What this document is
The State A / State B economic model for Nucor and DJJ: what is paid and received under the current disposal arrangement and under the CSA, each flow reported separately.
- State A is ASR disposal at an estimated $75/ton with an open RCRA reclassification exposure of $150–250/ton.
- State B: a $5.47M Year-1 Beneficiation Fee at Phase Initial, and a Circular Royalty™ of $6.57M in Year 2 growing to ~$328M gross over 30 years.
- Two independent gross transactions, reported separately; 48 direct FTE at Phase Initial and 192 at Phase Expanded; $80.6M annual regional impact ESTIMATED.
North Alabama Industrial Corridor
Economic Impact Report
State A leaves the ASR stream on a disposal predicate — State B converts the same tonnage into manufacturing feedstock and a 30-year royalty.
Introduction and Decision Summary
§1.1 — What This Report Measures
State A is the current system as diagnosed in the Waste Feedstock Study: Nucor/DJJ ASR streams disposed at ADEM-permitted Alabama landfills at an estimated $75/ton, with $0 residual value returned, and active RCRA reclassification exposure. State A is not re-diagnosed here.
State B is the Carbotura ACM deployment as specified in the Proposal EIR Input Block: 100/200/400 TPD phased build-out at Morgan County Industrial District, Decatur AL; Beneficiation Fee $150/ton (agreed); Circular Royalty™ commencing Month 13 at $180/ton (Year 2), escalating +1pp/yr. State B values originate exclusively from the Proposal — no independent derivation.
§1.2 — Decision Summary Table
| Decision Variable | State A (Current) | State B Year 1 | State B Year 2+ |
|---|---|---|---|
| Annual cost / obligation (Initial — 100 TPD) | −$2.74M disposal cost | −$5.48M Beneficiation Fee | |
| Capital obligation (Nucor/DJJ) | None (disposal is opex) | $0 — Carbotura BOO, fully privately financed | |
| RCRA reclassification exposure | Active — $150–$250/ton potential | Eliminated — ACM classified as manufacturing feedstock | |
| Key data gaps | FWDC verified rate (ESTIMATED); volumes (ESTIMATED); contract expiry dates | ||
| Decision: LOI/MOU execution | Required at T0. Each quarter of delay shifts first royalty payment by one quarter. | ||
| Cost of delay (per quarter, Expanded 400 TPD) | ~$3.6M deferred Circular Royalty™ + $2.74M additional disposal cost per quarter | ||
§1.3 — Fiscal vs. Regional Economic Separation
This report distinguishes between two categories throughout. Direct fiscal effects are cash flows between Nucor/DJJ and Carbotura under the CSA — Beneficiation Fee, Circular Royalty™, and avoided disposal cost. Regional economic effects are broader impacts on employment, property tax base, and supply chain in Morgan County and North Alabama. These two categories are not additive and must not be combined in any comparative statement.
State A Baseline
§2.1 — Feedstock Volume and Disposition
| Stream | Source | Est. TPD | Current Disposition | $/Ton Disposed |
|---|---|---|---|---|
| Light ASR (Fluff) — DJJ captive | DJJ SE shredder network | ~290 | ADEM-permitted lined landfill | $65–$85 EST |
| Heavy ASR — DJJ non-ferrous residual | DJJ processing operations | ~40 | ADEM-permitted lined landfill | $65–$85 EST |
| Third-party SE shredder ASR | Regional operators | ~30 | Contracted disposal — facility undisclosed | Unknown |
| Total addressable (IMMEDIATE) | DJJ captive | ~330 | 100% landfill — $0 residual return | $75 blended EST |
§2.2 — State A Cost Structure
| Cost Component | $/Ton | Annual Cost (330 TPD) | Source Type |
|---|---|---|---|
| Landfill gate rate (special waste, Alabama) | $30–$45 | $3.61M–$5.42M | EST |
| ASR special handling surcharge | $20–$30 | $2.41M–$3.61M | EST |
| Transport (shredder → landfill) | $10–$15 | $1.20M–$1.81M | EST |
| Residual return | $0 | $0 | Structural — no recovery mechanism |
| FWDC (blended all-in) | $75 | $9.04M/yr (@ 330 TPD) | EST |
§2.3 — State A Cost Trajectory — Three Escalation Mechanisms
| Mechanism | Current Status | Likely Direction |
|---|---|---|
| General landfill cost inflation | Alabama MSW tipping fees growing ~3–4%/yr (EREF 2024 trend) | ↑ Gradual escalation |
| ASR special waste surcharge tightening | ADEM framework stable; EPA Region 4 scrutiny increasing | ↑ Increasing compliance burden |
| RCRA Subtitle C reclassification | Non-hazardous currently; TCLP threshold approach possible | ↑↑ Step-change to $150–$250/ton if triggered |
§2.4 — State A Structural Position
State A offers no recovery mechanism for ASR. Every ton disposed is a permanent operational expense. The structural risk — RCRA Subtitle C reclassification — is not theoretical: ASR constituent profiles (lead, cadmium, PCBs) mean TCLP threshold exceedances are operationally plausible without significant feedstock control changes. State A holds this risk without mitigation.
State B Deployment Baseline
§3.1 — Inherited Flags
All State B values in this section originate exclusively from the Proposal EIR Input Block (April 2026). Confidence flags are inherited without modification — see Inherited Flags Block above. No independent derivation.
§3.2 — Deployment Configuration
| Phase | TPD | Modules | TPY | COD | First Royalty |
|---|---|---|---|---|---|
| Initial | 100 | 1 | 36,500 | T0+24mo | T0+37mo |
| Medium | 200 | 2 | 73,000 | T0+42mo | T0+55mo |
| Expanded | 400 | 4 | 146,000 | T0+60mo | T0+73mo |
§3.3 — Economic Terms (from Proposal)
| Parameter | Value |
|---|---|
| Beneficiation Fee — Year 1 | $150.00/ton (agreed rate, Carbotura ceiling) |
| Beneficiation Fee escalator | 2.5%/year compounding |
| Circular Royalty™ base | 120% of the current-year Beneficiation Fee = $180.00/ton (Year 2) |
| Royalty escalator | +1 percentage point/year |
| Royalty payment lag | 13 months after corresponding TMC payment |
| CSA term | 30 years |
| Counterparty capex obligation | $0 (BOO — Carbotura financed) |
| Accounting standard | US GAAP |
§3.4 — Residual Obligations
Third-party SE shredder ASR (~30 TPD) is outside the initial CSA scope and continues under current disposal arrangements during Phase Initial and Phase Medium. No residual disposal obligation exists for DJJ captive streams once CSA Phase Initial is operational.
§3.5 — Timeline Anchoring
All milestones referenced to T0 = LOI/MOU execution date. No confirmed T0 as of April 2026.
§3.6 — Phase Delta Map
The map below shows the transition from State A infrastructure (existing ASR generation and disposal network) to State B (ACM facility — Priority 1 candidate at Morgan County Industrial District). State A pins shown in grey/amber/blue tones; State B ACM site in Emerald.
Map requires a Google Maps API key.
Set GOOGLE_MAPS_API_KEY in config.js.
§3.6 Phase Delta Map
Delta Analysis
§4.1 — Three Delta Components
§4.1 — Phase-by-Phase Comparative Table
| Metric | Phase Initial (100 TPD) | Phase Medium (200 TPD) | Phase Expanded (400 TPD) |
|---|---|---|---|
| State A disposal cost for this volume | $2,737,500/yr | $5,475,000/yr | $10,950,000/yr |
| State B Beneficiation Fee — Year 1 | −$5,475,000 | −$10,950,000 | −$21,900,000 |
| Gross cost displacement (avoided disposal) | +$2,737,500 | +$5,475,000 | +$10,950,000 |
| Circular Royalty™ — Year 1 | $0 (pre-royalty) | $0 (pre-royalty) | $0 (pre-royalty) |
| Circular Royalty™ — Year 2 | +$6,570,000 | +$13,140,000 | +$26,280,000 |
| Total improvement vs. State A — Year 2 | +$3,695,625 | +$7,391,250 | +$14,782,500 |
| Counterparty capital obligation | $0 | $0 | $0 |
Year 1 and post-Month 13 periods have materially different fiscal characteristics. They must not be combined.
In Year 1, Nucor/DJJ pay the Beneficiation Fee ($150/ton) and receive $0 royalty; current disposal is $75/ton. Beginning Month 13, the Circular Royalty™ of $180/ton commences on a rolling basis; the $75/ton avoided disposal is reported separately. These two periods represent structurally distinct fiscal positions and averaging them produces a materially misleading figure.
§4.4 — Gross Cost Displacement — Selected Years (Phase Initial)
| Year | TPY | FWDC/Ton | Annual Gross Displacement | Cumulative Displacement |
|---|---|---|---|---|
| 1 | 36,500 | $75 | $2,737,500 | $2,737,500 |
| 5 | 36,500 | $75 | $2,737,500 | $13,687,500 |
| 10 | 36,500 | $75 | $2,737,500 | $27,375,000 |
| 20 | 36,500 | $75 | $2,737,500 | $54,750,000 |
| 30 | 36,500 | $75 | $2,737,500 | $82,125,000 |
FWDC held constant at $75/ton (ESTIMATED). Does not reflect potential FWDC escalation from landfill cost inflation or RCRA reclassification — both of which would increase this figure materially.
§4.5 — Circular Royalty™ — Selected Years (Phase Initial, 100 TPD)
| Year | Beneficiation Fee/ton | Royalty Rate | Royalty/ton | Annual Royalty | Annual TMC |
|---|---|---|---|---|---|
| 1 | $150.00 | N/A — pre-royalty | $0 | $0 | −$5,475,000 |
| 2 | $153.75 | 120% | $180.00 | +$6,570,000 | −$5,611,875 |
| 5 | $165.57 | 123% | $198.68 | +$7,251,820 | −$6,043,305 |
| 10 | $187.33 | 128% | $233.93 | +$8,538,445 | −$6,837,545 |
| 20 | $239.79 | 138% | $322.84 | +$11,784,460 | −$8,752,635 |
| 30 | $306.96 | 148% | $443.23 | +$16,177,895 | −$11,204,040 |
§4.6 — Three-Item Gross Fiscal Chart (Phase Initial)
1. Gross cost displacement is quantified separately from Circular Royalty™ cash flow.
2. At steady state, the Circular Royalty™ is designed to exceed the Beneficiation Fee on a per-ton basis.
3. Circular Royalty™ payments begin 13 months after corresponding Beneficiation Fee payments and ramp to full run-rate on a rolling basis.
Insight: Avoided Disposal (amber) + Circular Royalty™ (emerald) together exceed Beneficiation Fee (red) from Year 2. Royalty grows faster than TMC through rate escalation differential.
Source: Locked Assumption Registry — April 2026. FWDC $75/ton ESTIMATED.
§4.3 Pre-Royalty
Year 1 and post-Month 13 periods have materially different fiscal characteristics. They must not be combined.
In Year 1, Nucor/DJJ pay the Beneficiation Fee ($150/ton) and receive $0 royalty; current disposal is $75/ton. Beginning Month 13, the Circular Royalty™ of $180/ton commences on a rolling basis; the $75/ton avoided disposal is reported separately. These two periods represent structurally distinct fiscal positions and averaging them produces a materially misleading figure.
System-Level Impact
§5.1 — Employment Delta
Note: Employment figures are regional economic effects and are not county fiscal receipts. They are not additive with Circular Royalty™ or disposal cost figures above.
| Category | State A | State B — Initial | State B — Expanded |
|---|---|---|---|
| Direct FTE — ACM facility | 0 (landfill staff only — not Nucor/DJJ) | +48 | +192 |
| Indirect jobs — Morgan County supply chain | 0 | +120 | +480 |
| Annual economic impact — North Alabama | Disposal opex only | +$20.2M | +$80.6M |
§5.2 — Environmental Delta
Environmental performance figures are on a designed-for basis pending ASR characterization study. Pending characterization data; subject to revision following feedstock analysis.
| Metric | State A | State B (400 TPD) |
|---|---|---|
| Annual ASR landfilled | ~146,000 tpy (at full target volume) | 0 |
| Carbon displacement (designed-for) | Baseline | ~87,600 tCO2e/yr EST |
| Lead/cadmium landfill leach risk | Active — ongoing TCLP exposure | Eliminated via MCR anoxic processing |
| PCB containment | Reliant on landfill liner integrity | Eliminated in MCR process stream |
§5.3 — RCRA Structural Delta
Under State A, Nucor/DJJ hold open exposure to RCRA Subtitle C reclassification — a step-change event that would raise disposal costs to $150–$250/ton and require hazardous waste manifests, licensed TSD facilities, and environmental liability documentation. Under State B, ASR entering ACM is classified as manufacturing feedstock under manufacturing NAICS (325180/325998/327992/331110/331314/331492) . This classification eliminates Subtitle C exposure for the counterparty entirely.
§5.4 — No-Fallback Analysis
If Nucor/DJJ do not proceed with the CSA, State A continues with no structural change — except that landfill cost inflation, ADEM regulatory tightening, and RCRA reclassification risk all continue to accumulate unmitigated. There is no alternative industrial ASR processing option in North Alabama at equivalent scale or comparable commercial terms as of April 2026.
Risk and Sensitivity
§6.1 — Risk Register
| # | Risk | Driver | Who Bears | Residual |
|---|---|---|---|---|
| 1 | FWDC verification | $75/ton ESTIMATED; actual may differ | Internal (disclosure decision) | TMC at ceiling regardless — limited financial impact |
| 2 | Volume shortfall (<100 TPD) | Characterization study; contract constraints | DJJ (volume delivery) | CSA volume provisions; minimum delivery TBD in feasibility |
| 3 | RCRA reclassification — ASR | TCLP threshold exceedance; EPA policy shift | Carbotura (manufacturing classification) | None for counterparty under CSA |
| 4 | Existing contract switching cost | Active disposal contracts — expiry unknown | DJJ (commercial decision) | Phased transition aligned to expiry; parallel disposal during overlap |
| 5 | Timeline slippage — permitting | ADEM manufacturing permit; Morgan County IDB | Carbotura (BOO operator) | First royalty deferred proportionally; no counterparty penalty |
| 6 | PCB constituent exceedance in feed | ASR PCB levels >50 ppm | Carbotura / DJJ acceptance protocol | Stream exclusion or pre-treatment; protocol defined in feasibility |
| 7 | Output commodity price decline | Synthetic graphite, hydrogen pricing | Carbotura (sole output owner) | None — counterparty return is contractually fixed |
| 8 | Technology performance variability | MCR yield vs. ASR composition | Carbotura (BOO operator) | None — counterparty TMC obligation is tonnage-based |
| 9 | Landfill cost inflation (State A) | Alabama ADEM tightening; capacity constraints | Counterparty if CSA not executed | Increases urgency of CSA; strengthens State B economics retrospectively |
| 10 | EV fleet ASR composition shift | Battery enclosure materials differ from ICE ASR | Carbotura (MCR adaptation) | Low — MCR handles hydrocarbon-rich polymer streams broadly |
§6.2 — Feedstock Variability ±20%
| Scenario | TPD | TPY | Year 2 Royalty |
|---|---|---|---|
| Base (100 TPD) | 100 | 36,500 | $6,570,000 |
| −20% volume (80 TPD) | 80 | 29,200 | $5,256,000 |
| +20% volume (120 TPD) | 120 | 43,800 | $7,884,000 |
Volume variability scales royalty proportionally.
§6.3 — FWDC Sensitivity — Sign-Change Threshold
| FWDC Scenario | Sign Change? |
|---|---|
| $50/ton (below current est.) | No (Year 2+ always positive) |
| $75/ton (ESTIMATED — planning basis) | No |
| $100/ton | No |
| $150/ton (RCRA reclassification threshold) | Year 1 positive above $150 |
| $200/ton (post-reclassification) | Both periods strongly positive |
State A remains positive at all FWDC levels above $0.
§6.4 — Royalty Escalator Sensitivity
| Escalator Scenario | Year 10 Royalty/ton | Year 30 Royalty/ton |
|---|---|---|
| 0pp/year (no escalation) | $180.00 | $180.00 |
| +1pp/year (contract base) | $233.93 | $443.23 |
| +2pp/year (enhanced) | $291.97 | $763.65 |
§6.5 — Timeline Slippage
| T0 Delay | Phase Initial COD | First Royalty | Royalty Deferred (Initial) |
|---|---|---|---|
| On time | T0+24mo | T0+37mo | $0 |
| 1 quarter delay | T0+27mo | T0+40mo | ~$1,643,000 deferred |
| 1 year delay | T0+36mo | T0+49mo | ~$6,570,000 deferred |
| 2 year delay | T0+48mo | T0+61mo | ~$13,140,000 deferred |
Royalty figures are amounts received. The royalty is paid 13 months in arrears, so the figure shown for a year is earned on the previous year’s delivered tonnage.
Decision Window Analysis
§7.1 — Binding Constraints
| Constraint | Named Factor | Impact |
|---|---|---|
| Active disposal contracts | DJJ/Nucor ASR disposal agreements — expiry undisclosed | Governs earliest CSA transition date; contract review is first feasibility deliverable |
| ADEM manufacturing permit | Alabama Dept. of Environmental Management — manufacturing facility permit | Standard manufacturing pathway; not solid waste permitting. Estimated 12–18 month timeline. |
| Morgan County IDB site agreement | Morgan County Industrial Development Board — site control | IDB track record positive (Nucor $125M Towers & Structures, 2023). Site engagement required. |
| Carbotura financing close | Senior project finance + equity — $75M Phase Initial | Term Sheet phase verification is prerequisite for financing commitment. 6–9 month lead time. |
§7.2 — Decision Window
| Milestone | Required By | If Missed |
|---|---|---|
| LOI/MOU execution | T0 — as early as possible | Each quarter of delay shifts Phase Initial COD and first royalty payment by one quarter |
| Contract review complete | T0+2 months | Transition timeline undefined; parallel disposal costs continue |
| P1 site confirmed — Morgan County IDB | T0+3 months | P2/P3 fallback triggered; Carbotura financing timeline extends |
| CSA execution | T0+3 months | Carbotura financing cannot close without executed CSA |
| ADEM manufacturing permit application | T0+6 months | Permit clock resets; COD slips to T0+30 months or beyond |
§7.3 — Irreversibility Mechanism
The irreversibility mechanism in this engagement is the active ASR disposal contract. Once contract terms are understood and a transition window identified, the decision to redirect volume to ACM is commercially bounded — delay beyond the contract expiry window forfeits the transition without penalty provision and requires a new contracting cycle. At 400 TPD and $10.95M/year in disposal costs, each year of avoidable contract extension represents $10.95M in unrecoverable disposal expense with $0 return — while the first Circular Royalty™ payment at $26.28M/year (Year 2, Expanded) remains deferred.
§7.4 — Optionality Matrix
| Option | Available Now? | Preserved by Term Sheet phase verification? | Cost of Waiting |
|---|---|---|---|
| Execute the LOI/MOU only — no CSA commitment | Yes | N/A — this is the action | ~$0 (study cost only) |
| Negotiate CSA terms during Term Sheet phase verification | Yes | Yes | $0 if study authorized promptly |
| Defer to Phase Medium or Expanded entry only | Yes | Yes — CSA can be structured for later phases | Lost royalty from Phase Initial period |
| Continue State A indefinitely | Yes | N/A | ~$10.95M/yr in unrecoverable disposal cost at 400 TPD; rising RCRA exposure |
Effects Summary
§8.1 — Fiscal Effects
§8.2 — Regional Economic Effects
These are regional economic effects — not counterparty fiscal receipts. Not additive with Circular Royalty™ or disposal cost figures above.
At Expanded (400 TPD): +192 direct FTE, +480 indirect jobs, +$80.6M annual economic impact in Morgan County and North Alabama — sourced from ESTIMATED Carbotura standard employment multipliers pending Term Sheet phase verification.
§8.3 — Environmental Effects
Designed-performance basis — pending ASR characterization study.
At Expanded: 146,000 tpy of ASR permanently diverted from ADEM-permitted landfill. ~87,600 tCO2e/year carbon displacement (ESTIMATED). Lead, cadmium, and PCB landfill leach risk eliminated. RCRA Subtitle C exposure eliminated via manufacturing classification.
§8.4 — Structural Effects
Under State B: Nucor/DJJ's ASR liability profile converts from a growing regulatory exposure to a contractually fixed, royalty-returning manufacturing feedstock relationship. The CSA is a structural hedge against both FWDC escalation and RCRA reclassification for the full 30-year term.
§8.5 — Unresolved Data Gaps
| Data Gap | Impact on Analysis | Resolution Path |
|---|---|---|
| Verified FWDC (current disposal contract rates) | FWDC used at $75/ton ESTIMATED — verified rate may differ; does not affect Beneficiation Fee or royalty | DJJ operations data disclosure in Term Sheet phase verification |
| ASR volume confirmation (100/200/400 TPD) | All financial projections are ESTIMATED volume basis | DJJ shredder throughput data + ISRI yield verification in Term Sheet phase verification |
| Disposal contract expiry dates | Phase Initial transition timing undefined | Contract review — first deliverable in Term Sheet phase verification |
| ASR characterization — TCLP, PCB, composition | Environmental impact projections ESTIMATED; acceptance protocol undefined | Lab characterization — Term Sheet phase verification |
| Morgan County IDB site terms | P1 site PROVISIONAL; P2/P3 fallback sites not engaged | IDB engagement following LOI/MOU execution |
§8.5 — Unresolved Data Gaps
§8.5 — Unresolved Data Gaps
| Data Gap | Impact on Analysis | Resolution Path |
|---|---|---|
| Verified FWDC (current disposal contract rates) | FWDC used at $75/ton ESTIMATED — verified rate may differ; does not affect Beneficiation Fee or royalty | DJJ operations data disclosure in Term Sheet phase verification |
| ASR volume confirmation (100/200/400 TPD) | All financial projections are ESTIMATED volume basis | DJJ shredder throughput data + ISRI yield verification in Term Sheet phase verification |
| Disposal contract expiry dates | Phase Initial transition timing undefined | Contract review — first deliverable in Term Sheet phase verification |
| ASR characterization — TCLP, PCB, composition | Environmental impact projections ESTIMATED; acceptance protocol undefined | Lab characterization — Term Sheet phase verification |
| Morgan County IDB site terms | P1 site PROVISIONAL; P2/P3 fallback sites not engaged | IDB engagement following LOI/MOU execution |
Inherited Flags
Appendix A
| Figure | Methodology | Source |
|---|---|---|
| FWDC $75/ton | SE regional blend: Alabama MSW base ($30–45/ton, EREF 2024) + ASR special handling ($20–30) + transport ($10–15) | EREF 2024; Alta Environmental ASR benchmarks |
| Beneficiation Fee $150/ton | Agreed rate at Carbotura ceiling — not formula-derived for this engagement | Engagement agreement; Carbotura standard parameters |
| Phase sizing 100/200/400 TPD | User-specified; modules = ceil(TPD/100) per Carbotura standard | Carbotura BOO module standard |
| Royalty formula and parameters | Carbotura standard CSA: 120% base, +1pp/yr, 13-month lag | Carbotura CSA framework |
| Environmental performance basis | Carbotura standard parameters × TPD scalar — designed-for basis pending ASR characterization | Carbotura standard environmental model |
| Employment basis | Carbotura standard employment multipliers × TPD; regional indirect job ratio from standard multiplier tables | Carbotura standard parameters — ESTIMATED |
| Timeline basis | Carbotura standard deployment schedule — T0+24mo COD, T0+37mo first royalty | Carbotura standard parameters |
Appendix B
| Term | Definition |
|---|---|
| Delta Model | The analytical approach of this report: quantifying the difference between State A and State B on identical volume bases. No re-diagnosis of State A; no independent derivation of State B values. |
| Gross Cost Displacement | The disposal cost avoided per ton by redirecting ASR from landfill to ACM. At $75/ton FWDC (ESTIMATED): $2,737,500/year at Initial; $10,950,000/year at Expanded. Quantified separately from Circular Royalty™. |
| Pre-Royalty Period | Months 1–12 following Phase Initial COD. Beneficiation Fee is paid but no Circular Royalty™ has commenced. −$150/ton TMC paid; −$75/ton vs. State A. Structurally inherent to rolling lagged royalty mechanism. |
| Royalty Ramp Period | Month 13 through approximately Month 24. Rolling royalty commences at $180/ton (Year 2 base). Ramp to full run-rate as 13 months of TMC payments accumulate royalty claims. |
| Steady-State Period | Year 2 onward. Royalty fully accruing at 120%+ of Beneficiation Fee, growing at 1pp/yr differential. The royalty rate escalates faster than the fee every year. |
| State A | The current system as of April 2026: ASR disposed at ADEM-permitted landfills at $75/ton (ESTIMATED), $0 residual return, RCRA reclassification exposure active. |
| State B | The Carbotura ACM deployment scenario: 100→400 TPD phased ACM facility at Morgan County Industrial District, Decatur AL. Beneficiation Fee $150/ton; Circular Royalty™ from Month 13. |
| US GAAP | United States Generally Accepted Accounting Principles — the applicable accounting standard for this engagement. Nucor Corporation is a US public company (NYSE: NUE) reporting under US GAAP. All Carbotura SPV Finance figures use US GAAP. |
Appendix C
| Registry Figure | Public Source | Confidence |
|---|---|---|
| DJJ 19 auto shredders; SE largest region | djj.com/recycling (April 2026) | VERIFIED |
| Nucor Tuscaloosa: 33.234761°N, 87.508498°W | gem.wiki/Nucor_Steel_Tuscaloosa_plant (March 2026) | VERIFIED |
| FWDC $75/ton | EREF 2024 tipping fee report; Alta Environmental ASR benchmarks | ESTIMATED |
| ASR composition 66% organic, 14% metals, 20% inerts | ISRI industry data; EPA ASR characterization (DTSC 2013) | VERIFIED |
| ASR heating value ~5,400 BTU/lb | GEP Ecotech technical documentation; EPA literature | VERIFIED |
| Morgan County IDB — $125M Towers & Structures | governor.alabama.gov (February 2023) | VERIFIED |
| RCRA Subtitle C reclassification risk for ASR | Okon Recycling technical review (Oct 2025); Alta Environmental (Oct 2024); 40 CFR §262.11 | VERIFIED |
| Carbotura manufacturing classification basis (NAICS 31–33) | Carbotura corporate record | VERIFIED |
Planning basis notice: This Economic Impact Report is a delta model comparing State A and State B based on inputs from the Waste Feedstock Study and Proposal. All ESTIMATED values are flagged and require verification through Term Sheet phase verification. This document does not constitute financial, legal, or regulatory advice. US GAAP accounting standard applies.