevation up to just slightly above original grade, which will not be visible from the rights-of-
way. The structural fill will correct slopes and improve, drainage surrounding the site. Engineering
controls installed include geosynthetic liners, leachate collection system and groundwater monitoring
wells. A vegetative cover will make the site amenable for industrial or commercial development,
agricultural use, or green space. This provides the opportunity for future economic development
benefits without clearing of forested land. Moreover, putting CCPs into beneficial use for this project
obviates the need to disturb virgin lands to provide structural fill, thereby conserving natural resources

that would otherwise need to be obtained through other mining activity, and avoiding the energy
expenditures and emissions associated with that m:ining.
Disamenities not associated with the project include existing industrial facilities and related, truck and
rail traffic. Existing industrial facilities along Corinth Road are shown in Figures 4A,B, East of the mine
site along Christian Chapel Church Road is heavily wooded with some farms. There are several vistas in
this area from where Shearon Harris nuclear plant cooling tower can be seen from the road.
2.2.3 Population and Demographics
The census tracts within the vicinity of the Brickhaven mine are shown in Figure 5, which also shows the
one-mfle and five-mile distance radius from the site. The population of Chatham County, as reported in
the 2010 US. Census of Population, is 64,866. Census Tract 207.02, which includes the Brickhaven mine
site and the town of Brickhaven, NC has a population of 3,864. In this census tract, 78.8% of the
population is 18 years and older. Table 4 shows the population of study areas by census tract.
Chatham County Ihas an overall minority population of 29%, and none of the census blocks within a five-
mile radius of the mine site have a minority population over 50%. The impact on minority communities
is discussed in further detail in Section 4.0 Environmental Justice.
2,2.4 Employment and Median Household Income
Within Chatham County, 55.1% of the population over the age of 16 is employed. Across the census
tracts in the .study area (which include Lee County census tracts), employment is rather consistent,
ranging from a low of 54,.9% in Census Tract 307.02 located in Lee County to a high of 693% in Census
Tract 532.07 located in Wake County. The majority of the employed population in Chatham County
works in educational services, health care and social assistance jobs (26.1%), Another 13.7% work in
manufacturing and 11.79 are employed in professional, scientific, management and administrative
fields. Employment statistics for the census tracts in the study area are listed in Table S.
The median household income in Chatham County is $57,091; this is above the national average of
$53,046. Household income in Census Tract 207.2 where the mine is located has a median income of
$55,975. The lower bound on median income in the study area is $44,598 in Census Tract 307.02,
located In Lee County. The high end of income is in Wake County Census Track 534.13 with a median
income of $92,535, The income statistics for the census tracts in the study area are summarized in Table
6,
1541?
Both the Brickhaven mine and Colon mine structural fill projects are reclamation projects that will bring
the elevation of the mined land up to just slightly above original grade, which will not be visible from the
surrounding rights-of-way. The structural fill will correct potentially hazardous slopes and improve,
drainage surrounding the sites,, At the Brickhaven and Colon mines, a vegetative cover will make the site
amenable for industrial or commercial development, agricultural use, or green space, which could add
to the local economy once the site reclamation is complete.
Benefits of reclamation projects can include market-based (economic) benefits and non-market, or
social benefits, Economic benefits to a locality accrue from jobs added during construction and
6 ""' 641CH

operation, associated wages, business taxes, and indirect and induced benefits derived from spending in
the community, Indirect benefits are added to industries that are suppliers to the primary industry
conducting the reclamation project, which includes materials suppliers and subcontractors. Induced
benefits are a result of corollary spending within the community by direct employees of the project as
well as the workers in the indirect industries (i.e., subcontractor employees). Spending within the
community by these workers on food, retail purchases, and hotel accommodations produces additional
economic benefits to the area.
Non market benefits of reclamation projects can include ecological and aesthetic improvements,
recreational benefits, and changes in property values. Quantification of these benefits Often relies on
survey-based stated preference models that attempt to assess how much people are willing to pay to
derive social value from improvements (or be compensated for negative impacts). Where reclamation of
surface mines Is undertaken to make the land amenable to future economic development, both market
and non-market benefits may be accrued (Kuter, 2013). Fundamental objectives of the Colon and
Brickhaven mine reclamation projects are three-fold:
0 To ensure that post-mining land has a feasible self-sustaining future with respect to both
environmental and socioeconomic benefits
6 To encourage better use of energy and natural resources in reclamation by using recycled
materials
a To eliminate environmental and .safety impacts associated with slope instability and poor
drainage from the mine site
Economic studies of reclamation project benefits have consistently demonstrated a multiplier effect
compared to the Initial construction investment. In some cases this multiplier is as high as 3.2; in other
words, for every million, dollars in direct spending related to the reclamation project, 3.2 million doliars
in economic benefits would be accrued (Talberth et A, 2001). Reclamation designed to achieve new end
use can further increase the potential for economic benefits. There are numerous examples of
reclamation of sand, gravel, crushed stone, and clay quarries and mines for office parks and other
commercial or industrial uses (MEC, 2015). A study of the economic impacts, of mine restoration projects
In two Idaho counties found that expenditures of $6.8 million annually resulted in $9.1 million in total.
output each year, with the economic impacts expanding over the study period (Headwaters Economics,
2014).
Investigations of twelve case studies where landfills were constructed at abandoned mine sites show
that with proper design and engineering controls, this reclamation method presented no increased risk
of environmental contamination, and presented many siting advantages (Michaud et al., 1995).
Engineering controls that led to successful reclamation include liner, leachate management,
groundwater protection, landfill design, and construction quality.
For the Colon and Brickhaven mines, the reclamation structural fill projects will employ 75 or more
workers at each site through 2019. When possible, Charah is hiring local workers. Charah has already
hired 40 people for the Brickhaven site. Of those employees, 25 are local to the area (reside within
Chatham or Lee counties), In addition, Charah is utilizing local subcontractor's and suppliers, for fuel
supplies, construction equipment and materials, surveying, electrical work, and hotel accommodations
for out-of-town staff. Estimated spending for fuel supplies alone within Lee County is $7.5 million. Direct
and indirect spending for construction- related activities within Lee and Chatham counties is estimated
at $22.5 million. In addition, other indirect and induced benefits will be accrued through hotel
7

accommodations, food and other employee-related spending. As a result, the local economic impact
from the project is conservatively estimated at $49 million.

0M
Property values serve as indicators of the costs to communities of undesirable land uses, including
degraded landscapes from mining, brownfields, abandoned and derelict properties, pollution from
industrial facilities, and visual and odor issues associated with municipal solid waste landfills. These
undesirable land uses are typically considered disamenities.
Economic analyses of housing values related to disamenities typically employ hedonic pricing models,
which estimate the values for ecosystem or environmental services that directly affect home prices. The
premise of such models is that the value of a good (in this case, residential homes) are influenced by the
attributes of the area, either positively or negatively. For example, open space or parkland has been
shown to have a positive correlation with property values while surface mines or quarries typically have
a negative correlation with property values. H'edonic models are often used to isolate the influence of
factors such as land alteration and uses including mines, quarries, and landfills.
Numerous case studies have been published on the use of CCPs for coal mine reclamation. Because the
chemical composition of CCPs, mitigates acid: mine drainage, such reclamation projects provide
substantial ecological as well as economic benefits. Specific economic analyses of non-coal surface mine
filling projects using CCPs were not found. However, an evaluation of the impact of municipal solid
waste landfills, on local economics can prove to be instructive in this case. One must keep in mind the
many differences between a CCP structural fill project and a municipal solid waste landfill (landfill), The
former is a monofill and the composition of the CCPs is limited to inorganics. The latter accepts a wide
variety of wastes with varying composition, generates explosive gases that need to be captured and
managed, emits greenhouse gases, can have nuisance odor issues, and must be controlled for 'disease
vectors" such as rodents and other pests.
While each site and locality is unique, numerous empirical and case studies on the impact of landfills on
rural residential propertyvalues have found many landfills pose no statistically significant effect on
property values (Ready, 2005; Bouvier et al., 2000; Farber, 1998). Some studies have suggested that
landfills will not necessarily have negative impacts on property values, and that design and stewardship
are Important factors. Where landfills pose odor or pollution issues, or are visually prominent, property
values have been found to decrease, with distance from the landfill being a primary determinant in
housing value Impacts. Meta analysis of several different landfill studies suggest property values
increase approximately five to six percent per mile from the facility, with impacts confined to within two
to three miles (Ready, 2005; Bouvier et al., 2000).
Some studies have found property value impacts are associated with levels of risk concern while other
studies have not observed that relationship. A study by McClelland et aL (1990) revealed that perceived
risks by residents from a hazardous waste landfill can differ substantially from statistical environmental
and human health risks. Positive change in odor perception was correlated with a large reduction in
health risk beliefs. For the Brickhaven and Colon mine sites, odor and visual prominence will not be
detriments. Both mine sites are not visible from rights-of-way and neighboring properties and CCP fills
do not emit odors. Further, there is already, significant industrial activity in both study areas, as well as
related truck and rail traffic.
Although the mine structural fill projects will not be associated with many of the issues surrounding
municipal solid waste or hazardous waste landfills, a concern is whether perceived health risks from
CCPs, will influence property values. Community perceptions can be influenced by the media and by
'a-MICKi

education. As a, result of the than River spill in North Carolina, federal and state rulemaking addressing
coal ash disposal, and the publication of results of current private well testing being conducted in the
vicinity of coal ash ponds in North Carolina, there is understandable concern on the part of a community
about coal ash in general, and coal ash projects specifically. The federal CCR Rule (80 FR 21302-2150;
April 17, 2015) set the standard for coal ash disposal in a landfill, which requires construction with a
composite liner and a leachate recovery system. When, the projects, are completed, the CCPs will be
fully sequestered from the environment. Clear communication of these safeguards can be used to
address the citizen concerns about the use of CCPs in these projects.
Remediation projects that improve degraded landscapes and either restore original use or create new
use opportunities have been correlated with increases, in property value. Such positive effects have been
observed where the landfill closure was associated with redevelopment for recreational use (Farber,
1998). Housing data collected before and after the closure of a landfill facility suggest property values
increase by 10% once the facility is closed (Kinnaman, 2009). Further, because rural landfills are
frequently not easily visible, unless there is a, constant reminder of the landfill presence such as line -of-
sight from the right-of-way, closure usually mitigates the stigma of health risks (Bouvier et al., 2000;
McClelland et al., 1990),
For these reasons, reclamation and development of the Colon and Brickhaven sites are not likely to
have measurable impact on housing values. However, redevelopment of the mine sites for commercial,
industrial or recreational uses has the potential to provide additional economic benefits to the area.
10

4. Environmental Justice Analysis
An environmental justice analysis has been conducted to analyze whether the Brickhaven and Colon
mine projects would result in disproportionately high and adverse impacts on minority, low income,
and/or sensitive populations. As directed In Executive Order 12898, "Federal Actions to Address
Environmental Justice in Minority Populations and Low-income Populations" (59 FR 7629; February ,11,
1994), "each; Federal agency shall make achieving environmental justice part of its mission by identifying
and addressing, as appropriate, disproportionately high and adverse human health or environmental
effects of its programs, policies, and activities on minority populations and low-income populations,"
U.S. Census Bureau data were used to determine minority and low-income population percentages for
populations within a five-mile radius of the Brickhaven and Colon mines. The U.S. Census Bureau uses
geographic units, with the smallest census geographic unit being the Census Block, followed by Census
Block Groups, and Census Tracts, For this evaluation, census block groups within a five-mile radius of the
Brickhaven and Colon mines were evaluated. Data were gathered from the U.S. Census Bureau's 2010
Census and the 2009-2013 American Community Survey for all census block groups within the
evaluation area (U.S. Census Bureau 2010, 2013). Figures 6 and 7 show the Census Block Groups for the
Brickhaven and Colon facilities.
In order to identify minority and low-income populations, the following thresholds of'significance for
having, a potential environmental justice population were used:
For Race, any black group where 50 percent or more of the population is minority (defined as
individuals who identify themselves as American Indian or Alaskan Native, Asian, Native
Hawaiian or Other Pacific Islander, Black or African American, Hispanic, some other race, or two
or more races), is considered to have a potential environmental justice population.
For Race, any block group with a non-white population at least ten percentage points higher
than the county average would have a potential environmental justice population.
For Poverty Level, any block group where the percentage below poverty level is above the
county average by five percentage points or more is considered to have a potential
environmental justice population.
4.1 'MINORITY POPULATION ANALYSIS
Minorities comprise 29% of the population in Chatham County, 41% of the population in Lee County,
and 38% of the population of Wake County (two census block groups within a five mile radius of the
Brickhaven Mine are within Wake County), as shown on Table 7, Minorities comprise 35% of the
population of North Carolina.
Seventeen census, block groups are within a five-mile radius of the Colon mine and have minority
populations ranging from 9-90% (this includes three census block groups that are shared between the
two mines: Block Group 2, Census Tract 2016, Chatham County; Block Group 1, Census Tract 307.01, Lee
County; Block Group 2, Census Tract 307.01, Lee County). Fight of these census block groups meet the
definitions for having a potential environmental justice population based on minority population as
listed in Section 4.0 above.
41CFf

As shown in Figure 6, the census block groups with potential environmental justice populations
1comprising Census Tracts 301 through 304) are located within the south and southwest areas of the
five mile radius from the Colon Mine, and are located in or near the city of Sanford, North Carolina.
4.1.2 Brickhaven Mine
Eight census block groups are within a five-mile radius of the Brickhaven mine, and have minority
populations ranging from 15-34%. The census block groups surrounding the Brickhaven mine do not
meet the definitions for having a potential environmental justice population based on minority
population as listed as in Section 4.0 above, and are also below the 35% minority population of North
Carolina.
4.2 POVERTY LEVEL ANALYSIS
Table 8 presents data on low-income populations for the census block groups within a five-mile radius of
the Brickhaven and Colon facilities. In Chatham County, 12% of the population is below the poverty
level, in Lee County 19% of the population is below the poverty, level, and in Wake County 11% of the
population is below the poverty level. On the state level, 17% of the population of North Carolina is
below the poverty level.
For the seventeen census block groups that are within a five-mile radius of the Colon mine, the percent
of the population below the poverty level ranges from 1-49%. Eight census block groups meet the
definitions for having a potential environmental justice population based on poverty level as listed in
Section 4.0 above.
Seven of the eight Census block groups are the same census block groups that meet the definitions for
having a potential' environmental justice population based on minority population as listed in Section 4.1
above, and all eight census block groups are within Census Tracts 301 through 304, located within the
south and southwestern areas of the five-mile radius from the Colon Mine, and centered around the city
of Sanford, North Carolina, Table 9 provides a, summary of the potential environmental justice
communities by census block group in the vicinity of both mines.
4.2.2 Bricichaven Mine
For the eight census block groups within a five-mile radius of the Brickhaven mine, the percent of the
population below the poverty level ranges from 3-16%. The block groups surrounding the Brickhaven
mine do not meet the definitions for having a potential environmental justice, population based on
poverty level as listed as in Section 4.0 above, and are also below the 17% of the population of North
Carolina below the poverty level. This is also summarized on Table 9.
4.3 SENSITIVE RECEPTORS
Figures 8 and 9 show the locations of sensitive receptors within a five-mile radius of the Colon and
Brickhaven mines, respectively. Sensitive receptors include but are not limited to churches, schools,
daycare centers, medical facilities, parks, and recreational areas. These are areas where receptors may
be more susceptible to potential adverse human health impacts.
12

As can be seen in Figure 8, most sensitive receptors are located more than 2 miles away from the Colon
mine. A park, medical facility, school and pool were identified within approximately 2 miles of the m:line.
There are also several churches located less than 2 miles from the mine. Transportation of CCPs to the
Colon mine will be exclusively by rail, so sensitive receptor locations will not be affected by truck traffic.
For the Brickhaven mine, there are several churches identified between one and three miles from the
mine. A school was identified approximately three miles from the Brickhaven mine. Transportation of
CCPs to the Brickhaven mine will initially be by truck (as discussed In Section 2.2.1), and once a rail spur
is completed, CCPs will be delivered by rail. only two sensitive receptors (both churches) are located
along the trucking route to the Brickhaven mine site (shown on Figure 9). These are the same receptors
that would be located along the rail route. As noted earlier, these roads currently accommodate
significant truck traffic due to the industry already present in the area. This truck transportation will
cease once the rail spur is complete, so the impact to the community will be short-term.
The potential adverse environmental and human health impacts of the Brickhaven and Colon mine,
projects are summarized below, along with an analysis of the potential for disproportionately high and
adverse effects for the potential environmental justice population: Identified in Sections 4.1 and 4.2.
4.4,1 increased truck and rail traffic impacts
The projects are not expected to significantly impact residential areas at either the Brickhaven or Colon
mine sites. CCP will be delivered to the Colon mine by rail once the rail spur is complete. One train (110
cars) will deliver CCP approximately every three days. The addition of one train every three days will not
significantly increase freight traffic and associated noise or transportation-related impacts. Truck traffic
to the Brickhaven mine will follow the route that is currently used by other industrial facilities and that
avoids residential areas in the study area. Thus, there are no disproportionately high adverse impacts
expected for minority and low income populations. Potential transportation impacts related to traffic
are discussed in detail in Section 2. 1.1 and 2.2.1.
4.4.2 Potential releases of CCPs to the environment
in order to evaluate whether CCP could potentially be released into the environment at the Brickhaven
or Colon mines, the mechanisms for release of CCP to the environment (termed potential migration
pathways,), and the mechanisms by which human and environmental receptors could be exposed to
affected, media (termed potential exposure pathways) are identified.
Evaluation of Potential Migration, Pathways
The structural fill projects at the Colon and Brickhaven mines involve the use of a three-component liner
system to contain the CCPs, a leachate collection system, and a cover andstormwater management
system, as described in Section 1.0 Introduction. The Brickhaven and Colon projects are fully regulated
by DENR under CAMA14, including a rigorous permit application submission, review, and approval
process, under the DENR Division of Energy, Mineral and Land Resources. The project complies with
13 """k-RICH

CAMA14 and the cells and infrastructure represent the best available technology for completing the
project.
The principal potential migration pathways that are relevant to CCP structural fill at the Brickhaven and
Colon mine projects include:
Leaching, which can occur when precipitation infiltrates the fill material and constituents (i.e.,
metals/'inorganics) partition, from CCP to the infiltrating water, resulting in water within the
structural fill material that contains inorganics. The cover system that will be installed over the
structural fill once it has achieved final design grade will substantially mitigate infiltration of
storm water and, therefore, minimize leaching. However, precipitation events that occur while
the structural fill is being placed (i.e,, during construction) may result in accumulation of storm
water within the cells and subsequent leaching. However, infiltration of storm water during
construction will be minimized in accordance with a project storm water management plain.
Leachate that is generated through storm events during construction will be managed by a
leachate collection system,
01 Migration to groundwater, which involves the infiltration of leachate to the groundwater table,
will be an incomplete imi,gration pathway because the base finer is designed to prevent
migration of leachate to groundwater. In addition, the leachate collection system will prevent a
buildup of leachate volume on the base liner.
Erosion and subsequent transport to soil and surface water, which could occur if the CCP,
structural fill was left uncovered and storm events carried CCP- containing particles from the
project to downstream storm water receiving bodies, However, the cover that will be placed
over the structural fill will prevent direct contact of storm water with the CCP material (the
cover is designed to prevent storm water infiltration, to the structural fill and to shed storm
water and convey it away from the project).
The storm water management plan provided in the permit applications indicates that storm
water that does not contact structural fill will be diverted to storm water retention ponds, and a
perimeter ditch system will convey storm water runoff to sediment basins that then discharge to
existing drainage features. In addition, during construction, erosion and storm water
management controls, including interim soil covers, will be in place to prevent erosional
transport, Storm water that contacts structural fill during construction (i.e,, during placement of
fill) will be retained within the construction area and treated as leachate. Given the erosion and
sediment control measures that will be in place, coupled with the leachate collection and
treatment system, the potential for environmental impacts from these operations will be
minimal.
Wind erosion/dust migration refers to the partitioning of fine grained particles to the air due to
mechanical process or wind erosion. This migration pathway could occur through mechanical
process when CCP structural fill is moved from trucks and rail cars to the cells, graded, and
compacted. However, the project operations plan specifies dust controls that must be used
during construction to prevent migration of CCP structural fill material off of the project site.
Specifically, the plan requires that dust be controlled by using any one, or combination of the
following: watering; establishing vegetative cover; mulching; structural controls consisting of
wind breaks (Le., fencing and/or berms) and temporary coverings, (i.e., tarps); spray applied dust
suppressants ; soil stabilizers (i.e., soil cements); and modifying the active working area. In
addition, interim soil covers will be applied to open work surfaces during periods of construction
14 1111IR

inactivity. These measures will control dust and prevent migration of dust off -property during
construction. The final cover will isolate CCP structural fill, thereby rendering the wind erosion
migration pathway incomplete once construction is complete.
in summary, the only potential migration pathway that will exist for this project is leaching from the
CCPs; however, migration of leachate to groundwater will be an incomplete pathway due, to the design
of the project, which requires a three-component base liner and a leachate collection system.
Evaluation of Potential Exposure Pathways
Potential exposure pathways to the CCP structural fill could hypothetically include:
* Direct contact with structural fill;
* Inhalation of particulates released to the air from structural fill;
Direct contact with CCP- related, constituents migrating to groundwater or surface water, if
groundwater is used as source of drinking water and if surface water is used for recreational
purposes or supports an aquatic habitat; and/air
Direct contact with leachate collected via the leachate collection system.
Migration, pathways to air, groundwater, and surface, water are incomplete, as described above. The soil
cover will prevent direct contact with structural fill. Leachate is collected in a closed system and treated
and disposed of at a water treatment plant. Water discharged from the mines will be required to meet
water quality standards which will ensure protection of human health and the environment.
Based on this analysis, there are no complete exposure pathways to constituents associated with CCP
structural fill for human or environmental receptors. In addition, increased truck and rail traffic Impacts
are not expected as part of the Brickhaven and Colon mine projects. Therefore, the potential for
disproportionately high and adverse effects within a five-mile radius of the Brickhaven and Colon mines
and for the area around the city of Sanford in Lee County that has been identified as a potential
environmental justice population location has not been Identified.
W�
licli

The Colon and Brickhaven sites are former open-pit clay mines. The purpose of the structural fill
reclamation projects is to return, the land to beneficial re -use for industrial or other purposes, Without
these reclamation projects, the mines would continue to lay dormant, or other virgin fill would be
needed to accomplish the reclamation. Thus the project siting was driven by the existence of these
dormant mines. The projects will use CCPs from North Carolina power stations in an engineered
structural fill that meets all state requirements and is fully regulated by the state. The implementation
of the engineering requirements (installation of a three component liner system, the employment of the
leachate collection system, and the installation of the cover system) will effectively sequester the CCPs
from the surrounding environment. Transportation of CCPs to the project sites will be via rail; initially
CCP transportation to the Brickhaven mine will be via truck along specified truck routes, but once the
rail spur is completed, CCPs will be delivered by rail. The rail traffic will cease upon completion of each
projlect.
A detailed demographic and geospatial analysis relevant to socloeconomics and environmental justice
was conducted for the Colon and Brickhaven mine structural, fill sites to assess potentially adverse
Impacts and identify sensitive receptors. A. qualitative evaluation of these potential impacts has been
conducted. This study examined the socioeconomic factors present in a five-mile radius surrounding the
Colon and Brickhaven mine sites, including the surrounding areas, transportation, existing disamenities,
population and demographics, and employment and income. To assess the potential economic impacts,
market and non-market benefits of the reclamation projects were identified and adverse impacts on
property values were analyzed based on available literature and similar studies, An environmental
justice analysis was prepared to analyze whether the f3rickhaven and Colon mine projects would result
in disproportionately high and adverse impacts on minority, low income, and sensitive populations.
Based on this analysis, the Colon site has eight census block groups that meet the definition for having a
potential, environmental justice population based on minority populations, and eight census block
groups that meet the definition of having a potential environmental justice population based on poverty
level. Seven of the eight census block groups, meet the definition for having a potential environmental
justice population for minority population and poverty level thresholds of significance—All eight census
block groups are centered around the city of Sanford, NC which is south/southwest of the mine site and
CCP transportation corridors. Most sensitive receptors are located over two miles away from the Colon
mine. Due to the temporary timeframe for CCP transport, limited sensitive receptors in the immediate
vicinity, of the site, and existing disamenities in the study area, the Colon mine structural fill project is
not expected to have significant adverse impacts on environmental justice populations or property
values.
The Brickhaven mine study area does not have any census blocks that meet the definitions for having
environmental justice populations based on minority populations or poverty level. The transportation of
CCPs to the Brickhaven site by truck initially will avoid residential areas and travel along a road corridor
that is already utilized by other industries in the area. As both the truck and rail transport of CCP is
temporary, the Brickhaven mine structural fill project is not expected to have notable adverse impacts
on property values,
Further, because the structural fill reclamation projects will remedy existing disamenities associated
with the inactive mines, rehabilitate currently unusable land to allow for future economic development
16 1
DRICH

use, and add local jobs and spending associated with construction, the Brickhaven and Colon projects
have the potential to provide substantial economic benefits to Chatham and Lee counties,
17 1-11

P § 0 ff IMM =
Bouvier, RA, JM Halstead, KS Conway, AB Manalo. 2000. The Effect of Landfills on Rural Residential
Property Values: Some Empirical Evidence, Journal of Regional Analysis and Policy, 30(2):23-37,
Farber, S. 1998. Undesirable facilities and property values: a summary of empirical studies. Ecological
Economics, 24:1-14.
Federal Railroad Administration. 2015. Rail Network Development, Maps — Geographic Information
System, U.S. Department of Transportation. Web. 4 June 2015, htto://frap-is.fra.dot.Rov/GISFRASafetyI
Headwaters Economics. 2014. The Economic Impacts of Restoration: Custer and Lemhl Counties, Idaho.
Headwaters Economics, Bozeman, MT, Web. 77 May 2015, htIRiLhea,d,y'aterseconon,iics.org/wphw/wq-
content/uoloads/ldaho Restoration Renort.pdf
Kinnarnan, TC. 2009. Landfill Closure and Housing Values. Contemporary Economic Policy, 27(3)-1380-
389,
Kuter, N. 2013. Reclamation of Degraded Landscapes due to Opencast Mining, Advances in Landscape
Architecture, Dr. M. OzVavuz (Ed.), ISBN: 978-953-1167-2, InTech, DOI: 10.5772/557916.
List, G, R Foyle, H Canipe, J Cameron, E Stromberg, 2008. Statewide Logistics Plan for North Carolina,
Final Report. North Carolina Office of State Budget and Management,
McClelland, G, W Schulze, B Hurd. 1,990. The Effect of Risk Beliefs on Property Values: A Case Study of a
Hazardous Waste Site. Risk Analysis, 10(4);485-497.
Michaud, LH and D Bjork. 1995. The Feasibility of Constructing Solid Waste Landfills as a Reclamation
Method for Abandoned Mine Lands, Proceedings of the Conference on Mining and the Environment,
Sudbury, Ontario, May 28— June 1, 1995; pp. 227-237.
Minerals Education Coalition (MEQ. Reclamation Stories - Industrial. Minerals Education Coalition, n.d.
Web. 28 May 2015.
Ready, R. 2010, Do Landfills Always Depress Nearby Property Values? Journal of Real Estate Research,
32(3):371-339.
Talberth,J, R Conn, R Berrens, M McKee. 2001. A Framework for Assessing the Economic Benefits of
Mine Reclarnation. Ecology and Law Institute and Amigos, Bravos, 2001.
U.S. Census Bureau, 2010. American Fact Finder. 2010 Census Summary File 1. Table P9 Hispanic or
Latino, and not Hispanic or Latino by Race. Total Population, Accessed
at. htt,pj/f a ctf in de, r. ce ns us. RovIf aces/ n avTLOLpAg es/search results. xht m I? ref re,shmt#no ne
U.S. Census Bureau. 2013. Table:B17021 — Poverty Status of Individuals in the Past 12 Months, by Living
Arrangements. 2009-2013 American Community Survey 5-Year Estimates" Accessed
at: hllR afgs ,Lfpctfinder,c,gnAus.gov/faces/nav/isf/
_p jsearchresults.xhtmi?refresh= t#none.
18 11-11k 6'7�1�L"
'11CH

U.S. Census Bureau. 2013. American Fact Finder, Table S1901. Income in the Past 12 Months (in 2013
Inflation-Adjusted Dollars).
U.S. Census Bureau. 2013. American Fact Finder. Table DP03: Selected Economic Characteristics.
U,S. Census Bureau, 2013. American Fact Finder. Table S0601: Selected Characteristics of the Total and
Native Populations in the United States.
19

ri
t A
to a-
ti
15
X ,

Pdg. 1 .1, 1
T.We 2
E mplbV,.,.t St.Utk. f., Ca.— Traits 1. th. Vkirdly .1 d. CWn Ml—
71% 14,R%
1,6% SA%
L2% G G%
5.4%
67% 7.a% ia131F
2.7% $Z% 41155 35% a,E3S
13% 00% 8.016
kAt FY & AAJ I qllG H, INCL,
T.Ha Trans e1, W6=15
N. —nh
COMM TMM Xn.W., Can— TI.M 302, Lam n,.ST
T", WComllm
L,9WM�NTFA7
61., dl. ranee, and real cetavnand a,Y�31
2 In
L--Cft-MV-ft-n�,h-
CA—tv, W. nh
"- ty. �fl
��V� N. h"
VW
". �—twl lm�fi
C—tv. U.4h
Ndh U M..
�.Il-
�Ma.
Q.1ka
CAwl.
Cdr
Ww�-
P,
C-11-
uw�.
5
1
PnR!��d
55.�
im
919%
4A%
3i,g%
p 5y.
WA
U—N,"d
,
7-5%
MGM
c
J-m
A,
10.10%
412%
&.2%
4,5%
S.. .L
�: U Cens us Bui em U, X17914 2013 5 -wear Amc'rlcjl n Gomm u "hy sn' y
25'1: 4
I.545
zmo
1.7"
xAa
YIM
2,17D
1,620
11,640
NqhArq and hwhj, and
1..514
t.5%
co%
1.1%
C.5%
5155c
24%
611A
G.3%
11..5%
4.Ex
M2�--
21i'm
519%
2.90%
1.4%
73%
I(i-9%
2312%
AAA
2.3.4%
65%
21.9%
29.6%
2-M
A %
21.6%
71% 14,R%
1,6% SA%
L2% G G%
5.4%
67% 7.a% ia131F
2.7% $Z% 41155 35% a,E3S
13% 00% 8.016
kAt FY & AAJ I qllG H, INCL,
T.Ha Trans e1, W6=15
61., dl. ranee, and real cetavnand a,Y�31
2 In
ImA
7.4%
FrOPWOMAII, MmVlk, and mana;
......
"WAIsmil—d —1C rnanw—t eC.Ib.
I'sAefal
7-S%
im
919%
4A%
&.2%
4,5%
S.. .L
�: U Cens us Bui em U, X17914 2013 5 -wear Amc'rlcjl n Gomm u "hy sn' y
71% 14,R%
1,6% SA%
L2% G G%
5.4%
67% 7.a% ia131F
2.7% $Z% 41155 35% a,E3S
13% 00% 8.016
kAt FY & AAJ I qllG H, INCL,
T.Ha Trans e1, W6=15

Page 1 Uf I
Table A
JAI 5140INU fol CengudTrtletl In IfieVidirrity of tht Colon Mine
HALEY & AWRICH INC,
3 More 3 Cohn Inonme Com ua Track.x& U512015
Gnaws
UeCounty,
Cersw7rac%206
COMISUSTMILIJU2.02
npusTratI CensaTranSID3 CenmaTraM 306XI
CcnmjsTriict3OM
CensusTbU307.132
Hoosehold Income
North
ChalhannCounlry�
Lee County, Norit
Lt County, Nord Lee C(H.MVyrI I.ReCounty.Nurth
Loe County, North
tw. County, North
c4m1Ifl8
North Caraldrum
carollma
County, North
CAI
Camba
Camilab
Caroflniz
CaI
CarWho
tal Number of ljou�bIoUs
121�2!04
2.196
2,315
LIM
SIB?
1.2r.1
2846
Ile than $10,000
17,7%
1 � 14%
: 71VA
0AS
10,4%
27.9%
1.5%,
7.5%
7-6%
20,000 %m 5.14,999
jr.1%
M%
U%
419%
14 139%
13,0%
0,'914
17%
5.756
$15,00, 1 o 524,995
15:7%
11-514
15,6%
3-n,
M3%
20.9%
559%
M3%
17%
W
j$25,D tP $ �4,E`99
%
1218*6
18,3%
3118%
16.21%
17.2%
IL9%
915%
1s.9%
DO I a y49,999
$550,000
14.S-A
13.1%
11.0%
15.9%
0.2%
4416
1215%
37.6%
019%
117.4%
�35.8
1. $74,!�5,3
M 6'A
10.0%
213%
7515%,
133%
6.0%
234%
23-8%
$75,000 to $99,999
jun
10.27%
5.29%
ls.a%
13.0%
9.51%
17.2%
10.8%
15.6%
1$200,ow IQ $349„999
9L59%
141%
9.n9%
19A56
4,5rS
2149%
702%
0.616
7,6%
$1 "O'OUG to $139.999
v%
511UI of morn
1.
3.0%
:1 .796 1111
4.6%
O,ON
U%
2.65%
IVA
3.05%
M.d la n lmecrnc jdpvN ")
48,82.9
48.757
137.9.11
66,921
29,366
19,279
24,457
46,413
44,593
SII U.5. Cc n:s us Ru uep u, 20119
-Ml 3 $-Yea r
Arm ricari Ca mmun
Ity 5urve y
HALEY & AWRICH INC,
3 More 3 Cohn Inonme Com ua Track.x& U512015

Table 4
Demographic Stitlsttm Far C&nsus Tracks in the Vicinity of tire Br➢clhaven I'Alne
Chatham
Demographics County,
North,
Cormus Tract 2.06
Chatham County,
North, Uralln a
ITOW
9S.2%
JAGE
72,3%
6n'dLr 5 years
V%
4D%
5 to 17 years
15.5%
1.4.9%
�9.4%
18 to 24 years
6.2%
lmrA
25, to 44 year$
23,0% p28.2%
As to 54 years
14,5% 1173%
55 to 64 years
14.9% 115,4%
65 to 74 year$
12.1% 174%
75 years and over
9.2% 18,4%
Modlan ap (years)
44.8 14AS
RACE AND HISPANIC OR LATINO ORIGIN
174%
Due rare
98 z's 19519%
white
179.07£ 478.756
Weak or AfrIlcan Amorican
123.0% 46,9%
Amorlmn Ind1sor and Alaska Native
10.4% 0.0%
Asian
ri 4% 10.1%
NatIve iiawauanand, OtherPadfic Islander
a0%
0.0%
Some other raw
4.4%
3.1%
11.1%
Twwournnorerace5
I'M
112.8%
lHispanictsr Latin* onflin (of any race)
15,2%
lWhilte alone, not Hispanlc or Latino
7x,4% I78.06
source; U 5. cemus Bureau, 205-2011 5-YcarAMrJ,,an C0mnjUnhy5UTV,,yr
Pogo I a] I
U nstj g Tract 207.02 Ce nsw Ttact 30.x7.101 Unsus Tract IOU2 Census Tract MW Census Tract 534,13
Chatham County, Lee County, North Lee County. North wake County, North Wake County, North
North Carolina Carolina Carolina car olln 19 CarsAlrus
3,864
10.2%
7.9%
45.0
4'.5BB
7.3M
1312%
12.6%
23.1%
16.0%
12.2%
9,5%
6A%
41.7
198,276
9S.2%
ms%
72,3%
23.4%
24,0%
104%
1,8Ya
5.2%
22,2%
34.2
381
lmrA
01014
9417%
4.0%
91 856
L5%
9.1%
9.9%
876.8%
65,2%
4,04 6,973 S'2M
(510%
9.5%
5.6%
115.1%
23.4%
24,0%
8,5%
3.6%
5.2%
22,2%
34.2
381
14,075
97'.M
9417%
17.4%
10.7%
8-0%
6.5%
519%
'5.4'
8,991
0.7%
2'.195
42A
34.2
381
97.0%
97'.M
9417%
72.5%
05.2%
18,21%
9.1%
9.9%
14,4%
0.7%
0.4%
10.5%
110%
2.2%
174%
017%
1D.5%
3.0%
12.4%
1 5.9%
12.3%
13'%;
4A%
179.6%
75.3%
HALEY ek ALDRICH, INC.
TA, Wm 413rttkhnwen EicmographNCS.Cer 9u9 Trickn.xissx UVW01 6

Page 1 of I
Table 5
Employment Statistics for Census Tracts In the NAcliilty of the Orickhaven Mine
HALEY IS ALDRICH, INC,
Table 5 Bdckhaven.EmpPoymontCoinsus Trodks.xis 61522015
CeTISLIS Tfad
: Census Tract
Census Tract
Census7ract
Census Tract
Census' Tract 206
Chatham Ca u"
207.02 Chatham: 307. 01 Lee
307.02 Lee
532.07 Wake
534,.13 Wake
Employment
Chatham County,
Mirth Carol Ina
North Carolina
County, Nnrth,
County, North
County, North Cauntyu North
County, North
Carolina
Carolina
Carolina
Carolina
Carolina
EMPLOYMENT STATUS
58.2%
59.5 %
9 V. -69.3%
64-16%
unemployed
5.7%
5-1%
Szx.
7.(W.
�7.5%
lTG%
5.495
i[NDUSTRY
civilian employed population 16 years
28,895
2'r'40
2,170
�11819
31349
Z364
and over
Agriculture, forestry, fishingand
2.4%
1.99;
6.2%
2.419
6.2%
0.591.
1.79E
hunting,„ and mining
Construction
7.7%
1113%
4.195
5,4%
7.396
6396
t
3,69;
manufacturing
13.794
13.4%
10,146
24.9;%�
79,6%
13,�7t
17496
Wholesale trade
2594
12%
4,7%
5,414
4.036
4.0%
Q%
Retail trade
5.5%,
8.7%
61%
1.1.5%
8:2%
�811%
Transportation and warehousing,
l
and utilities
5,1%,
2.3%
4.0%
1.6%
1.8y.
2.9%
GA%
Information
1-1%
21%
100%
0.6%
a-OF.
S.D%
'17%
Finance and insurance, and real
estate and renta I and leasing
scientific, and
1Professional,
mranagament, and adminrstrative and
11.796
1633E
18. 744. 7y.
6.0%
9.4%
14.2%
12.69E
waste management services
Esdoucc and healt h care
aalllsnot tservices,
and
26.196
27.2%
137%
21..6%
14,4%
22.534
16.2%
Arts, entiqlairiment, and Tecreaflicm,
79%
G W.
6.4%
7.1%
33%1.
S. S T.
6 , 71y
and arcommodatlon and food services
Other services, tycept public
administration
5,9%
7,0%
10-4%
3 5 a
4.,6V.
4.91%
4.5%
I Public ttdm i m i tratiar
3'8%
4.546
13%
51211.
5.7%
63%
3.8%
Sourcc U.S, Census Bureau, 2009-2013 5-Year American Community
Survey
HALEY IS ALDRICH, INC,
Table 5 Bdckhaven.EmpPoymontCoinsus Trodks.xis 61522015

P0911 1 al I
Table 6
111EUMe SWIMIZ3 fOECEH5135 Tracts IA the "Chlity Oft he 94,411AVOn Mine
HALEY & ALDRiCH, INC.
TMAL 6 BrIrJthnven.Inmma.CLnmgs Trvck.mlsx W14015
ChatharnCounty, CermusTIW206
Census' Tract 207.12
Certsus Troct 307.131
Census Tract
Census Tract 532,07' CensusTrM0534.13
Northcarolwa
Chatham county,
Chatham county,
Leg County, North
3017,02, Loa
wake County, worth
Wake Courav, North
Household Income
North Carolina
North carouria
Carolina
County, North
Carolina
Catalina
t4ii
1,689
Less than S 10,000
518%
61.4%
�7,7%
73%
7.6",
1�7%
11.5%
1$10.,000 to $14,909
5.0%
.6%
5A%
3.7%
6�20M
0.7%
IS 15,,000 to 524, 999
M
11'5%
5-790
1633E
930301
1.5%
1$ 25,000 to S34,0,0
10,4%
IZS%
ILAIX
B.5%
10AM
2,4%
[s 35,000 to $49,991
12.2%
131%
12.2%
274%
10.90%
11.6%
IS SO,rxio to $74,050
2018%
18,93
23.9%
11.4119E
17,5%
1$75,WD to $99,995
11-7SC
10.2%
1018%
M 610%
16.06
MW
J$ 10%0W to $14 9,999
13.7%
241%
13-7%
816% 1111.
7413%
3311%
24.6%
lsiso'amto 5199 '999
5,1% 1111..
2.3%
1.9%
2.2%
2,2 D%
8.2%
111.5%
2uoxw or more
5.4%
3.11%
5.9%
123%
median 41 come WcManl
57,091
48,257
55,975
46,45:3
44.598
1111 1111...
92,535
Soufce: U. Census Hurea u, 20305.2013 5 -Year American CommuNty
Wrvey
HALEY & ALDRiCH, INC.
TMAL 6 BrIrJthnven.Inmma.CLnmgs Trvck.mlsx W14015

Page I of 1
Table 7
Race and 6 f thnicfty Data for Census Block Groups Within a S-Mile Radfu 5 of the StIckhaven amd Colon Mines
2010 Census Race and Eth n [city Data 10)
Blacl% or Total
2010 Percent African Percent Hispanic Percent Percent Minority
Census Block Groups Total White j%j American (%) or Latlno N other N 1%)
��North CaroMa 9,5 6'223'9951 65-6 2,019,854 21% 800,120 81% 1 491,514 5% F--3v-A-1
kftaOiarnCounly, North Carolina 45,1&9 7114, 8,272 13-A 8,228 13% 1,820 3% 29%
Lee County,Nonh Carolina 34,32I 59% 11,369 zo-A 10,576 12% f 1,6W 3% 41%
Wake County, North carohna 5 60,536 1 6296 1 182.793 20% 87.922 10% 69,742 8%
nice]( Gm ups Within a Five Mile Bantus of Bridth aven Facility
glack Group 2, Cerum Tract 206� 1,436 67% 580 21% 102 5% 38 2% P%
Chatham County, North I - arol ena 2,156 fl
Block Group 2, Census Tr I'm 1,125 85% 121 9116 49 4% 28 Z% 15%
chatharnCounty, North Carolina I
Wad Group 3, Census Trace 207.02, 2,010 664 661.16 242 2414 so 8% 24 2%
:Chatham CountV, Northcarohnn I a-7-1
�
!flock Group 1, Census Tract 307.01, IIE25 1,421 78% Ise 9% zo 5 11% n 2% 22%
Lee County, North C.WoNnit
Illock 2, Census Tract 307.01,
ter C '�rou' North Carolina 2,919 1,SS4 67% 596 20% 305 10% 81 a,% 33%
'I.ek -urrhyp 1, Census Ttact 3107.102, I'692 1,589 84% IOU SIA 162 S% 32 Z1% 16%
Lee County, North Carolina
Block Group 1. Census Tract 532.07. 2,241 =9 7616 26,0 12% 221 10% 51 2% 24%
awake County, North Carolina
�Slock Group 2, Census 7retA 524-I3. 1,2B4 3092 85% 5VA 5.3 4% 15%
ake County, North Carotna
lilack -Grcrups W16iR i Five MIM Radius of Colon Facility
r I
C:k Gra up 2, Ce nsus Tract 206, 21156 27% 102 5% 38 2% 331%
iatharn County, North Carolina 1� �"- 1, -;-4
lock Group 1, Census Tract 901.01,
e County, North Carolina 974 225 21% 176 IRV, 12 3% 44%
r1e
IMock Group 2, Census Tract 301.01, 1,321 1 604 461A 33.9 24% 364 28% 24 3% 54%
tee County, North Carolina
�IQck Group 3, Census IFaa KL01' 2,143 1,402 65% 349 16% 299, 14116 4% 1 85
Ire County, North Carolina
Re Group, 1, Cersus Tulsa N)I-M, 1,673 11528 75 4% 44 3% 26 2%
County, North Canolina
�ieck Group 2, Cansuis Tract M1.02, 1,841[ 1,487 811% 1,40 8% 163 9% 51 3"6
e County, North. Carolina NNN
�tock Group 1, Census Tract 302, Lee
ouwny, North Carolina so 3010 315% 219 25% 322 37% 19 256 65%
hock Group 2, Census Tract 302, Lee 1,474 270 18% 4911 33% 690 46% 34 2% 82%
ounty, North Carolina
Tock Group 3 Census Tract 362, 1,312 164 13% 357 27%, 761 58% go 2% 98%
County, North
Group 1, Census Tract 303, Lee 1,373 134 10% 11053 77% L57 11% 29 2% 9095
County, North Carolina
Block Group 2, Census Tra or 303, Lee
Purity, North Carolina 1,:64 23D 12% 1,649 SW S46 29% 39 2% 91%
ock Group 1, Census Ira ct 304.01,
1,537 S79 38% 476 31% 431 28% 5,1 3% 62%
�Ie County, North Carolina
lock Group 2, Census Tract 304,01,
664 45% 26 2
1,487 542 36% 255 17% %
rLee Coiuity� North Carolina -"%
�lock Group 2, Census Tract 306-01, 1,427 1,145 80116 262 11% 76 5114 114 31A 20%
. County, North Carvkna
rlock Group 1, Census Tract 307.01, 1,1315 1,421 78'6 Iss 9% 205 11% 31 2V.
e County' North CaroNna L�!-
.re
Group 2. Census Tract 307.CL 2,936 1,954 67% 595 20% 305 I1V16 at 3% L�-%
G
tu County, North Carc4nz
lock Group 1, Cemus Tract 307.02, 1.802 1,568 84% 100 5% 162 916 32 2.
e C.,."W, - 6 L
Ncrth Carolina
LL
Notes:
Sold denotes potential emkiannnentailu5tice area, m horitV populationswere Identidled where ttih,en
(1) the minority poputafion exceeds 50 percent; or
(2) the minority population percentage of 1hc affected area 1, ten Percent higher than the munerity popwriation percertagt county atmrage
(a) The racial and ethnic categories provided are further deirinad as: Whitt jWhita alone, not Hispanic or Latino): Black (clack or Afrlcarr
Amerlcan, alone, not Hispanic or Latina); Other (American indion and Alaska INatlwe alone, not HISPIMIC or Lalino'; Asian, not Hispanic or Latino;
Nattwe Hawafian and Other Patific Islander alone, not H15pa nlc or il., l in o,, some o0wr race atone, nut Hispanic or
Latino; I wo or more races, not Hispanic or Latlno)� Hispanic. [Mspamc or Lafina; Persons of Hispanic origin may he nF any race).
Sour": u.s, census Bureau, Census 2010.
HALEY & ALDRTC H, INC.
Table I Race TaWe.xIsx 16411r2 0 15

Page, 1 of I
Table 8
Poverty Data for Census Block Groups Within a 5-Mile Radius of the BrickhaVft and Colon Mines
HALEY 1S ALDRICH,, INC.
Table 8 Poverty Tabla.Asx 6ib/2015
Below Poverty
At or Above
Census Brock Groups
Total;
Level Percent 1%)
Poverty Level
Percent (1%)
Nquth Carolina
9,396,989
...... .. .....
1,643,389
17VP
7,753,600
1311
Chatham County, North Carolina
64,021
7,920
12%
SGJOI
88%
Lee County, North Carolina
57,,587
1.0,863
199'
46,724
81%
Wake,Coun 11Y, North Carolina
906,662
99,679
11%
806,983
893x,
Block Groups W Ithin a Five
M fle, Radius of Brickh avan Facility
6'1'o' E'k,Group 2, s Tract 205, Chatham' County, North Carolina
2,643
118
4%.
2,525
969,
Mock Group 2, Census Tract 207.02, Chatham County, North Carolina
1,246
164
13%
1,092
8 TA
Block Group 3, Census Tra ct 207 02, Chatham County, North Ca rol Ina
974
73
7%
9101
93%
Block Group 1, Census Tract 307,01, Lee, County, North Carolina
1,888
237
13%
1,651
87%
Block Group 2, Census Tract 307.01, Lee County, North Carolina
2,516
302
12y,
2,214
88%
Block Group 1, Census Tract 307,02, Lee County, North Carolina
1,952
305
1G%
1,,647
84%
IBIoEk Group 1, Census Tract 532-07, Wake County, North Carafina
2,370
320
243'
21,050
8010
]Block Group 2, Census Tract 53413, Wake County, North Carolina
1,141
33
3%
1,111
97%
Block Groups Within a rive mile Radius of Colon facility
Block G'ro"'tj p '2',-Censu"s _Tr'a"c t'2" 0 6',"C"h"a' t-ha" m'­C"'ot"A'n't'y'', -No r't"h' Ciro' lini,
. . ..
...... ......... 1113'
41% ......... ..
.... .... 2 525 ..... . .. ....
9530
"Block Group 1, Census Tract 301.01, Lee County, North Carolina
794
206
26%
588
74%
(Block Group 2, Census Tract 301.01, Lee County, North Carolina
1,185
221
19%
965
81'36
Black Group 3, Census Tract 301.01, Lee County, North Carolina
2,099
375
1830
1,724
12%
Block Group 1,, Census Tract 3101.02, Lee County, North Carolina
1,652
66
4%
1,586
9696
Block Group 2, Census Tract 301,112, Lee County, North Carolina
2,994
21
1%
1,973
99,96
Block Group 1, Census Tract 302, Lee County, North Carolina
737
330
48%
407
52%
Block Group 2, Census Tract 302, Lee County, North Carolina
1,777
433
24%
1,344
76%
Black Group 3, Census Tract 302, Lee County, North Carolina
1,416
409
29%
1,037
71%
Block Group 1, Census Tract 303, Lee County North Carolina
1,261
544
43%
717
57%
JBlock Group 2, Census Tract 303, Lee County, North Carolina
1,396
6•3
49%
713
51%
Group 1, Census Tract 304.01, Lee County, North Carolina
1,812
649
36%
1,163
64%
PBlock
ack Group 2, Census Tract 3C4.01, Lee County, North Carolina
I'187
525
44%
662
5676
]Block Group 2, Cennis, Tract 306.01, Lee County, North Carolina
1,617
79
5%
3,,538
95%
113lock Group 1, Census Tract 307.01, Lee County, North Carolina
1,888
237
13%;
1,651
87%
IBlock Group 2, Census Tract 307.01, Lee County, North Carolina
2,51G
302
IZ%
2,214
88%
Block Group 1, Census Tract 307-02, Lee County, North Carolina
11952
305
25%
1,547
844.
Nctesu
Bold denotes potential environmental Justice area. Viis analysts considers
any census block group with a percentage of Individuals
below poverty level that is above the percentage below poverty level is above the county average by five percentage
points or more to be low-income.
Source: U.S, Census Bureau, 2009-2019 American Community Survey 5-Year Estimates.
For populatlon for whom poverty status Is determined, Income In the past 12 months below poverty level or
at or above poverty level,
HALEY 1S ALDRICH,, INC.
Table 8 Poverty Tabla.Asx 6ib/2015

I M, I no 61
Table 9
Summary of Census Block Groups and Potential Environmental Justice Communities
Within, a S-Mlle Radius of the Brickhaven and Colon Facilities
Notes:
An "'X" denotes potential environmental justice area. See Tables 7 and 8 for more information on the identiflcation
of potential environmental justice communities based on minority status and/or income levels.
HALEY & ALDRICH, INC.
Table 9 Sumrnary.xlsx 6/5/2015;
Potential
Potential
Environmental
Environmental
Justice Community
Justice Community
State
County
Tract
Block Group
Based On Race
Ba,s'edI on Poverty
Block Groups Within a Five Mile Radius of BrIckhaven Facility
it
North Carolina
Chatham
20600
2
North Carolina
Chatham
20702
2
North Carolina
Chatham
20702
3
North Carolina
Lee
30701
1
North Carolina
Lee
30701
2
North Carolina
Lee
30702
1
North Carolina
Wake
53207
1
North Carolina
Wake
53413
2
Block Groups Within a Five Mile Radius of Colon Facility
North Carolina
Chatham
20600
2
North Carolina
Lee
30101
1
x
North Carolina
Lee
30101
2
it
North Carolina
Lee
30101
3
North Carolina
Lee
30102
1
North Carolina
Lee
30102
2
North Ca I rolina
Lee
30-200
1
Si
x
North Carolina
Lee
30200
2
x
x
North Carolina
Lee
30200
3
x I
x
North Carolina
i Lee
30300
1
x i
x
North Carolina
;Lee
30300
2
x p
x
North Carolina
Lee
3,0401
1
it
x
North Carolina
Lee
30401
2
x
x
North Carolina
Lee
30601
2
. . . . . . . . . . .
North Carolina
ILee
30701
.
1
. . ......................... ......
North Carolina
Lee
30701
2
North Carolina
Lee
30701
1
Notes:
An "'X" denotes potential environmental justice area. See Tables 7 and 8 for more information on the identiflcation
of potential environmental justice communities based on minority status and/or income levels.
HALEY & ALDRICH, INC.
Table 9 Sumrnary.xlsx 6/5/2015;

LEGEND
PROJECT ARC,
LEE COUNTY
0 BROWNFIELD SITE
HR is 3
"OWL—mosm -------- j
SCALE INMILES
Ha[ey & Aldrich. Inc,
COLON MINE AND BR [CKHAVEN MI NE R ECILAMAn ON P ROJECTS
H EE AND CRATHAM COUNTIES, NORTH CAROLINA
96"'6ti L
LOCATION OF BROWNFIELDS
WITHIN LEE COUNTY
JUNE 2m FIGURE 1
61512015

Figure 2A Abandoned General Shale Plant Site
t _
5 �
Figure 2B C &D Debris Remaining at the Site
Haley & Aldrich, Inc. 6/5/2015

Census"
r Tract ,
5 MILES 20i'.02
Census. • w.
Tract /
206 ' o
`1 F
/ i 1
� r �
_ ! Census
Tract ,
! -- 307,.01
1 1 MILE
I Census —_ /_. 1
Tract J
306.01
•'\ - - - 1.1.1!.+ � •
' I
Census '
Tract
Census 307,02 /
Tract
301162 /
Census /
Census; '� Traci: Tr
Census
1 Tract a
302' ct x-
4h30'1.01 ::�, ;1# „-:

Figure 4A Wood Products Manufacturing Plant
E7
Figure 4B Truck /Rail Traffic along Corinth Road
Haley & Aldrich, Inc. 61512015

U005 MILES
/ /
' - Census .�1P
Tract
/Census 207.02
Tract
< 206 t "' .-
f 1 MILE
If
< I Census _
h' 1 Tract_
' I 307.61,.
'%b
8�
` GensuS '
• 41*4 Tract 00,00 8i i 307.02 / f Census
Tract
8 � 710.02
Census
Tract
711.01
COLON MINE AND BRICKHAVEN MINE RECLAMATION PROJECTS
v LEGEND % �y RIIC+H LEE AND CHATHAM COUNTIES, NORTH CAROLINA
a' ® PROJECTAREA
® CENSUS TRACT CENSUS TRACTS WITHIN A 5 -MILE
d RADIUS OF THE BRICKHAVEN MINE
0 0.5 1 1.5
a
1 SCALE IN MILES JUNE 2015 FIGURE 5
w
O
Haley & Aldrich, Inc. 615!2015

Tract 020702_,
Block Group'3-
5 MILES
Wd
r f
op
Tract 020x6,_00
Block Group 2
/ Tract 030701
/ Block Group 1
4
0 / Tract 030701
I 1 MILE Block Group 2' L
{
/ or 1
_ 1
Tract 030601 '
Block•Group 2
j
A-1
4%b 40
Tract 030702
Block Group 9
Tract030101.
a \ : Block'Group 1 I
Tract 0301021 Tract.030401
c Block Group 1 Tract•030200 Block Group 2
Y � Blo'c`k Group 1 /
$' ♦ , Tract 030401 /
Block Group 1
w Tract 030101 /
" Tract030601 Block Group 2.Tract_030200
Block Group 1. BlocklGrnjp -2
g
Tract '03010'2 Tr5cV030200
Block Group 2 Block i Group 3
t
Tr c 030101 Tract"030300• I
act 030602 rd +--'= Tract 030702
Block Grdu 3 Block ?Grow 12
8 ck Group 2,,,;.' "' bP' P -, — — ! -- Block Group'.
Tract030300
Tract 030102 lc�6 • Tract .'030
BlockcGroup3l: r :
� Block Group 3 Bfock Group:2 –
Tract 030401 -
f0 Tract 030402 Tract 030702
Tract 030602 Block Group 1 Tract 030402 B1oGis �tfL7UA 3 Block Group 3
a
o LEGEND
a
® PROJECTAREA
32 ® CENSUS TRACT O r j�� 'CH LEE AN MINE AND COUNTIES, E , MINE RECLAMATION PROJECTS
°o � Lj��r LEE AND CHATHAM COl1N•I'IES, NORTH CAROLINA
CENSUS BLOCK GROUP
o'
ENVIRONMENTAL. JUSTICE GROUP
s POVERTY CENSUS BLOCK GROUPS WITHIN A
a 5 -MILE RADIUS OF THE COLON MINE
e RACE 0 0.5 1 1.5
w
J SCALE IN MILES POVERTY AND RACE
LL JUNE 2015 FIGURE 6
w
Haley & Aldrich, Inc. 6/5/2015

Tract 020800
Block Group 3
i
5 MILES
Tract 053413
Tract 020702
\
Block.Group 3
�
_
y"--�-
4f
f
j 0
`���
Tract 020fi00
Block4Group 2
Y
Tract 05320'
Block Group 1 ,
Tract 030701
I, Tract 0207€12
'
Block Group 1
Block Group 2
1 M ILE
�
t
a
'
`4
i!
Tract 030,701
Block Group 2
r 4
O
y1
`
4
�♦
Tract 030702
♦
Block Group 1
/
do
Tract 071002
n
Block Group 1
-
�
m
I
r
a
omw
m
4
COLON MINE AND BRICKHAVEN MINE RECLAMATION PROJECTS
LEE AND CHATHAM COUNTIES, NORTH CAROLINA
u
LEGEND
® PROJECTAREA
CENSUS TRACT
CENSUS BLOCK GROUPS WITHIN A
s
5 -MILE RADIUS OF THE
M CENSUS BLOCK GROUP
0.5 1 1.5
BRICKHAVEN MINE
o
N
SCALE IN MILES
JUNE 2615 FIGURE 7
o
-
Haley & Aldrich, Inc.
6/512015

5 MILES
' If,
I MILE
00
■
F.
law,
f
j U, 00
0
4l
Me '(4)
"
4,
77,
LEGEND
PROJECT AREA
RECEPTOR TYPE
CEMETERY
2
in
a, CHURCH
19 LIBRARY
8 41,
MEDICAL FACILITIES
0
PARK
IS
POOL
7:
SCHOOL
UNIVERISTY
a.
Haley
& Alddch, Inc.
COLON MINE AND BRICKHAVEN MINE RECLAMATION PROJECTS
H AND CHATHAM COUNTIES, NORTH CAROLINA
10H SENSITIVE RECEPTORS WITHIN
A 5-MILE RADIUS OF THE COLON MINE
0 o's 1 14
SCALE IN MILES JUNE2015 FIGURE 8
61,512015

LEGEND
RECEPTOR TYPE PROJECTAREA
mr CEMETERY TRUCKROUTE
C14UPCH
LIBRARY
9
MEDICAL FACILITIES
5 M1ILES
CCLC,N MINE AND SPICKHAVEN MINE RECLAMATION PROJECTS
LEE AND CHATHAM COUNTIES, NORTH CAROLINA
icii
0,
PARK
olp
0
POOL
SENSITIVE RECEPTORS WITHIN
A 5-MILE RADIUS OF THE
0
00
BRICKHAVEN MINE
UINWERISTY
0 as 1 1.5
SCALE IN MILES
JUNE 2016 FIGURE 9
Haley
Sk
61512015
IN,
y.
imA
I MILE
%4
c9
5!
dry
0010
4i
1
%*
00
LEGEND
RECEPTOR TYPE PROJECTAREA
mr CEMETERY TRUCKROUTE
C14UPCH
LIBRARY
9
MEDICAL FACILITIES
0-11I R�
CCLC,N MINE AND SPICKHAVEN MINE RECLAMATION PROJECTS
LEE AND CHATHAM COUNTIES, NORTH CAROLINA
icii
0,
PARK
0
POOL
SENSITIVE RECEPTORS WITHIN
A 5-MILE RADIUS OF THE
0
SCHOOL
BRICKHAVEN MINE
UINWERISTY
0 as 1 1.5
SCALE IN MILES
JUNE 2016 FIGURE 9
Haley
& AWrich, Inc,
61512015

(OMPR I. I I E I IS IV F 51A I �. FU, I LP� A t,l '
Haley & Alclnch, Inc
Figure 10
North Carolina's Rail System
615/2015

i
R
J r
,NEW FALL
I�
P NP
Jf
/ f
MERRY
OAKS 7 BON,SAL
i
MONCURE
P
BRICKFIAVEN
v
C
MINE q
s.r
n
CORINTH
vo
.s COHEN
COLON
COLON
BRI KHAVEN
MINE
l:
CLIMNOCK
6
LEI RICK
lFACaAN" _
s
POOLS
COLON
i
EP I C3ii
I
R
MONROE
f""1'l RK " .
pfiP i�p n�9v M1
.I
. per
G
WONS.e PO R&
�
I
j
"
COLON MINE ANDDRICKH'A NMAINE:RECE.Al�tA- MONPRu JEM
LEE AND CHATHAM CCIUNTIES, NORTH CAROUNA
LEGEND
MCOLON MINE
RAILROADS AND STATIONS IN THE
a RICICHAVE I MINE
VICINITY OF THE COLON AND
1151 STATION
i3 1.5 3
I I I�`aKI"'IAVEN MINES
RAILROAD
u
SCALE IN MILES
JUNE2015 FIGURE
Haley & Aldrich„ Inc,
61512015

>
i)
I
5
C
Existing Rail
Q
r
0
r
S)
o
o
Q �
Brickhaven Mine
<j U
Bridge 10
No Impact
Propose
Impact #12
Arch Culvert
90 LF 1
�C
D
u�
�o
Proposed Rail
Total I mpadsSariford and Bridchaven
\y Wet�ds(non- i sol ated) ��16ac \
Wetlands (i sol ated) 0.50 ac
Legend
Stream Proposed Grades
Linear Wetland Existing Unpaved Roads
Wetland Property Boundary
Stormwater Basin
SW Basin grickhav ickhaven Mine Permit # 19 -04
Culvert
Drawn by: RLNk4r-ah 302.15; CEC Proje
Data Source: C and HDR /
Chatham County,
North Carol i na
lJ
J
0
O
Moncure Holdings, LLC
Site delineated by others.
Verified: October 2014
- Updated Permit Map
p\\mNam i
Property Boundary
C°J
on
npact #13
.002 AC
101(
BRI CKHAVEN DATA
TOTAL PROJECT AREA +/- 332 ac
G
JURISDICTIONAL WATERS OF THE US
> Streams 43834 If
Wetlands (non - isolated) 3.98 ac
Wetlands (i sol ated) 0.50 ac
Open Water 0 ac
JURISDICTIONAL IMPACTS �
i
� � Streams 2,5401f _..I
Wetlands (non-isolated) 0.05 ac
J Wetlands(isolated) 0.50 ac
COpen Water n/a
AVOIDANCE/MINIMIZATION �,
Streams 2,2941f (47 %)
Wetlands (non - isolated) 3.93 ac (99 %)
Wetlands (isolated) 0 ac (0 %) r
Open Water n/a r
1,
MITIGATION
Streams
EEP(1:1) 2,5401f
WTI ands
Impact #2
0.04 AC
(4 small wetlands)
Impact #1
320 LF
IF
I
v
wtorti, I
I � /
Impact #6
/ 0.08 AC
Isolated
Impact #7
0.01 AC
Isolated
Lear Ler
224 South Grove Street, Suite F
HenderSOnvi I I e, North Carolina 28792
r
Impact #9
0.10 AC
Isolated
\l 1
v Impact #10
0.01 AC
=J—
Impact #11
0.02 AC
Isolated
i
( 0 250 500 11000
Feet
Si to R an and I mpact M ap
Figure 1b

SANFORD DATA
1
F�stin8 48LF ._
Replamment SSOLF
TOTAL PROJECT AREA
+/- 425 ac
JURISDICTIONAL WATERS OF THE US
Streams
11,540 If
Wetlands
18.70 Be
Open Water
7.78 ac
JURISDICTIONAL IMPACTS
Existing Unpaved Road" 1
Streams
1,716 if
Wetlands
1.11 ac
Open Water
0 Be
AVOIDANCE/MINIMIZATION
Starmw
SW Bas Mina Basin
in Colon Mine Permit # 53 -05
Streams
9,824 If (85%)
Wetlands
17.59 Be (94 %)
Open Water
7.78 ac (100 %)
MITIGATION
Streams
EEP (I:1)
1,716 If
Wetlands
EEP (1:1)
1.10 Be
Sanford (Colon) Mine - Updated Permit Map
Total Impacts Sanford and Brickhaven
Streams 4,2561f
Wetlands (non - isolated) 1.16 ac
Wetlands (isolated) 0.50 ac
Legend
1
F�stin8 48LF ._
Replamment SSOLF
J
Stream
Proposed Grades
Kai
Unear Wetland
Proposed CSX Rail Spur
`
Wetland
Existing Unpaved Road" 1
OPan Water
I Property Boundary
®
Starmw
SW Bas Mina Basin
in Colon Mine Permit # 53 -05
�\
\
General Mine Information Map - Sheets 1-4 (02.15.14)
_ .
Culvert
Drawn by: RLN 06.02.15; CLt
Data Source: Char h and HDI
..Impact #24 `. , Birelurd Rd ---�
Existing 401-F
Replacement 50LF r
Net Impact 10 LF _
�.- Impact i r - Impact #23
48LF
-�� Replacement 50LF — -
Net Impact 2 LF
VOW
li rtl M
% 1�\
1
F�stin8 48LF ._
Replamment SSOLF
J
2 LF
`
r
Use Existing crossing
v, No Impact
0 250 500 1,000
=511111101111" I Feet
Lee County,
uearWacer Site Plan and Impact Map
North Carolina 224 South Grove Street, Suite F Figure la
Hendersonville, North Carolina 28792