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AMES Copper Group - Shelby Draft Environmental Justice Report North Carolina Department of Environmental Quality October 15, 2020

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Page 1: AMES Copper Group - Shelby - North Carolina Quality/permits/2020_public_notice... · 2/11/2020  · The pretreatment will include manual and mechanical methods of sorting the recycled

AMES Copper Group - Shelby Draft Environmental Justice Report

North Carolina Department of Environmental Quality October 15, 2020

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Contents 1 Introduction ..........................................................................................................................................4

2 Environmental Justice Evaluation........................................................................................................4

3 Proposed Project .................................................................................................................................5

4 Geographic Area ..................................................................................................................................7

5 Regional and Local Settings: ...............................................................................................................8

5.1 Race and Ethnicity .............................................................................................................................9

Regional Setting ...................................................................................................................................9

Local Setting ....................................................................................................................................... 10

5.2 Age and Sex ..................................................................................................................................... 11

Regional Setting ................................................................................................................................. 11

Local Setting ....................................................................................................................................... 11

5.3 Disability ........................................................................................................................................... 13

Regional Setting ................................................................................................................................. 13

Local Setting ....................................................................................................................................... 15

5.4 Poverty ............................................................................................................................................. 18

Regional Setting ................................................................................................................................. 18

Local Setting ....................................................................................................................................... 20

5.5 Household Income ........................................................................................................................... 23

Regional Setting ................................................................................................................................. 23

Local Setting ....................................................................................................................................... 23

6 Limited English Proficiency (LEP) ..................................................................................................... 25

7 Health ................................................................................................................................................. 27

9 Local Sensitive Receptors ................................................................................................................. 28

8 Local Industrial Sites .......................................................................................................................... 30

10 Conclusion ...................................................................................................................................... 31

Figure 1. Facility Location with a one-mile radius. .............................................................................. 7 Figure 2. Census tracts and counties around facility location........................................................... 8 Figure 3. County health rankings ........................................................................................................ 27 Figure 4. Sensitive receptors surrounding the facility....................................................................... 29 Figure 6. Permitted facilities surrounding the facility ........................................................................ 30

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Table 1. Facility Emissions Overview ................................................................................................... 6 Table 5-1. Regional Setting- Race and Ethnicity ................................................................................ 9 Table 5-2. Local Setting - Race and Ethnicity ................................................................................... 10 Table 5-3. Regional Setting- Age Groups and Sex........................................................................... 11 Table 5-4. Local Setting- Age Groups and Sex ................................................................................. 12 Table 5-5. Project Radius- Age Groups and Sex .............................................................................. 12 Table 5-6. Regional Setting- Disability................................................................................................ 14 Table 5-7. Local Setting- Disability ...................................................................................................... 16 Table 5-8. Regional Setting- Poverty .................................................................................................. 19 Table 5-9. Local Setting- Poverty ........................................................................................................ 21 Table 5-10. Regional Setting- Household Income ............................................................................ 23 Table 5-11. Local Setting- Household Income .................................................................................. 24 Table 5-12. Project Radius- Household Income ............................................................................... 24 Table 6-1.Limited English Proficiency ................................................................................................. 26 Table 7-1. Health Outcomes................................................................................................................. 27

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1 Introduction Environmental justice is 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 (US EPA). This evaluation examines the demographic and environmental conditions in Cleveland County, as well as census tracts 9511, 9512, 9513, and the one-mile radius around the property boundary of the proposed AMES Copper Group- Shelby facility. Finally, the demographics of the entire state of North Carolina are also considered as they compare to both the county and local census tract and radius settings.

The primary goal of the draft EJ Report is to encourage comments and suggestions from the surrounding community, industry, and environmental groups throughout the comment period. Public comments will be considered throughout the remainder of the comment period to inform the final EJ Report.

2 Environmental Justice Evaluation The Department has assessed the permit application and the demographics of the communities surrounding the requested permit application. Accordingly, the Environmental Justice Report includes:

• Permit applications submitted by AMES Copper Group - Shelby • Facility emissions overview • Study of area demographics for both locations [determined by utilizing

the US EPA Environmental Justice tool (EJSCREEN) https://ejscreen.epa.gov/mapper/ and current, available census data. https://data.census.gov/cedsci/

• Comparison of local area demographics to both county and statewide census data • County health assessment • Surrounding sensitive receptors • Local industrial sites (using the NCDEQ Community Mapping System

https://ncdenr.maps.arcgis.com/apps/webappviewer/index.html?id=1eb0fbe2bcfb4cccb3cc212af8a0b8c8).

Demographics for Cleveland County, as well as the state, will be compared to the local (census tracts and project radius) level data to identify any disparities surrounding either of the project areas. Using standard environmental justice guidelines from the EPA and National Environmental Policy Act (NEPA) documentation, certain areas will be flagged as potentially underserved communities (more detail under Section 5: Regional and Local Settings; page 8)

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3 Proposed Project AMES Copper Group - Shelby submitted a permit application for a new facility located in Shelby, North Carolina (Facility ID No. 2300397). The applicant proposes to produce fire-refined copper using secondary recycled metals as a raw material. The fire-refined copper will be cast into anodes, sold to other companies, and shipped off-site for further refining. The cast copper anodes will be manufactured from a typical charge recycled feedstock comprised of approximately 90% copper on average. Typical steps in the processing of lower grade copper, such as blast furnace or convertor, will not be required in this process. The recycled feedstock material will be a mixture of copper-bearing scrap comprised of tubing, valves, windings, wire, radiators, turnings, mill scrap, ammunition casings, and high copper containing alloys. The secondary copper recovery process consists of scrap pretreatment, smelting, and casting. The pretreatment will include manual and mechanical methods of sorting the recycled scrap. The lighter scrap will be compressed into bales in a hydraulic press. The scrap and bales will be loaded into the scrap charging machine to load the furnace. There will be no sweating, burning insulation from the wire, or kiln drying at this facility. The smelting process consists of a 20.47 million Btu per hour natural gas-fired tilting refinery furnace. One cycle takes about 24 hours to complete. This cycle has the following steps: charging and melting, oxidation and de-slagging, reduction, and casting. The casting cycle is the final step in the process. The molten copper is transferred via a heated launder system from the anode furnace to the caster. Anode molds are configured on a casting wheel. As the molds are filled with liquid cooper, they are moved to the cooling areas. After solidification, the anodes are stacked and then packaged for transportation off-site. The final anode product has a purity of 99.7% copper.

The facility will be installing fabric filter controls for particulate emissions and a sodium bicarbonate injection system to control hydrogen chloride emissions. In an email letter dated July 14, 2020, EPA determined the facility is subject to NESHAP 40 CFR Part 63 Subpart FFFFFF “National Emission Standards for Hazardous Air Pollutants for Secondary Copper Smelting Area Sources.” Therefore, the facility it is required by regulation to obtain a Part 70 Permit (Title V) in accordance with 40 CFR 63.11153(d). In accordance with 15A NCAC 02Q .0702(a)(27), this facility is exempt from North Carolina State air toxics regulations. However, the DAQ is required to perform a health risk assessment. The facility completed a toxics review as part of its application and performed modeling on hydrogen chloride as required by the DAQ in 15A NCAC 02Q .0711. Based on the memo from DAQ’s Air Quality Analysis Branch dated June 10, 2020, the facility has modeled in compliance on a source-by-source basis for the refinery furnace (ID No. TRF-1). The model did include fugitive emissions from the process and indicated a maximum concentration of 82 microgram/m3 which is 12% of the hydrogen chloride acceptable ambient level in 15A NCAC 02D .1104. Therefore, the DAQ has determined that the toxic emissions from this facility will not cause an unacceptable risk.

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Table 1. Facility Emissions Overview

Pollutant Expected Actual Emissions (tons/yr)

Potential Emissions Before Controls (tons/yr)

Potential Emissions After

Controls (tons/yr) PM 17.00 2,698.53 18.88

PM10 13.41 2,694.92 15.27 PM2.5 13.20 2,694.69 15.05 SO2 0.08 0.30 0.30 NOX 63.23 71.91 71.91 CO 19.50 22.19 22.19

VOC 0.60 2.66 2.66 Highest Individual HAP (hydrogen

chloride) 8.46 1,271.33 9.65

Total HAP 8.63 1,272.20 10.52

The permit contains limitations for PM, PM10, PM2.5, NOx, and HAPs.

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4 Geographic Area The proposed facility for AMES Copper Group- Shelby, is located at 135 Old Boiling Springs Road, Shelby, NC 28152 (Figure 1) The highest off-site ambient air impacts will occur at the plant fence line. A one-mile radius was used to evaluate the local demographics and socioeconomics to appropriately include the surrounding community and help inform public outreach efforts.

Figure 1. AMES Copper facility location with one-mile radius.

This proposed facility is located in Cleveland County. In 2020, Cleveland County was designated as a Tier 1 county by the NC Department of Commerce. Tier 1 counties encompass the 40 most distressed counties based on average unemployment rate, median household income, percentage growth in population, and adjusted property tax per capita. Tier 2 counties encompass the next 40 counties based on this ranking system.

The one-mile radius used in this analysis includes areas encompassed by three census tracts. The facility address resides in Census Tract 9513 in Cleveland County. The one-mile buffer for the facility enters census tracts 9511 and 9512, all in Cleveland County (Figure 2). Census tracts are small, relatively permanent statistical subdivisions of a county with a unique numeric code (US Census Bureau). None of the census tracts encompass land within a state designated tribal statistical area. However, this does not mean that there are no individuals within these census tracts with Tribal or Native American/American Indian affiliation.

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Figure 2. Census tract boundaries surrounding the proposed facility location.

5 Regional and Local Settings

The following sections on race and ethnicity, age and sex, disability, poverty, household income, and Limited English Proficiency (LEP) populations are based on US Census Bureau data, first at a state and county level (regional setting), and then at a census tract and project radius level (local setting). The surrounding census tracts included will be any census tract that overlaps into the one-mile radius. Demographics of the counties will be compared to the local level data to identify any disparities surrounding the project area. Using standard environmental justice guidelines from the EPA and NEPA documentation, the following conditions will be flagged as potential communities of concern:

9511

9513 9512

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1. 10% or more in comparison to the county or state average 2. 50% or more minority 3. 5% or more in comparison to the county or state average for poverty

For example, if a census tract has 35% of the population classified as low income but the county consists of 30% low income, the census tract would exceed the county average by 16.7% and thus be flagged as a potential area of concern. For this report, census data from 2010 and census data estimates from 2011-2015 and 2018 were used. 2010 Census Bureau data is real data gathered every ten years, whereas the estimates from the more recent years are modeled based on the real data. For the data gathered from the 2014-2018 and 2011-2015 estimates, the margin of error (MOE) has been included. This value is a measure of the possible variation of the estimate around the population value (US Census Bureau). The Census Bureau standard for the MOE is at the 90% confidence level and may be any number between zero and the MOE value in either direction (indicated by +/-).

5.1 Race and Ethnicity

Regional Setting According to the 2010 US Census Data Table 9: Hispanic or Latino, and Not Hispanic or Latino by Race, North Carolina’s population totaled 9,535,483 individuals (Table 5-1). The three most common racial and ethnic groups across the state were White (68.3%), Black or African-American (21.2%), and Hispanic or Latino (of any race) at 8.4%.

Cleveland County had a total population of 98,078 individuals (Table 5-1). The three most common racial or ethnic groups within the county were White (74.2%), Black or African American (20.6%), and Hispanic or Latino (2.8 %). The only population that was greater than 10% different when compared to the state was the White population.

Table 5-1. Regional Setting - Race and Ethnicity

North Carolina Cleveland County

Race and Ethnicity Number Percent Number Percent Total Population 9,535,483 100.0 98,078 100 White 6,223,995 65.3 72,793 74.2 Black or African American 2,019,854 21.2 20,237 20.6 American Indian or Alaska Native 108,829 1.1 193 0.2 Asian 206,579 2.2 735 0.7 Native Hawaiian and Other Pacific Islander 5,259 0.1 22 0.0 Some other Race 15,088 0.2 74 0.1 Two or More Races 155,759 1.6 1,268 1.3 HISPANIC OR LATINO (of any race) 800,120 8.4 2,756 2.8 Source: US Census Bureau, 2010 Census All bolded and orange cells indicate a difference that is greater than 10% when compared to the State

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Local Setting

According to the 2010 US Census Data Table 9: Hispanic or Latino, and Not Hispanic or Latino by race or ethnicity, the largest population within Census Tract 9511 was White at 51.0%, followed by Black or African American at 42.6%, and Hispanic or Latino at 3.5% (Table 5-2). The Black or African American Population (42.6%) was greater than 10% different compared to the county (20.6%) and state (21.2%). The largest population group within Census Tract 9512 was White at 62.8%, followed by Black or African American at 30.4%, and Hispanic or Latino at 3.7%. The Black or African American Population (42.6%) was greater than 10% different compared to the county (20.6%) and the state (21.2%). The largest population within Census Tract 9513 was White at 85.4% followed by Black or African American (9.7%,) and Hispanic or Latino (3.6%). The White Population (85.4%) was greater than 10% different compared to the county (74.2%) and the state (65.3%). The largest population in the one-mile radius surrounding the AMES Copper facility was White at 84.0% (which is greater than 10% when compared to the state at 68.5%), followed by Black or African American (12.0%), and Hispanic or Latino (of any race) (3.0%). The White Population (84%) was greater than 10% different compared to the county (74.2%) and the state (65.3%).

Table 5-2. Local Setting– Race and Ethnicity

Subject Project Area - 1 Mile Census Tract 9511 Census Tract 9512 Census Tract 9513 Race and Ethnicity Number Percent Number Percent Number Percent Number Percent Total Population 538 100 2,842 100 5,253 100.0 2,914 100.0 White 452 84 1,449 51.0 3,299 62.8 2,488 85.4 Black or African American 67 12 1,211 42.6 1,595 30.4 282 9.7 American Indian or Alaska Native 1 0 10 0.4 11 0.2 5 0.2

Asian 3 1 24 0.8 60 1.1 5 0.2 Native Hawaiian and Other Pacific Islander 0 0 0 0.0 1 0.0 0 0.0

Some other Race 0 0 1 0.0 1 0.0 1 0.0 Two or More Races 5 1 48 1.7 90 1.7 28 1.0 HISPANIC OR LATINO (of any race) 19 3 99 3.5 196 3.7 105 3.6

Source: US Census Bureau, 2010 Census All bolded and orange cells indicate a difference that is greater than 10% when compared to the State All bolded and blue cells indicate a difference that is greater than 10% when compared to the county and the State

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5.2 Age and Sex

Regional Setting According to the 2010 US Census Data Table P 12: Sex by Age, North Carolina had a total population of 9,535,483 individuals (Table 5-3). The largest percentage of the total state population (63.1%) was between the ages of 18 and 64, followed by under 18 years (23.9%), and 65 years and older (12.9%).

Cleveland County had a total population of 98,078 individuals. The largest percentage of the total population (61.6%) was between the ages of 18 and 64, followed by under 18 years (23.4%), and 65 years and older (15.0%). Both sexes, male and female 65 years and over were greater than 10% different from the state. The median age for both sexes is slightly higher than that of the state by approximately 3 years.

Table 5-3. Regional Setting- Age Groups and Sex

North Carolina Cleveland County

Age Number Percent Number Percent

Both sexes Male Female Both

sexes Male Female Both Sexes Male Female Both

Sexes Male Female

Total Population 9,535,483 4,645,492 4,889,991 100 100 100 98,078 47,319 50,759 100 100 100 Under 5 years 632,040 322,871 309,169 6.6 7 6.3 5,819 2,942 2,877 5.9 6.2 5.7 Under 18 years 2,281,635 1,167,303 1,114,332 23.9 25.1 22.8 22,998 11,833 11,165 23.4 25.0 22.0 18 to 64 years 6,019,769 2,954,233 3,065,536 63.1 63.6 62.7 60,403 29,328 31,075 61.6 62.0 61.2 65 years and over 1,234,079 523,956 710,123 12.9 11.3 14.5 14,677 6,158 8,519 15.0 13.0 16.8

Median Age 37.4 36 38.7 40.3 39.1 41.5 Source: US Census Bureau, 2010 Census All bolded and orange cells indicate a difference that is greater than 10% when compared to the State

Local Setting According to the 2010 US Census Data Table P 12: Sex by Age, Census Tract 9511 had a total population of 2,842 individuals (Table 5-4). The largest percentage of the total population (58.4%) was between the ages of 18 and 64, followed by under 18 years (24.1%), and 65 years and older (17.5%). The total population, as well as the female subgroup, have a population of 65 years and older that is greater than 10% different than the county and state. The male subgroup has a population of under 5 years that is greater 10% different than the county and the state.

Census Tract 9512 had a total population of 5,253 individuals. The largest percentage of the total population (59.3%) was between the ages of 18 and 64, followed by under 18 years (22.7%), and 65 years and older (18.0%). The total population, as well as the male and female subgroups have a population of 65 years and older that is greater than 10% different than the county and state, with the female population being the highest.

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Census Tract 9513 had a total population of 2,914 individuals. The largest percentage of the total population (61.1%) was between the ages of 18 and 64, followed by under 18 years (25.0%), and 65 years and older (14.9%). The total population, as well as the male and female subgroups have a population of 65 years and older that is greater than 10% different than the state.

Table 5-4. Local Setting- Age Groups and Sex

Census Tract 9511 Census Tract 9512

Age Number Percent Number Percent

Both Sexes Male Female Both

Sexes Male Female Both sexes Male Female Both

sexes Male Female

Total Population 2,842 1,350 1,492 100 100 100 5,253 2,432 2,821 100 100 100 Under 5 years 223 109 114 7.8 8.1 7.6 363 175 188 6.9 7.2 6.7 Under 18 years 685 360 325 24.1 26.7 21.8 1,192 596 596 22.7 24.5 21.1 18 to 64 years 1661 819 842 58.4 60.7 56.4 3,114 1,459 1,655 59.3 60.0 58.7 65 years and over 496 171 325 17.5 12.7 21.8 947 377 570 18.0 15.5 20.2

Median Age 39.9 36.5 42.9 41 39.1 42.9 Source: US Census Bureau, 2010 Census All bolded and orange cells indicate a difference that is greater than 10% when compared to the State All bolded and blue cells indicate a difference that is greater than 10% when compared to the county and the State

Census Tract 9513

Age Number Percent

Both sexes Male Female Both

sexes Male Female

Total Population 2,914 1,454 1,460 100 100 100 Under 5 years 175 89 86 6.0 6.1 5.9 Under 18 years 699 364 335 24.0 25.0 22.9 18 to 64 years 1,780 890 890 61.1 61.2 61.0 65 years and over 435 200 235 14.9 13.8 16.1 Median Age 41.4 40.9 42.1

One Mile Radius EJSCREEN identified an approximate population of 538 in the 1-mile surrounding the facility. The largest population was 18+ years (76%), followed by 0-17 years at 21% (Table 5-5).

Table 5-5. Project Radius- Age Groups and Sex Age Project Area - 1 Miles

Number Percent Both sexes Male Female Both sexes Male Female

Total Population 538 260 278 100 48 52 Under 5 years 33 6 Under 18 years 129 24 18+ 409 76 65 years and over 96 18 Source: US Census Bureau, 2010 Census. Obtained through EJSCREEN 2019

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5.3 Disability

Regional Setting According to the 2018 American Community Survey 5-Year Estimates, Table S1810 Disability Characteristics from the US Census Bureau, the state of North Carolina had an estimated total population of 9,952,031noninstitutionalized citizens. Of those individuals, an estimated 13.6% (MOE +/- 0.1%) had a disability. The largest population of disabled civilians were 75 years and over (50.1%, MOE +/- 0.4%). The second largest population was the 65 years to 74 years at 26.6% (MOE +/- 0.3%). By race, American Indian and Alaskan Native had the highest estimated disability rate of 18.5% (MOE +/- 0.8%). Black or African-American, White, and Two or More Races were the next three highest population estimates with disabilities in North Carolina, at 14.8% (MOE +/-0.2%), 14.6% (MOE +/- 0.1%), and 11.4% (MOE +/- 0.5%), respectively (Table 5-6).

Cleveland County had an estimated total population of 96,923 noninstitutionalized civilians. Of those, an estimated 16.2% (MOE +/- .9%) had a disability. The largest population of disabled civilians were 75 years and over (50.1%, MOE +/- 2.8%) followed by 65 years to 74 years (49.2, MOE +/-4.3%). By race, Two or More races had the highest estimated disability rate (22.0%, MOE +/-10.1%). The following population groups displayed estimates that were greater than 10% different when compared to the state: Total population, 35 years to 64 years, 65 years to 74 years, male, female, White, Black or African American, American Indian and Alaska Native, Asian, and Two or more races.

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Table 5-6. Regional Setting- Disability

North Carolina Cleveland County

Subject Total With a Disability Percent with a

Disability Total With a Disability Percent with a Disability

Estimate Margin of Error +/- Estimate Margin of

Error +/- Estimate Margin of Error +/- Estimate Margin of

Error +/- Estimate Margin of Error +/- Estimate Margin of

Error +/- Total civilian noninstitutionalized population

9,952,031 1,743 1,350,533 7,387 13.6 0.1 96,923 111 15,736 846 16.2 0.9

Population under 5 years 603,155 767 4,761 613 0.8 0.1 5,389 44 24 39 0.4 0.7 Population 5 to 17 years 1,685,827 941 94,822 2,522 5.6 0.2 16,049 91 699 189 4.4 1.2 Population 18 to 34 years 2,216,915 1,791 146,329 3,165 6.6 0.1 19,888 122 1,430 302 7.2 1.5 Population 35 to 64 years 3,915,727 1,742 556,505 5,319 14.2 0.1 38,345 148 6,952 528 18.1 1.4 Population 65 to 74 years 932,178 1,157 248,418 2,902 26.6 0.3 10,389 95 3,254 281 31.3 2.7 Population 75 years and over 598,229 982 299,698 2,471 50.1 0.4 6,863 103 3,377 298 49.2 4.3

SEX Male 4,786,233 2,284 647,158 4,946 13.5 0.1 46,767 206 7,357 500 15.7 1.1 Female 5,165,798 1,829 703,375 5,616 13.6 0.1 50,156 222 8,376 626 16.7 1.2 RACE AND HISPANIC OR LATINO ORIGIN

White (not Hispanic or Latino) 6,316,065 2,254 920,269 6,535 14.6 0.1 13,885 214 11,707 649 16.5 0.9

Black or African American 2,123,353 5,762 314,216 3,706 14.8 0.2 7,202 228 3,361 434 16.6 2.2 American Indian and Alaska Native 118,231 1,604 21,874 929 18.5 0.8 23 26 65 65 21.2 22.0

Asian 279,615 2,022 13,450 961 4.8 0.3 130 22 113 79 11.4 8.3 Native Hawaiian and Other Pacific Islander 6,447 668 635 178 9.8 2.7 32 38 0 29 0.0 64.2

Some other Race 303,837 7,743 16,218 1,100 5.3 0.4 429 184 71 50 4.8 3.3 Two or more races 255,739 6,070 29,063 1,446 11.4 0.5 269 163 296 152 22.0 10.1 Hispanic or Latino 916,366 863 57,239 1,970 6.2 0.2 806 27 206 93 6.2 2.8 Source: US Census Bureau, ACS 5-year Estimates (2018) All bolded and orange highlighted cells indicate a difference that is greater than 10% when compared to the State

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Local Setting According to the 2018 American Community Survey 5-Year Estimates, Table S1810 Disability Characteristics from the US Census Bureau, Census Tract 9511 had an estimated total population of 3,085 noninstitutionalized citizens (Table 5-7). Of those individuals, an estimated 20.7% (MOE +/- 7.6%) had a disability. The largest population group of civilians with a disability were Some Other Race (MOE +/- 100%) and Hispanic or Latino (MOE +/- 76.9%), both at an estimated 100%. This population group was followed by those 75 years and over, at 54.4% (MOE +/- 16.9%) having a disability. The following population groups had estimates that were greater than 10% when compared to the state and county: total civilian noninstitutionalized population, 35 years to 64 years, 65 years to 74 years, female, White, Some other Race, Two or more Races, and Hispanic or Latino.

Census Tract 9512 had an estimated total population of 5,618 noninstitutionalized citizens. Of those individuals, an estimated 18.7% (MOE +/- 3.6%) had a disability. The largest population group of civilians with a disability was Asian (49.3%, MOE +/- 50.7%), followed by 75 years and older (46.9%, MOE +/- 14.4%). Both the total population with a disability and the Asian population groups had estimates that were greater than 10% when compared to the state and the county.

Census Tract 9513 had an estimated total population of 3,219 noninstitutionalized citizens. Of those individuals, an estimated 14% (MOE +/- 3.7%) had a disability. The largest population of disabled civilians were 75 years and over (49.8%, MOE +/- 15.3%), followed by 65-74 years (32.7%, MOE+/- 15.2%). The population groups 65 to 74 years and female were greater than 10% compared to the state. None of the population groups had estimates that were greater than 10% when compared to the state and the county.

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Table 5-7. Local Setting- Disability

Census Tract 9511 Census Tract 9512

Subject Total With a Disability Percent with a

Disability Total With a Disability Percent with a Disability

Estimate Margin of Error +/- Estimate Margin of

Error +/- Estimate Margin of Error +/- Estimate Margin of

Error +/- Estimate Margin of Error +/- Estimate Margin of

Error +/- Total civilian noninstitutionalized population 3,085 401 639 227 20.7 7.6 5,618 453 1,052 217 18.7 3.6

Population under 5 years 234 101 0 12 0.0 13.9 537 197 0 17 0.0 6.3 Population 5 to 17 years 422 128 18 29 4.3 6.8 686 223 19 32 2.8 4.5 Population 18 to 34 years 688 209 49 50 7.1 7.1 1,143 323 168 148 14.7 11.8 Population 35 to 64 years 1,194 207 301 155 25.2 13.6 2,160 328 434 145 20.1 6.2 Population 65 to 74 years 332 139 154 142 46.4 28.7 535 151 170 95 31.8 13.6 Population 75 years and over 215 88 117 63 54.4 16.9 557 130 261 100 46.9 14.4 SEX Male 1,522 237 206 102 13.5 6.7 2,501 361 477 174 19.1 6.4 Female 1,563 249 433 165 27.7 10.6 3,117 460 575 182 18.4 5.7 RACE AND HISPANIC OR LATINO ORIGIN

White (not Hispanic or Latino) 1,750 283 413 176 23.6 11.3 2,956 417 773 196 26.2 5.2 Black or African American 1,285 262 184 112 14.3 8.9 1,643 509 169 107 10.3 6.3 American Indian and Alaska Native 0 12 0 12 - - 0 17 0 17 - - Asian 0 12 0 12 - - 75 66 37 43 49.3 50.7 Native Hawaiian and Other Pacific Islander 0 12 0 12 - - 23 41 0 17 0.0 64.2

Some other Race 6 11 6 11 100.0 100.0 293 242 14 29 4.8 10.3 Two or more races 34 43 26 40 76.5 57.9 109 89 11 17 10.1 19.1 Hispanic or Latino 16 18 16 18 100.0 76.9 865 375 62 66 7.2 8.3 Source: US Census Bureau, ACS 5-year estimates (2018) All bolded and orange highlighted cells indicate a difference that is greater than 10% when compared to the State All bolded and blue highlighted cells indicate a difference that is greater than 10% when compared to the County and State

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Table 5-7. Local Setting- Disability cont’d

Census Tract 9513

Subject Total With a Disability Percent with a

Disability

Estimate Margin of Error +/- Estimate Margin of

Error +/- Estimate Margin of Error +/-

Total civilian noninstitutionalized population 3,219 308 451 120 14.0 3.7 Population under 5 years 161 99 0 12 0.0 19.4 Population 5 to 17 years 617 172 0 12 0.0 5.5 Population 18 to 34 years 379 130 13 19 3.4 5.4 Population 35 to 64 years 1,557 172 230 101 14.8 6.4 Population 65 to 74 years 254 63 83 45 32.7 15.2 Population 75 years and over 251 74 125 55 49.8 15.3 SEX Male 1,546 224 193 82 12.5 4.9 Female 1,673 175 258 80 15.4 4.7 RACE AND HISPANIC OR LATINO ORIGIN White (not Hispanic or Latino) 2,577 262 402 115 15.6 4.2 Black or African American 281 184 38 29 13.5 11.6 American Indian and Alaska Native 0 12 0 12 - - Asian 65 81 11 19 16.9 15.0 Native Hawaiian and Other Pacific Islander 0 12 0 12 - - Some other Race 189 186 0 12 0.0 16.8 Two or more races 52 55 0 12 0.0 42.7 Hispanic or Latino 272 172 0 12 0.0 12.1 Source: US Census Bureau, ACS 5-year estimates (2018) All bolded and orange highlighted cells indicate a difference that is greater than 10% when compared to the State All bolded and blue highlighted cells indicate a difference that is greater than 10% when compared to the County and State

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5.4 Poverty

Regional Setting According to the Census Table S1701, Poverty Status in the Past 12 Months, 2018 American Community Survey 5-Year Estimates, from the US Census Bureau, North Carolina had an estimated population of 9,881,292, with 15.4% (MOE +/- 0.2%) below the poverty level (Table 5-8). Across all subjects, Some Other Race had the highest percent living below the poverty level at 32.0% (MOE +/- 1.4%). The next three subjects with the highest poverty level were Hispanic or Latino at 30.1% (MOE +/- .8%), American Indian and Alaska Native at 26.2% (MOE +/- 1.5%), and Black or African-American at 24.9% (MOE +/- .4%). The age group with the highest population below poverty was under 18 (22.9%, MOE +/- 0.4%), followed by 18 to 64 (15.3%, MOE +/- 0.2%).

Cleveland County had an estimated population of 95,262 with 20.2% (MOE +/-1.7%) living below the poverty level. Across all subjects, Native Hawaiian and Other Pacific Islander had the highest percent living below the poverty level at 100% (MOE +/- 64.2%). The next subjects with the highest poverty level were Hispanic or Latino at 32.4% (MOE +/- 10.4%), and Black or African American at 29.6% (MOE +/-3.8). All subject groups had a greater than 5% difference when compared to the state, excluding Two or more Races, Asian, and American Indian and Alaska Native.

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Table 5-8. Regional Setting- Poverty

North Carolina Cleveland County

Subject Total Below poverty level Percent below

poverty level Total Below poverty level Percent below poverty level

Estimate Margin of Error +/- Estimate Margin of

Error +/- Estimate Margin of Error +/- Estimate Margin of

Error +/- Estimate Margin of Error +/- Estimate Margin of

Error +/- Population for whom poverty status is determined 9,881,292 1,522 1,523,949 15,319 15.4 0.2 95,262 301 19,262 1,609 20.2 1.7

AGE Under 18 2,258,876 1,607 498,013 7,632 22.0 0.3 21,003 186 5,860 715 27.9 3.3 18 to 64 6,092,009 1,103 884,618 9,282 14.5 0.2 57,007 251 10,990 950 19.3 1.7 65 years and over 1,530,407 995 141,318 2,705 9.2 0.2 17,252 135 2,412 386 14.0 2.2 SEX Male 4,779,533 2,237 669,307 8,648 14.0 0.2 46,018 263 8,218 896 17.9 1.9 Female 5,101,759 2,244 854,642 8,676 16.8 0.2 49,244 286 11,044 925 22.4 1.8 RACE AND HISPANIC OR LATINO ORIGIN

White (not Hispanic or Latino) 6,281,258 2,576 668,925 9,394 10.6 0.2 69,401 306 11,686 1,246 16.8 1.8 Black or African American 2,096,490 5,812 493,496 8,392 23.5 0.4 19,991 305 5,912 756 29.6 3.8 American Indian and Alaska Native 117,702 1,595 29,577 1,585 25.1 1.3 307 100 17 24 5.5 8.4 Asian 275,301 1,983 32,712 2,356 11.9 0.9 976 83 56 64 5.7 6.7 Native Hawaiian and Other Pacific Islander 6,414 671 1,246 264 19.4 4.2 23 41 23 41 100.0 64.2

Some other Race 302,934 7,911 89,305 5,371 29.5 1.5 1,422 438 467 328 32.8 18.2 Two or more races 252,709 6,223 54,335 2,369 21.5 0.8 1,344 338 386 180 28.7 11.1 Hispanic or Latino 915,426 901 260,607 5,682 28.5 0.2 3,283 33 1,064 341 32.4 10.4 All individuals below: 50 percent of poverty level 663,550 10,829 8,583 1,286 125 percent of poverty level 2,034,827 19,447 25,164 1,637 150 percent of poverty level 2,526,688 21,681 31,294 1,959 185 percent of poverty level 3,227,889 24,339 39,451 2,086 200 percent of poverty level 3,513,670 25,035 43,306 2,024 Source: American Community Survey 5-year Estimates, 2018 All bolded and orange cells indicate a difference that is greater than 5% when compared to the State

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Local Setting According to the Census Table S1701, Poverty Status in the Past 12 Months, 2018 American Community Survey 5-Year Estimates, from the US Census Bureau, Census Tract 9511 had an estimated population of 3,075 with 41.1% (MOE +/-12.4%) living below the poverty level (Table 5-9). Across all subjects, under 18 (64.6%, MOE +/- 17%) and Hispanic or Latino (62.5% MOE +/- 52.2%) had the highest percent living under the poverty level. All of the subject groups that had a greater than 5% difference when compared to the county and the state showed a difference higher than 5%.

Census Tract 9512 had an estimated population of 5,605 with 29.5% (MOE +/-8.4%) living below the poverty level. Across all subjects, Native Hawaiian and other Pacific Islander had the highest percent living below the poverty level at 100% (MOE +/- 64.2%). The next subjects with the highest poverty level were Asian at 74.7% (MOE +/- 43.3%), and Hispanic or Latino at 48% (MOE +/- 28.9%).

Census Tract 9513 had an estimated total population of 3,222 with 16.3% (MOE +/-5.9%) living below the poverty level. Across all subjects, Black or African American had the highest percent living below the poverty level at 34.5% (MOE +/- 31.3%), followed by under 18 at 26.9% (MOE +/- 14.2%).

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Table 5-9. Local Setting- Poverty

Census Tract 9511 Census Tract 9512

Subject Total Below poverty level Percent below poverty

level Total Below poverty level Percent below poverty level

Estimate Margin of Error +/- Estimate Margin of

Error +/- Estimate Margin of Error +/- Estimate Margin of

Error +/- Estimate Margin of Error +/- Estimate Margin of

Error +/- Population for whom poverty status is determined 3,075 400 1,265 452 41.10 12.4 5,605 448 1,655 510 29.50 8.40

AGE Under 18 646 170 417 167 64.60 17 1,201 275 453 278 37.70 18.90 18 to 64 1,882 329 789 358 41.90 15.3 3,312 331 1,103 305 33.30 8.80 65 years and over 547 128 59 35 10.80 6.9 1,092 139 99 74 9.10 6.80 SEX Male 1,512 237 603 207 39.90 12.3 2,488 359 532 232 21.40 8.90 Female 1,563 249 662 281 42.40 14 3,117 460 1,123 436 36.00 10.90 RACE AND HISPANIC OR LATINO ORIGIN

White 1,750 283 566 424 32.3 21.5 2,965 419 754 323 25.4 9.9 Black or African American 1,275 263 682 224 53.5 14.9 1,621 509 362 264 22.3 14.9 American Indian and Alaska Native 0 12 0.0 12 - - 0.0 17 0.0 17 - - Asian - 12 0.0 12 - - 75 66 56 64 74.7 43.3 Native Hawaiian and Other Pacific Islander - 12 0.0 12 - - 23 41 23 41 100.0 64.2

Some other Race 6 11 0.0 12 0.0 100.0 293 242 33 62 11.3 23.8 Two or more races 34 43 7 13 20.6 50.7 109 89 98 89 89.9 191.0 Hispanic or Latino 16 18.0 10.0 15.0 62.5 52.2 865.0 375.0 415.0 316.0 48.0 28.9 All individuals below: 50 percent of poverty level 622 460 460 260 125 percent of poverty level 1,588 506 1,688 507 150 percent of poverty level 1,713 492 1,824 513 185 percent of poverty level 1,880 502 2,552 556 200 percent of poverty level 1,971 529 2,802 529

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Table 5-9. Local Setting- Poverty cont’d

Census Tract 9513

Subject Total Below poverty level Percent below

poverty level

Estimate Margin of Error +/- Estimate Margin of

Error +/- Estimate Margin of Error +/-

Population for whom poverty status is determined 3,222 308 524 201 16.30 5.90

AGE Under 18 778 160 209 135 26.90 14.20 18 to 64 1,939 230 299 104 15.40 5.30 65 years and over 505 55 16 27 3.20 5.40 SEX Male 1,549 223 238 94 15.40 5.60 Female 1,673 175 286 127 17.10 7.10 RACE AND HISPANIC OR LATINO ORIGIN White 2,580 262 427 192 16.10 7.10 Black or African American 281 184 97 122 34.50 31.10 American Indian and Alaska Native 0 12 0 12 - - Asian 65 81 - 12 0.00 38.20 Native Hawaiian and Other Pacific Islander - 12 - 12 - - Some other Race 189 86 - 12 0.00 16.80 Two or more races 52 55 - 12 0.00 42.70 Hispanic or Latino 272 172 - 12 0.00 12.10 All individuals below: 50 percent of poverty level 365 187 125 percent of poverty level 839 307 150 percent of poverty level 1,008 330 185 percent of poverty level 1,151 350 200 percent of poverty level 1,253 361 Source: American Community Survey 5-year Estimates, 2018 All bolded and orange cells indicate a difference that is greater than 5% when compared to the State All bolded and blue cells indicate a difference that is greater than 5% when compared to the county and the State

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5.5 Household Income Regional Setting The following table (Table 5-10) was compiled using data from the Census Table S1901, Income in the Past 12 Months (in 2018 Inflation-Adjusted Dollars) 2018 American Community Survey 5-Year Estimates for North Carolina. The North Carolina household income range with the highest percent was for $50,000 to $74,999, at 18.1%. The median household income was $52,413 and the mean income was $73,753.

The household income range for Cleveland County with the highest percent was $35,000 to $49,999 at 17.3% (MOE +/- 1.2%). The median income was $40,393 and the mean income was $54,469.

Table 5-10. Regional Setting- Household Income North Carolina Cleveland County

Subject Households Households

Estimate Margin of Error +/- Estimate Margin of

Error +/- Total 3,918,597 8,585 36,882 556

Less than $10,000 6.8 0.1 11.0 1.4 $10,000 to $14,999 5.4 0.1 7.4 0.9 $15,000 to $24,999 10.7 0.1 13.4 1.3 $25,000 to $34,999 10.7 0.1 11.3 1 $35,000 to $49,999 14.2 0.1 17.3 1.2 $50,000 to $74,999 18.1 0.1 17.2 1.4 $75,000 to $99,999 12 0.1 9.5 1

$100,000 to $149,999 12.5 0.1 8.7 0.9 $150,000 to $199,999 4.7 0.1 2.5 0.5

$200,000 or more 4.9 0.1 1.7 0.4

Median income (dollars) 52,413 224 40,393 1,428 Mean income (dollars) 73,753 332 54,469 2,445

Per Capita Income 29,456 143 21,920 900

Source: American Community Survey 5-year Estimates, 2018 All bolded and orange cells indicate a difference that is greater than 10% when compared to the State

Local Setting The household income range for Census Tract 9511 with the highest percent was $10,000 to $14,999 at 20.8%, followed by the $15,000 to $$24,999 income bracket at 18.8% (MOE +/- 8.7). All three lowest income brackets were greater than 10% different when compared to both the state and the county. The median income was $22,131, and the mean income was $37,389.

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The household income range for Census Tract 9512 had the highest percent at $35,000 to $49,999 at 33.4% (MOE +/- 9.4%). The median income was $40,399 and the mean income was $51,998.

The household income range for Census Tract 9513 had the highest percent was $100,000 to $149,999 at 19.8% (MOE +/- 6.8%). The median income was $47,344 and the mean income was $68,059.

Table 5-11. Local Setting- Household Income Census Tract 9511 Census Tract 9512 Census Tract 9513

Subject Households Households Households

Estimate Margin of Error +/- Estimate Margin of

Error +/- Estimate Margin of Error +/-

Total 1,200 137 2,300 206 1,096 88 Less than $10,000 14.3 5.4 13.1 5.4 6.5 3.4 $10,000 to $14,999 20.8 8 6.4 4.0 3.7 3.0 $15,000 to $24,999 18.8 8.7 15.1 6.0 10.1 5.0 $25,000 to $34,999 12.6 5.2 5.6 3.3 13.4 5.7 $35,000 to $49,999 8.8 6 33.4 9.4 18.8 6.8 $50,000 to $74,999 15.1 7.3 9.7 4.4 12.7 4.8 $75,000 to $99,999 3.8 2.6 7.9 4.2 7.6 4.4

$100,000 to $149,999 1.9 2.3 7.3 3.5 18.7 6.8 $150,000 to $199,999 3.3 3.7 0.7 1.1 5.9 3.8

$200,000 or more 0.6 1 0.9 1.4 2.6 2.8

Median income (dollars) 22,131 5,368 40,399 3,770 47,344 10,798

Mean income (dollars) 37,389 6,949 51,998 15,544 68,059 8,099 Per Capita Income 16,225 3977 22,462 6474 23,994 3069

Source: US Census, 2018 ACS 5-Year Estimates. All orange and bolded highlighted cells indicate a difference that is greater than 5% when compared to the state. All bolded and blue highlighted cells indicate a difference that is greater than 5% when compared to the county and the state

Table 5-12. Project Radius- Household Income

Subject 1 mile

Number Percent MOE Number of Households 211 100% 104

Owner Occupied 164 78% 85 Renter Occupied 47 22% 101

Per Capita Income (dollars) 24,004

Household Income <$15,000 17 8% 67

$15,000-$25,000 21 10% 58 $25,000-$50,000 56 27% 106 $50,000-$75,000 53 25% 70

$75,000+ 64 31% 78

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Per Capita Income Per Capita Income data was obtained through the Census Table B19301, Per Capita Income in the Past 12 Months (In 2018 Inflation-Adjusted Dollars), 2014-2018 American Community Survey 5-Year Estimates. The North Carolina per capita income estimate was $26,779, and $21,920 in Cleveland County. The estimates for the census tracts were: $16,225 (9511), $22,462 (9512), and $23,994 (9513). Within the one-mile radius, the per capita income was $24,004, slightly higher than the census tracts. The county, all census tracts, and the one-mile radius had a lower Per Capita Income compared to the state (Tables 5-10, 5-11, and 5-12).

6 Limited English Proficiency (LEP)

Per the Safe Harbor Guidelines, should an LEP Group be identified during the permit application process, written translations of vital documents for each eligible LEP language group that constitutes five percent or includes 1,000 members (whichever is less) of the population of persons eligible to be served or likely to be affected or encountered. If there are fewer than 50 persons in a language group that reaches the five percent trigger, then DEQ will not translate vital written materials, but instead will provide written notice in the primary language of the LEP language group of the right to receive competent oral interpretation of those written materials, free of cost. The safe harbor provisions apply to the translation of written documents only. Safe harbor guidelines are per the EPA guidance for LEP persons, and implemented by DEQ when deemed appropriate. Four potential LEP language groups were identified during this initial screening of demographic data as having more than zero individuals within one of the 3 census tracts with individuals who speak English less than very well (Table 6-1). Of these, only the Spanish or Spanish Creole language group reached the 5% threshold, with 131 of 2,398 individuals speaking English less than very well. DEQ will evaluate the resources available and determine the best options to reach the Spanish speaking community in this census tract, following the Safe Harbor Guidelines.

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Table 6-1. Limited English Proficiency

LANGUAGE SPOKEN AT HOME Census Tract 9511 Census Tract 9512 Census Tract 9513

Estimate Margin of Error Estimate Margin

of Error Estimate Margin of Error

Total (population 5 years and over): 2,368 313 4,945 463 2,801 234 Speak only English 2,225 266 4,438 465 2,740 237 Spanish or Spanish Creole: 131 186 315 225 61 76 Speak English "very well" 0 12 187 133 61 76 Speak English less than "very well" 131 186 128 105 0 12 Gujarati 0 12 51 98 0 12 Speak English "very well" 0 12 14 26 0 12 Speak English less than "very well" 0 12 37 73 0 12 Chinese 0 12 39 54 0 12 Speak English "very well" 0 12 0 17 0 12 Speak English less than "very well" 0 12 39 54 0 12 African languages 5 12 45 72 0 12 Speak English "very well" 0 12 29 46 0 12 Speak English less than "very well" 5 12 16 27 0 12

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7 County Health The University of Wisconsin Population Health Institute, in collaboration with the Robert Wood Johnson Foundation, calculated a County Health Rankings system for all the States in the United States (www.countyhealthrankings.org).This ranking is based on health outcomes (such as lifespan and self-reported health status) and health factors (such as environmental, social and economic conditions). According to this 2020 report, out of all 100 counties in North Carolina (with 1 indicating the healthiest), Cleveland County ranks 66th in health factors and 82nd in health outcomes.

Figure 5. County Health Rankings for Health Factors in North Carolina provided by University of Wisconsin Public Health Institute

According to the NC DEQ Community Mapping System Environmental Justice Tool, the rates of death in Cleveland county are slightly higher than the state averages (Table 7-1). Additionally, the hospitalization due to asthma in Cleveland County is 95 (per 100,000 individuals), as compared to the state at 90 individuals per 100,000 individuals. The number of primary care physicians in Cleveland county (7.966 per 10,000 residents) is slightly higher than the state average (4.812 per 10,000 residents).

Table 7-1. Health Outcomes

Cause of Death Cleveland County

North Carolina

Cancer 201.7 169.1 Heart Disease 210 163.7 Stroke 55.3 43.1 Cardiovascular Disease 279.2 221.9 Diabetes 31.8 22.8 Source: NCDEQ 2020 EJ Tool

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8 Local Sensitive Receptors

The Environmental Protection Agency suggests that sensitive receptors include, but are not limited to, hospitals, schools, daycare facilities, elderly housing and convalescent facilities. These are areas where the occupants are more susceptible to the adverse effects of exposure to toxic chemicals, pesticides, and other pollutants. Extra care must be taken when dealing with contaminants and pollutants in close proximity to areas recognized as sensitive receptors. For instance, children and the elderly may have a higher risk of developing asthma from elevated levels of certain air pollutants than a healthy individual aged between 18 and 64.

Within the one-mile project radius of the AMES Copper facility, the following potential sensitive receptors were identified (Figure 6):

• Calvary Baptist Church • Cleveland Funeral Services and Crematory

Located slightly beyond the one-mile project radius, the following potential sensitive receptors were identified:

• Crest High School • Crest Middle School • Cleveland County Schools • Beaver Dam Baptist Church • Dover Baptist Church • Westview Church • John Knox Presbyterian Church • Graham Elementary School • Shelby Fire Station 2

Additional sensitive receptors may be identified during the permit application process, such as during the field reconnaissance visit or through public comment.

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Figure 6. Sensitive receptors surrounding the AMES Copper Group facility.

AMES Copper Facility

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9 Local Industrial Sites Within the one-mile radius, 19 other facility permits or incident reports were identified using the NCDEQ Community Mapping System (as of October 5, 2020).

Figure 9. Permitted facilities and incidents with the one-mile radius surrounding the proposed AMES Copper facility.

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10 Conclusion Environmental justice is 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 (US EPA). This report examined the demographic and environmental conditions in North Carolina, Cleveland County, census tracts 9511, 9512, and 9513, and the one-mile radius around the AMES Copper Group proposed facility. Potential emissions rates outlined in the permit application and county level health data were also included, as well as data from the NCDEQ Community Mapping System.

It is important to keep in mind that based on the available data, the following limitations of this report: census data is from 2010 and may be outdated; the more recent census data through 2017 are estimates; EJSCREEN does not provide all of the data categories that were used in this analysis so the census tract and county data cannot be compared to the radius used surrounding the facility boundary for all criteria; census tracts can still be large areas and do not allow for exact locations of each population; some of the census tracts slightly overlap with the one-mile radius; and the Department cannot determine which populations are in that small amount of overlap around the facility.

The Department assessed the available demographic and socioeconomic data of the communities surrounding the AMES Copper Group facility regarding its permit application. The County, project area, and the census tracts display generally higher percentages of White populations than that of the state. However, the census tract data for the census tracts encompassing more of downtown Shelby have higher African American populations than state and county estimates. The surrounding census tracts display a population of individuals over 65 years old that is higher than the state average. Overall, the disability estimates are slightly higher, but very similar to those for the state. The two census tracts closer to the more urban area of Shelby display overall poverty estimates that are slightly higher than the state and the county. However, the census tract that encompasses the facility is on par with the state level for overall poverty and lower than the county. Census tracts 9511 and 9512 showed the lowest household income levels, with a much higher percentage making less than $10,000 in each census tract. The other two census tracts had a lower percentage in the less than $10,000 income bracket than the state. All three census tracts and the project radius have a per capita income lower than the state. Cleveland County ranks 66th in health factors and 82nd in health outcomes. There were 19 permitted facilities and incidents within one-mile from the proposed facility.

Based on the data from this report, the following recommendations for enhanced outreach have been made:

• Additional outreach to the identified sensitive receptors. • Further analysis of feasibility to translate relevant materials into Spanish. • Enhanced outreach within census tracts 9511 and 9512, where there was a higher

percentage of low-income urban or suburban populations identified.