Professional Profile Paul A. Eisen, CCM Principal Scientist

Technical Specialties: facility in Riverton, NJ. The facility operated over 40 Expert witness in air quality, atmospheric dispersion modeling, emission sources associated with its production of metal meteorology, and environmental regulatory compliance. Air powders for automobile engine, large appliance and related quality impact and risk assessment. Environmental management durable metal goods. A number of privately owned boats, services. Clean Air Act (PSD/NSR) permitting and applicability docked in five marinas approximately one mile north of the reviews. Environmental Impact Statement preparation and review. facility filed suit to recover alleged damages consisting of brown discoloration and pitting of clear plastic windows on the Experience Summary: boats. The expert report discussed prevailing wind patterns, Over thirty-five years of experience: Principal other nearby sources of emissions, available historical Scientist/Meteorologist at Roux Associates; Chief Operating emissions data, ambient air quality monitoring data, and the Officer at Terranext, LLC, Senior Environmental Scientist at New York Power Authority, Regional Director at WAPORA, Inc., Air likelihood that Hoeganaes’ operations were substantially Quality Scientist at LIPA, Environmental Scientist at NOAA’s responsible for the observed damage. Environmental Research Laboratories, Meteorologist at National  Provided expert witness reports and testimony regarding the Weather Service major fire and chemical explosion that occurred in April 1995, Credentials: at Napp Technologies, Inc. on Main St. in Lodi, NJ. The fire M.S. Meteorology, Pennsylvania State University, 1972 killed four plant workers and burned for 35 hours. Area B.S. Meteorology, University of Massachusetts, 1970 residents raised a number of health-related questions, and Certified Consulting Meteorologist, American Meteorological expert witness services were required to evaluate the Society (Certificate #534) atmospheric dispersion of chemicals released from the fire and explosion. Atmospheric dispersion modeling was conducted Professional Affiliations: and studies by others were critiqued. Provided expert witness Air & Waste Management Association; depositions and testimony in proceedings to review the events Programming Committee, MASS Section and subsequent efforts to draw conclusions regarding public American Meteorological Society; exposure. NY Academy of Sciences (NYAS) Past Chairman, Atmospheric Sciences Section  Provided expert witness investigation and testimony under NY State Article X licensing hearings regarding a 300 MW simple Air Quality and Atmospheric Dispersion Modeling cycle combustion turbine facility proposed for Kings Park, New York. This testimony resulted from review of the Draft  Providing air quality and noise expert witness services to the NYSDEC Air Permit, permit and performance data for similar City of Brockton, MA regarding the proposed approval by the facilities (Stack Tests, CEMs Data Summaries, permit Mass DEP and State Siting Board of plans for proposed conditions, etc.), and atmospheric dispersion modeling of the construction of a 350 MW power plant in the Oak Hill proposed facility. Testimony was on critical issues related to Industrial Park section of Brockton, MA. The comments and facility siting, equipment selection, anticipated performance hearing testimony focused on methods used to assess air quality (i.e., air quality modeling and BACT/LAER analyses). The impact, and attainment of air quality standards. They also proposed simple cycle configuration was compared and addressed the risks associated with storage and use of ammonia contrasted with a combined cycle alternative. Calculations onsite. Finally, a number of other regulatory issues were were presented that demonstrated that the simple cycle assessed including Mass DEP air permitting requirements, alternative would have a significant air quality impact when PSD/NSR issues, proposed emission rate limits, adequacy of compared to a combined cycle alternative. BACT and LAER control technology assessments, environmental justice, etc.  Expert witness and technical evaluations in association with efforts to resolve New Source Review disputes between pulp  Expert witness services regarding air permit and air regulation and paper mills and the U.S. EPA. This assistance has been compliance at major synthetic organic chemical manufacturing provided for the Glatfelter pulp and paper mill in facilities in Louisiana and Texas between 1997 and 2005 Spring Grove, PA, and the Smurfit Stone pulp and paper mill (Environmental Analytics v. CSIC). The key parties involved in West Point, VA. Activities have included investigations in this matter were the insurance company (Chartis, or CSIC) regarding emissions, applicable regulations, air quality that was reviewing claims made in this matter, the U.S. impacts, potentially available air quality control technologies, Environmental Protection Agency (U.S. EPA), environmental etc. Appearances at U.S. Dept. of Justice and U.S. EPA staff and management of Formosa Plastics Corporation’s settlement conferences and technical sessions to discuss the (FPC’s) TX and LA facilities, and Environmental Analytics series of events that led to the issuance of Notices of Inc. (a contractor working for FPC at both sites). Paul Violations, and feasible technical solutions. Reviews have prepared an expert report, and provided deposition testimony focused on potential pollution control system performance for on behalf of Chartis. The main focus of the testimony was the NOx and SO2 control on each mill’s power boilers (coal, oil Leak Detection and Repair (LDAR) activities of the FPC and woodwaste fired with NCG combustion). The NOx facilities in Texas and Louisiana, and how complete and control evaluations have included fuel switching, Low NOx compliant they were, considering the provisions of the burners, SNCR, and SCR. They have been comprehensive facilities air permits, and State and Federal enforcement evaluations that include balance of plant impacts specific to activities at that time. each mill. Most recently, after the recent approval and  Prepared an expert report regarding air emissions and impacts adoption of a Consent Order (West Point Mill), an of the Hoeganaes Corporation powdered metal manufacturing investigation is being conducted into the latest options for

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installation of SO2 scrubbing on a large coal fired boiler that is New York facility is located in Staten Island and recycles one of the mill’s primary sources of steam and power. Stack approximately half of New York City’s waste paper and design modeling is being conducted as well as conceptual cost cardboard. Support for this facility includes Title V permitting estimation and balance of plant assessment for the various and reporting, Storm water Pollution Prevention, and SPCC scrubber technologies. These evaluations consider future Plan, Chemical Bulk Storage, etc. Prepared Title V operating regulations (Boiler MACT and new NOx budget limits) that permit application for this large pulp and paper recycling mill will affect the equipment. in Staten Island, NY. Sources included in the application include facility boilers, paper machine, corrugator and tanks.  Responsible for the successful licensing of the 248 MW The facility recycles various paper wastes (newspaper, Cambalache Combustion Turbine Project for the Puerto Rico cardboard, etc.) and produces recycled paper and corrugated Electric Power Authority (PREPA). The facility was the first boxes for commercial and industrial uses. power plant to be successfully licensed on the island in 25 years. It consisted of 3 combustion turbines which were  Air permitting consultant for a major industrial gas installed to run as peaking units to support the island’s power manufacturing plant which lacked a necessary Title V permit, grid during power shortages. A year-long pre-construction and was required to install a thermal oxidizer for air pollution monitoring program was conducted on-site for ambient air control. The facility distills, purifies and stores a number of quality and meteorological conditions. PSD permitting, Best industrial gases including ethylene and propylene. Paul Available Control Technology review and expert witness prepared the air permit construction application for a thermal support was provided during the licensing process. After oxidizer which was required for control of volatile organic facility construction and initial operation, technical support carbon (VOC) emissions from gas distillation and was provided regarding performance of air pollution control manufacturing operations. Subsequent to approval of the systems (e.g., SCR for NOx control). More recently, PSD construction permit, Paul provided oversight and agency applicability review (netting analyses), air quality impact coordination for performance testing of the thermal oxidizer. assessments were performed in support of planning the In addition, Paul assisted in development of recordkeeping and potential conversion of the power plant to a base loaded unit reporting systems that needed to be developed for compliance (producing an additional 120 MW of power). Similar PSD with the air permit. He also assisted in negotiations with the netting analyses have been performed in conjunction with State air permitting agency regarding final air permit planning for four other power plant site upgrades in Puerto provisions and approval. Rico.  Managed a project to conduct an environmental compliance  Provided expert witness investigation and testimony in Federal audit for a lens manufacturer, with over 55 million customers Court regarding a proposed new Brooklyn Federal Courthouse. (since it was founded in 1964). The audit was conducted at a Reviewed the DEIS, FEIS and Record of Decision for a new site in Plainview, NY, one of several nationwide facilities U.S. Eastern District Courthouse that was to be constructed in operated by this vision and eye care service provider. This downtown Brooklyn. This review included atmospheric particular facility manufactures plastic and glass lens glasses dispersion modeling and impact assessment of the traffic through a series of grinding, fining, polishing, and edging emissions associated with roadways serving the project site processes. Lenses are further enhanced through the area. All project documentation was reviewed for NEPA application of anti-reflective coatings, tinting, hardening, and compliance and technical accuracy. Issues of particular other refinements. The audit evaluated site operations and concern were air quality impact, alternative sites and designs, practices to assess compliance with the following and project need. Partly as a result of this review and environmental regulations testimony, major revisions were made to project design and mitigation features recommended were incorporated into the o Clean Air Act and New York State Environmental Final EIS prior to its certification. Conservation Law (ECL);  Project manager and principal scientist for U.S. EPA’s o Resource Conservation and Recovery Act (RCRA) nationwide human exposure and risk assessment studies of and NYSDEC ECL associated provisions for Hazardous Waste emissions of 37 hazardous/toxic air pollutants. The work was Management; conducted on behalf of U.S. EPA’s Office of Air Quality Planning and Standards and consisted of refinement of o Clean Water Act, NY State and Nassau County emission inventories, atmospheric dispersion modeling, human wastewater and stormwater regulations; exposure analyses, risk assessment, and consultations with stakeholders and U.S. EPA on the results and regulatory o Chemical and Petroleum Bulk Storage (NY State and recommendations. One specialized area of investigation was Nassau County); hazardous waste disposal facilities (landfill’s, surface impoundment’s, etc.). A methodology was developed to assist o Spill Management (U.S. EPA Oil Pollution in the assessment of emissions and impacts of such facilities. Prevention); Environmental Regulatory Compliance o Emergency Planning and Community Right-to-Know,  Project Manager for provision of all compliance related services Transportation of Hazardous Materials (49 CFR 107 and 172 (DOT to Pratt Paper (NY), Inc. Pratt is America’s 5th largest Hazardous Materials)); corrugated packaging company and the world’s largest, privately-held 100% recycled paper and packaging company.

2 of 5 Professional Profile Paul A. Eisen, CCM Principal Scientist o Potential Site Contamination related to historic site o Recordkeeping & reporting activities  Project Manager for comprehensive environmental, health and Upon completion of the audit and review of its key findings, safety audits of airport support operations (fueling, Paul assisted in implementing corrective actions. maintenance, food services, etc.) at approximately ten major airports in the U.S. and Canada. The audits were confidential  Managed the support of air permits and compliance activities for and performed in conjunction with due diligence activities. three major power plants owned and operated by Dominion They covered numerous topics, including: Energy in New England. These included two gas fired power plants (Providence, RI, and East Salem, MA), and the largest o Employee training in safety, operations and related coal fired power plant in New England (Brayton Point, in record keeping. Somerset, MA). Support included preparation of routine compliance certifications, regulatory reports, Title V renewal o Effectiveness of management in implementing applications, etc. policies relating to environmental, health and safety  Project Manager for environmental permitting and management compliance; services at a large New Jersey steel mill (Gerdau, Sayreville, NJ). Prepared monthly presentations to mill management, o Proper maintenance/ operation of above-ground NJDEP and public advisory committee on emissions control storage tanks activities and measured air quality impacts from steel manufacturing operations. Obtained permit approval for o Spill Prevention (SPCC) and Storm Water Pollution construction of a replacement Billet Reheat Furnace. The new Prevention Plans furnace markedly increased energy efficiency while reducing air quality impacts by optimizing “hot rolling” operations. o Hazardous Flammable Liquids and Their Managed pilot test investigations into available measures to Management control mercury emissions from the mill’s melt shop (primarily, Electric Arc Furnace). These investigations included pollution o Environmental compliance record-keeping and prevention, process modifications and add-on controls. updating activities Prepared and delivered presentations on pilot test results to NJDEP senior management (air compliance, enforcement and  Project Manager for a compliance audit at the New York City science and technology). Discussed alternative methods of Dept. of Transportation Sign Shop in Queens, NY. The scope compliance with existing and future mercury control of services included determining compliance with city, state requirements and emissions standards. Supervised the and federal environmental regulations, with a focus on air development of the facility’s Title V operating permit, quality. Compliance requirements and compliance status of stormwater pollution prevention plan (and Best Management various operations at the Facility were reviewed including a Practices), spill prevention and countermeasure plans, etc. screen wash process, a screen printing process, a powder Managed preparation of major Clean Air Act (PSD) permit coating oven, fuel dispensing operations and facility boilers. application for a significant increase in steel production at the Additionally, air testing was conducted at the facility to facility. This permitting process includes State-of-the-Art determine levels of air pollutants in various workspaces for review for the facility’s melt shop and its associated pollution comparison to OSHA guidelines for worker safety. control systems, air quality impact and risk assessment review  Project manager for air permit application preparation (Title V using U.S. EPA and New Jersey DEP approved models and Operating Permit, PSD permit, RACT Plan, MACT Plan) at health risk assessment analysis. Glatfelter pulp and paper mill in Spring Grove, PA.  Project Manager for environmental audit program at a network Supervision of efforts to estimate emissions from numerous air of hospitals and health care facilities in New York City. The emission sources at the mill (lime calciner, recovery boilers, focus of the audit program was on pharmaceutical waste power boilers, paper machines, coaters, pulp mill vents, disposal practices and their compliance with applicable waste wastewater treatment plant operations, etc.). Conducted management regulations (e.g., RCRA). Other environmental extensive air quality dispersion modeling of facility SO2 requirements were also reviewed (SPCC Plans, Air Permits, emissions to evaluate impacts in simple and complex terrain etc.). The audit program included review of: and assure attainment of National Ambient Air Quality Standards. Conducted stack design studies to determine o Hospital formularies to identify pharmaceuticals of feasible equipment arrangements upon modification of the concern for waste tracking facility. Waste characterization procedures (chemical,  Project manager and overall QA/QC for air permitting and on- o site environmental support services at Hoeganaes Corporation biomedical, hazardous) in Riverton, NJ. Initially, an NJDEP inspection of this Waste stream segregation, waste storage, and RCRA powdered metal manufacturing facility identified several air o pollution sources that appeared to need further control. The generator status determination (large vs. small quantity) facility has over forty sources of air emissions. Initially, the Labeling, packaging and shipping for disposal by major focus was on the facility’s melt shop and Electric Arc o Furnace (subject to New Source Performance Standards - 40 licensed facilities CFR Part 60, Subpart AAA). The facility was asked to install

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controls for fugitive emissions. The investigation of control chemical purchasing and storage procedures, low level options concluded that a new canopy hood system needed to radiological material handling and disposal, and hazardous be installed with a dedicated baghouse. Preparation of permit waste storage, transport and disposal practices. Existing applications and supporting documentation included air quality research laboratories were examined, staff were interviewed emissions estimates, impact assessment and risk assessment. and air quality modeling was performed to characterize The emissions estimations demonstrated that the melt shop potential impacts at the new facility according to procedures modifications did not trigger PSD permitting requirements. utilized the NY State (Air Guide-1). Regulations applicable to Subsequent to these successful permitting efforts, work has the existing laboratories were also reviewed to determine expanded to the provision of full environmental management whether operations were in compliance. Participated in the and compliance services for the facility. public hearings before the lead agency (Town Board) and its supporting bodies (Planning Board and Board of Zoning  Responsible for emergency preparedness support at New York Appeals). The facility was approved for construction. Power Authority nuclear power plants (Indian Point and James Fitzpatrick stations). Support was provided in evaluating Publications/Presentations: meteorological data collection systems, and conducting dose Eisen, P. A., “Storm Tide and Wind Impact of Hurricane Sandy assessment modeling using atmospheric dispersion models. Along the Hudson River”, Accepted for presentation at the Participated in emergency preparedness drills and performed Air & Waste Management Association international weather analysis and forecasting and off-site consequence conference: Climate Change: Impacts, Policy and analyses. Regulation, September, 2013. Environmental Impact Assessment Eisen, P.A., “New Clean Air Act Regulations Create New Challenges for University Facilities”, May 2011 meeting of  Preparation of Air Quality Impact evaluation for proposed the Long Island Consortium of Physical Plant major re-development of Ocean Breeze Park in Staten Island, Administrators (LICPPA) NY. The proposed development consists of a new Field House (includes 2,500 seat Arena) with Parking Garage, 4 Baseball Eisen, P. A., “Climate Change, Regulatory Developments”, Fields, Soccer/Football Field, Maintenance Facility, Nature Presented at January, 2010 meeting of the Gloucester and Trail, Dog Run, Playground, Bikeway, and 5k Cross Country Salem County, NJ Plant Executives Race Course. Evaluation performed followed latest NYC Eisen, P. A., “Air Pollution, Clean Air Act, Past, Present and CEQR Technical Manual guidance for evaluation of stationary Future Perspectives”, Presented to Touro Law School - and mobile source air quality impacts based upon worst case Environmental Law Class, March 2008 assumptions regarding future uses of the facility. Eisen, P. A., “Air Pollution Control in New York”, Presented at the New York Environmental Law & Management : Year  Provided overall QA/QC Management for an EIS prepared on 2000 Update, Government Institutes Division, ABS Group, behalf of the NY State University Construction Fund for a new Inc. October 16, 2000. Huntington, NY sports stadium and enhanced athletic facilities at the State University of New York at Stony Brook. The EIS was Eisen, P. A., Egdall, R. S., Hennessy, P. J. and Wesolowski, T. B. performed under strict adherence to New York’s SEQRA Proceedings: Air & Waste Management Association 92nd regulations. Key issues included traffic, parking, air quality Annual Meeting and Exhibition. “Development and and noise. Validation of Permit Limits for an EAF Meltshop. (1999) Spisak, J. F. and Eisen, P. A. TAPPI Proceedings, 1999  Retained by the Borough of Little Ferry, NJ to work with the International Environmental Conference, “Best Management County’s engineering consulting firm to review odor controls Practice and Environmental Management Systems: Are You proposed for the Bergen County Utilities Authority (BCUA) Really Prepared? Volume 2: 691-692. (1999) wastewater treatment plant. The review included proposed Eisen, P. A., Wang, J. and Callahan, R. E. Proceedings: Air & sludge dewatering facilities designed pursuant to the State of Waste Management Association 91st Annual Meeting and New Jersey mandate to eliminate ocean dumping. Sludge Exhibition. “A Streamlined Approach for NAAQS produced at the BCUA plant was to be dewatered on-site. Compliance Demonstration Modeling (1998) Wastewater from the dewatering was to be cycled back to the WWTP for treatment. Sludge cake was to be chemically fixed Eisen, P. A., Callahan, R.E., and Wang, J. TAPPI Proceedings, and utilized as landfill cover or incinerated. This investigation 1998 International Environmental Conference, “An Updated helped assure that: 1) the full range of odorous compounds that Approach for Major Source Air Permit Modeling” Book 2: were known to have the potential of being emitted from 711-720. (1998) the facility were addressed; 2) that the design and selection of Eisen, P. A., and Callahan, R.E., TAPPI Proceedings, 1997 the air pollution control systems was evaluated from a state- International Environmental Conference, “Retrospective of-the-art perspective; and 3) that the application covered Permitting For RACT and MACT Compliance At a standard design concerns as specified in EPA's "Design Northeast Pulp and Paper Mill” Book 1: 277-296. (1997) Manual: Odor and Corrosion Control in Sanitary Sewerage Eisen, P. A., and Callahan, R. E. Proceedings: Air & Waste Systems and Treatment Plants”. Management Association 89th Annual Meeting and Exhibition. “RACT and MACT Compliance at a Northeast  Responsible for preparation of key sections of a NY State Pulp and Paper Mill.” (1996) Environmental Impact Statement (EIS) for the re-location of Ciba’s U.S. Corporate Headquarters to Tarrytown, NY, as well Eisen, P. A., and Callahan, R. E., TAPPI Proceedings, 1996 the research and development laboratory for its Additive’s International Environmental Conference. “RACT and division. Evaluated air toxic emissions, as well as reviewed

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MACT Compliance at a Northeast Pulp and Paper Mill.” Book 2: 853-859. (1996)

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