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OAQPS ENVIRONMENTAL JUSTICE ANALYTICAL TEAM REPORT

RULE / ACTION

Chemical Sector - Polyether Polyols Production; Pesticide Active Ingredient Production; Polymers 

and Resins IV

OBJECTIVE

This report aids rule writers in drafting required environmental justice preamble language for 

E.O. 12898.

SCOPE

 Total # of unique source unit locations = 166

 Total # of facilities = 70

 Data Source: Updated 2005 NATA EI (Anne Pope)

EJ ASSESSMENT

Method(s)

 Proximity-to-Source: Comparative analysis of 3 mile radius demographics to national 

averages.

 Risk-based Demographic Assessment: Identification of potential cancer and non-cancer 

risks that may affect different social, demographic, and economic groups within the 

populations living near facilities (50 km) associated with inhalation exposures to 

hazardous air pollutants (HAPs) emitted by these facilities.

Source(s)

 CenRANK (proximity)

 EC/R and HEID/ATAG (cancer and non-cancer risk)
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Results Summary

Proximity-to-Source

The sector-wide demographic analysis reveals that while most demographic categories are 

within 2 percentage points of national averages, the African American population exceeds the 

national average by 6 percentage points (18% versus 12%), or 50%. A facility-level review shows 

that the EMERALD POLYMER ADDITIVES LLC, OH facility is a main contributor with an African 

American population of 33,484, comprising 16% of the total Chemical Sector African American 

population (33,484 / 203,487). This Ohio facility exceeds the African American national average 

by 20 percentage points (32% versus 12%), or 166%. 

When multiplying the national averages by a factor of 1.25, we find there are 33 facilities with a 

population of 645,832 that are equal to, or exceed, this increased threshold in one or more 

race, ethnicity and/or poverty demographic categories. Additionally, 17 facilities exceed a 

threshold factor of 2 times the national averages in one or more of the aforementioned 

demographic categories.

Below is a snapshot of the data highlighting 1) facilities exceeding 1.25 times the national 

averages in race, ethnicity and/or poverty, 2) emissions, 3) 3 mile population, and 4) facility 

clusters. (The excel file attached provides all of the supporting documentation discussed within 

this section.) While the Top 3 facilities for each section warrant additional attention, those of 

environmental justice interest are the facilities exceeding the 1.25 threshold identified below, 

and within the excel file. Please review the excel file in detail.

1. Facilities with populations exceeding 1.25 times the national averages in one or more of 

the below demographic categories: 33 facilities – 645,832 total population

 Minority Only

 Hispanic Only

 Poverty Only

 Minority & Hispanic

 Minority & Poverty

 Hispanic & Poverty

 Minority, Hispanic & 

Poverty

o Top 3 States: 

 TX – 9 facilities; 181,560 

 LA – 7 facilities; 33,391

 SC – 5 facilities; 44,190

o Top 3 Facilities: 

 EMERALD POLYMER ADDITIVES LLC, OH – 102,556

 Dow Chemical Company, CA – 78,718 

 GB Biosciences Corporation, TX – 64,903
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2. Total HAP Emissions: 2,271 tons per year (TPY)

o Top 3 HAP Categories:

 Ethylene Glycol – 684 TPY (30% of total)

 Methanol – 353 TPY (16%)

 Acetaldehyde – 305 TPY (13%)

o Top 3 States:

 SC – 590 TPY (26%)

 TX – 405 TPY (18%)

 WV – 268 TPY (12%)

o Top 3 Facilities :

 Eastman Chemical Co South Carolina Operations, SC – 172 TPY (8%)

 Eastman Chemical Co Texas Operations, TX – 155 TPY (7%)

 Performance Fibers, Inc., NC – 140 TPY (6%)

3. Total Study Area (3 mi) Population1: 1,116,923 – 70 facilities

o Top 3 States:

 TX – 235,640

 MI – 124,620 

 OH – 120,299 

o Top 3 Facilities: 

 EMERALD POLYMER ADDITIVES LLC, OH – 102,556

 BASF Corp, MI – 92,397

 Dow Chemical Company, CA – 78,718

4. Facility Clusters: 

Five facility cluster

o UNION CARBIDE CORP SOUTH CHARLESTON PLANT, WV + 

INSTITUTE PLANT UNION CARBIDE CORP, WV + 

BAYER CORP, WV + 

BAYER CROPSCIENCE LP, WV + 

BAYER MATERIALSCIENCE - SOUTH CHARLESTON, WV = 

80,942 total population; 79.9 TPY2

Three facility cluster

o SHELL CHEMICAL LP/GEISMAR PLANT, LA +

BASF CORPORATION/GEISMAR SITE, LA +

 

1 Where facilities are in close proximity to each other such that the study areas overlap, demographic information 

will only be assigned to one facility to ensure populations are not double counted.

2 This cluster has one or more facilities exceeding the 1.25 * national average threshold.
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RUBICON LLC, LA =

1,724; 41.8 TPY2

Two facility clusters

o LYONDELL CHEMICAL CO - CHANNELVIEW PLANT, TX + GB BIOSCIENCES 

CORPORATION, TX = 84,603; 89.5 TPY2

o DU PONT LA PORTE PLANT, TX + ROGER W POWELL PLANT, TX = 30,491; 72.4 

TPY2

o ATOFINA PETROCHEM INC/CARVILLE POLYSTYRENE, LA + SYNGENTA CROP 

PROTECTION INC/ST GABRIEL PLANT/CIBA-Geigy Corporation, LA = 4,722; 60.3 

TPY2

o ARKEMA Inc, AL + E I Dupont De Nemours & Co, AL = 1,421 population; 46.2 TPY

o STEPAN CO, IL + INEOS Americas LLC, IL = 7,884; 33.2 TPY

Facility demographic analysis attached:

Chemical Sector 

v5.xlsx
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