"Breath to the People"
Sacred Air and Toxic Pollution
A report prepared for the United Church of Christ on
100 super polluters in populated areas across the U.S.

 INDEX
Introduction ………………………………………………….3
Acknowledgements……………………………………….....5
Executive Summary………………………………………....6
Recommendations …………………………….....9
The Toxic 100 ……………………………………………....10
Chemicals Released……………………………..11
Demographics…………………………………....13
Compliance & Enforcement…………………...15
Toxic Air Emission Hot Spots…………………...…….....16
Houston Metropolitan Area, Texas…….…….18
Louisiana’s “Cancer Alley”………………….…22
Southeast Coast of Lake Erie in Ohio………..25
Conclusion and Recommendations……………….……..27
Notes…………………………………………………………29
Matters of Morality and Faith: A Postscript………...…31
Appendix ..........................................................................32

2

 Introduction
You will neither waver nor be crushed until justice is established on earth for the
coastlands await your teaching. Thus says God, the Lord, who created the heavens and
stretched them out, who spread out the earth and what comes from it, who gives breath
to the people upon it and spirit to those who walk in it: I am the Lord, I have called you
in righteousness, I have taken you by the hand and kept you.
—Isaiah 42:4-6
There is a moral urgency to the present crisis of toxic air pollution. It is an urgency familiar
to parents, grandparents, and anyone in the position of protecting and caring for children in
their lives. For it is children—with their small, vulnerable, developing bodies—who most
suffer from breathing in toxic air pollutants. This report addresses this urgency by detailing
the sheer number of children under age five who live near 100 super polluting facilities in
our country. These super polluters are responsible for 39 percent of the toxic air emissions
reported in 2018. Yet, this report also makes clear that there is a real and viable path of
hope. The data shows how certain policies could effectively combat current threats to the
health and future of our nation’s children.
To understand the origins of this report, one must first travel back in time. In 1987, the
Commission for Racial Justice of the United Church of Christ undertook an unusual step
for an activist organization that came out of the civil rights movement. It issued an
environmental report. That report became the first report to comprehensively demonstrate
environmental racism in the United States in relationship to the dumping of toxic waste. In
2020, the United Church of Christ is again compelled to release a report, but of a somewhat
different nature. Since the establishment of the Environmental Protection Agency fifty years
ago, our nation has not witnessed an assault of this scale on environmental protections by a
presidential administration.
The present administration has sought to roll back 95 protections. To make matters worse,
the protections in place are losing their teeth as enforcement drops to levels not seen in
decades. The overall picture is one of institutional dismantlement and destruction.
As this report makes clear, this could not be happening at a worse time. Super polluters
operate with limited oversight as we witness the rapid expansion of the chemical industry.
Nearly a quarter of the emissions from these super polluters come from leaks and fugitive
emissions which are often preventable and avoidable. At precisely the moment when all the
signs tell us that we should be increasing our vigilance, we are decreasing it and putting our
children at even greater risk.
With this report, we can pinpoint where the children in the most danger live. They are the
children who live near clusters of toxic polluting facilities. Children who often live lives
defined by multiple jeopardies and injustices. Children who live along the fence line in
places like Houston and Louisiana’s “cancer alley”—that stretch of industrial toxic territory

3

 from Baton Rouge to New Orleans. Yet, it is not only the children in these well-known
areas of toxic danger who command attention in this report. Some of the facilities in the
report’s Toxic 100 list have a seemingly inconspicuous existence. They hide in plain sight
and threaten children in communities across the country.
When over 112,500 children under age five in our nation live within three miles of the 100
super polluting facilities identified in this report and when over 11,500 live within a mile, it
is indeed a moral crisis that our nation faces. As people of faith, we are not easily satisfied
when the fate of our children and the planet is at stake. Ultimately, what we desire is for our
toxic economy to become a toxic-free economy. This happens by putting children first in
striving for measures to ensure their health and wellbeing. It happens by reforming and
implementing existing protections, and it happens by bold policy prescriptions like the
Green New Deal. If such ambitions should seem grandiose or utopian, then put yourself in
the shoes of the countless parents and caregivers who would do anything to protect the lives
of their children. Love is a powerful force that will stop at nothing.

The Rev. Traci Blackmon

The Rev. Brooks Berndt

Associate General Minister
Justice and Local Church Ministries

Minister of Environmental Justice

4

 ACKNOWLEDGEMENTS
The origins of this report began in May of 2018 at a convening of environmental justice
leaders in New Orleans. We had gathered to discuss how to best respond to the dismantling
of the Environmental Protection Agency under the current administration. The
conversation was rich and insightful. We are deeply indebted to those who gathered which
included Mustafa Ali, Shantha Ready Alonso, Dorien Blythers, Dr. Robert Bullard, Peggy
Shepard, Kerene Tayloe, and Dr. Beverly Wright. Without their initial guidance, this report
would not have materialized.
We additionally extend our gratitude to Texas Environmental Justice Advocacy Services
(t.e.j.a.s.). T.e.j.a.s. played an instrumental role in providing feedback for policy
recommendations and arranging a powerful and informative environmental justice tour for
UCC staff and clergy in the Houston area.
This report was written and researched by Courtney Bernhardt, Keene Kelderman, and Ben
Kunstman of the Environmental Integrity Project and prepared for the United Church of
Christ.

The Environmental Integrity Project
The Environmental Integrity Project (http://www.environmentalintegrity.org) is a
nonpartisan, nonprofit organization established in March of 2002 by former EPA
enforcement attorneys to advocate for effective enforcement of environmental laws. EIP has
three goals: 1) to provide objective analyses of how the failure to enforce or implement
environmental laws increases pollution and affects public health; 2) to hold federal and state
agencies, as well as individual corporations, accountable for failing to enforce or comply
with environmental laws; and 3) to help local communities obtain the protection of
environmental laws.
For questions about this report, please contact:
Tom Pelton, Environmental Integrity Project, (202) 888-2703 or
tpelton@environmentalintegrity.org

PHOTO CREDITS:
Cover photo: Taken in Houston, Texas by Madison Mayhew

5

 Breath to the People: Sacred Air and Toxic
Air Pollution
Executive Summary

A

cross the country, thousands of industrial facilities release toxic pollutants into
nearby communities, burdening them with negative health and environmental
consequences. These polluters are far from evenly distributed—in fact, they are
concentrated in several pollution hubs, and those living nearby are especially at risk from
their noxious fumes. The Environmental Integrity Project analyzed the most recent
available toxic air emission data reported to the U.S. Environmental Protection Agency’s
Toxics Release Inventory (TRI), which tracks air releases from over 15,500 facilities, to
determine which are releasing the most toxic air pollution into heavily populated areas.
Toxic air pollution can or may cause cancer, birth defects, or other serious health effects like
brain damage.
Some chemicals contain more potent toxins than others, so in order to assess where the
most toxic releases occurred we applied an EPA’s methodology that assigns greater weight
to pollutants that are more toxic when inhaled. For example, applying EPA’s weighting
factors to compare the relative toxicity of two different pollutants, a ton of benzene is
roughly equivalent to 393 tons of ethylene oxide. The 300,724 tons of air emissions that the
15,500 facilities reported to
the TRI in 2018 translates to
over 4.7 billion toxicityweighted tons of air
pollution, consisting of
hundreds of different
carcinogens, persistent bioaccumulative toxins, metals,
and other toxic chemicals.
Three of the most toxic
chemicals released include
ethylene oxide, hexavalent
chromium, and nickel, all
potent human carcinogens.
Our analysis shows that
over a third (39 percent) of
all toxic emissions
nationwide came from just
100 facilities that have at

The map above shows locations of the “Toxic 100” facilities identified in this
report. Clusters of plants are near Houston Texas, between Baton Rouge and
New Orleans in Louisiana, and along the Southeast Coast of Lake Erie in
Ohio.

6

 least 250 people living within a mile. We’re calling this list “The Toxic 100.” Table A lists
the top 10 plants.
Table A. 10 Toxic 100 plants that released the most toxicity-weighted air pollution, 2018
Rank

1

Facility
(Location)
Huntsman Petrochemical
LLC Port Neches Facility

Population
within One
Mile

2

Tons of Air
Pollution
Reported

Million ToxicityWeighted Tons of
Air Pollution

1,820

Ethylene Oxide, Benzene,
Propylene Oxide

143.8

235.8

775

Ethylene Oxide, Benzene,
Chlorine

193.4

92.9

327

Ethylene Oxide,
Diaminotoluene (Mixed
Isomers), 4,4’Methylenedianiline

189.4

90.1

(Jefferson County, TX)
Sasol Chemicals (USA) LLC
– Lake Charles Chemical
Complex

Top 3 Chemicals
Released

(Calcasieu Parish, LA)

3

4

5

6

7

8

BASF Corp
(Ascension Parish, LA)
Midwest Sterilization Corp
(Webb County, TX)
Medtronic Xomed
(Duval County, FL)
Shell Chemical, LP
(Ascension Parish, LA)
Denka Performance
Elastomer LLC
(St. John the Baptist Parish,
LA)
St. Charles Operations
(Taft/Star) Union Carbide
Corp.

1,147

Ethylene Glycol, Ethylene
Oxide

7.6

83.1

4,265

Ethylene Oxide

7.0

77.4

116.5

57.4

54.3

50.8

216.4

44.2

1,076.2

43.98

3.7

40.62

279

1,834

Eastman Chemical Co.
Texas Operations

Ethylene Oxide,
Formaldehyde, 1,3Butadiene

368

Ethylene Oxide,
Chloroform, 1,3-Butadiene

607

Ethylene Oxide, Ethylene
Glycol

(Harrison County, TX)
Midwest Sterilization Corp.
10

(Cape Girardeau County,
MO)

Chloroprene, 1,4-Dichloro2-butene, 1,3-Butadiene

418

(St. Charles Parish, LA)

9

Ethylene Oxide,
Acetaldehyde, Cobalt
Compounds

Source: Toxics Release Inventory, 2018; 2019 EJSCREEN

7

 Of the top 10 plants listed in Table A, nine reported releasing ethylene oxide. Two of the top
10 plants are owned by Midwest Sterilization, which uses ethylene oxide to sterilize medical
equipment.
More than a third (34 percent) of all toxicity-weighted air emissions came from just ten
counties across the country, and 19 percent (884 million toxicity-weighted tons) of all toxic
emissions reported to the TRI in 2018 came from 352 facilities in just 4 counties in Texas,
including Calhoun, Jefferson, Harris, and Webb counties. The remainder of the top ten
counties include: Ascension and Calcasieu parishes in Louisiana; Humboldt County,
Nevada; and Des Moines County, Iowa; and Montgomery County, Virginia.
In all but three of the top ten counties, a single facility reported over two-thirds of the
county’s toxic emissions. For example, the Huntsman Petrochemical LLC Port Neches
Facility, located in Jefferson County, Texas, was responsible for 87 percent of the toxicityweighted emissions reported in the county. According to the Toxics Release Inventory, the
facility reported releasing 144 tons of 28 chemicals. According to EPA’s assessments of the
relative toxicity of different pollutants, the plant’s toxic air releases are equivalent to 236
million tons of toxic air pollution. 1 Nearly all of the plant’s toxicity-weighted emissions
consisted of ethylene oxide, a human carcinogen.
Nearly a quarter (24 percent, or 450 of 1,850 million toxicity-weighted tons) of toxic
emissions came from leaks (called “fugitive emissions” by EPA), according to company
reports. These leaks persist during routine operations but can spike as a result of poor
maintenance, accidents, extreme weather events, and plant malfunctions, and are often
difficult to detect and measure. According to a review of the EPA’s Enforcement and
Compliance History Online database, 26 of the Toxic 100 facilities were in violation of the
Clean Air Act in 2018.
The data show that large emissions from a small subset of “super-emitters” can have a
disproportionate impact on people living downwind, who often have to cope with more
than one source and type of air pollution, which compounds the risk. Harris County has five
“Toxic 100” facilities: Lyondell Chemical Co., Dixie Chemical Co., Albemarle Corp’s
Bayport Plant, and ExxonMobil’s Baytown Refinery, and ExxonMobil’s Baytown Olefins
Plant. Other counties that have more than one Toxic 100 facility include Louisiana’s
Ascension, East Baton Rouge, St. Charles, and St. John the Baptist parishes; as well as
Arizona’s Gila County; Kanahwa County in West Virginia, and Brazoria and Montgomery
Counties in Texas (both of which are in the Houston Metropolitan area along with Harris
County). Having several toxic air emission sources within a small area is a serious concern
for people living nearby.
Across the U.S., an estimated 169,654 people live within a mile of a facility on the Toxic
100 list and 1.6 million people, about the population of the city of Phoenix, AZ, live within
three miles of one. We analyzed the percentage of these populations that are vulnerable or
disadvantaged – namely, people who are Hispanic, Latino or of color; low-income (defined
as more than two times below the federal poverty level); under the age of five; or over the

8

 age of 64. We then compared them to state averages calculated by the EPA. In total,
percentages within a mile of 98 of the 100 facilities exceed state averages for one or more
vulnerable population indicator.
At the national level, the percentage of people of color or Hispanics or Latinos, low-income
residents, and children under five living within one mile of the Toxic 100 were all higher
than national averages. Forty-four percent of the population is low income, which is
significantly higher than the national average of just under 33 percent. Forty percent are
people of color or Hispanic or Latino, while the national average is 38 percent. The
percentage of children living within a mile of the Toxic 100, seven percent, is close to the
national average of six percent. An estimated 11,581 children live within a mile of the Toxic
100, while 112,681 live within three miles.
Our analysis adds to the wealth of literature documenting the uphill battle that frontline
communities face in working towards long-overdue environmental justice goals, such as
clean air, clean water, and fair treatment under the law.

Recommendations:
•

Targeted environmental enforcement by federal and state authorities should be a
priority to reduce emissions from facilities that release the most toxic pollution. A
disproportionate amount of toxic air pollution comes from a small subset of plants,
and 26 of the Toxic 100 facilities were in violation of the Clean Air Act in 2018.

•

Companies should significantly reduce leaks and fugitive emissions. For example,
companies that use or process ethylene oxide or benzene (both carcinogens) should
be required to install fence line monitoring systems to detect leaks and provide
monitoring data to the public, first responders and regulators so that proper measures
can be taken to reduce health risks. Oil refineries are already required to install fence
line monitoring systems for benzene.

•

The chemical industry is rapidly expanding thanks to low prices of natural gas and
an abundance of natural gas liquids feedstock. The well-being and fair treatment of
residents of surrounding communities need to be top priorities when considering
approvals for expansions or new construction, especially in areas where communities
are surrounded by several toxic pollution sources.

•

The TRI is a valuable but limited dataset. It relies on companies to report accurate
information, and EPA should do all it can to ensure that the data are accurate and
reliable. Many industries and types of facilities are not required to report, making it
difficult to assess where communities might be exposed to some of the most
dangerous toxins. Municipal waste incinerators and gas processing plants, for
instance, should be required to report to the TRI, as evidence from other sources like
state emission inventories suggest that they would meet reporting requirements.

9

 The Toxic 100
The Environmental Integrity Project (EIP) analyzed air emissions reported to the EPA’s
Toxics Release Inventory (TRI) for the 2018 calendar year. 2 These emissions can originate
from both designated emission points (stacks) and leaks (fugitive emissions) that occur
during normal operations or from unexpected accidents or malfunctions. Facilities report
the amount of each chemical they release in pounds. However, not all chemicals pose the
same threat to human health at the same concentrations. A pound of ethylene oxide can do
a lot more harm than a pound of styrene. Weighting chemical emissions by the harm they
can cause if inhaled provides a more accurate indication of where emissions might pose the
largest threat to human health.
In order to identify the “super-emitters” that have the potential to impact the most people,
EIP identified the 100 facilities that reported releasing the most toxic emissions in areas that
have at least 250 people living within a mile. 3 These facilities, which we refer to as the
“Toxic 100,” emitted 39 percent (1,850 of 4,759 million tons) of the toxicity-weighted air
pollution reported in 2018, yet they represent less than one percent of the over 15,500
facilities that reported toxic air emissions to the TRI. An estimated 169,654 people live
within a mile of a Toxic 100 plant, and over 1.6 million live within 3 miles.
Table A in the Executive Summary lists the 10 facilities that emitted the most toxicityweighted air pollution in 2018. All 100 facilities are listed in Appendix A. The map in the
Executive Summary shows locations of the Toxic 100. The counties surrounding Houston,
Texas, as well as “Cancer Alley” in Louisiana are obvious hot spots. Several facilities are
also clustered along Lake Erie in Ohio. These hot spot areas are discussed in further detail
later in the report. Some examples are listed below:
•

Huntsman Petrochemical’s Port Neches Facility in Jefferson County, Texas released
the highest amount of toxicity-weighted air pollution. The plant released 28 different
pollutants to the air, including ethylene oxide, dioxins, benzene, and propylene oxide
through a combination of stack emissions and leaks. The plant’s toxicity-weighted
emissions add up to 236 million tons, largely consisting of ethylene oxide.

•

Sasol Lake Charles Chemical Complex in Calcasieu Parish, Louisiana released the
second highest amount of toxicity-weighted air pollution. The plant reported
releasing 32 different toxic pollutants to the air, including ethylene oxide, benzene,
and chlorine largely from stacks and flares. The plant’s toxicity-weighted emissions
add up to 92.9 million tons.

•

BASF Corp.’s Ascension Parish, Louisiana plant reported the third highest amount
of toxicity-weighted air pollution. The plant reported releasing 20 different chemicals
to the air, including ethylene oxide, diaminotoluene, and 4,4’-methylenedianiline.
The plant’s toxicity weighted emissions add up to 90.1 million tons, a large portion
of which consisted of ethylene oxide.

10

 Over one third (36 percent) of the facilities in the Toxic 100 engage in chemical
manufacturing, and over one quarter (26 percent) of the facilities manufacture primary or
fabricated metals (Table B). The chemical industry has undergone a rapid expansion over
the past decade, with many expansions to existing facilities and construction of new ones in
areas that are already petrochemical hubs along the Gulf Coast in Texas and Louisiana. 4
Table B. Industries with facilities in the Toxic 100
Number of
Facilities
36

Tons of Air
Pollution Reported
8,477.4

Million Toxicity-Weighted
Tons of Air Pollution
970.1

Miscellaneous Manufacturing (339)

7

24.1

265.2

Primary Metals (331)

15

794.9

191.8

Fabricated Metals (332)

11

56.2

125.2

Transportation Equipment (336)

9

19.9

87.6

Machinery (333)

4

22.8

67.2

Electrical Equipment (335)

3

34.7

28.2

Plastics and Rubber (326)

1

3.5

27.0

Petroleum (324)

5

2,254.9

26.2

Nonmetallic Mineral Products (327)

3

1.5

22.1

Electric Utilities (2211)

4

1,220.3

21.4

Hazardous Waste (562)

1

9.9

13.1

Paper (322)

1

45.2

5.4

100

12,965.4

1,850.4

Industry (Industry Code)
Chemicals (325)

TOTAL
Source: Toxics Release Inventory, 2018

Nearly a quarter (24 percent, or 450 of 1,850 million toxicity-weighted tons) of the
emissions from the Toxic 100 facilities came from leaks, which are reported to the TRI as
“fugitive” emissions, rather than from stacks or other designated emission points. Leaks can
occur because of human error, poor maintenance, malfunctions, or as a result of extreme
weather events like hurricanes and floods, making leaked emissions more difficult to
quantify accurately using traditional methods. Leaks can go undetected for long periods
with little to no pollution controls in place. Leaking emissions are also often released closer
to the ground than those from a stack or flare, making them more likely to be inhaled at
high concentrations by people living immediately downwind or just beyond a facility’s
property line.

Chemicals Released
The US EPA maintains a list of inhalation toxicity weights that it uses to estimate hazards
from toxic releases of 440 chemicals in its Risk Screening Environmental Indicators model.
The higher the toxicity, the higher the weight. The most toxic chemicals are dioxin and
dioxin-like compounds, which are highly potent toxins that have an inhalation toxicity
weight of 1.4 billion. Twenty facilities in the Toxic 100 reported releasing just 0.04 pounds
of dioxin, yet the toxicity-weighted emissions are equivalent to 30,677 tons. Dioxins are
likely under-reported to the TRI, largely because of reporting requirement exemptions.

11

 Dioxins typically form when burning plastic. Yet municipal waste incinerators, except for
the few that are regulated under the Resource Conservation and Recovery Act, that burn
plastic are not required to report to the TRI. Of the facilities on the Toxic 100 list, Colstrip
Steam Electric Station, a coal-fired power plant in Rosebud County, Montana, reported
releasing the most dioxins and dioxin-like substances, with 0.014 pounds (equivalent to
9,659 tons after accounting for inhalation toxicity).
The Toxic 100 reported releasing a total of 166 different chemicals or chemical compounds
to the air in 2018. Table C lists the 10 chemicals that facilities reported releasing in the
highest quantities, once weighted for inhalation toxicity. The most toxic chemical in the
table below is propyleneimine, a flammable carcinogen that is used in making paint,
pharmaceuticals, and other chemicals. 5 It is the sixth most toxic chemical cataloged by EPA
for its inhalation toxicity. Only one facility reported releasing this chemical, Dixie Chemical
Co. Inc. in Pasadena, Texas, which released 160.6 pounds of the chemical through a
combination of leaks and stacks, with a toxic equivalent of 12 million tons.
Table C. Top 10 chemicals released, according to total toxicity-weighted emissions
Chemical (CAS No.)

Number
of
Facilities

Inhalation
Toxicity
Weight
(millions)
11
43
17
0.93
1.1
15
2.1
0.11
0.39
150

Ethylene Oxide (75218)
27
Chromium and Chromium Compounds (7440473 & N090)
58
Cobalt (7440484 & N096)
32
Nickel (7440020 & N495)
54
Chloroprene (126998)
2
Arsenic And Arsenic Compounds (N020)
7
Nitroglycerin (55630)
1
1,3-Butadiene (106990)
17
Polycyclic Aromatic Compounds (N590)
19
Propyleneimine (75558)
1
Source: Toxics Release Inventory, 2018; EPA’s 2017 RSEI model
*Toxicity weight only applied to the hexavalent chromium portion according to EPA methodology.

Tons
Reported
92.51
40.9
7.6
62.6
40.9
2.4
12.6
201.8
45.3
0.08

ToxicityWeighted
Tons
1,017,559,840
419,164,471*
129,713,502
58,200,416
44,914,050
36,645,000
26,377,050
22,195,415
17,682,677
12,040,250

Chromium and chromium compounds are also some of the most toxic chemicals reported
by facilities on the Toxic 100 list. One form of chromium, hexavalent chromium, is highly
toxic if inhaled at high levels over short periods of time (acute exposure) and at low levels
over longer periods of time (chronic exposure). Acute exposure can cause shortness of
breath, coughing, and wheezing, while chronic exposure can cause damage to the septum,
bronchitis, decreased heart function, pneumonia, and other respiratory damage. 6
Hexavalent chromium is the ninth most toxic chemical cataloged by the EPA.
It is important to recognize that companies report total chromium releases to EPA, and not
all of those emissions are toxic. EPA’s Risk Screening Environmental Indicators model
assumes that a portion of the total chromium emissions are toxic based on data reported to
the National Emission Inventory, and the toxicity weight for chromium is only applied to
the toxic (hexavalent) portion. 7 We used the same assumptions and methods in this report.
Fifty-eight facilities reported emitting 40.8 tons of chromium, 9.7 tons of which we assumed

12

 to be hexavalent. This amount of hexavalent chromium is equivalent to over 419 million
tons of toxicity-weighted tons of air pollution after adjusting for inhalation toxicity.
Ethylene oxide is another potent toxin that facilities in the Toxic 100 reported releasing to
the air. It is a flammable gas used to make other chemicals and products like antifreeze,
textiles, plastics, detergents, and adhesives. It’s also used to sterilize medical equipment. 8
Acute exposure can cause headaches, dizziness, nausea, fatigue, respiratory problems,
vomiting, and other digestive system problems. Chronic exposure to ethylene oxide can
cause eye, nose, throat, and lung irritation, as well as damage the brain and nervous system.
Long-term exposure can also cause breast cancer and cancers that impact white blood cells
like non-Hodgkin lymphoma, myeloma, and lymphocytic leukemia. 9 EPA in 2016 classified
ethylene oxide as a human carcinogen and updated its health values for the chemical to
more adequately account for its toxicity. According to EPA, people who live near facilities
and are exposed to ethylene oxide for very long periods of time (such as over a lifetime)
have the highest risk of health impacts. The cancer risk is greater for children than for adults
after just one year of exposure. 10

Demographics
High volumes of toxic emissions are a serious concern no matter where they occur, and no
matter who they impact. But because certain populations are more susceptible and
vulnerable to the negative impacts of pollution, we examined the demographics within one
and three miles of the Toxic 100 to evaluate whether vulnerable populations live within
close proximity. We used a geospatial aerial apportionment method based on point
locations available from the TRI and demographic indicators available from EPA’s 2019
EJSCREEN dataset to derive our estimates. 11
We selected distances of one and three miles of each plant because leaks and “fugitive”
releases of toxic chemicals to the air can impact people closer to a facility than those emitted
through stacks or emission points designed to disburse emissions higher into the air so they
are diluted if and/or when they reach people downwind. The three-mile estimate also
allowed us to reduce some of the uncertainty associated with using facility point locations
instead of their actual boundaries to estimate distances, as facility footprints vary in size.
However, different chemicals behave differently in the air, and meteorological conditions
that impact dispersion of air pollution also vary from place to place and over time. We did
not include these factors in our analysis.
The 2019 EJSCREEN dataset contains census block level demographics from the U.S.
Census Bureau’s 2013-2017 American Community Survey. We considered the following
four demographic indicators to evaluate which of the Toxic 100 were located in areas near
populations that are most likely to be vulnerable to environmental pollution:
•

The number and percentage of people considered low-income (defined as individuals
having a household income less than or equal to twice the federal poverty level),

13

 •
•
•

The number and percentage of people of minority racial or ethnic backgrounds
(defined as people of color and Hispanics or Latinos),
The number and percent of people under age five, and
The number and percent of people over age 64.

Young children are often the most susceptible to air pollution because they breathe at higher
rates and because their developing brains and bodies are more sensitive to certain types of
pollution. Older adults may have preexisting conditions that make the impacts of pollution
more dangerous or likely to result in more serious outcomes, like death. According to EPA,
low-income individuals and people of color or Hispanics and Latinos are less likely to have
health insurance, which makes it more difficult for them to cope with the health impacts
caused by pollution. Some groups, like those who do not speak English or engage in certain
cultural practices (i.e. eating more self-caught fish and shellfish) may be less able to avoid
situations that put them in contact with pollution. Low income and minority impacts are
most commonly used in environmental justice analyses. While the four indicators we chose
are not the only indicators of potential susceptibility or vulnerability to environmental
pollution, they are some of the most widely used. 12
We compared the percentage of people in each demographic category to national averages
calculated by the EPA (Table D). Higher percentages relative to national and state averages
generally indicate that closer attention to vulnerable populations living near highly polluting
facilities. At the national level, 169,654 people live within one mile of a Toxic 100 facility,
and 1.6 million live within three miles of one. Forty-four percent of people living within a
mile of the Toxic 100 facilities are low income, though the national average is just under 33
percent. These residents live with more poverty than almost three quarters of the country.13
Forty percent of people living within a mile are people of color or Hispanic or Latino, which
is higher than the national average of just over 38 percent.
Table D. Demographic characteristics of people living within a mile and three miles of 100
facilities
Demographic Indicator

National Average

People of color
or Hispanic or
Latino
38.5%

Low Income

32.7%

Children
under 5
years old
6.2%

Adults over
64 years old
14.9%

1 Mile
Population

68,403

73,961

11,581

23,849

Percentage of total population (169,654)

40.3%

43.6%

6.8%

14.1%

Population

753,462

689,006

112,681

222,744

Percentage of total population (1,645,552)

45.8%

41.9%

6.8%

13.5%

3 Miles

Source: EIP analysis of 2019 EJSCREEN geospatial database

The results above are based on aggregate demographic totals compared to national averages,
yet demographics vary by facility and the state in which they are located. State averages can

14

 vary greatly. For example, the average percentage of low-income people in Virginia is 26
percent, but it is 44 percent in Mississippi (the national average is just under 33 percent).
We counted the number of facilities in the Toxic 100 that had demographic indicators
greater than their state averages (Figure 1). A total of 98 of the 100 facilities had
demographic percentages greater than state averages for one or more vulnerable population
indicator. About two-thirds (65) of the Toxic 100 had a higher percentage of people living
with low incomes within a mile than their state average. Fifty-six facilities had a higher
percentage of children under age five, 51 had a higher percentage of people of color or
Hispanic or Latino, and 43 had a higher percentage of people over age 64. This suggests that
these facilities are located near potentially vulnerable populations.

Number of Facilities with
Percentages Higher than their
State Average

Figure 1. Number of facilities in the Toxic 100 with demographic indicators within one mile
that are higher than their state average
70

65
56

60

51

50

43

40
30
20
10
0
Low Income

Under Age 5

People of color or
Hispanic or Latino
Demographic Indicator

Over Age 64

Compliance & Enforcement
EIP reviewed Clean Air Act compliance information available through the US EPA’s
Enforcement and Compliance History Online (ECHO) website to determine if any of the
facilities on the Toxic 100 list violated the Clean Air Act in 2018. Seven facilities had
violations and 19 more were considered “high priority violators.” Fifty-seven were in
compliance. Seventeen had no Clean Air Act records available in ECHO. Based on ECHO
data alone, it is difficult to determine whether the violations were related to toxic emissions.
However, violations indicate that over a quarter of the facilities are not complying with their
air emission permits, and since these are some of the largest emitters of toxins that report to
the TRI, targeted enforcement could play a strong role in reducing emissions.
Five of the 26 facilities that were in violation or considered high-priority violators of the
Clean Air Act in 2018, according to ECHO, include BASF Corp. in Ascension Parish,
Louisiana, St. Charles Operations (TAFT/STAR) Union Carbide Corp. in St. Charles
Parish, Louisiana, Huntsman Petrochemical in Montgomery County, Texas,, Haynes
International in Howard County, Indiana, and SFI of Tennessee in Shelby County,
Tennessee. Each facility’s 2018 Clean Air Act compliance status is included in Appendix A.

15

 Four facilities that we could have included on the Toxic 100 list were suspected to have
reported erroneous data to the EPA, according to an analysis by ProPublica. These facilities
include Smith International, Inc. in Harris County, Texas, which reported releasing 67.7
tons of chromium, nickel, and manganese to the air; SPX Flow Technology in Marion
County, Florida, which reported emitting 52.6 tons of xylene, chromium, and nickel;
Modern Industries, Inc. in Erie County, Pennsylvania, which reported releasing 120.2 tons
of chromium, zinc, nickel, copper, ammonia, and manganese; and Fecon LLC in Warren
County, Ohio, which reported releasing 30.3 tons of copper, nickel, manganese, and
chromium. If we had included them on this list of 100 plants, they would have ranked
numbers 1, 3, 12, and 17, respectively, after weighting emissions by inhalation toxicity.
It is imperative that facilities report accurate information to the Toxics Release Inventory,
otherwise it undermines the purpose of the TRI program and robs communities and
decision-makers of accurate and reliable information. Facilities can submit revised TRI
report forms to EPA, but EPA does not immediately post the data to its website or update
its public database. Additionally, EPA’s public TRI database does not identify facilities that
are suspected of having submitted erroneous data, and there is no easy way to report
suspected errors to the TRI Program.

Toxic Air Emission Hot Spots
The Toxic 100 represent less than one percent of facilities that reported to the TRI in 2018,
yet they released 39 percent of the toxicity-weighted emissions. In order to better understand
what drives hot spots for toxic air pollution, we calculated toxicity-weighted emissions by
county (Figure 2). Facilities in just 10 counties reported 34 percent of all toxic emissions
(1,632 million of 4,759 million toxicity-weighted tons) (Table E). Four of the counties with
the highest reported toxic releases are located in Texas, and two are in Louisiana. Others
are located in Florida, Nevada, Iowa, and Virginia. Of the 2,260 counties where facilities
reported toxic air releases in 2018, 77 percent (1,729) counties were home to more than one
facility. Harris County, Texas had the most facilities reporting (296) with Cook County,
Illinois had the second highest (256).
In all but two of the top 10 counties, over two thirds of toxic emissions came from a single
facility. Seven of the 10 counties had one or more Toxic 100 facility, and the three that did
not had populations not dense enough to be included on the Toxic 100 list but were still
home to large emitters. Facilities that released a lot of pollution in Calhoun County, Texas,
Humboldt County, Nevada, and Des Moines County, Iowa, which are not home to any of
the Toxic 100 plants, include Union Carbide Corp’s Seaport Plant, Sierra Pacific Power’s
North Valmy Power Station, and a US Army Ammunition Plant, respectively. This
underscores the finding that large “super-emitters” have an oversized impact on toxic
emissions.

16

 Table E. 10 Counties where facilities released the most toxicity-weighted air pollution

Calhoun, TX

Toxic 100
Facilities/Total
TRI Facilities
that Reported
Air Releases
0/6

21,807

1,166.7

323.0

Percent of Total
County Toxic Air
Releases that Came
from a Single SuperEmitter
97.3%

Jefferson, TX

1/47

255,210

2,967.2

269.6

87.5%

Harris, TX

County/Parrish,
State

Population
(20132017
average)

Tons of
Toxic Air
Pollution
Reported

Total Reported
Toxic Air Releases
(Million toxicityweighted tons)

5/296

4,602,523

5,420.0

208.8

13.4%

Humboldt, NV

0/7

6,727

118.3

178.8

97.4%

Ascension, LA

3/18

121,176

6,924.9

166.4

54.1%

Des Moines, IA

0/10

39,600

140.6

136.4

99.5%

Calcasieu, LA

1/30

200,182

2,628.5

106.1

87.6%

Webb, TX

1/3

272,053

7.6

83.1

99.9%

Montgomery, VA

1/5
97,997
81.0
71.8
Duval, FL
1/40
924,229
79.1
464.8
Source: EPA 2018 Toxics Release Inventory, U.S. Census 2013-2017 American Community Survey

67.4%
97.8%

Figure 2. County-level toxic air emissions reported to the TRI, 2018, weighted for
inhalation toxicity
Southeast Coast of Lake Erie

Houston, Texas

“Cancer Alley,”
Louisiana

17

 Houston Metropolitan Area, Texas
The Houston metropolitan area experienced some of highest amount of toxic air releases in
2018, according to the Toxics Release Inventory. The metropolitan area includes Austin,
Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller
counties, and is home to one of the United States’ largest petrochemical manufacturing
hubs. A total of 410 facilities around Houston released 288 million tons of toxicity-weighted
air pollution in 2018, accounting for 24 percent of the 1.2 billion tons of toxic emissions
reported across all of Texas and 6 percent of the 4.8 billion tons of toxic emissions reported
nationally.
Ten of the Toxic 100 facilities are located in the Houston metropolitan area, in Brazoria,
Harris, Fort Bend, and Montgomery counties. They emitted 109 million tons of toxicityweighted air pollution in 2018. Eight of the ten facilities manufactured chemicals, one one
refines oil, and one manufactures fabricated metals. Figure 3 shows the locations of Toxic
100 facilities in the Houston area. Table F lists the Toxic 100 facilities located in and near
Houston and the demographics surrounding each one. Demographic indicators in bold font
are those that exceed state averages.
Dow Chemical Co. Freeport Facility (number 45 on the Toxic 100 list) is a 7,000-acre
petrochemical complex located in Freeport, Texas, in Brazoria County. According to Dow’s
corporate website, the Freeport facility is the largest chemical manufacturing facility in the
Western Hemisphere. The complex is also home to the company’s new 1.5 million metric
ton ethylene cracker and
polyethylene plastic
manufacturing facility,
which started up in
2017. 14 The ethylene
cracker is currently
undergoing another
expansion that the
company expects to
complete in 2020. 15 The
plant makes a variety of
performance materials
and coatings, industrial
chemical intermediates,
and plastics. 16 It released
The Dow Chemical Freeport Facility in 2018 released 11.7 million toxic
83 different chemicals to
tons of air pollutants into a neighborhood that has some of the highest
the air, the most toxic of
percentages of low income people and children under five in the state.
which included
carcinogens like dioxins, ethylene oxide, and diaminotholuene, with toxicity-weighted
emissions of 11.7 million tons.

18

 An estimated 1,827 people live within a mile of the plant. Eighty-six percent are people of
color or Hispanic or Latino, 75 percent are low income individuals, 10 percent are children
under 5, and 2.7 percent are over age 64. These percentages are all higher than the state
average, except for the percent of people over age 64. The percentages of low income and
children are some of the highest in the state. Impacts to vulnerable populations should be
investigated and that the regulators approving expansions of the plant should seriously
consider the impacts to children and the impoverished.
Nalco Champion (number 84 on the Toxic 100 list), an Ecolab subsidiary, is an organic
chemical manufacturing plant that makes chemicals used in the oil, gas, and petrochemical
industries. It is located in Fresno in Fort Bend County, Texas, south of Houston. It released
5.4 million tons of toxicity-weighted air pollution in 2018, consisting of ethylene oxide,
xylene, and propylene oxide, and other chemicals. Ethylene oxide is a carcinogen, and
propylene oxide is a probable human carcinogen. Xylene is not a carcinogen, but short-term
exposure can irritate the eyes, nose, and throat, disrupt the digestive system, and cause
neurological damage. Long-term exposure can damage the kidneys and the central nervous,
respiratory, and cardiovascular, systems. 17
An estimated 3,234 people live within a mile of the Nalco Fresno plant, 87 percent are
people of color or Hispanic or Latino, 25 percent are low income, 9.7 percent are children
under age 5, and 7.4 percent are over age 64. Percentages are higher than state averages for
people of color or Hispanic or Latino and for children under age five.

19

 Figure 3. Locations of the ID Toxic IOO Facilities in the Houston Metropolitan Area, Texas

NOV Texas Oil TeeistTES Cenree

ah

Huntsman Pete-chemical LLC

The Wendi . 
an 


335}!

.E
if?" 
Lyendell Chemical CU.
E1903- Houston
0 we -tmun
a 
DPaeadena
E: .
Suwl?and ?arbemarle Corp Bayrp?rt Plant
my . Dixie Chemical (In. Inc.
Roeenberg ?Peariand
9 Male: Champion

League '2!ij
.

USA LLC Bayou Piant
13? - OITenucae. Gib;

20

?h EmenMehil Refining Sunni,?r Baytewn

xxenMehil Bavtewn Ole?ns Plant



A He '1 .1a a
Material WIId?ife
Fle?uge

Table F. Toxic 100 Facilities in the Houston Metropolitan Area
Tons Air
Pollution
Reported
/ Million
ToxicityWeighted
tons

No.
people
living
within
a mile

% People
of color
or
Hispanic
or
Latino

Rank

Facility (County)

14

Lyondell Chemical
Co. (Harris)

Ethylene Oxide,
1,3-Butadiene,
Benzene

510 / 28.1

446

76%

51%

3%

8%

23

Huntsman
Petrochemical LLC
(Montgomery)

Ethylene Oxide,
Acrylonitrile,
Propylene Oxide

21.7 / 25.5

598

53%

61%

10%

10%

38

Dixie Chemical Co.
Inc. (Harris)

Propyleneimine,
1,3-Butadiene,
Maleic Anhydride

8.7 / 12.3

329

40%

13%

4%

19%

41

Dow Chemical Co.
Freeport Facility
(Brazoria)

Ethylene Oxide,
1,3-Butadiene,
Formaldehyde

443.4 / 11.7

1,827

86%

75%

10%

3%

60

Albemarle Corp.
Bayport Plant
(Harris)

Cobalt and Cobalt
Compounds,
Nickel and Nickel
Compounds,
Molybdenum
Trioxide

24.2 / 7.3

542

49%

12%

5%

13%

80

Nalco Champion
(Fort Bend)

Ethylene Oxide,
Propylene Oxide,
Formaldehyde

1.4 / 5.4

3,234

87%

26%

10%

7%

84

NOV Texas Oil
Tools/CTES Conroe
(Montgomery)

Chromium, Nickel,
Copper

1.5 / 5.2

1,115

46%

28%

6%

13%

85

INEOS USA LLC
Chocolate Bayou
Plant (Brazoria)

1,3-Butadiene,
Benzene,
Naphthalene

255.7 / 5.1

5,203

37%

41%

9%

15%

93

ExxonMobil Refining
& Supply Baytown
Refinery (Part)
(Harris)

Nickel and Nickel
Compounds, 1,3Butadiene,
Benzene

755.6 / 4.6

911

82%

51%

6%

17%

99

ExxonMobil
Chemical Co.
Baytown Olefins
Plant (Part) (Harris)

1,3-Butadiene,
Nickel and Nickel
Compounds,
Formaldehyde

426.9 / 4.19

1,203

57%

47%

5%

16%

% Low
income

%
Under
age 5

%
Over
age
64

Top 3
Chemicals
Released

Note: Bold demographic indicators exceed state averages calculated by EPA.
Source: EPA 2018 Toxics Release Inventory, 2017 RSEI chemical toxicity weights, and 2019 EJSCREEN

21

 Louisiana’s “Cancer Alley”
Eleven Toxic 100 facilities are located along Mississippi River in Louisiana between Baton
Rouge through New Orleans, an area that has earned the moniker “Cancer Alley” because
of high levels of toxic releases and associated cancer clusters. The region includes the
parishes of St. Charles, St. James, St. John the Baptist, Ascension, East Baton Rouge,
Iberville, West Baton Rouge, East Baton Rouge, Jefferson, Plaquemines, Assumption, New
Orleans, and St. Bernard. One hundred and forty-two facilities in these parishes released
343.3 million tons of toxicity-weighted air pollution in 2018, with 87 percent (299.2 million
toxicity-weighted tons) from facilities on the Toxic 100 list, and 4 of which rank in the top
10. Nine of the 11 facilities manufacture chemicals, one refines oil, and one does both.
Table G lists the 11 Toxic 100 facilities located in this heavily and historically polluted
region of Louisiana. Figure 4 shows their locations.
The ExxonMobil Baton
Rouge Refinery and
Chemical Plants (numbers 71
and 94 on the Toxic 100 list)
are located on the
northwestern side of the city
of Baton Rouge. One
manufactures petrochemicals
and plastics, and the other
refines oil. Together, they
released 11.4 million tons of
toxic air pollution in 2018
consisting of chemicals like
benzene, chromium,
polycyclic aromatic
compounds, and a brew of
other hazardous air
pollutants, carcinogens, and
ExxonMobil’s Baton Rouge Chemical Plant and Refinery reported
metals. The plants are located
releasing 11.4 million toxic tons of air pollution in 2018.
adjacent to each other and
across the street from residential neighborhoods and just south of Southern University and
A&M College. An estimated 4,664 people live within a mile of either plant, 95 percent are
people of color or Hispanic or Latino, 59 percent are low income, eight percent are children
under age five, and seven percent are over age 64. All of these percentages are higher than
Louisiana state averages except for the percent of people over age 64, and are some of the
highest in the state for people of color or Hispanics or Latinos and the impoverished.
ExxonMobil Baton Rouge is subject to fence-line monitoring requirements for large
refineries, which include regular monitoring along the perimeter of the facility for benzene.
The primary goal of the fence-line monitoring network is to ensure refineries are properly

22

 monitoring and managing fugitive hazardous air pollutant emissions. Benzene, a cancercausing pollutant, is used as a surrogate pollutant for fugitive leaks of hazardous air
pollutants due to its presence in nearly all refinery process streams. Facilities determine the
net concentration due to the refinery as an annual average, and assess against an EPA
action level of nine micrograms per meter cubed over background levels, which EPA set as
the maximum modeled concentration at any refinery across the nation. When the action
level is exceeded, the facility must conduct a root cause analysis and take actions to correct
any issues that led to the exceedance.
EIP reviewed publicly accessible fence-line monitoring data, and found that ExxonMobil
Baton Rouge’s net benzene concentration at the fence-line has generally risen over the
course of 2019. ExxonMobil Baton Rouge’s net concentration increased from 6.5
micrograms per meter cubed in January 2019 to 8.4 micrograms per meter cubed in the
most recent monitoring period ending at the end of September 2019. Although the fence-line
benzene concentration is just below the EPA action level, the concentration is over twice the
lowest reference exposure level for inhalation of benzene (three micrograms per meter
cubed, as determined by the California Office of Environmental Health Hazard
Assessment). The actual exposure to benzene in nearby communities can vary from the
concentrations measured at a refinery’s border, depending on factors like emissions from
non-refinery sources, weather conditions, and wind direction.
Figure 4. Locations of 11 Toxic 100 plants in Louisiana’s “Cancer Alley”

23

 Table G. Toxic 100 facilities located in Louisiana’s “Cancer Alley”

Rank

Facility
(Location)

Top 3
Chemicals
Released

Tons Air
Pollution
Reported
/ Million
ToxicityWeighted
Tons

3

BASF Corp.
(Ascension
Parish)

Ethylene Oxide,
Diaminotoluene
(Mixed Isomers),
4,4’Methylenedianiline

189.4 / 90.1

6

Shell Chemical LP
(Ascension
Parish)

Ethylene,
Acetaldehyde,
Cobalt
Compounds

116.5 / 57.4

7

Denka
Performance
Elastomer LLC
(St. John the
Baptist Parish)

Chloroprene, 1,4Dichloro-2Butene, 1,3Butadiene

54.3 / 50.8

8

St. Charles
Operations
(TAFT/STAR)
Union Carbide
Corp. (St.
Charles Parish)

Ethylene Oxide,
Formaldehyde, 1,3Butadiene,

29

The Dow
Chemical Co
Louisiana
Operations
(Iberville Parish)

Ethylene Oxide,
1,3-Butadiene,
Benzene

45

Evonik Materials
Corp. (St. John
the Baptist
Parish)

64

67

No.
people
living
within a
mile

327

% People
of color
or
Hispanic
or Latino

% Low
income

%
Under
age 5

%
Over
age 64

45%

12%

7%

10%

49%

16%

8%

11%

1,834

80%

46%

6%

20%

216.4 / 44.2

418

50%

27%

3%

9%

916.5 / 17.5

440

57%

47%

9%

16%

Ethylene Oxide,
Propylene Oxide,
Methyl Isobutyl
Ketone

5.2 / 10.0

526

60%

48%

8%

16%

Westlake Vinyls
Co (Ascension
Parish)

Chloroprene, 1,2Dichloroethane,
Chloroform

63.7 / 7.0

332

45%

13%

7%

10%

ExxonMobil
Baton Rouge
Chemical Plant
(East Baton
Rouge Parish)

Chromium, Nickel
and Nickel
Compounds,
Benzene

767.5 / 6.6

2,991

94%

58%

8%

7%

24

279

 Tons Air
Pollution
Reported
/ Million
ToxicityWeighted
Tons

No.
people
living
within a
mile

11.9 / 5.5

250

51%

26%

4%

8%

% People
of color
or
Hispanic
or Latino

Rank

Facility
(Location)

Top 3
Chemicals
Released

78

Shell Catalyst &
Technologies
(West Baton
Rouge Parish)

Cobalt and Cobalt
Compounds,
Nickel
Compounds,
Molybdenum
Trioxide

81

Shell Norco
Chemical Plant
and Refinery (St.
Charles Parish)

1,3-Butadiene,
Benzene, Cobalt
and Cobalt
Compounds

599.2 / 5.3

2,131

8%

31%

6%

13%

90

ExxonMobil
Baton Rouge
Refinery (Part)
(East Baton
Rouge Parish)

Chromium, 1,2Dibromoethane,
Cobalt and Cobalt
Compounds

575.4 / 4.8

3,007

96%

56%

5%

7%

% Low
income

%
Under
age 5

%
Over
age 64

Note: Bold demographic indicators exceed state averages calculated by EPA.
Source: EPA 2018 Toxics Release Inventory, 2017 RSEI chemical toxicity weights, and 2019 EJSCREEN

Southeast Coast of Lake Erie in Ohio
The industrialized southeast coast of Lake Erie in Ohio (Ashtabula, Lake, Cuyahoga, and
Lorain Counties) is home to 185 facilities that released 61.8 million tons of toxicityweighted air pollution in 2018. Four of the 185 facilities are among the Toxic 100 and
released 53.6 million toxicity-weighted tons of air pollution. Two of the four facilities
manufacture chemicals, one manufactures fabricated metals, and one manufactures
transportation equipment. Table H lists the four Toxic 100 facilities located along the
southeast coast of Lake Erie, and Figure 5 shows their locations.
MPC Plating (number 72 on the Toxic 100 list) is a fabricated metals manufacturing facility
located in the Hough neighborhood of Cleveland, Ohio. The plant reported releasing 6.4
million tons of toxicity-weighted air pollution in 2018, the majority of which (six million
tons) was hexavalent chromium. The plant also reported releasing nickel, trichloroethylene,
copper, and nitric acid. Chromium, nitric acid, and copper were released through both leaks
and stacks, while emissions of nickel and trichloroethylene, a carcinogenic solvent, were
released through leaks. Over 7,000 people live within a mile of the plant. Ninety-one percent
are people of color or Hispanic or Latino, 71 percent are low income, eight percent are
children under five, and 14 percent are over age 64. These percentages are all higher than
state averages, except for the percentage of people over age 64. The percentages of people of
color and low-income individuals are some of the highest in the state.

25

 Figure 5. Locations of four Toxic  00 facilities on the southeast coast of Lake Erie in Ohio




I2 

 

26

Table H. Toxic 100 facilities located on the Southeast coast of Lake Erie in Ohio

Facility
(Location)

Top 3 Chemicals
Released

Tons Air
Pollution
Reported
/ Million
ToxicityWeighted
Tons

11

BASF Corp.
(Lorain
County)

Chromium and
Chromium
Compounds, Nickel
Compounds,
Copper
Compounds

7 / 31.8

7,367

49

Bescast Inc.
(Lake
County)

Chromium, Cobalt,
Nickel

1.5 / 9.5

68

MPC Plating
Inc.
(Cuyahoga
County)

Chromium and
Chromium
Compounds,
Nickel,
Trichloroethylene

71

INEOS
Pigments USA
Inc.
(Ashtabula
County)

Carbonyl Sulfide,
Titanium
Tetrachloride,
Hydrogen Sulfide

Rank

No.
people
living
within a
mile

% People
of color
or
Hispanic
or Latino

%
Over
age
64

% Low
income

%
Under
age 5

23%

48%

8%

13%

3,446

10%

27%

4%

28%

7 / 6.4

7,195

91%

71%

8%

14%

1,713 / 6.0

531

11%

43%

7%

18%

Note: Bold demographic indicators exceed state averages calculated by EPA.
Source: EPA 2018 Toxics Release Inventory, 2017 RSEI chemical toxicity weights, and 2019 EJSCREEN

Conclusion & Recommendations
One hundred large “super-emitters” released over a third (39 percent) of the toxic air
pollution reported in 2018, after adjusting emissions for inhalation toxicity. These facilities,
which we’ve included on the “Toxic 100” list, are located in areas that have at least 250
people living within a mile. Ninety-eight of them have higher percentages of potentially
vulnerable people living within a mile compared to state averages. It is without question
that their toxic emissions have a high likelihood of impacting public health.
Nearly a quarter (24 percent) of toxic emissions came from leaks, according to what
companies reported to the Toxics Release Inventory. These leaks occur as a result of poor
maintenance, accidents, extreme weather events, and plant malfunctions, and are often
difficult to detect and measure, and yet many causes, such as poor maintenance, are
avoidable. Stronger leak detection and repair provisions could significantly reduce
emissions, if they were required and enforced. At a minimum, facilities that use or process
carcinogenic chemicals like benzene, 1,3-butadiene, and ethylene oxide should be required

27

 to install fence-line monitoring systems that provide information to the public, neighbors,
first responders, and health care providers so that they can mitigate exposure to toxins.
Fence-line monitoring for all toxics for which the technology exists to do so would be ideal.
The fence-line monitoring programs should apply to all potential emission sources within
the facility, including tanks, and companies should be required to undertake immediate
corrective action to repair and fix any leaks of toxic chemicals and notify nearby residents.
Given that such a large portion of reported toxic emissions come from relatively few
facilities, targeted environmental enforcement should be a priority for reducing emissions
from “super-emitters.” According to a review of the EPA’s Enforcement and Compliance
History Online database, 26 of the Toxic 100 facilities were in violation of the Clean Air Act
in 2018, 19 of which were considered high priority violators by EPA.
The chemical industry, which accounted for over a third (36) of the facilities among the
Toxic 100, is undergoing a rapid expansion because of cheap fuel and feedstock driven by
record-breaking oil and gas production. Several of the Toxic 100 facilities have recently
expanded or are undergoing expansions. Previously reported toxic emissions, existing
demographics and health, and cumulative impacts to surrounding communities must be
evaluated by state, local, and federal officials in their siting decisions, environmental
approvals, and tax credit awards. Similarly, all notices of projects that have the potential to
increase emissions should be provided in non-English languages where needed, and
professional interpretation services should be provided at public proceedings.
While our analysis identifying America’s super-emitters is a useful tool for holding some of
the nation’s most dangerous polluters accountable, the data used to create the list are limited
and rely on companies to report accurate information. Many industries and types of
facilities are not required to report to the Toxics Release Inventory, and those that are do
not have to report all toxic releases. Municipal waste incinerators and gas processing plants,
for instance, should be required to report emissions, as evidence from other sources like
state emission inventories and scientific literature suggest that they would meet all other
reporting requirements.
Air pollution is a major driver of public health problems, and the people impacted often
have little recourse to improve their situation. Those tasked with management and oversight
of heavily polluting facilities, such as the Toxic 100, must work harder to provide a safe
environment and clean bill of health to those living in close proximity to these plants. As
this report shows, addressing excess pollution at the biggest emitters could go a long way
towards improving the well-being of hundreds of thousands of people across the country.

28

 NOTES
A list of toxicity weights from EPA’s Risk Screening Environmental Indicators model is available at
https://www.epa.gov/sites/production/files/2018-12/toxicity_data_rsei_v237.xlsx. For more information,
see EPA’s RSEI Documentation and Help, available at https://www.epa.gov/rsei/rsei-documentation-andhelp.
1

The Toxics Release Inventory is a useful yet limited dataset. Data are self-reported by companies that are
required to report. For more information about considerations for using the TRI, see US Environmental
Protection Agency (2019) TRI for Researchers. Available at: https://www.epa.gov/toxics-release-inventorytri-program/tri-researchersa (Accessed 1/30/2020).
2

It would be inaccurate to characterize the facilities identified in this report as the largest emitters or the most
toxic in the country because of limitations to the TRI and because we focused on facilities that had at least 250
people living within a mile. The TRI is limited to certain chemicals, industry sectors, and facilities that meet
specific reporting requirements. Therefore, it does not consider all toxic air emissions that occurred in the US.
For instance, the TRI does not include major sources of emissions like municipal waste incinerators, which
emit considerable amounts of dioxins, or sources that employ fewer than 10 full time equivalent employees,
even if they are considered as part of an industry sector that is required to report to the TRI. It also doesn’t
require covered industries to report chemical releases below certain thresholds. More information about
considerations when using TRI data can be found on EPA’s website.3 It is accurate to say that the 100 facilities
we identify reported the most toxic air emissions to the TRI in 2018, after accounting for inhalation toxicity.
Similarly, the counties highlighted in this report are not to be interpreted as the most toxic in the country, but
they should be characterized as those where TRI facilities reported the most toxic emissions.
3

The Environmental Integrity Project has been tracking new and expanding petrochemical plants since 2012.
See https://www.environmentalintegrity.org/oil-gas-infrastructure-emissions/ for a map of new and
expanded facilities, downloadable permit documents, and potential emission increases of criteria air pollutants
and greenhouse gases.
4

New Jersey Department of Health and Senior Services (2005) Hazardous Substance Fact Sheet, available at
https://nj.gov/health/eoh/rtkweb/documents/fs/1614.pdf (Accessed 1/30/2020).

5

US Environmental Protection Agency (2000) Chromium Compounds, available at
https://www.epa.gov/sites/production/files/2016-09/documents/chromium-compounds.pdf, (accessed
1/30/2020).
6

If no information is available, EPA assumes 34 percent of total chromium emissions is toxic. See: US
Environmental Protection Agency (2018) EPA’s Risk-Screening Environmental Indicators (RSEI)
Methodology, RSEI Version 2.3.7, available at https://www.epa.gov/sites/production/files/201812/documents/rsei_methodology_v2.3.7.pdf, p. 12. (Accessed 1/30/2020)
7

US Environmental Protection Agency (2020) Hazardous Air Pollutants: Ethylene Oxide. Available at
https://www.epa.gov/hazardous-air-pollutants-ethylene-oxide, (Accessed 1/30/2020).

8

US Environmental Protection Agency (2020) Background Information on Ethylene Oxide. Available at:
https://www.epa.gov/hazardous-air-pollutants-ethylene-oxide/background-information-ethylene-oxide#what
(Accessed 1/30/2020).
9

US Environmental Protection Agency (2020) Frequent Questions: Health Information about Ethylene
Oxide. Available at: https://www.epa.gov/hazardous-air-pollutants-ethylene-oxide/frequent-questionshealth-information-about-ethylene-oxide#acute (Accessed 1/30/2020).
10

29

 While this method is widely used to estimate demographics within certain distances of a facility, including
by EPA, it would yield more precise estimates if a) the facility boundaries were used to generate buffers rather
than single point locations, and b) population estimates were available in smaller resolution units. Results
would likely differ if racial categories available through EJSCREEN were broken down into subgroups, such
as African American, Hispanic or Latino, Asian, Native American, and so forth. The aerial apportionment
analysis was performed in ArcGIS Pro.
11

U.S. Environmental Protection Agency (2019) EJSCREEN Environmental Justice Mapping and Screening
Tool Technical Documentation, available at: https://www.epa.gov/sites/production/files/201709/documents/2017_ejscreen_technical_document.pdf, pp. 17-18. (Accessed 1/30/2020).
12

There is no official policy for determining where an environmental justice or children’s health concern does
or does not exist based on demographic indicators alone. Ibid. p. 26.

13

Dow (2019) Driving Dow’s Growth in Texas: The Making of Dow’s Largest Site, available at:
https://corporate.dow.com/en-us/about/company/history/texas-facility.html (Accessed 1/30/2020).

14

DowDupont (2019) Annual Report, available at:
https://s23.q4cdn.com/981382065/files/doc_downloads/featured_information/2019/04/Dow-FinalInformation-Statement.pdf, p. 31.(Accessed 1/30/2020)
15

16

Ibid. p. 85

US Environmental Protection Agency (2000) Xylenes (Mixed Isomers), available at:
https://www.epa.gov/sites/production/files/2016-09/documents/xylenes.pdf. (Accessed 1/30/2020)

17

30

 Matters of Morality and Faith: A Postscript
The real-life consequences of EPA rollbacks and the toxic circumstances faced by fence line
communities, especially children, motivated this report. In many ways, the situation faced
today evokes the plight of the miner’s canary. For those unfamiliar with this parable for
societal ills and disparities, miners once carried canaries with them into the mine to serve as
a warning signal. When dangerous levels of gas filled the air, the canary’s respiratory system
would become distressed and cause the canary to collapse as an alert to the miners. Children
in the fence line communities of Louisiana and Texas have almost literally been forced to
serve as our society’s canary.
Yet, other states are by no means paragons of virtue. The Toxic 100 list serves as a moral
spotlight highlighting facilities in communities across the country that might otherwise fall
under the radar of awareness. For instance, while it is no surprise that Cleveland, Ohio
suffers from air pollution, we were surprised to learn that a facility on the Toxic 100 list has
a seemingly inconspicuous presence not terribly far from our offices. There are no giant
smokestacks belching clouds into the air, no tall columns sending burning flares into the air
for all to see. Instead, the building has the outward appearance of a warehouse that one
could easily drive by without hardly noticing it.
But this facility spews chromium, copper, formaldehyde, nickel, nitric acid,
trichloroethylene, and lead into the air. This is in a community that has also suffered from
one of the worst lead crises in the country. Disturbingly, 565 children under age five live
within one mile of the plant, while 4,408 live within three miles.
This is decidedly a moral matter, and it is also a faith matter. As the title of this report
makes clear, our faith tradition teaches us that the air is sacred. It is the very breath of God
given to us. We could not live for a moment without it. Yet, too often we take this sacred,
life-giving, and life-sustaining part of our existence for granted. We now have no other
choice. We can no longer continue in this way. The dangers and consequences are too real
and too painful. Something must change.
It is not an accident that we are releasing this report on Ash Wednesday, a holy day
associated with repentance. The meaning of the word “repent,” however, has often been lost
in translation. In its Greek origins, it is about turning around and changing course to go in a
new and better direction. Our nation today is faced with a moral reckoning, but it is also
faced with an opportunity to head in a new and better direction, a direction that seeks to
protect without fail the health and wellbeing of children. On this sacred occasion, let us
commit to doing just that.
Rev. Brooks Berndt, PhD
Minister for Environmental Justice, United Church of Christ
February 26, 2020

31

 Demographics Within 1 Mile
(bold percentages exceed state averages)

Toxic Air Emissions
Rank

Facility Name

County / Parish

State

Total reported
(tons)

Inhalation toxicity- Population
weighted (million
tons)

People of Color/ Low Income
Hispanic/ Latino Individuals

Industry

2018 Clean Air Act
Compliance Status

More Info (chemicals
released, etc.)

1

Huntsman Petrochemical LLC
Port Neches Facility

Jefferson

TX

143.78

235.75

1,820

436
(23.9%)

622
(34.2%)

65
(3.6%)

173
(9.5%)

Chemicals

In Compliance

TRI Facility Report

2

Sasol Chemicals (USA) LLC-Lake
Charles Chemical Complex

Calcasieu

LA

193.44

92.90

775

185
(23.8%)

275
(35.5%)

43
(5.5%)

114
(14.7%)

Chemicals

In Compliance

TRI Facility Report

3

BASF Corp

Ascension

LA

189.39

90.12

327

148
(45.3%)

41
(12.4%)

24
(7.2%)

32
(9.9%)

Chemicals

High Priority Violator

TRI Facility Report

4

Midwest Sterilization Corp

Webb

TX

7.56

83.12

1,147

1031
(89.9%)

551
(48.1%)

146
(12.7%)

47
(4.1%)

Miscellaneous
Manufacturing

No data available

TRI Facility Report

5

Medtronic Xomed

Duval

FL

7.04

77.44

4,265

1576
(37%)

1323
(31%)

268
(6.3%)

602
(14.1%)

Miscellaneous
Manufacturing

In Compliance

TRI Facility Report

6

Shell Chemical Lp

Ascension

LA

116.46

57.40

279

137
(49.2%)

43
(15.5%)

22
(8%)

30
(10.9%)

Chemicals

In Compliance

TRI Facility Report

7

Denka Performance Elastomer
LLC

St John The
Baptist

LA

54.29

50.82

1,834

1476
(80.4%)

839
(45.7%)

111
(6%)

363
(19.8%)

Chemicals

In Compliance

TRI Facility Report

8

St Charles Operations

St Charles

LA

216.39

44.20

418

210
(50.1%)

111
(26.6%)

13
(3%)

39
(9.4%)

Chemicals

High Priority Violator

TRI Facility Report

9

Eastman Chemical Co Texas
Operations

Harrison

TX

1,076.23

43.98

368

141
(38.2%)

144
(39.2%)

33
(9%)

44
(11.9%)

Chemicals

In Compliance

TRI Facility Report

10

Midwest Sterilization Corp

Cape Girardeau

MO

3.70

40.62

607

39
(6.4%)

213
(35%)

46
(7.5%)

58
(9.5%)

Miscellaneous
Manufacturing

In Compliance

TRI Facility Report

11

BASF Corp

Lorain

OH

6.97

31.81

7,367

1659
(22.5%)

3551
(48.2%)

558
(7.6%)

968
(13.1%)

Chemicals

In Compliance

TRI Facility Report

12

Le Jones Co LLC

Menominee

MI

5.28

28.80

1,304

29
(2.2%)

433
(33.2%)

57
(4.4%)

285
(21.9%)

Primary Metals

In Compliance

TRI Facility Report

32

Children
under Age 5

Facility Information
Adults over
Age 64

 Demographics Within 1 Mile
(bold percentages exceed state averages)

Toxic Air Emissions
Rank

Facility Name

County / Parish

State

Total reported
(tons)

Inhalation toxicity- Population
weighted (million
tons)

People of Color/ Low Income
Hispanic/ Latino Individuals

Industry

2018 Clean Air Act
Compliance Status

More Info (chemicals
released, etc.)

13

Dragon Products North Silsbee
Facility

Hardin

TX

2.57

28.72

913

270
(29.6%)

286
(31.4%)

68
(7.4%)

185
(20.3%)

Machinery

In Compliance

TRI Facility Report

14

Lyondell Chemical Co

Harris

TX

510.01

28.09

446

338
(75.7%)

228
(51.1%)

13
(2.9%)

35
(7.9%)

Chemicals

Violation

TRI Facility Report

15

Baxter Healthcare Corp

Baxter

AR

3.49

27.02

1,617

75
(4.6%)

429
(26.6%)

106
(6.6%)

506
(31.3%)

Plastics and Rubber In Compliance

TRI Facility Report

16

Kennametal Isa

Lawrence

PA

14.88

27.00

967

90
(9.3%)

301
(31.1%)

60
(6.2%)

220
(22.8%)

Primary Metals

No data available

TRI Facility Report

17

Croda Inc

New Castle

DE

3.24

26.88

1,643

977
(59.4%)

811
(49.4%)

102
(6.2%)

199
(12.1%)

Chemicals

In Compliance

TRI Facility Report

18

Haynes International Inc

Howard

IN

7.99

26.53

3,093

491
(15.9%)

915
(29.6%)

149
(4.8%)

641
(20.7%)

Primary Metals

High Priority Violator

TRI Facility Report

19

Alliant Techsystems Operations
LLC (New River Energetics)

Montgomery

VA

12.75

26.38

2,098

212
(10.1%)

1003
(47.8%)

100
(4.8%)

367
(17.5%)

Chemicals

No data available

TRI Facility Report

20

Freeport-Mcmoran Miami Inc

Gila

AZ

136.53

26.22

283

137
(48.5%)

133
(47.1%)

19
(6.8%)

74
(26%)

Primary Metals

In Compliance

TRI Facility Report

21

SFI Of Tennessee

Shelby

TN

4.88

25.92

968

894
(92.3%)

563
(58.2%)

138
(14.2%)

61
(6.3%)

Fabricated Metals

Violation

TRI Facility Report

22

B Braun Medical Inc
Manufacturing Div

Lehigh

PA

2.33

25.65

2,303

778
(33.8%)

684
(29.7%)

89
(3.9%)

406
(17.6%)

Miscellaneous
Manufacturing

In Compliance

TRI Facility Report

23

Huntsman Petrochemical LLC

Montgomery

TX

21.70

25.51

598

318
(53.3%)

366
(61.3%)

58
(9.7%)

59
(9.8%)

Chemicals

High Priority Violator

TRI Facility Report

24

Boeing Co Of Portland

Multnomah

OR

13.58

25.17

3,201

1434
(44.8%)

1650
(51.5%)

184
(5.8%)

382
(11.9%)

Transportation
Equipment

In Compliance

TRI Facility Report

33

Children
under Age 5

Facility Information
Adults over
Age 64

 Demographics Within 1 Mile
(bold percentages exceed state averages)

Toxic Air Emissions
Rank

Facility Name

County / Parish

State

25

Union Carbide Corp Institute
Facility

Kanawha

WV

26

Sterilization Services Of Virginia

27

Total reported
(tons)

Inhalation toxicity- Population
weighted (million
tons)

People of Color/ Low Income
Hispanic/ Latino Individuals

Children
under Age 5

Facility Information
Adults over
Age 64

Industry

2018 Clean Air Act
Compliance Status

More Info (chemicals
released, etc.)

Chemicals

Violation

TRI Facility Report

63.11

23.67

1,227

468
(38.1%)

600
(48.9%)

111
(9%)

184
(15%)

Richmond (City) VA

1.75

19.23

1,145

677
(59.1%)

232
(20.3%)

101
(8.9%)

145
(12.7%)

Miscellaneous
Manufacturing

In Compliance

TRI Facility Report

Hausner Hard-Chrome Of
Kentucky

Daviess

KY

1.13

18.91

1,962

313
(16%)

817
(41.7%)

159
(8.1%)

192
(9.8%)

Fabricated Metals

In Compliance

TRI Facility Report

28

SFI of Arkansas

Faulkner

AR

3.44

17.56

948

348
(36.7%)

381
(40.2%)

46
(4.8%)

96
(10.2%)

Fabricated Metals

In Compliance

TRI Facility Report

29

The Dow Chemical Co - Louisiana
Iberville
Operations

LA

916.51

17.53

440

250
(56.8%)

208
(47.3%)

39
(8.8%)

69
(15.6%)

Chemicals

High Priority Violator

TRI Facility Report

30

Kubota Manufacturing Of
America Corp

Hall

GA

4.79

17.31

899

151
(16.7%)

390
(43.3%)

40
(4.4%)

169
(18.8%)

Machinery

In Compliance

TRI Facility Report

31

Thistle Processing LLC

Cabell

WV

17.72

15.47

3,986

534
(13.4%)

2150
(53.9%)

329
(8.3%)

699
(17.5%)

Primary Metals

In Compliance

TRI Facility Report

32

Rohr Inc (A Collins Aerospace
Company)

Baldwin

AL

1.70

15.35

979

275
(28.1%)

195
(19.9%)

35
(3.6%)

188
(19.2%)

Transportation
Equipment

In Compliance

TRI Facility Report

33

BASF Toda America Inc

Calhoun

MI

0.92

14.39

516

236
(45.7%)

272
(52.7%)

52
(10.1%)

58
(11.2%)

Chemicals

No data available

TRI Facility Report

34

Steel & O'Brien Manufacturing
Inc

Wyoming

NY

2.19

14.06

311

9
(2.9%)

110
(35.2%)

15
(4.8%)

50
(16.1%)

Fabricated Metals

No data available

TRI Facility Report

35

Terumo Bct Sterilization Services
Jefferson
Inc

CO

1.23

13.57

6,331

1560
(24.6%)

2068
(32.7%)

421
(6.6%)

948
(15%)

Miscellaneous
Manufacturing

In Compliance

TRI Facility Report

36

Alpha Omega Recycling Inc

TX

9.93

13.11

1,591

198
(12.5%)

731
(46%)

161
(10.1%)

193
(12.1%)

Hazardous Waste

No data available

TRI Facility Report

Gregg

34

 Demographics Within 1 Mile
(bold percentages exceed state averages)

Toxic Air Emissions
Rank

Facility Name

County / Parish

State

Total reported
(tons)

Inhalation toxicity- Population
weighted (million
tons)

People of Color/ Low Income
Hispanic/ Latino Individuals

Children
under Age 5

Facility Information
Adults over
Age 64

Industry

2018 Clean Air Act
Compliance Status

More Info (chemicals
released, etc.)

37

Slater Fabric Filter-Bha Group Inc Saline

MO

13.20

12.30

719

125
(17.4%)

379
(52.7%)

58
(8.1%)

130
(18.1%)

Machinery

No data available

TRI Facility Report

38

Dixie Chemical Co Inc

Harris

TX

8.71

12.28

329

131
(39.9%)

41
(12.5%)

12
(3.6%)

64
(19.4%)

Chemicals

No data available

TRI Facility Report

39

Ineos Nitriles Usa LLC

Allen

OH

45.29

12.05

744

109
(14.7%)

190
(25.6%)

23
(3.1%)

165
(22.2%)

Chemicals

Violation

TRI Facility Report

40

Asarco LLC Ray Complex/ Hayden
Gila
Smelter & Concentrator

AZ

292.38

11.68

266

217
(81.4%)

96
(36.2%)

7
(2.6%)

50
(18.7%)

Primary Metals

High Priority Violator

TRI Facility Report

41

Dow Chemical Co Freeport
Facility

Brazoria

TX

443.40

11.66

1,827

1562
(85.5%)

1376
(75.3%)

183
(10%)

50
(2.7%)

Chemicals

High Priority Violator

TRI Facility Report

42

Howard Industries Inc

Jones

MS

12.34

11.41

484

233
(48.1%)

341
(70.4%)

28
(5.8%)

69
(14.3%)

Electrical Equipment In Compliance

TRI Facility Report

43

Monument Chemical Kentucky
LLC

Meade

KY

11.68

10.81

451

41
(9.1%)

203
(44.9%)

24
(5.2%)

75
(16.7%)

Chemicals

In Compliance

TRI Facility Report

44

3P Processing Inc

Sedgwick

KS

15.63

10.49

3,053

1181
(38.7%)

1725
(56.5%)

301
(9.9%)

290
(9.5%)

Fabricated Metals

In Compliance

TRI Facility Report

45

Evonik Materials Corp

St John The
Baptist Paris

LA

5.23

10.01

526

318
(60.4%)

252
(47.9%)

41
(7.8%)

86
(16.3%)

Chemicals

In Compliance

TRI Facility Report

46

Harbisonwalker International Inc
Blair
Sproul Pa Plant

PA

0.68

9.94

461

12
(2.7%)

181
(39.3%)

38
(8.3%)

64
(13.8%)

Nonmetallic Mineral
No data available
Product

TRI Facility Report

47

Century Aluminum Of Kentucky

KY

219.64

9.84

424

17
(3.9%)

170
(40%)

38
(8.9%)

58
(13.8%)

Primary Metals

In Compliance

TRI Facility Report

48

Eastman Chemical Co Tennessee
Sullivan
Operations

TN

1,021.83

9.59

1,727

249
(14.4%)

966
(55.9%)

86
(5%)

408
(23.6%)

Chemicals

High Priority Violator,
Violation

TRI Facility Report

Hancock

35

 Demographics Within 1 Mile
(bold percentages exceed state averages)

Toxic Air Emissions
Rank

Total reported
(tons)

Inhalation toxicity- Population
weighted (million
tons)

People of Color/ Low Income
Hispanic/ Latino Individuals

Facility Name

County / Parish

State

2018 Clean Air Act
Compliance Status

More Info (chemicals
released, etc.)

49

Bescast Inc

Lake

OH

1.50

9.46

3,446

351
(10.2%)

938
(27.2%)

126
(3.7%)

966
(28%)

Transportation
Equipment

In Compliance

TRI Facility Report

50

Lanxess Corp

Charleston

SC

21.38

9.26

2,155

1861
(86.3%)

1328
(61.6%)

143
(6.6%)

353
(16.4%)

Chemicals

Violation

TRI Facility Report

51

Kennametal Stellite Lp

Elkhart

IN

1.02

8.95

2,885

529
(18.3%)

999
(34.6%)

66
(2.3%)

1189
(41.2%)

Primary Metals

In Compliance

TRI Facility Report

52

Baker Hughes Oilfield Operations
Oklahoma
LLC

OK

2.22

8.85

1,944

1056
(54.3%)

570
(29.3%)

227
(11.7%)

152
(7.8%)

Machinery

No data available

TRI Facility Report

53

Cardington Yutaka Technologies
Morrow
Inc

OH

0.64

8.84

285

6
(2%)

125
(43.8%)

16
(5.7%)

37
(13.1%)

Transportation
Equipment

In Compliance

TRI Facility Report

54

Union Carbide Corp South
Charleston Facility

Kanawha

WV

13.96

8.77

3,015

644
(21.4%)

1259
(41.7%)

248
(8.2%)

431
(14.3%)

Chemicals

In Compliance

TRI Facility Report

55

Whirlpool Corp - Clyde
Operations

Sandusky

OH

1.49

8.63

1,773

149
(8.4%)

571
(32.2%)

135
(7.6%)

267
(15.1%)

Electrical Equipment In Compliance

TRI Facility Report

56

Carpenter Technology Corp

Berks

PA

17.73

8.49

8,553

6559
(76.7%)

5147
(60.2%)

715
(8.4%)

860
(10.1%)

Primary Metals

In Compliance

TRI Facility Report

57

Sgl Carbon LLC

Burke

NC

20.90

8.14

654

74
(11.4%)

260
(39.7%)

14
(2.1%)

158
(24.1%)

Electrical Equipment In Compliance

TRI Facility Report

58

American Chrome & Chemicals
Inc

Nueces

TX

0.89

8.07

979

898
(91.7%)

464
(47.3%)

59
(6%)

99
(10.2%)

Chemicals

In Compliance

TRI Facility Report

59

Trace Die Cast Inc

Warren

KY

16.29

7.75

1,152

388
(33.7%)

559
(48.5%)

102
(8.9%)

69
(6%)

Fabricated Metals

In Compliance

TRI Facility Report

60

Albemarle Corp Bayport Plant

Harris

TX

24.16

7.34

542

264
(48.7%)

68
(12.5%)

29
(5.4%)

72
(13.3%)

Chemicals

High Priority Violator

TRI Facility Report

36

Children
under Age 5

Facility Information
Adults over
Age 64

Industry

 Demographics Within 1 Mile
(bold percentages exceed state averages)

Toxic Air Emissions
Rank

Facility Name

County / Parish

State

61

American Electric Power Amos
Plant

Putnam

WV

62

Custom Processing Services LLC

Montgomery

63

Arvin Sango Inc

64

Total reported
(tons)

Inhalation toxicity- Population
weighted (million
tons)

People of Color/ Low Income
Hispanic/ Latino Individuals

Children
under Age 5

Facility Information
Adults over
Age 64

Industry

2018 Clean Air Act
Compliance Status

More Info (chemicals
released, etc.)

In Compliance

TRI Facility Report

276.06

7.30

685

13
(1.9%)

193
(28.2%)

66
(9.6%)

112
(16.3%)

Electric Utilities

PA

0.49

7.23

2,951

228
(7.7%)

582
(19.7%)

210
(7.1%)

272
(9.2%)

Nonmetallic Mineral
No data available
Product

TRI Facility Report

Jefferson

IN

0.61

7.21

1,036

169
(16.3%)

537
(51.9%)

92
(8.9%)

168
(16.2%)

Transportation
Equipment

Violation

TRI Facility Report

Westlake Vinyls Co

Ascension

LA

63.70

7.00

332

150
(45.1%)

42
(12.5%)

24
(7.2%)

33
(9.8%)

Chemicals

In Compliance

TRI Facility Report

65

Zenith Cutter Inc

Winnebago

IL

0.58

6.91

2,823

306
(10.9%)

747
(26.5%)

124
(4.4%)

414
(14.7%)

Fabricated Metals

In Compliance

TRI Facility Report

66

Calsonickansei Na - Shelbyville

Bedford

TN

0.46

6.69

1,032

346
(33.5%)

432
(41.9%)

58
(5.6%)

194
(18.8%)

Transportation
Equipment

In Compliance

TRI Facility Report

67

Exxonmobil Baton Rouge
Chemical Plant (Part)

East Baton
Rouge

LA

767.46

6.65

2,991

2811
(94%)

1739
(58.2%)

244
(8.2%)

207
(6.9%)

Chemicals

High Priority Violator

TRI Facility Report

68

MPC Plating Inc

Cuyahoga

OH

7.01

6.38

7,195

6516
(90.6%)

5093
(70.8%)

565
(7.8%)

1012
(14.1%)

Fabricated Metals

In Compliance

TRI Facility Report

69

Ozark Mountain Technologies
LLC Dba Lmi Aerospace

Crawford

MO

1.01

6.33

342

35
(10.3%)

221
(64.7%)

28
(8.2%)

37
(10.8%)

Fabricated Metals

In Compliance

TRI Facility Report

70

Wood River Refinery

Madison

IL

258.44

6.26

1,346

74
(5.5%)

623
(46.3%)

119
(8.9%)

190
(14.1%)

Petroleum

High Priority Violator

TRI Facility Report

71

Ineos Pigments Usa Inc

Ashtabula

OH

1,713.04

5.96

531

57
(10.7%)

227
(42.8%)

35
(6.6%)

97
(18.2%)

Chemicals

In Compliance

TRI Facility Report

72

Ashland Specialty Ingredients Gp Hopewell (City)

VA

193.43

5.89

2,466

1703
(69.1%)

1416
(57.4%)

264
(10.7%)

285
(11.6%)

Chemicals

In Compliance

TRI Facility Report

37

 Demographics Within 1 Mile
(bold percentages exceed state averages)

Toxic Air Emissions
Rank

Total reported
(tons)

Inhalation toxicity- Population
weighted (million
tons)

People of Color/ Low Income
Hispanic/ Latino Individuals

Facility Name

County / Parish

State

Industry

2018 Clean Air Act
Compliance Status

More Info (chemicals
released, etc.)

73

Vantage Specialties

Lake

IL

0.87

5.84

2,461

1449
(58.9%)

702
(28.5%)

144
(5.8%)

220
(9%)

Chemicals

In Compliance

TRI Facility Report

74

Structural Steel Of Carolina

Forsyth

NC

2.60

5.70

5,655

4373
(77.3%)

3250
(57.5%)

368
(6.5%)

456
(8.1%)

Fabricated Metals

In Compliance

TRI Facility Report

75

Cannon-Muskegon

Muskegon

MI

1.05

5.60

2,880

433
(15%)

755
(26.2%)

100
(3.5%)

497
(17.3%)

Primary Metals

No data available

TRI Facility Report

76

Ethicon Inc

Tom Green

TX

0.51

5.56

530

325
(61.2%)

283
(53.3%)

63
(11.9%)

68
(12.8%)

Miscellaneous
Manufacturing

In Compliance

TRI Facility Report

77

4 Guys Inc

Somerset

PA

0.38

5.48

329

4
(1.2%)

108
(33%)

12
(3.7%)

76
(23.1%)

Transportation
Equipment

No data available

TRI Facility Report

78

Shell Catalyst & Technologies

West Baton
Rouge

LA

11.91

5.46

250

129
(51.5%)

66
(26.4%)

10
(3.8%)

19
(7.6%)

Chemicals

In Compliance

TRI Facility Report

79

Ahlstrom-Munksjo Na Specialty
Solutions LLC

Oneida

WI

45.18

5.42

1,742

162
(9.3%)

670
(38.4%)

43
(2.5%)

246
(14.1%)

Paper

In Compliance

TRI Facility Report

80

Nalco Champion

Fort Bend

TX

1.38

5.36

3,234

2819
(87.2%)

831
(25.7%)

312
(9.7%)

240
(7.4%)

Chemicals

High Priority Violator

TRI Facility Report

81

Shell Norco Chemical Plant

St Charles

LA

599.20

5.26

2,131

162
(7.6%)

667
(31.3%)

134
(6.3%)

279
(13.1%)

Petroleum

High Priority Violator

TRI Facility Report

82

Howmet Castings & Services Inc

Laporte

IN

0.58

5.24

2,514

549
(21.8%)

1146
(45.6%)

229
(9.1%)

358
(14.2%)

Primary Metals

High Priority Violator

TRI Facility Report

83

Rain Cii Carbon LLC

Crawford

IL

46.24

5.24

742

52
(6.9%)

330
(44.4%)

30
(4%)

96
(12.9%)

Petroleum

In Compliance

TRI Facility Report

84

Nov Texas Oil Tools/Ctes Conroe Montgomery

TX

1.49

5.20

1,115

511
(45.8%)

315
(28.3%)

67
(6%)

147
(13.2%)

Fabricated Metals

No data available

TRI Facility Report

38

Children
under Age 5

Facility Information
Adults over
Age 64

 Demographics Within 1 Mile
(bold percentages exceed state averages)

Toxic Air Emissions
Rank

Facility Name

County / Parish

State

Total reported
(tons)

Inhalation toxicity- Population
weighted (million
tons)

People of Color/ Low Income
Hispanic/ Latino Individuals

Children
under Age 5

Facility Information
Adults over
Age 64

Industry

2018 Clean Air Act
Compliance Status

More Info (chemicals
released, etc.)

85

Ineos Usa LLC - Chocolate Bayou
Brazoria
Plant

TX

255.70

5.14

5,203

1944
(37.4%)

2114
(40.6%)

450
(8.7%)

763
(14.7%)

Chemicals

High Priority Violator

TRI Facility Report

86

Unison Engine Components
Terre Haute

Vigo

IN

0.71

5.10

5,756

1425
(24.8%)

2512
(43.6%)

137
(2.4%)

509
(8.8%)

Transportation
Equipment

No data available

TRI Facility Report

87

Colstrip Steam Electric Station

Rosebud

MT

155.42

5.08

415

81
(19.5%)

37
(9%)

15
(3.5%)

45
(10.8%)

Electric Utilities

In Compliance

TRI Facility Report

88

Crossville Inc

Cumberland

TN

0.34

4.92

568

61
(10.8%)

301
(53.1%)

40
(7%)

81
(14.3%)

Nonmetallic Mineral
In Compliance
Product

TRI Facility Report

89

Greenville Metals Inc

Mercer

PA

1.84

4.80

462

18
(4%)

90
(19.6%)

42
(9.2%)

77
(16.7%)

Primary Metals

Violation

TRI Facility Report

90

Exxonmobil Baton Rouge
Refinery (Part)

East Baton
Rouge

LA

575.45

4.78

3,007

2875
(95.6%)

1693
(56.3%)

159
(5.3%)

222
(7.4%)

Petroleum

High Priority Violator

TRI Facility Report

91

Cardinal Plant

Jefferson

OH

227.51

4.74

458

11
(2.3%)

205
(44.7%)

21
(4.7%)

90
(19.7%)

Electric Utilities

In Compliance

TRI Facility Report

92

Great Lakes Chemical - Central

Union

AR

65.75

4.71

259

74
(28.7%)

86
(33.3%)

23
(9%)

38
(14.8%)

Chemicals

High Priority Violator

TRI Facility Report

93

Exxonmobil Refining & Supply
Baytown Refinery (Part)

Harris

TX

775.59

4.65

911

744
(81.7%)

465
(51.1%)

57
(6.3%)

153
(16.7%)

Petroleum

High Priority Violator

TRI Facility Report

94

Cytec Carbon Fibers LLC

Greenville

SC

35.57

4.60

604

367
(60.8%)

369
(61.1%)

55
(9.1%)

49
(8.2%)

Chemicals

In Compliance

TRI Facility Report

95

Southern Tool Inc

Calhoun

AL

0.51

4.53

1,971

740
(37.5%)

1011
(51.3%)

55
(2.8%)

376
(19.1%)

Primary Metals

No data available

TRI Facility Report

96

Global Tungsten & Powders Corp Bradford

PA

76.86

4.53

807

6
(0.8%)

213
(26.4%)

68
(8.4%)

149
(18.5%)

Primary Metals

In Compliance

TRI Facility Report

39

 Demographics Within 1 Mile
(bold percentages exceed state averages)

Toxic Air Emissions
Rank

Facility Name

County / Parish

State

97

Faurecia Emission Control
Technologies

Bartholomew

IN

98

Fort Martin Power Station

Monongalia

WV

99

ExxonMobil Chemical Co.
Baytown Olefins Plant (Part)

Harris, TX

100

Chromalloy Castings

Hillsborogh

FL

Total reported
(tons)

Inhalation toxicity- Population
weighted (million
tons)

People of Color/ Low Income
Hispanic/ Latino Individuals

Children
under Age 5

Facility Information
Adults over
Age 64

Industry

2018 Clean Air Act
Compliance Status

More Info (chemicals
released, etc.)

0.30

4.30

2,046

558
(27.3%)

961
(47.0%)

148
(7.2%)

263
(12.9%)

Transportation
Equipment

No data available

TRI Facility Report

561.32

4.30

317

26
(8.1%)

118
(37.2%)

11
(3.4%)

41
(13.1%)

Electric Utilities

In compliance

TRI Facility Report

246.89

4.19

1,203

686
(57.0%)

561
(46.6%)

63
(5.2%)

192
(16.0%)

Chemicals

High Priority Violator

TRI Facility Report

0.87

4.08

2,761

1806
(65.4%)

1,140
(41.3%)

270
(9.8%)

201
(7.3%)

Primary Metals

In compliance

TRI Facility Report

Sources: Environmental Protection Agency's 2018 Toxics Release Inventory as of November 2019; 2019 EJSCREEN; RSEI Inhaltion Toxicity Weights; Enforcement and Compliance History Online

40