Jordan Lumber And Supply Company - NC

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Jordan Lumber and Supply Company Draft Environmental Justice Report North Carolina Department of Environmental Quality December 18, 2020

DRAFT Environmental Justice Report Jordan Lumber and Supply Company December 18, 2020 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 . 12 Regional Setting . 12 Local Setting . 14 5.4 Poverty . 16 Regional Setting . 16 Local Setting . 18 5.5 Household Income . 19 Regional Setting . 19 Local Setting . 19 Per Capita Income . 20 6 Limited English Proficiency (LEP) . 21 7 Health . 21 9 Local Sensitive Receptors . 24 8 Local Industrial Sites . 25 10 Conclusion . 26 Figure 1. Jordan Lumber facility location with one-mile radius. . 7 Figure 2. Census tract encompassing the facility location and one-mile radius. . 8 Figure 3. County Health Rankings for Health Factors in North Carolina provided by University of Wisconsin Public Health Institute. . 23 Figure 4. Sensitive receptors surrounding Jordan Lumber and Supply Company. . 24 Page 2

DRAFT Environmental Justice Report Jordan Lumber and Supply Company December 18, 2020 Figure 5. Permitted facilities and incidents with the one-mile radius surrounding the Jordan Lumber and Supply Company. 25 Table 1. Facility Emissions Overview . 6 Table 2. Regional Setting - Race and Ethnicity. 9 Table 3. Local Setting– Race and Ethnicity . 10 Table 4. Regional Setting- Age Groups and Sex . 11 Table 5. Local Setting- Age Groups and Sex . 11 Table 6. Project Radius- Age Groups and Sex . 12 Table 7. Regional Setting- Disability . 13 Table 8. Local Setting- Disability . 15 Table 9. Regional Setting- Poverty. 17 Table 10. Local Setting- Poverty. 19 Table 11. Regional Setting- Household Income. 20 Table 12. Local Setting- Household Income. 21 Table 13. Limited English Proficiency . 22 Table 14. Health Outcomes . 23 Page 3

DRAFT Environmental Justice Report Jordan Lumber and Supply Company December 18, 2020 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 Montgomery County, in census tract 9602, and in the one-mile radius around the property boundary of the existing Jordan Lumber facility. Finally, the demographics of the entire state of North Carolina are also considered as they compare to both the county and the 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 of Environmental Quality (DEQ or Department) has assessed the permit application and the demographics of the communities in the area surrounding the requested permit application. Accordingly, this Draft Environmental Justice Report includes: Permit application submitted by Jordan Lumber and Supply Company Facility emissions overview Study of area demographics [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 the county and statewide census data County health assessment Surrounding sensitive receptors Local industrial sites (using the NCDEQ Community Mapping System ndex.html?id 1eb0fbe2bcfb4cccb3 cc212af8a0b8c8). Demographics for Montgomery County as well as the state, are compared to the local (census tracts and project radius) level data to identify any disparities surrounding the project area 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). Page 4

DRAFT Environmental Justice Report Jordan Lumber and Supply Company December 18, 2020 3 Proposed Project Jordan Lumber & Supply, Co. (Jordan Lumber) currently holds Title V Permit No. 03469T27 with an expiration date of February 28, 202,1 for a lumber mill in Mt. Gilead, Montgomery County, North Carolina. Jordan Lumber submitted permit application No. 6200015.20B on September 1, 2020, for the conversion of Kiln K-7 to a direct gasified wood-fired / natural gas-fired continuous kiln (ID No. K-7) with a capacity of 67.34 million board feet (MMBF) per year. This modification is considered a major modification under Prevention of Significant Deterioration (PSD) rules. A description of the lumber manufacturing process at Jordan Lumber is summarized as follows: Southern yellow pine logs are trucked to the site and cut into lumber by one of the two sawmills at Jordan Lumber. In the newer of the two sawmills (installed in 2010), the logs are debarked and then cut to specified lengths. The rough-cut lumber is dried in one of seven kilns onsite – four steam-heated lumber kilns, one direct-fired batch lumber kiln, one indirect fired continuous kiln, and one direct gasified wood-fired / natural gas-fired continuous kiln. An additional steam-heated kiln is permitted but has not yet been constructed. Steam for the steam-heated kilns is provided by four wood-fired boilers and one natural gas-fired boiler. The green lumber is dried in the kilns for 18 to 24 hours, depending on the initial moisture content, age, and size of the wood. The dried lumber is finished by planning and trimming in two planer mills. Finished lumber is then sorted by length, size, and grade; packaged; and then shipped off site. Bark from the logs is sold to customers for processing into landscaping material. Scrap lumber is ground into chips, and the wood chips, along with planer shavings, are sold and shipped off site as byproducts. The facility currently has approximately 250 employees and operates its boilers and kilns 24 hours a day, seven days a week. The sawmills operate 8 hours per day, five days per week, or more often depending on business demands. Kiln K-7 was originally permitted and operated as a batch steam heated kiln, but was converted to a direct, natural gas / wood-fired continuous lumber drying kiln, assuming a throughput of 45 MMBF per year. Jordan Lumber used projected actual emissions from Kiln K-7 with a throughput of 45 MMBF to demonstrate the kiln conversion was not a major modification under PSD. In the current permit application (6200015.20B), Jordan Lumber specifies that the future actual production of the kiln is likely to exceed the originally projected estimate of 45 MMBF per year. The application includes a new PSD applicability evaluation using the potential emissions from the kiln at the design capacity of the kiln of 67.34 MMBF per year. The change to the calculations (i.e., changing “projected actual emissions” to “potential emissions”) represents not only a revision to the previous PSD applicability determinations for Kiln K-7, but also serves as a permit modification to increase the kiln throughput. With the production increase in Kiln K-7, the increased volatile organic compound (VOC) emissions will exceed the PSD significant emission rate of 40 tons per year (tpy), triggering a PSD review. Potential emissions for this modification are provided in the following table (Table 1). Page 5

DRAFT Environmental Justice Report Jordan Lumber and Supply Company December 18, 2020 Table 1. Facility Emissions Overview Potential Emissions Resulting from Converting Kiln K-7 to a Direct Gasified Wood-Fired/ Natural Gas-Fired Continuous Lumber Drying Kiln PSD Significant Potential Project Emissions Pollutant emission rate (SER) Above PSD SER? (tpy) (tpy) Total PM 25 No PM10 4.71 15 No PM2.5 10 No SO2 3.29 40 No CO 78.84 100 No VOC 146.1 40 Yes Lead 6.31E-03 0.6 No CO2e 27,548 75,000 No Notes: Baseline actual emissions were set to “zero” as a conservative assumption. Potential emissions from drying wood in the Kiln K-7 were based on kiln throughput of 67.34 MMBF per year. Emissions from natural gas combustion in Kiln K-7 were based on a maximum heat input of 24 million Btu/hr, and 8,760 hours of operation. Emissions from combustion of wood in Kiln K-7 were based on a maximum heat input of 30 million Btu/hr, and 8,760 hours of operation. CO2e emissions were calculated with 40 CFR Part 98 Mandatory Reporting Rule factors for wood and natural gas firing. Page 6

DRAFT Environmental Justice Report Jordan Lumber and Supply Company December 18, 2020 4 Geographic Area Jordan Lumber and Supply Company, is located at 1959 Highway 109 South Mount Gilead, NC 27306 (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. The one-mile buffer around the Jordan Lumber facility is located wholly within Montgomery County. Figure 1. Jordan Lumber facility location with one-mile radius. Montgomery County is designated as a Tier 2 county by the NC Department of Commerce. According to the 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. Jordan Lumber and the one-mile radius is located within census tracts 9604.01 and 9604.02 in Montgomery County (Figure 2). Census tracts are small, relatively permanent statistical subdivisions of a county with a unique numeric code (US Census Page 7

DRAFT Environmental Justice Report Jordan Lumber and Supply Company December 18, 2020 Bureau). The census tracts do not encompass land within a state-designated tribal statistical area. Census Tract 9604.02 Census Tract 9604.01 Figure 2. Census tract encompassing the facility location and one-mile radius. 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 U.S. 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 are those that overlap into the one-mile radius. Demographics of the county 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: 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 Page 8

DRAFT Environmental Justice Report Jordan Lumber and Supply Company December 18, 2020 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 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 (U.S. Census Bureau). The Census Bureau standard for the MOE is at the 90% confidence level and may be any number between 0 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 2). The three most common racial groups across the state were White (65.3%), Black or African-American (21.2%), and Hispanic or Latino (of any race) at 8.4%. Montgomery County had a total population of 27,798 individuals (Table 2). The three most common racial or ethnic groups within Montgomery county were White (64.3%), Black or African American (18.6%), and Hispanic or Latino (2.8%). None of the racial or ethnicity groups in Montgomery County is greater than 10% different as compared to the state. Table 2. Regional Setting - Race and Ethnicity Race and Ethnicity Total Population White Black or African American American Indian or Alaska Native Asian Native Hawaiian and Other Pacific Islander Some other Race Two or More Races HISPANIC OR LATINO (of any race) Source: US Census Bureau, 2010 Census Page 9 North Carolina Number Percent 9,535,483 100 6,223,995 65.3 2,019,854 21.2 108,829 1.1 206,579 2.2 5,259 0.1 15,088 0.2 155,759 1.6 800,120 8.4 Montgomery County Number Percent 27,798 100 17,875 64.3 5,182 18.6 102 0.4 439 1.6 3 0.0 16 0.1 255 0.9 2,756 2.81

DRAFT Environmental Justice Report Jordan Lumber and Supply Company December 18, 2020 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 9604.01 in Montgomery County was Black or African American at 55.9%, followed by White at 39.5%. The largest population within Census Tract 9604.02 was White at 68.6%, followed by Black or African American at 20%. Within the one-mile radius, White (47.8%) was the largest population, followed by Black or African American (41.3%). Black or African American for both Census Tract 9604.01 and the 1mile radius, was greater than 10% different when compared to the county and state (Table 3). Asian for both Census Tract 9604.02 and the 1-mile radius, was greater than 10% different when compared to the County and State. Table 3. Local Setting– Race and Ethnicity Race and Ethnicity Total Population White Black or African American American Indian or Alaska Native Asian Native Hawaiian and Other Pacific Islander Some other Race Two or More Races Project Area - 1 Mile Census Tract 9604.01 Census Tract 9604.02 Number 276 132 114 Percent 100 47.8 41.3 Number 2,134 842 1,192 Percent 100 39.5 55.9 Number 2,306 1,581 462 Percent 100 68.6 20.0 2 0.7 0 0.0 15 0.7 22 8.0 34 1.6 183 7.9 0 0.0 0 0.0 0 0.0 3 3 1.1 1.1 1 22 0.0 1.0 0 24 0.0 1.0 HISPANIC OR LATINO (of any 6 2.2 43 2.0 41 1.8 race) Source: US Census Bureau, 2010 Census All bolded and blue cells indicate a difference that is greater than 10% when compared to the county and the State P a g e 10

DRAFT Environmental Justice Report Jordan Lumber and Supply Company December 18, 2020 5.2 Age and Sex Regional Setting According to the 2010 US Census Data Table P 12: Sex by Age, and Table P13: Median Age, North Carolina had a total population of 9,535,483 individuals (Table 4). 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%). Montgomery County has a total population of 27,798 individuals. The largest percentage of the total population (60.0%) was between the ages of 18 and 64, followed by under 18 years (18.0%). Table 4. Regional Setting- Age Groups and Sex North Carolina Montgomery County Number Percent Number Both Both Both Male Female Male Female Male Female sexes sexes Sexes Total Population 9,535,483 4,645,492 4,889,991 100% 100% 100% 27,798 13,458 14,340 Under 5 years 632,040 322,871 309,169 6.6 7 6.3 1,729 864 865 Under 18 years 2,281,635 1,167,303 1,114,332 23.9 25.1 22.8 5,017 2,538 2,479 18 to 64 years 6,019,769 2,954,233 3,065,536 63.1 63.6 62.7 16,688 8,169 8,519 65 years and over 1,234,079 523,956 710,123 12.9 11.3 14.5 4,364 1,887 2,477 Median Age 37 36 38.7 40.2 39.1 41.2 Source: US Census Bureau, 2010 Census All bolded and orange cells indicate a difference that is greater than 10% when compared to the State Age Both Sexes 100 6.2 18.0 60.0 15.69 Percent Male Female 100 6.4 18.9 60.7 14.02 100 6.0 7.3 59.4 17.27 Local Setting According to the 2010 US Census Data Table P 12: Sex by Age, and Table P13: Median Age, Census Tract 9604.01 had a slightly younger median population than Census Tract 9604.02 (Table 5). Both census tracts had higher median ages than the state and county. Table 5. Local Setting- Age Groups and Sex Age Census Tract 9604.01 Number Percent Both Both Male Female Male Female sexes sexes 2,134 997 1,137 100 100 100 100 53 47 4.7 5.3 4.1 491 257 234 23.0 25.8 20.6 1,245 589 656 58.3 59.1 57.7 Census Tract 9604.02 Number Percent Both Both Male Female Male Female sexes sexes 2306 1161 1145 100 100 100 95 49 46 4.1 4.2 4.0 440 228 212 19.1 19.6 18.5 1409 708 701 61.1 61.0 61.2 Total Population Under 5 years Under 18 years 18 to 64 years 65 years and 398 151 247 18.7 15.1 21.7 457 225 232 over Median Age 44.3 40.8 46.4 48.1 47.4 48.9 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 green cells indicate a difference that is greater than 10% when compared to the county. P a g e 11 19.8 19.4 20.3

DRAFT Environmental Justice Report Jordan Lumber and Supply Company December 18, 2020 Project Radius EJSCREEN identified a population of 276 individuals in the 1-mile surrounding the facility. The largest population was 18 years (77%), followed by under 18 years at 23% (Table 6). Table 6. Project Radius- Age Groups and Sex Age Number Project Area - 1 Miles Both Male Female sexes Total Population 276 135 141 Under 5 years 15 Under 18 years 63 18 213 65 years and over 45 Source: US Census Bureau, 2010 Census. Obtained through EJSCREEN 2019 Both sexes 100 5 23 77 16 Percent Male Female 49 51 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 9,952,031 noninstitutionalized 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 7). Montgomery County had an estimated total population of 26,227 noninstitutionalized citizens. Of those, an estimated 14.9% (MOE /- 1.5%) had a disability. The largest population of disabled civilians were Native Hawaiian and Other Pacific Islander (100%, MOE /- 100%), followed by 75 years and over (52.7%, MOE /- 7.9%). The total population with a disability, 35 to 64 years, male, female, American Indian and Alaska Native, Asian, Native Hawaiian and Other Pacific Islander, and some other race, displayed estimates that were greater than 10% different when compared to the state. P a g e 12

DRAFT Environmental Justice Report Jordan Lumber and Supply Company December 18, 2020 Table 7. Regional Setting- Disability North Carolina Total Subject Estimate With a Disability Margin of Error /- Total civilian noninstitutionalized 9,952,031 population Population under 5 years 603,155 Population 5 to 17 years 1,685,827 Population 18 to 34 years 2,216,915 Population 35 to 64 years 3,915,727 Population 65 to 74 years 932,178 Population 75 years and over 598,229 SEX Male 4,786,233 Female 5,165,798 RACE AND HISPANIC OR LATINO ORIGIN White (not Hispanic or Latino) 6,316,065 Black or African American 2,123,353 American Indian and Alaska Native 118,231 Asian 279,615 Native Hawaiian and Other Pacific 6,447 Islander Some other Race 303,837 Two or more races 255,739 Hispanic or Latino 916,366 Source: US Census Bureau, ACS 2018 5-year Estimates Montgomery County Percent with a Disability 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 /- 1,743 1,350,533 7,387 13.6 0.1 26,227 302 3,906 392 14.9 1.5 767 941 1,791 1,742 1,157 982 4,761 94,822 146,329 556,505 248,418 299,698 613 2,522 3,165 5,319 2,902 2,471 0.8 5.6 6.6 14.2 26.6 50.1 0.1 0.2 0.1 0.1 0.3 0.4 1,512 4,701 4,706 10,174 3,164 1,970 5 46 243 220 80 103 49 85 89 1,843 801 1,039 61 64 52 280 130 169 3.2 1.8 1.9 18.1 25.3 52.7 4.0 1.4 1.1 2.7 4.0 7.9 2,284 1,829 647,158 703,375 4,946 5,616 13.5 13.6 0.1 0.1 12,892 13,335 325 201 2,011 1,895 282 238 15.6 14.2 2.1 1.8 2,254 5,762 1,604 2,022 920,269 314,216 21,874 13,450 6,535 3,706 929 961 14.6 14.8 18.5 4.8 0.1 0.2 0.8 0.3 16,775 4,429 66 407 133 306 94 36 2,921 859 0 25 348 153 23 38 2.1 3.8 37.9 9.3 1.6 3.3 9.1 6.9 668 635 178 9.8 2.7 5 9 5 9 100.0 100.0 7,743 6,070 863 16,218 29,063 57,239 1,100 1,446 1,970 5.3 11.4 6.2 0.4 0.5 0.2 546 454 4,144 295 278 38 0 17 79 23 19 95 6.2 4.0 2.3 2.5 5.2 2.2 All bolded and orange highlighted cells indicate a difference that is greater than 10% when compared to the State P a g e 13 Total

DRAFT Environmental Justice Report Jordan Lumber and Supply Company December 18, 2020 Local Setting According to the 2018 American Community Survey 5-Year Estimates, Table S1810 Disability Characteristics from the US Census Bureau, Census Tract 9604.01 in Montgomery County had an estimated total population of 2,086 noninstitutionalized citizens (Table 8). Of those individuals, an estimated 18.8% (MOE /- 5.2%) had a disability. The subject group with the largest population of disabled civilians was Native Hawaiian and Other Pacific Islander (100%, MOE /- 100%). The second largest population was 75 years and over at 43.6% (MOE /17.6%). The population groups of male and Native Hawaiian and Other Pacific Islander had an estimate that was greater than 10% different when compared to the state only. The following population groups had estimates that were greater than 10% when compared to the state and the county: total civilian noninstitutionalized population, 35to 64 years, female, White, and Black or African American. Census Tract 9604.02 in Montgomery County had an estimated total population of 2,749 noninstitutionalized citizens. Of those individuals, an estimated 15.2% (MOE /- 5.8%) had a disability. The subject group with the largest population of disabled civilians was the population 75 years and over (48.4%, MOE /- 23.2%). The second largest population was 65 to 74 years at 41.4% (MOE /- 19.9%). The total civilian noninstitutionalized population, male, female, and Asian population groups had an estimate that was greater than 10% different when compared to the state only. The following population groups had estimates that were greater than 10% when compared to the state and the county: 65to 74 years, White, and Black or African American. P a g e 14

DRAFT Environmental Justice Report Jordan Lumber and Supply Company December 18, 2020 Table 8. Local Setting- Disability Census Tract 9604.01 Total Subject Estimate Margin of Error /- Total civilian noninstitutionalized 2,086 331 population Population under 5 years 44 37 Population 5 to 17 years 289 134 Population 18 to 34 years 367 130 Population 35 to 64 years 788 148 Population 65 to 74 years 373 95 Population 75 years and over 225 77 SEX Male 947 176 Female 1,139 215 RACE AND HISPANIC OR LATINO ORIGIN White (not Hispanic or Latino) 817 203 Black or African American 1,244 273 American Indian and Alaska Native 6 9 Asian 14 25 Native Hawaiian and Other Pacific 5 9 Islander Some other Race 0 12 Two or more races 0 12 Hispanic or Latino 0 12 Source: US Census Bureau, ACS 2018 5-year Estimates With a Disability Census Tract 9604.02 Percent with a Disability 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 /- 392 107 18.8 5.2 2,749 539 417 149 15.2 5.8 0 0 17 193 84 98 12 12 16 70 43 49 0.0 0.0 4.6 24.5 22.5 43.6 46.4 11.4 4.7 8.5 11.6 17.6 74 477 281 1,349 285 283 55 284

Jordan Lumber & Supply, Co. (Jordan Lumber) currently holds Title V Permit No. 03469T27 with an expiration date of February 28, 202,1 for a lumber mill in Mt. Gilead, Montgomery County, North Carolina. Jordan Lumber submitted permit application No. 6200015.20B on September 1, 2020, for the

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