### U.S. Environmental Protection Agency, Region 9

ENVIRONMENTAL JUSTICE ANALYSIS

M C 

### E LMO 

### C REEK 

### U NIT 

### O IL 

### P RODUCTION 

### F ACILITY


### P ROPOSED 

### PSD P ERMIT 

### N O



### . NU 05-01

October 2014



### I NTRODUCTION

Executive Order 12898, entitled “Federal Actions To Address Environmental Justice in Minority Populations and Low-Income Populations,” states in relevant part that “each Federal agency shall make achieving environmenta l justice part of its mission by identifying and addressing, as appropriate, disproportionately hi gh and adverse human health or environmental effects of its programs, policies, and activitie s on minority populations and low- income populations.” Section 1-101 of Exec. Order 12898, 59 Fed. Reg. 7629, (Feb. 16, 1994). “Federal agencies are required to implement this order consistent with, and to the extent permitted by, existing law.” Id. at 7632. Based on this Executive Order, the EPA’s Environmental Appeals Board (EAB) has held that environmental justice issues must be consid ered in connection with the issuance of federal Clean Air Act (CAA) Prevention of Significant Deterioration (PSD) permits issued by EPA Regional Offices and states acting unde r delegations of Federal authority. See, e.g., In re Prairie State Generating Company , 13 E.A.D. 1, 123 (EAB 2006); In re Knauf Fiber Glass, GmbH , 8 E.A.D. 121, 174-75 (EAB 1999) (“Knauf I”). EPA Regional Offices or their delegates in the states have for several years incorporated enviro nmental justice considerations into their review of applications for PSD perm its. The EAB reinforced the importance of completing an environmental justice analysis in a re cent opinion discussed further below. See In re: Shell Gulf of Mexico, Inc. and Shell Offshore, Inc. , OCS Appeal Nos. 10-1 to 10-4, Slip Op. at 63-4 (EAB December 30, 2010) (“ Shell II ”).

EPA determined that there may be tribal, mi nority or low-income populations potentially affected by its proposed action on the McElmo Creek Unit Oil Production Facility (MCU Facility or Facility) PSD permit application, and determined that it would be appropriate to prepare an Environmental Justice Analysis fo r this action. EPA therefore prepared this Environmental Justice Analysis.

For purposes of the Executive Order on environmental justice, EPA has recognized that compliance with the applicable National Am bient Air Quality Standards (NAAQS) is emblematic of achieving a leve l of public health protection th at demonstrates that EPA’s issuance of a PSD permit for a proposed facility will not have disproportionately high and
adverse human health or environmental eff ects on minority populat ions and low-income populations. See, e.g., Shell II., slip op. at 74; In re Shell Offshore Inc. , 13 E.A.D. 357, 404-5 (EAB 2007) (“ Shell I ”); In re Knauf Fiber Glass, GmbH , 9 E.A.D 1, 15-17 (EAB 2000) (“ Knauf

II

”); In re AES Puerto Rico , L.P., 8 E.A.D. 324, 351 (EAB 1999). This is because the NAAQS are health-based standards, designe d to protect public health with an adequate margin of safety, including sensitive populations such as childre n, the elderly, and asthmatics. As the EAB recently observed, “[i]n the contex t of an environmental justice analysis, compliance with the NAAQS is emblematic of achieving a level of public health protec tion that, based on the level of protection afforded by the NAAQS, demonstrates that minority or low-income populations willMCU Oil Production Facili ty (Proposed Amended PS D Permit No. NU 05-01) Environmental Justice Analysis
October 2014 2 not experience disproportionately high and advers e human health or environmental effects due to exposure to relevant criteria pollutants.” Shell II , Slip Op. at 73.

The studies assessed by EPA in se tting NAAQS and the integration of the scientific evidence presented therein have undergone extensive critical review by EPA, the Clean Air Scientific Advisory Committee (CASAC), and the public. See e.g., Primary National Ambient Air Quality Standards for Nitrogen Dioxide, Final Rule , 75 Fed. Reg. 6474, 6478 Feb. 9, 2010. “The rigor of the review makes these studies, and their integr ative assessment, the most reliable source of scientific information on which to base decisions on the NAAQS.” Id. When setting the NAAQS, “[t]he Administrator’s fi nal decisions draw upon scientif ic information and analysis related to health effects, popul ation exposures, and risks; j udgments about the appropriate response to the range of uncertainties that are in herent in scientific ev idence and analyses; and comment received from CASAC and the public.” Id. at 6483. In light of these characteristics of the process for setting the standa rds, the EAB generally “relies on and defers to the Agency’s cumulative expertise when upholding a permit issue r’s environmental justice analysis based on a proposed facility’s compliance with the relevant NAAQS in a PSD appeal.” Shell II , Slip Op. at 74. The NAAQS are also the underpinning for th e State Implementation Plan process, which requires states to adopt rules and programs th at will reduce emissions causing air pollution.

With respect to the proposed amended PSD permit for the MCU Facility, EPA regulates emissions affecting the following NAAQS: nitrogen dioxide (NO 2 ) (1-hour and annual average), ozone (1-hour average), sulfur dioxide (SO 2 ) (1-hour and 3-hour aver age), and carbon monoxide (CO) (1-hour and 8-hour average). The pollutants that do not require PSD review are particulate matter less than 2.5 micrometers in diameter (PM 2.5 ), particulate matter less than 10 micrometers in diameter (PM 10 ), and lead (Pb). EPA has determined that the MCU Facility’s projected
emissions will not cause or contribute to a violation of the app licable NAAQS. EPA has determined that compliance with the applicable NAAQS is sufficient to satisfy the Executive Order as to the pollutants regul ated under the PSD program.



### F ACILITY 

### D ESCRIPTION

The MCU Facility is an existing oil and ga s production operation lo cated in Section 31, Township 40 South, Range 25 East within the F our Corners Area on the Navajo Nation Indian
Reservation near the ci ty of Aneth, San Juan County, Utah. The map in Figure 1 shows the location of the Facility.MCU Oil Production Facili ty (Proposed Amended PS D Permit No. NU 05-01) Environmental Justice Analysis
October 2014 3 Figure 1: Location of McElmo Creek Unit Oil Production Facility

The McElmo Creek Unit oilfield is one of four oilfield units in the greater Aneth oilfield on the Navajo Indian Reservation in southeas tern Utah as shown in Figure 2.MCU Oil Production Facili ty (Proposed Amended PS D Permit No. NU 05-01) Environmental Justice Analysis
October 2014 4 Figure 2: Oil field Units in the Aneth Oil Field

(Source: Resolute Natural Resources Company)

The Facility is on the McElmo Creek Unit oilfie ld, which includes field operations and a gas compression plant. The Main Flare is located at the gas compression plant. The MCU Facility started operation in the 1950s and was owned by S uperior Oil at the time. Mobil Exploration and Producing U. S. Inc. (Mobil) 1 purchased the Facility in 19 84. Resolute Natural Resources

1 References to Mobil include Mobil Exploration & Producing U.S., Inc. and ExxonMobil Production Company. The ExxonMobil Production Corporation was formed in 1999 by the merger of Exxon and Mobil, and ExxonMobil became the owner and operator of the MCU facility that year.MCU Oil Production Facili ty (Proposed Amended PS D Permit No. NU 05-01) Environmental Justice Analysis
October 2014 5 Company (Resolute), in partners hip with Navajo Nation Oil a nd Gas Company, acquired Mobil’s ownership interest in April 2006 and assumed oper ation of the Facility on June 1, 2006.



### P ROJECT 

### D ESCRIPTION

This permit action consists of incorporating pollution limits, terms, and conditions for the already existing Main Flare into the PSD Permit for the MCU Facility pursuant to a federal Consent Decree, which was filed and became eff ective on June 8, 2005. Paragraph 14.a of the Consent Decree requires th e owner and operator of the MCU Faci lity to submit, to EPA, a PSD permit application in accordance with the C AA and the PSD regulations at 40 CFR § 52.21 for the MCU Facility’s Main Flare no t later than the 180 days after th e effective date of the Consent
Decree. The Consent Decree re quires that the PSD application include, among other things, BACT and air quality analyses for SO 2 , CO, NO x , and VOC for the Main Flare. It also requires that the PSD application include terms and condi tions that are at leas t as stringent as the following Consent Decree requirements. 2

 Paragraph 9.a (Emission Limits)

 Paragraph 10 (Monitoring)

 Paragraph 11 (Operation and Maintena nce of Main Flare and Compressors)

 Paragraph 25(i)-(ix) (Reporting and Recordkeeping Requirements)

Mobil submitted a PSD application dated Dece mber 5, 2005 for the Main Flare, and also provided supplemental information in 2006 and 2007. Resolute submitted a revised PSD application dated April 2008 for th e Main Flare, as well as various supplemental information
thereafter.

This PSD permit action also consists of updati ng the equipment covered in the PSD Permit, which includes removing emission units that ha ve been shut down and removed from the MCU Facility site and the associated requir ements that apply to these units.



### R EGULATORY 

### F RAMEWORK

Under the CAA, a new major stationary source and a major modification to an existing major stationary source in an area that has been design ated attainment or unclassifiable are regulated under the PSD program. In addition, certain othe r pollutants for which no NAAQS have been set are subject to regulation with a defined applicability threshol d under the PSD regulations.

As mentioned previously in this document, th e MCU Facility is located in the Four Corners Interstate Air Quality Control Region which is cu rrently designated as attainment or unclassified for all criteria pollutants: NO 2 , SO 2 , CO, PM 10 , PM 2.5 , lead, and ozone. The U.S. Environmental Protection Agency (EPA) is the PSD permitting au thority for stationary source located on the Navajo Nation Indian Reservation since the tr ibe does not have a delegated or federallyapproved PSD program.

2 See Paragraph 4.o of the Consent Decree.MCU Oil Production Facili ty (Proposed Amended PS D Permit No. NU 05-01) Environmental Justice Analysis
October 2014 6 The following is a summary of the PSD permit history associated with the MCU Facility. 3

 February 2, 1987 – Initial PSD perm it issued for the Stage 2 CO 2 Project.

 October 27, 1987 – Amended PSD permit issued replacement of the three reciprocating internal combustion engines with two 3216 HP natural gas-fueled.

 March 21, 1989 – Amended PSD permit issu ed to change stack heights.

 April 19, 1991 – Amended PSD permit authoriz ed (1) replacement of existing heating with a waste heat recovery unit; (2) tempor ary replacement of an gas turbine with an identical unit during maintenance overhaul of th e turbine, (3) increase of the rating of an existing gas turbine from 3216 HP to 4390 HP; and (4) removal of a gas turbine from the permit that was never installed.

EPA’s current PSD permit action for the MCU Facil ity consists of incorporating the applicable
terms and conditions of the Consent Decree in to the PSD Permit for the MCU facility, and updating the PSD Permit to remove equipment th at has been shut down and removed from the Facility. Other than the repla cement of a fixed speed fan with a variable speed fan to provide better pollution control at the Main Flare, th is permit action does not authorize any new
construction or modification of exis ting equipment at the MCU Facility.



### E NVIRONMENTAL 

### J USTICE 

### S CREENING

Description of Local Area The existing Facility is located near the city of Aneth, San Juan County, Utah on the Navajo
Nation Indian Reservation. The area near Aneth is used primarily for oil and gas extraction and production. As shown in Figure 2 above, the MCU site is one of four oil field units located in
the Aneth Oil Field.

Figure 3 below shows the locations of cities and towns within 50 km (31 miles) of the MCU Facility, as well as other cities within the vicin ity of the site. Table 3 below shows that almost
all of the cities and towns within 50 km of the site each have populations that are less than 1000 persons. The Ute Mountain Reservation in south eastern Utah and in s outhwestern Colorado is the only other Indian reservation locate d within 50 km of the MCU Facility.

3 The previous PSD permits for the MCU Facility were is sued by the United States Environmental Protection Agency, Region 8 Office (EPA Region 8). EPA Region 8 was the PSD permitting authority for the portion of the Navajo Nation Indian Reservation in Utah until October 9, 1991. According to a Memorandum of Agreement dated October 9, 1991 between EPA Regions 6, 8, 9 and the Navajo Nation Indian Reservation regarding the implementation of EPA-related activities on the reservation, this authority was transferred to EPA Region 9. The Navajo Nation Indian Reservation covers portions of northeastern Arizona, southeastern Utah, and northwestern
New Mexico.MCU Oil Production Facili ty (Proposed Amended PS D Permit No. NU 05-01) Environmental Justice Analysis
October 2014 7 Figure 3: Cities/Towns with in 50 km of MCU Facility

Table 1: Cities/Towns within Vicinity of MCU Facility City Distance from MCU Facility Population Aneth, UT 5 km ( 3.1 mi) 501 Montezuma Creek, UT 19 km (11.8 mi) 335 Bluff, UT 30 km ( 18.6 mi) 258 White Mesa, UT 32 km (19.9 mi) 242 Red Mesa, AZ 36 km ( 22.4 mi) 480 Tselaki Dezza, UT 36 km (22.4 mi) 109 Teec Nos Pos, AZ 39 km (24.2 mi) 730 Towaoc, CO 42 km (26.1 mi) 1,087 Beclabito, NM 48 km (29.8 mi) 317 Cortez, CO 60 km (37.3 mi) 8,482 Shiprock, NM 71 km (44.1 mi) 8,295 Farmington, NM 109 km (67.7 mi) 45,877 Kayenta, AZ 110 km (68.4 mi) 5,189
(Source: U.S. Census Bureau, 2010 Demographic Profile)MCU Oil Production Facili ty (Proposed Amended PS D Permit No. NU 05-01) Environmental Justice Analysis
October 2014 8 Demographics EPA’s screening for potential environmental just ice concerns focused on an area encompassed by a 50 km radius from the MCU Facility. This radius includes the prim ary populations that are expected be impacted by the emissions from th e Facility. In Tables 2 and 3, EPA captured demographic information within four radii surrounding the MCU Facility at 5, 15, 25 and 50
km. 4 Appendix A contains maps of this data.

Table 2: Average Population and Median Househ old for Facility Location and Surrounding Areas

Distance / Area Population Median Household Income 5 km (3.1 mi) 167 $29,159 15 km (9.3 mi) 1,152 $32,378 25 km (15.5 mi) 1,856 $35,239 50 km (31.1 mi) 11,199 $34,932
Ute Mountain 1,742 Not available Navajo Nation 173,667 Not available San Juan County, UT 14,299 $37,615 State of Utah 2,657, 236 $60,564

The population data in Table 2 shows that there are less than 200 people within 5 km (3 miles) of the MCU Facility site, and a littl e more than 11,000 people within 50 km (31 miles) of the site. This is about 6% of the total population on the Nava jo Nation Indian Reservation. This data, as well as the population data in Table 1 above, indi cates that the area near the MCU Facility is sparely populated compared to th e population on the Navajo Nati on Indian Reservation, and that are likely very few reside nces near the site.

The median household incomes for populations within 5 to 50 km of the Facility range between $29,159 and $35,239. These figures are just below the average median income of $37,615 for San Juan County, but much lower than the av erage median income of $60,564 for Utah. Comparable income data was not available for the Navajo Nation Indian Reservation.

4 U.S. Census Bureau, 2000 and 2010 Data; ESRI, 2012; TANA, 2006; Google, 2012. Population derived assuming uniform population distribution and, therefore, represents an average.MCU Oil Production Facili ty (Proposed Amended PS D Permit No. NU 05-01) Environmental Justice Analysis
October 2014 9

Table 3: Other Average Demographic Informatio n for Facility Location and Surrounding Areas

Distance / Area Percent Minority Population Percent Population

under 18
Years of Age Percent Population

over 64 Years of Age Percent Linguistically

Isolated

Households Percent Over Age 25 w/o High School

Diploma

5 km (3.1 mi) 95.7% 37.3% 8.0% 7.9% 20.3% 15 km (9.3 mi) 93.4% 36.1% 8.0% 7.5% 21.2% 25 km (15.5 mi) 65.6% 32.8% 10.6% 4.8% 21.5% 50 km (31.1 mi) 54.5% 32.2% 11.6% 7.9% 19.9%

Ute Mountain 97.7% 29.4% 4.8% Not available Not available Navajo Nation 98.1% 37.4% 9.5% Not available Not available San Juan County, UT 55.8% 34.2% 10.8% 1.4% 10.4%

State of Utah 18.8% 31.4% 8.9% 1.0% 5.3%

Table 3 shows several demographic percentages near the MCU Facility. The percentage of minority population near the Facility is over 90%. These percentages are close to the minority population percentage of 98% for the Navajo Nation Indian Reservation. The minority population within 50 km of the Facility and on th e Navajo Nation Indian Reservation is almost
all Native American. These values are above the percentages of 55.8% and 18.8% for San Juan County and Utah, respectively.

Linguistic isolation limits a household’s capacity for civic engagement in the regulatory

process. 5 The percentage of linguist ically isolated households be tween 5 and 50 km from the Facility ranges from 4.8% and 7.9%. These values are much higher than the percentages of 1.4% and 1.0% for San Juan County and Utah, respectivel y. Comparable data for linguistically isolated
households was not available for the Navajo Nation Indian Reservation.

Children and elderly populations are sensitive groups that are particularly susceptible to exposures of high concentrations of air cont aminants. These groups are reflected in the populations under the age of 18 for children, and over the age of 64 for the elderly. Table 3 shows the percentage of the population under th e age of 18 ranges from 32.2% and 37.3%, and over the age of 64 from 8.0% to 11.6% between 5 km and 50 km of the site. These percentages are similar to the percentages for the Navajo Nation Indian Reservation of 37.4% for populations under 18, and 9.5% for populations over 64. Additi onally, these percentages for population close to the Facility are similar to the percentage s for San Juan County and Utah of 34.2% and 31.4%, respectively, for populations under age 18, a nd 10.8% and 8.9% for populations over age 64.

Education level is another fact or that may influence susceptib ility and vulnerability to air pollution. Limited formal education is a barrier to employment, health care and social resources, and can increase the risk of poverty, stress, a nd impacts from environmental stressors. The percentage of the population with less than a high school education with in 50 km of the MCU

5 A linguistically isolated household is defined by the U.S. Census Bureau as a household in which no member 14 years old and over (1) speaks only English or (2) speaks a non-English language and speaks English “very well.” In other words, all members 14 years old and over have at least some difficulty with English.MCU Oil Production Facili ty (Proposed Amended PS D Permit No. NU 05-01) Environmental Justice Analysis
October 2014 10 Facility ranges from 19.9% to 21.5%. These pe rcentages are much higher compared to the percentages of 10.9% and 5.3% for San Ju an County and Utah, respectively. Status of Air Quality in the Area The MCU Facility is located within the Four Corners Interstate Air Quality Control Region which is currently designated as attainment or unclassified for all criteria pollutants for which EPA has established a national ambient air quality standard (NAAQS). These pollutants include ozone, PM 10 , PM 2.5 , NO 2 , CO, SO 2 , and lead.

Impact of MCU Facility’s Emissions This environmental justice analysis focuses on the potential impacts on mi nority or low income populations from emissions that may affect the NAAQS that are applicable in the PSD review for the Facility. For this project, those ar e emissions potentially affecting the NAAQS for NO 2 (1-hr and annual), ozone (1-hour average), SO 2 (1-hour and 3-hour average), and CO (1-hour and 8-hour average). 6 EPA has determined from the modeled results for the project that impacts from the project are below the applicable NAAQS for all of the PSD pollutants regulated under the PSD permit, as discussed in more detail below.

The maximum modeled concentrations for the MCU Facility’s Main Flare are below the significant impact levels (SIL s) for annual and 1-hour NO 2 , and for annual, 24-hour and 3-hour

SO 2 , and EPA determined that a cumulative air qu ality impacts analysis was not required to demonstrate compliance for these pollutants/averaging times. See Table 4 below. For these pollutants/averaging times, EPA has determined fro m the modeled results for the Main Flare that the impacts are below the applicable NAAQS.

Table 4: McElmo Creek Unit Significant Impacts NAAQS pollutant & averaging time Project-only Modeled Impact μ g/m 3 Significant Impact Level (SIL), μ g/m 3 Project impact significant?

NO 2 , 1-hour 5.0 7.5 (4 ppb) No

NO 2 , annual 0.15 1 No

SO 2 , 1-hour 11.6 7.9 (3 ppb) Yes

SO 2 , 3-hour 11.6 25 No

SO 2 , 24-hour 4.65 5 No

SO 2 , annual 0.93 1 No CO, 1-hour 30 2000 No CO, 8-hour 30 500 No

For 1-hour SO 2, Resolute performed a PSD cumulative air quality impacts analysis. The results of this analysis, shown below in Table 5, demons trate that emissions from the Main Flare will
not cause or contribute to exceedances of the 1-hour SO 2 NAAQS.

6 The potential emissions of PM 2.5 , PM 10 , and Pb for this project are not subject to PSD review.MCU Oil Production Facili ty (Proposed Amended PS D Permit No. NU 05-01) Environmental Justice Analysis
October 2014 11 Table 6: McElmo Creek Unit Compliance with SO 2 (1-hour) NAAQS NAAQS pollutant & averaging time All Sources Modeled Impact (ug/m 3 ) Background
Concentration (ug/m 3 ) Cumulative impact w/ background (ug/m 3 ) NAAQS (ug/m 3 )

SO 2 , 1-hour 26.76 79 105.76 196

As stated above, the NAAQS are health-based st andards and are designed to protect public health with an adequate margin of safety, including sensitive populations, such as persons with asthma, children, and the elderly. Given EPA’s determination that the emissions increase for pollutants subject to PSD review for the MCU Facility will not cause or contribute to exceedances of the NAAQS, we do not expect the emissions increase of NO 2 , CO , and SO 2 associated with the Facility’s Main Flare to result in adverse human health impacts to any population; therefore, we do not expect that our action would have disp roportionately high and
adverse human health or environmental eff ects on minority or low-income populations.



### P UBLIC 

### P ARTICIPATION 

### /O UTREACH 

### A CTIVITIES

EPA is undertaking a numb er of actions to provide public pa rticipation opportunities to the community for the proposed PSD permit decision for the MCU Facility.

Availability of Proposed PSD Permit Decision The proposed PSD permit, Ambient Air Qual ity Impact Report/Fact Sheet (AAQIR/Fact Sheet), and Public Notice will be available for review at the following locations which include Navajo Nation chapter houses and libraries in the region:

 Navajo Nation Environmental Protection Ag ency, Fort Defiance, AZ, (928) 871-7692

 Monticello Library, Montic ello, UT, (435) 587-2281

 Blanding Library, Blanding, UT, (435) 678-2335

 Montezuma Creek Library, Mont ezuma Creek, UT, (435) 651-3309

 Bluff Library, Bluff, UT, (435) 672-9996

 La Sal Library, La Sal, UT, (435) 686-9936

 Aneth Chapter House, Aneth, UT, (435) 651-3525

 Red Mesa Chapter House near Montezuma Creek, UT, (928) 656-3679

 Teec Nos Pos Chapter House, Teec Nos Pos, AZ, (928) 656-3662

 Mexican Water Chapter House, Bluff, AZ, (928) 429-0986

 Sweetwater Chapter House, Sw eetwater, AZ, (928) 429-0977

 Dennehotso Chapter, Dennehotso, AZ, (928) 658-3300

Other key documents in EPA’s administrative record for the proposed PSD permit, including the permit application, the proposed permit, a nd AAQIR/Fact Sheet, are also available for public review on the EPA Region 9 website at http://www.epa.gov/region9/air/permit/r9- permits-issued.html , as well as at the EPA Region 9 office in San Francisco, CA.MCU Oil Production Facili ty (Proposed Amended PS D Permit No. NU 05-01) Environmental Justice Analysis
October 2014 12 Public Meeting and Hearing EPA has scheduled one public information mee ting followed by a public h earing for its proposed PSD permit decision: November 20, 2014 at the An eth Chapter House in Aneth Creek, Utah. The purpose of the public information meeting is to provide interested pa rties with additional information and an opportunity for informal di scussion of proposed PSD permit decision. The purpose of the public hearing is to provide the pu blic with an additional opportunity to provide
oral and/or written comments on EPA’s proposed PSD permit for the proposed PSD permit
decision.

While the percentage of linguistically isolated households is relatively low in the nearby communities and towns, the native Navajo langua ge is Diné Bizaad, and some members of the Diné-speaking population in the nearby communities may prefer to express their comments in their native language at the public hearings. In order to encourag e participation a nd aid attendees
who would like to submit their comments in Diné , EPA is providing a Diné interpreter at both public information meetings and public hear ings for its proposed PSD permit decision.

EPA has also prepared a public information sheet for distribution at the he arings that provides a brief overview of EPA’s proposed PSD permitti ng action for the Project. This handout is available on the EPA Region 9 website at http://www.epa.gov/region9 /air/permit/r9-permitsissued.html

.

Publication of Public Notice The notice of the proposed permit is being provid ed to the public through a wide variety of methods, including the following:

 Posting on the EPA Region 9 website;

 Publication in the Navajo Times; San Juan Record in San Juan County, Utah; Cortez Journal in Cortez, CO; and Farmington Daily Times in Farmington, NM;

 Distribution to a mailing list of those who have requested to be notified by U.S. Mail of any actions related to the Facility; and

 Distribution by email to those who have requested to be notified by email.

Public Service Announcement Radio Broadcast Additionally, because of the high percentage of the population that is Navajo Indian in the area, EPA is issuing a public service announcement (PSA ) in the Navajo Indian language of Diné to notify affected communities of our proposed PSD permit decision. The PSA will be made through the KTNN AM-660 ® commercial radio station that provides information and local news to the Four Corners Region (Ari zona, New Mexico, Utah, and Colorado).MCU Oil Production Facili ty (Proposed Amended PS D Permit No. NU 05-01) Environmental Justice Analysis
October 2014 13 

### C ONCLUSION

Our analysis indicates that the emissions of the pollutant associated with the MCU Facility project and regulated under EPA’s proposed PSD permit will not result in adverse human health impacts to any population, and that there will not be disproportionately high and adverse human health or environmental effects with respect to these air pollutants on minority or low-income populations residing near the propo sed Project or the community as a whole. We also note that our outreach strategy will make information rela ted to our proposed actio n more accessible to nearby communities, including potentially linguisti cally isolated populations that are primarily Diné speaking.

## APPENDIX A

DEMOGRAPHIC INFORMATIO N & ASSOCIATED MAPS

Contents
Appendix # Demographic Info / Map
A-1 Population Density A-2 Percent of Minority Population A-3 Percent of Population Under Age 18 A-4 Percent of Population Over Age 64 A-5 Percent Linguistically Isolated Households A-6 Percent Over Age 25 wi thout a High School Diploma
A-7 Median Household Income

### A PPENDIX 

### A-1: P OPULATION 

### D ENSITY

### A PPENDIX 

### A-2: P ERCENT 

### M INORITY 

### P OPULATION

### A PPENDIX 

### A-3: P ERCENT 

### P OPULATION 

### U NDER 

### A GE 

### 18

### A PPENDIX 

### A-4: P ERCENT 

### P OPULATION 

### O VER 

### A GE 

### 64

### A PPENDIX 

### A-5: P ERCENT 

### L INGUISTICALLY 

### I SOLATED 

### H OUSEHOLDS

### A PPENDIX 

### A-6: P ERCENT 

### P OPULATION 

### O VER 

### A GE 

### 25 W ITHOUT 

### H IGH 

### S CHOOL 

### D IPLOMA

### A PPENDIX 

### A-7: M EDIAN 

### H OUSEHOLD 

### I NCOME