i o
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Air Quality
EPA Regions Have Considered
Environmental Justice
When Targeting Facilities for
Air Toxics Inspections
Report No. 15-P-0101
February 26, 2015
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Report Contributors:	Rick Beusse
Erica Hauck
Richard Jones
Julie Narimatsu
Tempestt Woodard
Clean Air Act
U.S. Environmental Protection Agency
Environmental justice
Fiscal year
High-Risk Facilities
National-Scale Air Toxics Assessment
Office of Enforcement and Compliance Assurance
Office of Inspector General
Particulate Matter
Cover photo: A neighborhood in close proximity to an operating power plant. (EPA photo)
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
February 26, 2015
Why We Did This Review
The U.S. Environmental Protection
Agency (EPA), Office of Inspector
General (OIG), conducted this review
to determine whether the EPA's Office
of Enforcement and Compliance
Assurance (OECA) and EPA regions
have targeted facilities in overburdened
communities, or communities with
disproportionate impacts, for air toxics
inspections. Air toxics compliance
evaluations (commonly referred to as
inspections) are onsite visits and offsite
record reviews to determine whether a
facility is in compliance with laws and
regulations that limit emissions.
Air toxics are pollutants known or
suspected to cause cancer or other
serious health effects. Communities
that experience elevated or
disproportionate impacts from air toxics
may be areas of environmental justice
(EJ) concern. EPA regions are
supposed to consider potential EJ
concerns and impacts to communities
when targeting sources for air toxics
This report addresses the
following EPA goals or
cross-agency strategies:
•	Addressing climate change and
improving air quality.
•	Protecting human health and the
environment by enforcing laws and
assuring compliance.
•	Working to make a visible
difference in communities.
Send all inquiries to our
public affairs office at (202) 566-2391
or visit www.epa.gov/oiq.
The full report is at:
EPA Regions Have Considered
Environmentai Justice When Targeting
Faciiities for Air Toxics inspections
What We Found
All 10 EPA regions have considered EJ when
targeting facilities for air toxics inspections.
EJ is one of many different factors that
regions used when deciding where to conduct
air toxics inspections. Other common factors
that EPA regions used to target air toxics
inspections included:
•	Cancer risk in the area surrounding a facility.
•	Overall emissions from a facility.
•	A facility's compliance history.
Regions have had limited resources to do air toxics inspections, and these
factors helped regions prioritize their inspections.
OECA has developed several tools to help regions select air toxics facilities
for inspection. One tool, the High-Risk Facilities (HRF) list, identifies large
facilities in areas with elevated cancer risks associated with air toxics. The
list includes an "EJ Score" for each facility to help regions prioritize which
facilities to inspect. The most recent HRF list, provided to the regions in
November 2014, uses EJ information from a relatively new EPA tool, called
EJSCREEN, to develop the "EJ Score." EJSCREEN is an online mapping
and analysis tool developed and issued internally by the EPA to help
program offices and regions integrate EJ into multiple facets of the
agency's work. While regional staff identified several aspects of
EJSCREEN that limit its usefulness for the targeting of air toxics
inspections, recent and planned updates to EJSCREEN include
enhancements that address most of these limitations.
In addition, OECA has developed new mapping tools that combine data
from EJSCREEN with data layers from the EPA's GeoPlatform. These
tools produce maps that include useful information about the location of
facilities and also note areas of potential EJ concerns in nearby
communities. OECA demonstrated these tools to EPA regions and has
worked with two regions to develop individualized mapping tools based on
specific regional needs. We believe that these new mapping tools will help
regions target potentially overburdened communities for air toxics
We make no recommendations.
The EPA has considered
EJ in its air toxics facility
targeting activities, and
the implementation of
new tools should
enhance agency efforts.

February 26, 2015
SUBJECT: EPA Regions Have Considered Environmental Justice
When Targeting Facilities for Air Toxics Inspections
Report No. 15-P-Ol01
FROM: Arthur A. Elkins Jr.
Cynthia Giles, Assistant Administrator
Office of Enforcement and Compliance Assurance
This is our report on the subject evaluation conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). This report represents the opinion of the OIG and does
not necessarily represent the final EPA position.
Because this report contains no recommendations, you are not required to respond to this report.
However, if you submit a response, it will be posted on the OIG's public website, along with our
memorandum commenting on your response. Your response should be provided as an Adobe PDF file
that complies with the accessibility requirements of Section 508 of the Rehabilitation Act of 1973, as
amended. The final response should not contain data that you do not want to be released to the public;
if your response contains such data, you should identify the data for redaction or removal along with
corresponding justification.
We will post this report to our website at http://www.epa.gov/oig.

EPA Regions Have Considered Environmental Justice
When Targeting Facilities for Air Toxics Inspections
Table of C
Purpose		1
Background		1
Responsible Offices		3
Scope and Methodology		3
OECA Has Developed Guidance and Tools to Assist
EPA Regional Air Toxics Targeting Efforts		4
All EPA Regions Have Considered EJ in Their Air Toxics Targeting Efforts		5
EJSCREEN v2.0 Should Enhance Targeting for Air Toxics Inspections		6
Using EJSCREEN Data in Combination With the GeoPlatform Tool
Is a Promising Practice		9
Conclusions		11
A Distribution	 12

The U.S. Environmental Protection Agency (EPA), Office of Inspector General
(OIG), conducted this review to determine whether the EPA's Office of
Enforcement and Compliance Assurance (OECA) and EPA regions have targeted
facilities in overburdened communities, or communities with disproportionate
impacts, for Clean Air Act inspections for air toxics.
Air toxics are pollutants known or suspected to cause cancer or other serious
health effects, such as reproductive effects, birth defects, or adverse
environmental effects. The EPA estimates that 13.8 million Americans live in
communities where the estimated individual risk of getting cancer due to a
lifetime exposure to outdoor air toxics exceeds 1 in 10,000. This rate is double the
average national cancer risk from air toxics in the United States.1
Air toxics emitted from sources in a community may remain close to that
community, rather than dispersing over a larger area. This may result in elevated
concentrations of air toxics in the community's air. In communities with multiple
sources of air toxics emissions, or where sources do not comply with air toxics
regulations, residents may face increased or disproportionate risks, raising
concerns about environmental justice (EJ).
Environmental Justice at EPA
Issued in 1994, Executive Order 12898 directs federal agencies to include EJ as
part of their mission. Agencies should identify and address disproportionately
high and adverse human health or environmental effects of their programs,
policies and activities on minority and low-income populations. The EPA and
other federal agencies are required to develop an agencywide EJ strategy.
The EPA's Plan EJ 2014 is meant to mark the 20th anniversary of the signing of
Executive Order 12898 and is the agency's overarching strategy for advancing EJ.
Issued in 2011, Plan EJ 2014 is the EPA's comprehensive and cross-cutting
strategy for incorporating EJ principles into the agency's programs, policies and
activities. Plan EJ 2014 includes the following definitions:
• EJ 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."
1 The average national cancer risk from air toxics in the United States is 50 in 1 million, or 1 in 20,000, according to
the EPA's most recent National-Scale Air Toxics Assessment.

• Fair treatment means that "no group of people should bear a
disproportionate burden of environmental harms and risks, including those
resulting from the negative environmental consequences of industrial,
governmental, and commercial operations or programs and policies."
The EPA developed the term "overburdened community" to better capture the
concept of EJ within communities. According to Plan EJ 2014, an overburdened
community is a minority, low-income, tribal or indigenous population that could
experience "disproportionate environmental harms and risks as a result of greater
vulnerability to environmental hazards." This vulnerability may be due to
negative (or the lack of positive) environmental, health, economic or social
Advancing EJ Through Compliance and Enforcement
One of the five cross-agency focus areas in Plan EJ 2014 is "Advancing EJ
through Compliance and Enforcement." The goal of this focus area is to "fully
integrate consideration of environmental justice concerns into the planning and
implementation of OECA's program strategies, case targeting strategies, and
development of remedies in enforcement actions to benefit [overburdened]
OECA facilitates the process of advancing EJ through compliance and
enforcement within the EPA. Every 3 years, OECA selects a limited number of
high-priority national environmental and compliance problems to address through
concentrated, nationwide enforcement efforts. In selecting these areas of focus,
OECA looks for important environmental and public health problems that are
caused, at least in part, by widespread failure of regulated sectors to comply with
federal environmental laws. These are areas where OECA believes a concentrated
federal enforcement effort can make a difference in correcting violations and
reducing pollution. The selected areas of focus are called "National Enforcement
One of OECA's National Enforcement Initiatives for fiscal years (FYs)
2011-2013, and continuing for FYs 2014-2016, is the National Air Toxics
Compliance and Enforcement Initiative. The National Air Toxics Compliance and
Enforcement Initiative's goal is to reduce illegal emissions of toxic air pollutants
from leaks, flares and excess emissions at facilities that have a significant impact
on air quality and health in communities. The initiative notes that many of these
types of emissions are often underestimated by facilities and regulators. Also,
many of these facilities may be located in areas that experience disproportionate
and adverse impacts. The initiative directs the EPA to incorporate EJ into all
activities as described, including the targeting of facilities. Accordingly, the
National Air Toxics Compliance and Enforcement Initiative called for each region

to develop a plan for FYs 2011-2013 that considered EJ in targeting stationary
sources2 for air toxics inspections.
Responsible Offices
The EPA offices with primary responsibility for the issues discussed in this report are
EPA regions and two OECA offices: the Office of Compliance and the Office of
Environmental Justice. EPA regions are responsible for targeting and inspecting air
toxics facilities in areas of potential EJ concern within their states and territories. The
Office of Compliance is responsible for developing guidance and tools to assist EPA
regional air toxics targeting efforts. The Office of Environmental Justice works to
protect communities overburdened by air toxics pollution by integrating EJ into EPA
programs, policies and activities.
Scope and Methodology
We conducted our review from March through December 2014. We conducted
this performance audit in accordance with generally accepted government
auditing standards. Those standards require that we obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions based on
our objective. We believe the evidence obtained provides a reasonable basis for
our findings and conclusions based on our objective.
To answer our objective, we reviewed relevant laws, regulations and executive
orders, including:
•	The 1990 Clean Air Act (CAA), as amended.
•	The National Emissions Standards for Hazardous Air Pollutants.
•	Executive Order 12898: Federal Actions to Address Environmental Justice
in Minority Populations and Low-Income Populations.
•	A 2011 White House Memorandum of Understanding on Executive
Order 12898.
We also reviewed the following EPA guidance documents pertaining to air toxics
inspections and EJ:
•	Performance Based Strategy for the Air Toxics National Compliance and
Enforcement Priority, FYs 2008-2010.
•	Area Source Rule Implementation Guidance, June 2010.
•	CAA Stationary Source Compliance Monitoring Strategy,
September 2010.
2 A stationary source is a place or object from which pollutants are released that do not result from an internal
combustion engine for transportation purposes, or from a nonroad engine or vehicle. Stationary sources include
power plants, petroleum refineries, chemical plants, food-processing plants, large factories, gas stations, incinerators
and pipelines.

•	Air Toxics Compliance and Enforcement Initiative, FY s 2011-2013.
•	Memorandums from the EPA Deputy Administrator concerning
EJ analysis tools, April and October 2012.
•	Plan EJ 2014 and associated documents, including National Environmental
Justice Advisory Council Comments to Plan EJ 2014 and Plan EJ 2014
Progress Report.
•	Action Development Process: Guidance on Considering Environmental
Justice During the Development of an Action, January 2014.
•	EPA Strategic Plan, FY s2011-2015.
To determine whether OECA and EPA regions consider EJ concerns in their
targeting efforts for air toxics inspections, we reviewed the targeting plans each
region developed under the National Air Toxics Enforcement and Compliance
Initiative. Our review was limited to up-front targeting activities that regions
undertook. We did not review records or data from completed facility inspections.
We interviewed staff and managers from OECA's Office of Compliance and
Office of Environmental Justice. We also interviewed enforcement staff and
managers from each of the 10 EPA regions.
In addition, we reviewed and assessed tools that EPA headquarters has developed
and provided to the regions to help them target air toxics inspections in areas of
EJ concern, including EJSCREEN, EJSCREEN v2.0,3 and GeoPlatform. We also
attended webinar demonstrations on GeoPlatform offered by Region 1 and
OECA's Office of Compliance. The webinars demonstrated how GeoPlatform
can be used in conjunction with EJSCREEN to target inspections.
OECA Has Developed Guidance and Tools to Assist EPA Regional
Air Toxics Targeting Efforts
OECA assists EPA regional air toxics targeting efforts by developing guidance
and tools that can be used by regions to make their targeting decisions. As noted
above, OECA developed the National Air Toxics Compliance and Enforcement
Initiative to provide guidance on targeting inspections for air toxics for the
planning cycles FYs 2011-2013 and FYs 2014-2016. The initiative requires
regions to consider EJ in their targeting efforts. Under this initiative, regions
commit to conducting a specific number of air toxics inspections each year, but
there is no requirement to conduct a certain number of inspections in areas of EJ
concern. The requirement is that regions consider EJ when making decisions
about where to invest their limited inspection resources.
In addition, OECA's Office of Compliance developed a tool called the High-Risk
Facilities (HRF) list to help regions target their air toxics inspections. This list
3 In this report, EJSCREEN refers to the first version of EJSCREEN that was released in 2012. EJSCREEN v2.0
refers to an updated version that was released for internal EPA use in September 2014. EJSCREEN v2.0 replaces

identifies over 6,000 major source4 facilities located in counties that have census
tracts with more than a 1-in-1-million cancer risk from air toxics emissions from
point sources. The Office of Compliance included an "EJ score" for each facility
on the list, which was generated using an EJ screening tool no longer in use. EJ
scores range from 1 to 10. Facilities with EJ scores of 1, 2 or 3 indicate areas with
the greatest potential for EJ concern.5 The Office of Compliance first provided the
HRF list to the regions in FY 2011, and provided an updated list in FY 2012. In
November 2014, the Office of Compliance released a new version of the HRF list
that incorporates EJ-related information from a newer EJ screening tool called
ESCREEN. This new HRF list is discussed in more detail below.
The Office of Compliance is also working to develop additional mapping tools to
enhance EPA regional targeting efforts. These tools are also discussed in detail
All EPA Regions Have Considered EJ in Their Air Toxics
Targeting Efforts
All EPA regions have considered EJ in their targeting efforts for air toxics
inspections of stationary sources, as called for in the EPA's FY 2011-2013
National Air Toxics Compliance and Enforcement Initiative.6 However, the
methodology and EJ-related information used to target the inspections vary by
region. Regions reported using EJ scores from the HRF list in their targeting
efforts, a relatively new EPA tool called EJSCREEN, and/or local knowledge
about areas of potential EJ concern. While all regions included EJ in their
targeting efforts, EJ was only one factor among many that regions used to decide
which facilities to inspect. Other factors considered in the targeting included:
cancer risk near the facility, the amount of air toxics emitted from the facility, and
the compliance history of the facility.
EPA regions conduct a relatively small number of the total air toxics inspections
conducted in the United States. Most air toxics inspections are conducted by state
and local air agencies, which are overseen by EPA regions. Currently, there is no
requirement that states target facilities in areas of EJ concern. EPA regional staff
told us that states generally have not targeted air toxics sources specifically in
areas of EJ concern because states are required to inspect all major sources every
2 years and other large sources (called synthetic minors) every 5 years. Because
states are supposed to inspect all large facilities on a regular basis, EPA regions
have not required states to target stationary sources specifically for EJ.
4	A major source has actual or potential emissions that meet or exceed the major source threshold for its location.
The major source threshold for any "air pollutant" is 100 tons/year (the "default value"). Major source thresholds for
air toxics are 10 tons/year for a single pollutant or 25 tons/year for any combination of pollutants.
5	EJ scores were based on the highest risk decile census tract within 2/3-of-a-mile radius. An EJ score of 1 means
the facility is within 2/3 of a mile of a census tract whose EJ score is among the highest 10 percent within its state.
6	OECA has decided to carry over the National Air Toxics Compliance and Enforcement Initiative to
FYs 2014-2016.

EJSCREEN v2.0 Should Enhance Targeting for Air Toxics Inspections
In 2012, EPA headquarters released EJSCREEN to help EPA program offices and
regions incorporate EJ into their work. EJSCREEN is an EJ mapping and analysis
tool available to all EPA employees. The tool was developed in response to the
EPA's commitment in Plan EJ 2014 to develop a consistent nationwide screening
tool for EJ, and has replaced older EJ screening tools. EJSCREEN allows users to
identify areas of potential EJ concern at the census block group level7 using
demographic information8 and 12 environmental indicators. For example, a user
can enter the address of a facility that emits air toxics, and then obtain
demographic and environmental data about the census block group where the
facility is located, as well as information pertaining to surrounding areas.
The key output of EJSCREEN is called the
primary EJ Index, which helps the user
answer the following question:
How much does each location
contribute to the overall disparity
we see in environmental scores
(between demographic groups,
The tool produces a primary EJ Index for
the census block group of interest for each
of the 12 environmental indicators. Each
EJ Index combines one environmental
indicator with certain demographic
information to provide a measure of any
potential disproportionate impacts of that environmental factor. The EPA has
determined that a block group may be a good candidate for additional EJ review
when an EJSCREEN analysis for that area shows one or more EJ Indices at or
above the 80th percentile for the nation. This 80th percentile threshold allows the
EPA to focus on communities that are of the highest concern.
The EJSCREEN tool was intended to help the EPA be more effective and
efficient in understanding where the impacts of existing pollution may be greatest
and ensure that such areas receive appropriate consideration. Based on feedback
from regional staff, EJSCREEN is an improvement over previous EJ screening
tools and is useful for many EJ-related applications. However, the regions
A block is the smallest geographic area considered by the U.S. Census Bureau. A block group is a collection of
blocks. On average, around 40 blocks are aggregated into a block group. Census block groups vary widely in total
population, geographic area and population density. There are approximately 211,000 block groups in the United
States. The average population of a block group is about 1,500.
8 The primary demographic information used is an average of the percent that are low-income and the percent that
are minority, although other demographic information is also available.
Twelve environmental indicators
in the EPA's EJSCREEN mapping
and analysis tool
•	Particulate Matter (PM) 2.5 Level in Air.
•	Ozone Level in Air.
•	Diesel Particulate Matter Level in Air.
•	Air Toxics Cancer Risk.
•	Air Toxics Neurological Hazard Index.
•	Air Toxics Respiratory Hazard Index.
•	Traffic Proximity and Volume.
•	Lead Paint Indicator (percent pre-1960).
•	Risk Management Plan Facility Proximity
and Count.
•	Superfund Site Proximity and Count.
•	Treatment Storage Disposal Facility
Proximity and Count.
•	Major Direct Dischargers to Water,
Proximity and Count.

identified three aspects of EJSCREEN that limit its usefulness as a tool for
conducting up-front targeting for air toxics inspections:
1)	EJSCREEN identifies areas of potential EJ concern, but not air toxics
facilities within those areas.
2)	EJSCREEN can only provide EJ Indices for the area surrounding one
facility at a time; it cannot provide information for multiple facilities at
once. The user must run the screen for each facility (address) separately,
which is not feasible for regions that have hundreds or thousands of air
toxics facilities.
3)	EJSCREEN produces an EJ Index for only one environmental indicator at
a time.
In September 2014, the EPA released an updated version of EJSCREEN, referred
to as EJSCREEN v2.0, for internal EPA use. When fully implemented,9
EJSCREEN v2.0 will include a number of data updates and tool enhancements.10
Based on discussions with the Office of Environmental Justice and our review of
a pre-release version of EJSCREEN v2.0, we believe the updated version will
address two of the above concerns. Specifically, EJSCREEN v2.0 will:
•	Have the capability to overlay Envirofacts11 facility locations (including
known air toxics facility sites from the Toxics Release Inventory data)
on one screen.
•	Provide information for multiple facilities at once. This version will also
include a batch processing tool that allows users to process thousands of
locations simultaneously.
These two new functions will better enable the regions to use the EJSCREEN tool
to identify potential facilities to inspect based on EJ considerations. Regarding the
third limitation, EJSCREEN v2.0 will not have any new capability to produce an
EJ Index that incorporates more than one environmental indicator.
EJSCREEN v2.0 relies heavily on data from the EPA's National-Scale Air Toxics
Assessment (NATA) to estimate risks from air toxics in communities. The NATA
is an assessment tool through which the EPA conducts modeling to estimate
9	Although the EPA has released EJSCREEN v2.0 for internal use, not all planned enhancements are currently
available. For example, the batch processing functionality that is planned for EJSCREEN v2.0 is not yet operational.
10	The environmental data categories used to create EJ Indices in EJSCREEN v2.0 remain the same. However, the
EPA has updated the names of the 12 environmental indicators as follows: PM 2.5, Ozone, NATA Diesel PM,
NATA Cancer Risk, NATA Neuro Hazard Index, NATA Respiratory Hazard Index, Traffic Proximity, Lead Paint
Indicator, RMP Proximity, NPL Proximity, TSDF Proximity, and Water Discharger Proximity.
11	Envirofacts is a single point of access to select EP A environmental data. The Envirofacts website
(http://www.epa.gov/enviro/facts/ef overview.html) provides access to several EPA databases containing
information about environmental activities that may affect air, water and land anywhere in the United States.

health risks, including cancer risks, from air toxics based on emissions data from
the EPA's National Emissions Inventory. The EPA collaborates with state, local
and tribal agencies to obtain information that serves as the basis for the NATA.
Although not identified by the regions as a limitation, the most recent NATA was
issued by the EPA in 2011 and is based on air toxics emissions data from 2005.
Thus, the air toxics risk data in EJSCREEN v2.0 is based on emissions data that is
almost 10 years old. The EPA is currently updating the NATA with air toxics
emissions data from 2011 and plans to release the updated NATA to the public in
early 2015. OECA plans to update EJSCREEN v2.0 after the newer NATA data
are released.
Figure 1 provides an example of EJSCREEN v2.0's mapping output. Areas in
yellow, orange and red represent areas that warrant additional review based on air
toxics cancer risk data and selected demographic information. The blue dots
represent the location of air emission facilities12 incorporated into
EJSCREEN v2.0 from Envirofacts.
Figure 1: Example of EJSCREEN v2.0 output for environmental indicator "NATA Cancer Risk,"
showing the locations of air emissions facilities from Envirofacts a
(j) Report on Selected Place & Map Data
Water dischargers
NATA Respiratory HI
Traffic Proximity
* Primary EI Index
NATA Cancer Risk ~ 0
] Data not available
| | Less than 50%ile
RMP Proximity
NPL Proximity
TSDF Proximity
Water Discharger Proximity
~ Demographic Indicators i*
Source: EJSCREEN v2.0 analysis conducted by the OIG.
a Yellow denotes areas in the 80th to 90th percentile; orange the 90th to 95th percentile; and red the 95th to 100th
percentile. The blue dots represent the location of air emissions facilities that are tracked in the EPA's
Envirofacts database.
12 Note that the air emissions facility data layer available in EJSCREEN v2.0 contains all types of air emissions
facilities from Envirofacts, and not just air toxics facilities. There is no data layer specifically for air toxics facilities.

The EPA plans to release EJSCREEN v2.0 to the public in December 2014. The
Office of Environmental Justice and EPA regions have been working with states
to prepare for EJSCREEN v2.0's public release, and to explain how the tool
works and the EPA uses the tool. Once EJSCREEN v2.0 is released publicly, state
and local agencies will be able to use the tool in a manner similar to the way EPA
regions use it to consider EJ in their targeting efforts for air toxics inspections.
Using EJSCREEN Data in Combination With the GeoPlatform
Tool Is a Promising Practice
OECA is beginning to use the agency's GeoPlatform tool in conjunction with
EJSCREEN data to produce better air toxics targeting tools for EPA regions.
The EPA's GeoPlatform is a Web-based geographic information system tool that
the agency launched in May 2012. The GeoPlatform allows EPA staff to build
custom maps by adding any of the thousands of available data layers to
GeoPlatform base maps. It also allows agency staff to easily share completed
mapping products with other EPA users.
Using GeoPlatform allows OECA and EPA regions to develop more detailed
maps to meet specific regional needs and include information that is not available
in EJSCREEN, such as a composite view of selected environmental stressors in a
given area. OECA recently developed two GeoPlatform targeting tools for air
•	Storage Tanks Tool—OECA combined GeoPlatform data layers from the
EPA's Office of Air and Radiation's National Emissions Inventory with
data from the Office of Air and Radiation's Risk and Technology Review
database to identify petroleum storage tank facilities by Standard
Industrial Classification code. OECA then added EJSCREEN information
on air toxics cancer risk to show the percentiles for each block group. The
Storage Tanks Tool is a national map currently available to EPA regions.
•	Model-to-Monitor Tool—OECA compared monitoring data from
thousands of ambient air monitors around the nation to the Office of Air
and Radiation's modeling data available for those locations. In many
cases, the monitored concentrations were significantly higher than the
modeled risks. OECA created a GeoPlatform map of monitor locations,
the locations of facilities within 30 kilometers of the monitors, and the
wind direction on the days when the highest concentrations of air toxics
were measured, to help EPA regions identify where the emissions may
have originated. OECA also included EJSCREEN percentiles for air toxics
cancer risk for nearby census block groups. The Model-to-Monitor Tool is
a national map currently available to EPA regions.

In addition, in November 2014, OECA released an updated version of the HRF
list, which includes every known major source of air emissions located in a
county with a census tract with greater than a 1-in-1-million cancer risk from
stationary source emissions. The updated list identifies facilities that are located in
areas with potential EJ concerns. Specifically, the list includes an "EJ Score" for
each facility that reflects the number of EJ Indices from EJSCREEN for which a
facility scored at or above the 80th percentile. OECA has added the updated HRF
list as a data layer to the GeoPlatform.
OECA has begun outreach activities with individual regions to demonstrate the
GeoPlatform tools and to discuss region-specific mapping needs. For example,
OECA has partnered with Region 6 to develop a map of high-risk flare facilities,
since flaring is an important issue in that region. Similarly, OECA has partnered
with Region l's enforcement staff and geographic information specialists to
combine EJSCREEN data with GeoPlatform data layers to include the following
data in a single online map:
•	Census block groups meeting the 80th percentile EJSCREEN threshold for
any environmental indicator.
•	Locations of storage tanks, gas processing plants and compressor stations.
•	Cancer and noncancer data from the National-Scale Air Toxics
Assessment (with special emphasis on benzene and formaldehyde
•	The boundaries of ozone nonattainment areas.
•	Wind and stream data from the National Oceanic and Atmospheric
•	Population density per square mile.
•	Educational institutions.
•	Percent of population below the poverty level by tract.
•	Percent of population over 64 years by tract.
•	Percent of population under 5 years by tract.
•	Percent of minority population by tract.
•	Tribal boundaries.
•	Federal Registry Service facility data.
By combining EJSCREEN data with GeoPlatform data layers, Region 1 has
produced a regional map view of leaking storage tanks in areas of potential EJ
concern that would not be available to regions using EJSCREEN (or EJSCREEN
v2.0) alone. Figure 2 provides an example of the mapping done by Region 1 that
uses EJSCREEN data in conjunction with GeoPlatform data layers for targeting
purposes. The purple areas represent census block groups meeting the 80th
percentile EJSCREEN threshold for any of the 12 environmental indicators in
EJSCREEN. The dots on the map represent individual facilities or storage tanks.

Figure 2: Example of GeoPlatform data layers used in conjunction with EJSCREEN data
f¥l Details t Add | §§ Basemap
O About [J] Content := Legend
® EJSCREEN Block Groups
Threshold Layer
® OECA R1 Tanks (5/12/14)
@ GMAP Targeting List (11/14/13)
Q Formaldehyde - Est Non-Cancer
Resp Risk (Haz Quot)
Q Formaldehyde - Esbmated
Cancer Risk (per Million)
Q Formaldehyde - Est. Exposure
Concentration (ug/m3)
Q Formaldehyde - Est. Ambient
Concentration (ug/m3)
Q NonAttainment Areas For Ozone
1997 8-hr Standard Of 0.08 ppm
~	NonAttainment Areas For PM 2.5
2006 24-hr Standard Of 35
~	Benzene - Esbmated Cancer Risk
(per Million)
Q Benzene - Esbmated Exposure
Concentration (ug/m3)
~	Benzene - Esbmated Ambient
Concentration (ug/m3)
~	Estimated Non-Cancer
Respiratory Risk (Hazard Index)
Q Esbmated Non-Cancer
Neurological Risk (Hazard Index)
Q Cumulabve Cancer Risk (per
Source: GeoPlatform map generated by Region 1's CAA Inspection Targeting Group, July 2014.
aThe checked boxes on the left indicate that only three of the data layers used to create this map are selected
or "turned on," Blue dots indicate storage tank locations. Red and orange dots indicate Region 1's targeted air
toxics facilities based on the region's GeoPlatform mapping analysis. Region 1 has completed inspections of
these facilities.
In our view, the development of tools that integrate EJSCREEN data with
GeoPlatform data layers is a promising practice that will help EPA regions more
effectively identify areas of potenti al EJ concern, and help regions consider EJ
and risks to communities during targeting efforts. OECA demonstrated these new
tools to EPA regions at a meeting of regional air enforcement managers in
September 2014.
All 10 EPA regions have considered EJ when targeting facilities for air toxics
inspections, and EPA continues to update and advance important tools to support
regional targeting efforts. Through the modifications made to EJSCREEN and the
new GeoPlatform mapping tools being developed by OECA, the agency is taking
important and proactive steps to enhance the ability of EPA regions to consider
areas of EJ concern when targeting air toxics inspections. We make no
recommendati ons.
Directions ^ Measure 0!j Bookmarks

Appendix A
Office of the Administrator
Assistant Administrator for Enforcement and Compliance Assurance
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Regional Administrators, Regions 1-10
Deputy Associate Administrator for Environmental Justice, Office of Enforcement and
Compliance Assurance
Director, Office of Compliance, Office of Enforcement and Compliance Assurance
Audit Follow-Up Coordinator, Office of Enforcement and Compliance Assurance
Audit Follow-Up Coordinators, Regions 1-10