MEMORANDUM

To: Docket EPA

- HQ

- OAR

- 2011

- 0081 : Response to Petition from New Jersey Regarding SO 2 Emissions from the Portland Generating Station

From: Martha Keating, Geographic Strategies Group, OAQPS, US EPA Doug Solomon, Geographic Strategies Group, OAQPS, USEPA Arthur Zuco, Community and Tribal Programs Group, OAQPS, USEPA

Date: September 7, 2011
Subject: Environmental Justice Assessment for Section 126 Petition from New Jersey Regarding SO 2 Emissions from the Portland Generating Station

1.0 Executive Summary Executive Order 12898 (59 FR 7629, February 16, 1994) establishes Federal executive policy on environmental justice (EJ) . Its main provision directs Federal agencies, to the greatest extent practicable and permitted by law, to make EJ pa rt of their mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of their programs, policies, and activities on minority populations and low

- income populations in the United States

. EPA defines “environmental j ustice” to include meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and polices. This memorandum describes the approach EPA used to identify potential EJ communities in counties impacted by sulfur dioxide (SO 2 ) emissions from the Portland Generating Station located in Northampton County, Upper Mount Bethel Township, Pennsylvania. The areas of high est impact were identified by air quality modeling as summarized in the proposed rule (76 FR 19662) and as described in detail in the Modeling Technical Support Document
, which can
be found in the public docket for this rulemaking

. 1

1 Geographic Information Systems (GIS) software was used to identify and summarize the demographic makeup of the population residing in areas near the facility.

http://www.regulations.gov EPA

- HQ_OAR

- 2011

- 0081EPA has determined that this action will not have disproportionately high and adverse
human hea lth or environmental effects on minority or low

- income populations

. An analysis of demographic data illustrates that the population residing near the source is represented by fewer minority and low

- income residents than either the surounding counties, the average demographic composition of the S tates of New Jersey and Pennsylvania, and national averages. In addition, this rule increases the level of environmental and public health protection for all affected populations since, when fully implemented, it wil l result in attainment of the health

- based 1

- hour
SO 2 national ambient air quality standard (NAAQS). Section 2 of this memorandum describes the Portland Generating Station and provides an overview of the air quality modeling results. Section 3 describes t he GIS methodology used to identify the appropriate census block and block groups relevent to this analysis and the sources of the underlying census data. Section 4 summarizes the findings of the demographic analysis, Section 5 discusses meaningful involve ment of the affected communities, and Section 6 provides
conclusions.
2.0 Facility Description and Overview of Air Quality Modeling Results The Portland Generating Station is a 427 megawatt (MW) coal

- fired power plant located in Upper Mount Bethel Township in Northampton County, Pennsylvania. Within 500 feet and directly across the Delaware River is Knowlton Township in Warren County, New Jers ey. The facility includes two main boilers, an auxiliary oil

- fired boiler, and 3 small turbines which burn oil and natural gas. The facility is bordered to the north and northwest by terrain higher than any
of the stacks at the Portland Station. On April 7, 2011, EPA pro posed to find that SO 2 emissions from the Portland Station are contributing to nonattainment and interfering with maintenance of the 1

- hour SO 2 NAAQS in New Jersey. EPA also proposed emission limits and compliance schedules to ensure that the SO 2 emissions from the facility are sufficiently reduced to mitigate the interstate transport and non

attainment issues in the neighboring county. The basis for EPA’s proposed emission limits were the results of EPA’s independent modeling assessment of the Portland Sta tion’s SO 2 emissions. Allowable emissions were modeled using the AERMOD dispersion model to estimate the impacts of the facility’s emissions on ambient air quality. The area modeled around the plant (receptor grid) was selected
based on an assessment of me teorological data including prevailing wind direction and windspeed, terrain, and results of a preliminary (coarse grid) modeling assessment to ascertain the approximate area of maximum impact. Figure 1 depicts the modeling grid used to assess ambient ai r impacts due to SO 2 emissions from the plant. 2 The grid stretches 5 kilometers (km) (~3 miles) north of the plant, 4 km (2.5 miles) east, 1 km (0.6 miles) south, and 2 km (1.2 miles) west. The modeled maximum
99 th percentile (4 th

- highest daily maximum 1

- h our SO 2 concentration during the period 2007

- 2009 ) is used to compare ambient levels with the 1

- hour SO 2 NAAQS value of 75 ppb or about 196 ug/m 3 . The highest m odeled value from the Portland S tation was 851.1 ug/m 3 and is located northeast of the facility. In addition, as shown in Figure 1, while other “corners” of the grid show lower modeled emissions, every point in the grid shows modeled SO 2 levels that are higher than
the 1

- hour SO 2 standard of 196 ug/m 3

.

2 Air Quality Modeling Technical Support Document: NJ 126 Petition. Air Quality Assessment Division, U.S. Environmental Protection Agency. EPA 454/R

- 10 March 2011. Figure 1 . Modeling grid and AERMOD results for Portland Station3.0 GIS Methodology and Data Sources As described above, EPA’s AERMOD modeling indicated that SO 2 concentrations that
exceed the 1

- hour SO 2 NAAQS extend beyond the ranges of modeling grid. Consequently, the EJ analysis was not constrained to the geographic area of the modeling grid. Using GIS, the location of the facility and county and state boundaries were mapped. Within counties, census
bl ock groups surrounding the Portland Station were also identified. A census block conta ins about 50 people on average; a census block group contains about 26 blocks on average, or about 1,350 people. The purpose of assessing the larger block groups was to i nclude potential at

- risk populations outside of the modeling domain and to compare the demographics of these populations to county and state populations . However, to be certain that using census block groups for the EJ analysis did not skew the demographic results (by averaging over a larger geographic area) we also conducted the analysis at a finer scale. Specifically, census blocks
within a 3

- and 5

- mile buffer around the Portland Station were identified and the demographic
data summarized for the entire buffer area. This supporting analysis is presented in Appendix A.
3.1 Determining Census Block Groups for Analysis As shown in Figure 2, the areas included in this analysis are those six census block groups (numbered 1through 6) that are intersected by th e boundary of modeling domain and two census block groups (numbered 7 and 8) adjacent to boundary of the modeling domain. The block groups were identified using an intersect analysis. The intersect analyses were performed using the GIS product, ArcMap®, pa rt of ESRI Corporation’s ArcGIS® version 10 line of products. 3 (1) The modeling domain boundaries were imported to ArcView® and ArcView ® ’s intersect tool was used to identify census block groups with any portion intersected by the AERMOD modeling domain, and )

. The basic steps followed are:

(2) A visual inspection of the modeling domain and census block groups was used identify and add two additional census block groups (numbe r 7 and 8) located just outside the modeling domain in Warren County, New Jersey. In all, three block groups in Northampton County (PA) and five block groups in Warren County (NJ) were assessed. The geographic range of the EJ analysis extends roughly 15 km (~

3 http://www.esri.com/software/arcgis/arcview/key

- features.html10 miles) northeast, 11 km (~ 7 miles) east, 9 km (~ 6 miles) south, and 14 km (~9 miles) west of the Portland Station. These distances are greater than the radius of 5 km (~ 3 miles) that has been used in other demographic analyses focused on areas ar ound potential sources. 4
, 5
, 6 , 7

3.2 Census Data In addition, since the air modeling analysis did not indicate where the ambient air concentrations of SO 2 decline to acceptable levels, a demographic analysis of all of Warren County, NJ and Northampton County, PA was also conducted to be inclusive of a larger geographic area around the facility

.

Census data from the U.S. Census Bureau, 2000 Decennial C ensus were used in this analysis for determining population and socioeconomic demographics. Data for the block groups were aggregated for race, ethnicity, age, educational level and poverty status (F igure 2)

. Blo ck group level d ata for population and race were obtained from the Population and Housing Summary File 3 (SF3). The SF 3 c ontains sample data, which is information compiled from the questions asked of a sample of all people a nd housing units that were surveyed in the 2000
Census

. The dataset includes racial and ethnic classifications, age, income, educational level
, poverty status, language, home value, and population totals for foreign born and ancestry groups.

4.0 Demographic Results Table 1 summarizes the results of the demographic analysis. The data are presented separately for the block groups that are located in Northampton County, Pennsylvania and the block groups that are located in Warren County, New Jersey. Since multiple block groups were assessed for each county, average values for the assessed block groups withi n each county was
calculated. The averages for these block groups are listed as well as averages of county data (W arren , N ew J ersey and Northampton , P ennsylvania )
, state data ( Pennsylvania and New Jersey )
and the entire U.S.

4 U.S. GAO (Government Accountability Office). Demographics of People Living Near Waste Facilities. Washington DC: Government Printing Office; 1995. 5 Mohai P, Saha R. “Reassessing Racial and Socio

- economic Disparities in Environmental Justice Research”. Demography . 2006;43(2): 383

– 399. 6 Menn is J. “Using Geographic Information Systems to Create and Analyze Statistical Surfaces of Populations and Risk for Environmental Justice Analysis”. Social Science Quarterly , 2002;83(1):281

- 297. 7 Bullard RD, Mohai P, Wright B, Saha R, et al. Toxic Waste an d Race at Twenty 1987

- 2007 . United Church of Christ. March, 2007.Figure 2. Block groups ( numbered and outlined in gray) proximate to Port land Station that were selected for demographic analysis.

5.0 Meaningful Involvement
Included in the definition of “Environmental Justice” is the principle that EPA will include meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental l aws, regulations, and polices. For this action EPA published notice of the action in the Federal Register on April 7, 2011. The notice also included information on a public comment period for submittal of written comments and announced a public hearing. The public hearing w as heald on April 27, 2011 in the Pequest Trout Hatchery and Natural Resources Education Center located in Warren County, New Jersey. Information about the hearing was also announced by the New Jersey Sierra Club 8 , the Facebook page of Knowlton, New Jersey 9 , the MSP Alliance website 10

, and on the NJ.com website. 11

8 https://secure3.convio.net/scnj/site/Advocacy?cmd=display&page=UserAction&id=909Environmental justice concerns were not raised by any member of the public either at the hearing or in writing to the public docket during the public comment period.
6 .0 Conclusions
The results of the demographic analysis, as summarized in Table 1, illustrate that EPA’s proposed action (i.e., reducing emissions of SO 2 from the Portland Station) will have neither a disproportionate nor adverse impact on minority or low

- income populations

. The demog raphic data illustrate that the population residing near the source is represented by fewer minority and
low

- income residents than either the surrounding counties, the average demographic composition
of the S tates of New Jersey and Penns ylvania, or nation al averages. The percent of population between 0 and 17 years of age, the percent of population below poverty level, and the percent without a high school diploma are all lower in areas in proximity to the facility compared to county, state , and national averages. The percent of population older than 64 is slightly higher in the 3 blocks groups assessed in Northampton, P ennsylvania compared to county and state populations. As shown in Table 1, t he average percent of population older than 64 in the 3 block groups in Northampton County was 17 per cent compared to an average of 15 percent in Northampton County as a whole and the State of Pennsylvania. Since this rule, when fully implemen ted, will result in attainment of the health

- based 1

- hour SO 2 NAAQS in areas proximate to the Portland Station and consequently increases the level of environmental and public health protection for all affected populations, EPA has determined that this action will not have disproportionately high and adverse human h ealth or environmental effects on minority or low

- income populations.

9 http://www.facebook.com/notes/knowlton

- nj

- on

- njcom/epa

- to

- hold

- public

- hearing

- in

- oxford

- tomorrow

- on

pen nsylvania

- power

- plant

- air

- em/206069752758193 10 http://www.mspnews.com/news/2011/04/07/5431804.htm 11 http://www.nj.com/warrenreporter/index.ssf/2011/04/epa_t o_hold_public_hearing_in.htmlTable 1. Summary Results of Demographic Ana lysis

Demographic Summary White African American Native American Other or Multiracial Hispanic or Latino Age < 17 Age > 64 No High School Diploma Below Poverty

Level

Pennsylvania Average of 3 Block Groups in Northampton County (PA) 98% 1% 0% 1% 2% 21% 17% 18% 6%
Northampton County (PA) 86% 5% 0% 5% 11% 22% 15% 19% 8% Pennsylvania 82% 11% 0% 5% 6% 24% 15% 18% 11%

New Jersey Average of 5 Block Groups in Warren County 98% < 1% 0% 2% 1% 26% 12% 13% 3% Warren County (NJ) 90% 4% 0% 4% 7% 23% 14% 15% 5% New Jersey 69% 14% 0% 11% 18% 25% 13% 18% 8%
United States 75% 12% 1% 12% 14% 27% 12% 13% 13%Appendix A Demographic Buffer Analysis of Portland Station

As described in Section 3.0 above, an alternative finer

- scale demographic analysis was conducted to ensure all potential at

- risk populations surrounding the Portland Station were
identified. In this analysis a 3

- and 5

- mile buffer was identified and , using the same data sources as described above, demographic data for all block groups whose centroid was located within the buffer were summarized. Figures A.1 and A.2 present the buffers and locatio n of the population
centroids with the 3

- and 5

- mile buffers, respectively.

Figure 1.A. Block Centroids within 3 miles of Portland Generating StationFigure 1.B. Block Centroids within 5 miles of the Portland Generating Station

Table A.1 summarizes the results of this analysis. As shown, the results of the finer

- scale block analysis are essentially the same as those presented above for the block group analysis. Thus, the conclusion that that EPA’s proposed action (i.e., reducing emissions of SO 2 from the Portland Station) will have neither a disproportionate nor adverse impact on minority or low

- income

p opulations is further reinforced.Table A. 1. Summary Results of Buffer Demographic Analysis

POPULATION WHITE AFRICAN AMERICAN NATIVE AMERICAN OTHER OR MULTIRACIAL HISPANIC OR LATINO 1 AGE 0 - 17 AGE > 64 NO HIGH SCHOOL DIPLOMA BELOW POVERTY

LEVEL NEAR SOURCE TOTAL (3 miles) 4,487 4,363 25 7 92 122 1,086 622 508 228 % OF NEAR SOURCE TOTAL 97% 1% 0% 2% 3% 24% 14% 11% 5% NEAR SOURCE TOTAL (5 miles) 10,214 9,977 59 8 170 213 2,543 1,448 1,134 503 % OF NEAR SOURCE TOTAL 98% 1% 0% 2% 2% 25% 14% 11% 5% NATIONAL TOTAL 285,339,128 214,539,706 35,043,873 2,489,515 33,265,937 39,083,760 77,355,207 35,412,451 36,657,905 37,118,454 % OF NATIONAL TOTAL 75% 12% 1% 12% 14% 27% 12% 13% 13% Sources: The demographics are from the U.S. Census Bureau, 2000. Information on the facilities is from U.S. EPA. 1. The Census Bureau defines “Hispanic or Latino” as an ethnicity rather than as a racial category, Hispanics or Latinos may belong to any race.

DEMOGRAPHIC SUMMARY