1

MEMORANDUM

To : Docket ID No. EPA

- HQ

- OAR

- 2012

- 0133

From : Nick Parsons, US EPA

Date: December 11, 2013
Subject: Environmental Justice Review: Amino/Phenolic Resins, Acrylic and Modacrylic

Fibers Production, and Polycarbonate Production

1.0 INTRODUCTION
Executive Order 12898 (59 FR 7629, February 16, 1994) establishes federal executive
policy on environmental justice. Its main provision directs federal agencies, to the greatest extent
practicable and permitted by law, to make environmental ju stice part 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 Unite d States.
EPA defines “Environmental Justice” 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 pol ices. A key
element of environmental justice is ensuring that all people have an opportunity for meaningful

involvement in decision

- making. Certain groups may not have participated in decision making
historically because of economic (e.g., income), social (e.g., language barriers, education levels,
distrust of government), and structural reasons. A critical concern is whether, and the extent to
which, communities have the ability to influence the types and number of regulated activities
taking place in the ir community, as well as the requirements, conditions, and parameters by
which they must operate (e.g., permit conditions).
The EPA aims to notify and engage the public in a variety of ways. Each rule is reviewed
to identify the appropriate methodology and meaningful involvement may consist of one or more
of the following: notices on the EJAir website, community call discussions, fact sheets,
community meetings, and/or webinars. A fact sheet for the proposed risk and technology review

of the National Emissi on Standards for Hazardous Air Pollutants: Amino/Phenolic Resins,2

Acrylic and Modacrylic Fibers Production, and Polycarbonate Production will be posted on the EPA’s Technology Transfer Network at http:// www.epa.gov/ttn/oarpg/t3fs.html

.

2.0 DEMOGRAPHICS

The EPA has determined that this proposed rule will not have disproportionately high and
adverse human health or environmental effects on minority, low income, indigenous populations

because it increases the level of environmental protection for all affected populations without
having any disproportionately high and adverse human health or environmental effects on any
population, including any minority, low income, or indigenous populations.
These proposed st andards may improve public health and welfare, now and in the future,
by reducing HAP emissions that may contribute to adverse environmental and human health
impacts. The reductions in HAP emissions associated with the rule are expected to benefit all

popu lations living near the sources affected by this rule.
To gain a better understanding of the source category and near source populations, the
U.S. EPA conducted a demographic analysis on each of the source categories for this
rulemaking. This analysis onl y gives some indication of the prevalence of sub

- populations that
may be exposed to air pollution from the sources and therefore would be those populations that
may be expected to benefit most from these regulations; it does not identify the demographic

ch aracteristics of the most highly affected individuals or communities, nor does it quantify the
level of risk faced by those individuals or communities.
The information in each of the following tables provides near source (within 3 miles) data

for several demographic categories, and highlights those that exceed 20 percent of their
corresponding national averages.

Table 2.1 Summary of Demographic Data Analysis (Amino/Phenolic Resins)

DEMOGRAPHIC
SUMMARY 1 NEAR SOURCE
TOTAL % OF NEAR

SOURCE TOTAL NATIONAL

TOTA L % OF NATIONAL

TOTAL
POPULATION 577,008 312,861,256
WHITE 388,377 67% 226,405,205 72%
AFRICAN AMERICAN 123,835 21% 39,475,216 13%
NATIVE AMERICAN 5,212 1% 3,646,995 1%
OTHER OR MULTIRACIAL 59,584 10% 43,333,840 14%

MINORITY 2 188,631 33% 86,456,051 28%
HISPANIC OR LATINO 3 59,095 10% 54,181,245 17%
AGE 0

- 4 39,996 7% 20,465,068 7%3

AGE 0

- 17 138,011 24% 75,217,176 24%
AGE 65+ 66,529 12% 40,830,262 13%
NO HIGH SCHOOL
DIPLOMA 63,535 11% 32,060,510 10%

BELOW POVERTY LINE 115,121 20% 43,616,850 14% >= 1.2 of National Average
Sources: The demographics are from the U.S. Census Bureau, 2010. Information on the facilities is from U.S. EPA. 1. Where facility study areas overlap, the census block populations are only counted once in this table. Therefore, a facility level total may not match this summary total. 2. The “Minority” population is the overall population (in the first column) minus white population (in the second column). 3. The Census Bureau defines “Hispanic or Latino” as an ethnicity rather than as a racial category, Hispanics or Latinos may belong to any race. All of the races noted in the table may include Hispanics.

African American = +8 percentage points or +70%
Below Poverty Line = +6 percentage points or +43%

T able 2.2 Summary of Demographic Data Analysis (Acrylic and Modacrylic Fibers Production)
DEMOGRAPHIC
SUMMARY 1 NEAR SOURCE
TOTAL % OF NEAR

SOURCE TOTAL NATIONAL

TOTAL % OF NATIONAL

TOTAL
POPULATION 18,420 312,861,256
WHITE 8,185 44% 226,405,205 72%
AFRICAN AMERICAN 8,292 45% 39,475,216 13%
NATIVE AMERICAN 107 1% 3,646,995 1%
OTHER OR
MULTIRACIAL 1,836 10% 43,333,840 14%

MINORITY 2 10,235 56% 86,456,051 28%
HISPANIC OR LATINO 3 2,159 12% 54,181,245 17%
AGE 0

- 4 1,467 8% 20,465,068 7%
AGE 0

- 17 4,881 26% 75,217,176 24%
AGE 65+ 1,835 10% 40,830,262 13%
NO HIGH SCHOOL
DIPLOMA 1,890 10% 32,060,510 10%

BELOW POVERTY LINE 2,599 14% 43,616,850 14% >= 1.2 of National Average

Sources: The demographics are from the U.S. Census Bureau, 2010. Information on the facilities is from U.S. EPA. 1. Where facility study areas overlap, the census block populations are only counted once in this table. Therefore, a facilit y level total may not match this summary total. 2. The “Minority” population is the overall population (in the first column) minus white population (in the second column). 3. The Census Bureau defines “Hispanic or Latino” as an ethnicity rather than as a racial category, Hispanics or Latinos may belong to any race. All of the races n oted in the table may include Hispanics.

African American = +32 percentage points or +257%
Minority = +28 percentage points or +101%
Age 0

- 4 = +1 percentage point or +22%4

Table 2.3 Summary of Demographic Data Analysis (Polycarbonate Production)

DEMOGRAPHIC
SUMMARY 1 NEAR SOURCE
TOTAL % OF NEAR

SOURCE TOTAL NATIONAL

TOTAL % OF NATIONAL

TOTAL
POPULATION 51,367 312,861,256
WHITE 36,506 71% 226,405,205 72%
AFRICAN AMERICAN 5,500 11% 39,475,216 13%
NATIVE AMERICAN 422 1% 3,646,995 1%
OTHER OR
MULTIRACIAL 8,939 17% 43,333,840 14%

MINORITY 2 14,861 29% 86,456,051 28%
HISPANIC OR LATINO 3 20,653 40% 54,181,245 17%
AGE 0

- 4 4,448 9% 20,465,068 7%
AGE 0

- 17 15,473 30% 75,217,176 24%
AGE 65+ 5,063 10% 40,830,262 13%
NO HIGH SCHOOL
DIPLOMA 7,222 14% 32,060,510 10%

BELOW POVERTY LINE 7,878 15% 43,616,850 14% >= 1.2 of National Average
Sources: The demographics are from the U.S. Census Bureau, 2010. Information on the facilities is from U.S. EPA. 1. Where facility study areas overlap, the census block populations are only counted once in this table. Therefore, a facility level total may not match this summary total. 2. The “Minority” population is the overall population (in the first column) minus white population (in the second column). 3. The Census Bureau defines “Hispanic or Latino” as an ethnicity rather than as a racial category, Hispanics or Latinos may belong to any race. All of the races noted in the table may include Hispanics.

Other or Multiracial = +3 percentage points or +26 %
Hispanic = +23 percentage points or +132%
Age 0

– 4 = +2 percentage points or +32%
Age 0

– 17 = +6 percentage points or +25%
No High School Diploma = +4 percentage points or +37%

The analysis of demographic data used proximity

- to

- a

- source as a surrogat e for exposure
to identify those populations considered to be living near affected sources, such that they have
notable exposures to emissions from these sources. The demographic data for this analysis were
extracted from the 2010 census data, which were p rovided to the EPA by the United States
Census Bureau. Distributions by race are based on demographic information at the census block
level, and all other demographic groups are based on the extrapolation of census block group

level data to the census bloc k level. The socio

- demographic parameters used in the analysis
included the following categories: Racial (White, African American, Native American, Other or
Multiracial, and All Other Races); Ethnicity (Hispanic); and Other (Number of people below the5

pove rty line, Number of people with ages between 0 and 18, Number of people greater than or
equal to 65, Number of people over age 25 without a high school diploma).
In determining the aggregate demographic makeup of the communities near affected
sources, the EPA focused on those census blocks within 3 miles of affected sources and
determined the demographic composition (e.g., race, income, etc.) of these census blocks and
compared them to the corresponding compositions nationally. The radius of 3 miles (or

ap proximately 5 km) is consistent with other demographic analyses focused on areas around
potential sources 1 2 3 4 however, not necessarily associated with the distance health risks are seen.
To the extent that any minority, low income, or indigenous subpopula tion is disproportionately
impacted by the emissions as a result of the proximity of their homes to these sources, that
subpopulation also stands to see increased environmental and health benefit from the emission
reductions called for by this rule.

1 U.S. GAO (Government Accountability Office). Demographics of People Living Near Waste Facilities. Washington DC: Government Printing Office; 1995. 2 Mohai P, Saha R. “Reass essing Racial and Socio

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

– 399. 3 Mennis 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. 4 Bullard RD, Mohai P, Wright B, Saha R, et al. Toxic Waste and Race at Twenty 1987

- 2007. United Church of Christ. March, 2007.