PEOPLE ● PRIDE ● PROGRESS ● PARTNERSHIP 2145 Suttle Avenue ● Charlotte, NC 28208 ● (704) 336-5430 ● FAX (704) 336-4391

http://airquality.charmeck.org

MECKLENBURG COUNTY

Land Use and Environmental Services Agency - A I R Q U A L I T Y -

Environmental Justice Snapshot Issued March 11th, 2020

For the area surrounding Charlotte Pipe & Foundry Company, Inc.

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Environmental Justice Snapshot 1 Background

During a public hearing on May 8th, 2019 for the permit renewal for Charlotte Pipe & Foundry (CPF), Mecklenburg County Air Quality (MCAQ) agreed to perform an Environmental Justice (EJ) Analysis for the neighborhoods surrounding CPF. This air permit renewal was required by federal regulations for Title V facilities every 5 years. This permit action was not a result of proposed changes at the facility. Concerns from the surrounding community were raised about facility emissions in a potential Environmental Justice area. The purpose of our study and this report is to screen the surrounding community for Environmental Justice indicators as suggested by the U.S. Environmental Protection Agency. The final report will be available at the end of that process.

1.1 Environmental Justice Assessment 1.1.1 Definition of Environmental Justice

The U.S. Environmental Protection Agency (EPA) defines Environmental Justice as the fair treatment and 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 policies.

1.1.2 Description of an EJ Snapshot An Environmental Justice Snapshot reviews the demographic and socioeconomic data of the community that surrounds a facility. Typically, EJ Snapshots are completed prior to the construction of a facility to ensure that the surrounding community will not be disproportionately affected by any emissions from any new facility. The information is gathered based on a designated, appropriate radius from the facility and looks at race, poverty level, at risk populations (i.e. children and older adults), and non-English speakers. The radius includes all the neighborhoods that were represented at the hearing and modeled after snapshots performed by North Carolina Department of Environmental Quality. EJ snapshots are based on available data from the most recent census (2010 and 2017 estimates), EPA’s EJ Screen tool, and the North Carolina Department of Environmental Quality (NC DEQ) community mapping tool. No physical reconnaissance of the community is included. However, MCAQ staff has visited the Wilmore neighborhood previously for service requests.

1.2 Background on CPF Charlotte Pipe and Foundry has several facilities located around the United States and is headquartered in Charlotte, North Carolina. The facility in question is located on a 55-acre property near Uptown Charlotte at 1335 S Clarkson Street. The company was founded in 1901 and employs about 500 people in the Charlotte-area. Charlotte Pipe & Foundry operates a gray iron foundry and produces cast iron pipe and fittings from scrap metal. Specific operations include: raw material handling, iron melting and holding operations, permanent mold pipe production, fitting production, shell core production, pipe/fitting core manufacturing, pipe manufacturing, air set core making process, finishing shot blasting, grinding, coating and painting operations, woodworking workshop, and gasoline dispensing.

Regulated emissions from these processes include particulate matter (PM10), carbon monoxide (CO), volatile organic compounds (VOC), sulfur dioxide (SO2), nitrogen oxide (NOx), hazardous air pollutants (HAPs) and toxic air pollutants (TAPs). CP&F is classified as a major source under Title V of the Clean Air Act. A major source is a stationary source or group of stationary sources that emit or have the potential to emit 100 tons per year or more of criteria air pollutants.

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The facility’s emission sources are required to operate with pollution control equipment including baghouses to control particulate emissions, a wet scrubber to control pipe manufacturing emissions, and an afterburner to control emissions from iron melting and holding. Additionally, at the time of this snapshot, CPF is in compliance with all air permit requirements and have demonstrated that the facility is employing maximum feasible control to reduce the odor associated with production.

2 Geographic Area 2.1 Neighborhoods included in the Environmental Justice Snapshot

The Wilmore, Westover Hills, and Wesley Heights neighborhoods, along with Trademark Condominiums were specifically included in the Environmental Justice Analysis. These neighborhoods were identified through the CPF public hearing process.

2.1.1 Wilmore The Wilmore neighborhood is indicated on the map below in green. It is in Census Tract 36, which was used to obtain demographic data.

2.1.2 Westover Hills The Westover Hills neighborhood is indicated on the map below in yellow. It is in Census Tract 36, which was used to obtain demographic data.

2.1.3 TradeMark Condominiums TradeMark Condominiums is indicated on the map below as the orange dot. It is in Census Tract 1, which was used to obtain demographic data.

2.1.4 Wesley Heights The Wesley Heights neighborhood is indicated on the map below in blue. It is in Census Tract 41, which was used to demographic data.

2.2 Location of Charlotte Pipe & Foundry Charlotte Pipe & Foundry is located at 1335 S Clarkson St, Charlotte, NC 28208. It is in Census Tract 4 in Mecklenburg County. A census tract, established by the Census Bureau, is a geographic region defined for the purpose of taking the census. CPF is shown on Figure 1 below, CPF is indicated along with a 1.5-mile radius around the facility. This radius incorporates all the neighborhoods that were represented and expressed concerns about facility emissions at the hearing.

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Figure A

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3 Demographic Data 3.1 1.5- Mile Radius and County Demographic Indicators (From EPA’s EJ Screen tool)

The EPA has an online tool to look at environmental justice called EJ Screen. Below are the demographic indicators from EJ Screen for the population living within 1.5-mile radius of CPF. Additionally, indicators from EJ Screen were included for Mecklenburg County. The demographic index is a value calculated through EJ Screen by averaging two demographic indicators; Percent Low-Income and Percent Minority.

Table 1

The information obtained about the 1.5-mile radius shows that there is a lower demographic index, and smaller minority population, smaller linguistically isolated population, and smaller at-risk population (under age 5 and over age 64) compared to Mecklenburg County as a whole. The population was broken down by age because children and older adults are both considered sensitive populations with regard to air pollution. The 1.5-mile radius has a larger low-income population and larger population without a high school diploma than Mecklenburg County as a whole. Some EJ indicators are present (low income population and level of education), while others are not shown in the data (minority population, linguistically isolated, and at-risk populations). The 1.5- mile radius includes other neighborhoods in addition to those identified during the public hearing. A more detailed look at individual census tracts within the 1.5-mile radius is needed for further screening of EJ indicators.

3.2 County and Census Tract Demographic Data (From Census Data) To identify demographic and socioeconomic information in the neighborhoods of interest, MCAQ used Census Data from the Census Tracts for each neighborhood. Each Census Tract is shown below, along with the county data in order to gain a better understanding of the significance of the data. The category “identifies as a minority” includes all individuals who did not indicate that they were non-Hispanic whites. Only Spanish was highlighted as non-English speakers because it was the only language identified with over 1% of the population speaking it in these census tracts. The federal poverty level is determined on a scale based on household income and number of people in the household. For example, for an individual to be considered under the federal poverty line, they would have to earn less than $12,490 per year and a family of four would need to have a combined household income of less than $25,750.

1.5-mile Radius

of CPF Value Mecklenburg

Value

Demographic Indicators

Demographic Index 41% 42%

Minority Population 46% 52%

Low Income Population 35% 32%

Linguistically Isolated Population 1% 5%

Population with Less Than High School Education

11% 10%

Population under Age 5 4% 7%

Population over Age 64 7% 10%

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Table 2

Census Tract 1 (Trademark Condos)

Census Tract 36 (Wilmore & Westover

Hills)

Census Tract 41 (Wesley Heights)

Mecklenburg County

Total Population 4,661 4,166 3,438 1,093,901 Persons Under 18 2.7% 27.1% 11.7% 23.6%

Persons Over 65 9.9% 9.9% 6.3% 11.2% Identify as a Minority 32% 56% 65% 53.6%

Aged 5+ Spanish speaking in home

4.8% 4.3% 3.4% 11%

Persons Below Federal Poverty level

14% 23% 25% 11.4%

These numbers vary slightly from those of Table 1 because the 1.5-mile radius includes additional neighborhoods in Charlotte as seen in Figure A. None of the census tracts have a higher linguistically isolated population or population over 65 than Mecklenburg County as a whole. Census Tract 1 has a comparatively higher population living below the federal poverty level than Mecklenburg County as a whole, but lower than Census Tracts 36 and 41. Census Tract 36 has a comparatively higher population under 18, minority population, and population living below the federal poverty level than both Mecklenburg County and Census Tract 1. Census Tract 41 has a comparatively higher minority population, and population living below the federal poverty level than Mecklenburg County and Census Tracts 1 and 36.

4 Environmental Data 4.1 1.5- Mile Radius and County Environmental Indicators (From EPA’s EJ Screen tool)

Environmental indicators were retrieved from the EPA online tool, EJ Screen. The Particulate Matter value on the table below is an annual average calculated from the EPA’s Office of Air and Radiation (OAR) fusion of model and monitoring data. The ozone value is the ozone summer seasonal average of daily maximum 8-hour concentration in air, and the data was also from OAR fusion of model and monitoring data. NATA is EPA’s air toxics screening tool. It uses emissions information to estimate exposure and risk from breathing air toxics. NATA diesel PM provides a modeled estimate of the diesel particulate matter level in air. The NATA Air Toxics Cancer Risk is the lifetime cancer risk from inhalation of air toxics per million people. The NATA Respiratory Hazard Index is the ratio of exposure concentration to health-based reference concentration. Traffic Proximity and Volume is the count of vehicles (average annual daily traffic) at major roads within 500 meters, divided by distance in meters.

Table 3

The ozone and particulate matter (PM 2.5) values for the 1.5-mile radius of CPF is the same as the Mecklenburg County value. However, the Traffic Proximity and Volume in the 1.5-mile radius are comparatively higher than Mecklenburg

1.5-mile Radius of

CPF Value Mecklenburg

Value

Environmental Indicators

Particulate Matter (PM 2.5 in ug/m3) 10.8 10.7 Ozone (ppb) 45.1 45.1

NATA Diesel PM (ug/m3) 2.17 1.26 NATA Air Toxics Cancer Risk (risk per MM) 68 52

NATA Respiratory Hazard Index 3.5 2.4 Traffic Proximity and Volume (daily traffic

count/distance to road) 1600 380

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County as well as NATA indicators. These indicators are associated more with Mobile Sources, than Permitted Sources in these census tracts. Mobile Sources includes vehicles and pieces of equipment that emit pollutants while driving or moving throughout Mecklenburg County. Examples of Mobile Sources are on-road vehicles (cars, motorcycles, all types of trucks and buses) and nonroad equipment (tractors, dozers, locomotives, boats, lawnmowers, mobile generators).

5 Conclusion Based on the demographic data collected, some of the neighborhoods surrounding CPF have a high percentage of minority residents and a high percentage of residents who fall below the federal poverty line while others do not. Based on environmental indicators for the 1.5-mile radius of CPF compared with Mecklenburg County, there is no evidence of disproportionate impact from ozone or PM 2.5 in those communities. There are comparatively higher NATA indicators and traffic proximity and volume, both of which originate from mobile sources, such as cars and other on-road and non-road equipment.

5.1 Next Steps – Addressing Emissions From Mobile Sources Because the environmental data showed a larger impact from traffic and diesel particulate matter in the area around CPF compared to the county as a whole, MCAQ can work with the community to identify ways to reduce mobile source emissions. MCAQ can:

• prioritize GRADE (Grants to Replace Aging Diesel Engines) applications based within 1.5 miles of CPF; • connect local business to the Charlotte Area Air Awareness Business Coalition, which offers programs to

reduce emissions from commuting and fleet vehicles; and • continue to screen rezoning applications for heavy construction near sensitive populations,

recommending strategies that reduce emission from construction equipment when applicable. 5.2 Next Steps – Enhanced Communication and Outreach

In areas with low income population and high minority populations, the EPA recommends enhanced communication and outreach during the permitting process. Moving forward, MCAQ will follow the best practices suggested by the EPA when a Charlotte Pipe and Foundry permit modification would result in an emissions increase to include:

• provide notice for the public comment period, • create fact sheets with necessary information about proposed permit changes, • make permit files accessible on MCAQ’s website, and • offer informational and educational opportunities to community members.

MCAQ will continue to investigate complaints in a timely manner and ensure CPF continues to meet all their air quality permit requirements. MCAQ has also encouraged CPF to engage in discussions with leaders from the surrounding neighborhoods to evaluate actions to benefit the community.