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Technical Support Document

Definition of important terms used in this document:

1) Designated “unclassifiable” – an area where Environmental
Protection Agency (EPA) could not determine if there was a violation of
the 2008 Lead National Ambient Air Quality Standard (NAAQS) or a
contribution to a violation in a nearby area, because there was
insufficient air quality data for both 2006-2008 and 2007-2009 and where
additional monitoring data for 2010 could not result in a different
designation.

2) Designated “attainment” – an area which EPA has determined,
based on the most recent 3 years of certified air quality data from
2006-2008 or 2007-2009, has no violations of the 2008 Lead NAAQS during
36 consecutive valid 3-month site means; and which EPA has further
determined does not contribute to a violation of the 2008 Lead NAAQS in
a nearby area and that additional monitoring data from 2010 could not
result in a different designation.

3) Designated nonattainment area – an area which EPA has determined,
based on a State recommendation and/or on the technical analysis
included in this document, has a violation of the 2008 Lead NAAQS during
the most recent three consecutive years of quality-assured, certified
air quality data.

4) Prior nonattainment area – an area that is currently designated as
nonattainment or maintenance for the 1978 Lead NAAQS (including both
current nonattainment areas and maintenance areas).

5) Recommended nonattainment area – an area a State or Tribe has
recommended to EPA be designated as nonattainment.

6) Violating monitor – an ambient air monitor whose design value
exceeds 0.15 micrograms per cubic meter (µg/m3).  As described in
Appendix R of part 50, a violation can be based on either Pb-Total
Suspended Particulate (TSP) or Pb-Particulate Matter 10 microns or
smaller in size (PM10) data and only three months of data are necessary
to produce a valid violating design value.

7) 1978 Lead NAAQS – 1.5 µg/m3, NAAQS for lead promulgated in 1978. 
Based on the lead-total suspended particulate (Pb-TSP) indicator and
averaged over a calendar quarter.

8) 2008 Lead NAAQS -  0.15 µg/m3,  NAAQS for lead promulgated in 2008. 
Based on the Pb-TSP indicator and a three-month rolling average.  Data
for the Pb-PM10 (lead-particles smaller than 10 micrometers) indicator 
may be used in limited instances, including to show nonattainment.

Pennsylvania

Area Designations For the 

2008 Lead National Ambient Air Quality Standards

r (μg/m³) to 0.15 μg/m³ measured as total suspended particles (TSP).
 EPA has revised the secondary (welfare-based) standard to be identical
in all respects to the primary standard.

Pursuant to section 107(d) of the Clean Air Act, EPA must designate as
“nonattainment” those areas that violate the NAAQS and those nearby
areas that contribute to violations.  The table below identifies the
counties or portions of counties in the Commonwealth of Pennsylvania
that EPA is designating “nonattainment” for the 2008 lead national
ambient air quality standard (2008 Lead NAAQS). 

Table 1. Nonattainment Areas

Area (listed alphabetically)	Pennsylvania’s  Recommended Nonattainment
Counties	Pennsylvania’s Recommended Nonattainment Townships/Boroughs
EPA’s Designated Nonattainment Counties	EPA’s Designated
Nonattainment Townships/Boroughs

Lower Beaver Valley Area	Beaver County (partial) 	Potter and Vanport
Beaver County (partial)	Potter and Vanport

Lyons Area	Berks County (partial)	Maxatawny, Richmond, and Lyons	Berks
County (partial)	Maxatawny, Richmond, Lyons, and Kutztown

North Reading Area	Berks County (partial)	Muhlenberg, Laureldale, and
Alsace	Berks County (partial)	Muhlenberg, Laureldale, and Alsace



Figure 1. Map of Beaver and Berks Counties in relation to the rest of
the Commonwealth of Pennsylvania.

Technical Analysis for Lyons Nonattainment Area

Introduction  

This technical analysis for Lyons Nonattainment Area in Berks County
identifies the partial county with a monitor that violates the 2008 Lead
NAAQS and evaluates nearby counties for contributions to lead
concentrations in the area.  EPA has evaluated these counties based on
the weight of evidence of the following factors recommended in previous
EPA guidance:  

Air quality in potentially included versus excluded areas;

Emissions and emissions-related data in areas potentially included
versus excluded from the nonattainment area, including population data,
growth rates and patterns and emissions controls;

Meteorology (weather/transport patterns);

Geography/topography (mountain ranges or other air basin boundaries);

Jurisdictional boundaries (e.g., counties, air districts, reservations,
etc.); and

Any other relevant information submitted to or collected by EPA (e.g.,
modeling where done appropriately).

On December 17, 2009, Pennsylvania recommended that parts of Berks
County be designated as nonattainment for the 2008 Lead NAAQS based on
air quality data from 2006-2008.  The Commonwealth’s recommendation
was based on data from Federal Reference Method (FRM) or Federal
Equivalent Method (FEM) monitors located in the state.  As part of
Pennsylvania’s recommendation they used modeling for drawing the
nonattainment area boundaries in Berks County.  EPA’s review of this
modeling can be found in Appendix A of this document.  This modeling
supports Pennsylvania’s recommendation that the Lyons Nonattainment
Area and the North Reading Nonattainment Area in Berks County should be
two separate nonattainment areas.  A conservative approach was used by
Pennsylvania, where it included the whole township or borough that
contained any part of the contours of the modeling results at or above
half the 2008 Lead NAAQS or 0.075 µg/m3.  A map of these contour lines
showing the two separate nonattainment areas can be found in Figure A-2
in Appendix A of this document.

Based on EPA's technical analysis described below, EPA is designating
parts of Berks County in Pennsylvania as nonattainment for the 2008 Lead
NAAQS as the Lyons Nonattainment Area, based upon currently available
information.  This county and the townships/boroughs included in the
nonattainment area are listed above in Table 1.

Detailed Assessment

Air Quality Data 

This factor considers the lead design values (in µg/m3) for air quality
monitors in Berks County in the Lyons Area and the surrounding areas
based on data for the 2006-2008 and 2007-2009 periods.  A monitor’s
design value indicates whether that monitor attains a specified air
quality standard.  The 2008 Lead NAAQS are met at a monitoring site when
the identified design value is valid and less than or equal to 0.15
µg/m3.  A design value is only valid if minimum data completeness
criteria are met.  A lead design value that meets the NAAQS is generally
considered valid if it encompasses 36 consecutive valid 3-month site
means (specifically for a 3-year calendar period and the two previous
months).  For this purpose, a 3-month site mean is valid if valid data
were obtained for at least 75 percent of the scheduled monitoring days
in the 3-month period.  A lead design value that does not meet the NAAQS
is considered valid if at least one 3-month mean that meets the same 75
percent requirement is above the NAAQS.  That is, a site does not have
to monitor for three full calendar years in order to have a valid
violating design value; a site could monitor just three months and still
produce a valid (violating) design value.

The 2008 Lead NAAQS design values for Berks County in the Lyons
Nonattainment Area and surrounding area are shown in Table 2.

Table 2. Air Quality Data  

County	State Recommended Nonattainment?	Monitor Air Quality System ID
Monitor Location	Lead Design Value 2006-2008 (µg/m3)	Lead Design Value
2007-2009 (µg/m3)

Berks County, PA

	Yes (partial)

	420110005

	Lyons Area	0.10	0.07



420110717

	Lyons Area	0.21	0.21



420111717	North Reading Area	0.36	0.36

Monitors in Bold have the highest 2007-2009 design value in the
respective nonattainment area.

Figure 2. Lyons Nonattainment Area with Monitors

The Lyons Nonattainment Area shows a violation of the 2008 Lead NAAQS. 
Therefore, some area in this county must be designated nonattainment. 
However, the absence of a violating monitor alone is not a sufficient
reason to eliminate nearby areas as candidates for nonattainment status.
 Each area has been evaluated based on the weight of evidence of the
factors and other relevant information. 

Figure 2 is a map of the area analyzed showing the locations of air
quality monitors in the nonattainment area.  Currently, in the Lyons
Nonattainment Area, there are two monitors.  Of these two monitors, one
is violating the 2008 Lead NAAQS and the other is not violating, as
shown in Table 2.  The monitor that is within Lyons Borough in Figure 2
is the design monitor and is exceeding the 2008 Lead NAAQS.  The monitor
to the south, located in Richmond Township, is attaining the 2008 Lead
NAAQS, therefore, EPA agrees with Pennsylvania that no other
townships/boroughs to the East of Richmond Township should be included
into the Lyons Nonattainment Area.

Emissions and Emissions-Related Data

Evidence of lead emissions sources surrounding a violating monitor is an
important factor for determining whether a nearby area is contributing
to a monitored violation.  For this factor, EPA evaluated county level
emission data for lead and population data.

Emissions 

Emissions data were derived from the 2005 National Emissions Inventory
(NEI), version 2, which was the most up-to-date version of the national
inventory available when these data were compiled for the designations
process in 2009.  See
http://www.epa.gov/ttnchie1/net/2005inventory.html.  EPA recognizes that
for certain counties, emissions may have changed since 2005.  For
example, certain large sources of emissions in or near this area may
have installed emission controls or otherwise significantly reduced
emissions since 2005.  Some States provided updated information on
emissions and emission controls in their comments to EPA.  Pennsylvania
provided updated emissions information.  This updated data is provided
in Table 3 below.  The data provided by Pennsylvania is the most current
emission information available.  The lead inventory information from
these years allows for a direct comparison between the model results and
the most recently available design values since the emissions are from
roughly the same time periods; 2007 or 2008 for lead emissions and
2007-09 for monitor design values.

Table 3 shows total emissions of lead (given in tons per year) in and
around the Lyons Nonattainment Area for sources emitting (or anticipate
to contribute) greater than 0.1 ton per year of lead according to the
state emission inventory (Environment Facility Application Compliance
Tracking System (eF.A.C.T.S.)) for the years 2007 and 2008.  See
http://www.dep.state.pa.us/dep/efacts/.  Facilities that are part of the
Lyons Nonattainment Area for the 2008 Lead NAAQS are shown in boldface. 
Additional facilities whose annual emissions are less than 0.1 ton per
year of lead and within the Lyons Nonattainment Area are listed in Table
4 below.  The EPA has chosen to accept Pennsylvania’s use of the
inventory, and also accepts Pennsylvania’s use of the highest yearly
emissions in its modeling analysis as a conservative approach.  See
Appendix A of this document for modeling analysis.

Table 3. Facility lead emissions greater than 0.1 tons per year

County	Facility in State Recommended Nonattainment Area?	Facility Name
Facility – Total Air Emissions 

2007-eFacts Pennsylvania’s State inventory 

(tons per year)	Facility – Total Air Emissions 

2008-eFacts Pennsylvania’s State inventory 

(tons per year)	Facility Location

Berks County, PA	Yes 	EastPenn Manufacturing Co. Inc/Battery Assembly
2.47	2.49	147 Deka Rd.







	Berks County, PA	Yes 	EastPenn Manufacturing Co. Inc/ Smelter Plant
0.12	0.20	147 Deka Rd. 

Berks  County, PA	No	Exide Tech/ Reading Smelter	1.474	1.441	2nd &
Washington Sts.

Berks County, PA	No	Yuasa Battery Inc/ Laureldale	0.14	0.15	2901
Montrose Ave

Berks County, PA	No	RRI Energy Mid Atlantic/Titus Gen. Station	0.12	0.12
296 Poplar Neck Rd

Berks County, PA	No	Lehigh Cement Co. LLC/ Evansville Cement Plant and
Quarry	0.119

537 Evansville Rd.

Berks County, PA	No	Boyertown Foundry Co./ FKA EAFCO

0.127	9th & Rothermal Sts.



Table 4. Facility lead emissions less than 0.1 tons per year

County	Facility in State Recommended Nonattainment Area?	Facility Name
Facility – Total Air Emissions 

2007-eFacts Pennsylvania’s State inventory 

(tons per year)	Facility – Total Air Emissions 

2008-eFacts Pennsylvania’s State inventory 

(tons per year)	Facility Location

Berks County, PA	No	EastPenn Manufacturing Co. INC/ Kutztown	0.01	0.01
191 Willow St.







	Berks County, PA	No	Kutztown University of Pennsylvania	0.0092

Hinterliten Rd.

Berks  County, PA	No	McConway & Torley LLC/Kutztown Foundry

0.0051	230 Railroad St.



There are approximately 20,000 airport facilities in the U.S. at which
leaded aviation gasoline is consumed.  To evaluate the potential impact
of emissions at and near these facilities, EPA recommends that states
use the draft 2008 NEI.  Data for airport facilities in Berks County
which use leaded aviation gasoline are included in Table 5.

Table 5. Airport Emissions greater than 0.1 tons per year in Berks
County, PA

County	Airport in State 

Recommended Nonattainment Area?	Airport Name	Airport – Total Air
Emissions 

Draft 2008 NEI 

(tons per year)	Airport Location

Berks County, PA 	No	Kutztown	0.12	CLOSED 

November 2008

Berks County, PA	No	Reading  Regional Airport (RDG)	0.24	2501 Bernville
Road



Figure 3. Lyons Nonattainment Area with facility locations identified by
annual emissions in tons per year.

In Pennsylvania’s recommendation, the facilities in Table 4 were not
mentioned.  It is EPA’s determination that Kutztown Borough should be
included as part of the Lyons Nonattainment Area because although small
in size it does have lead emitting facilities.  The locations of the
facilities in Kutztown Borough are shown in Figure 3.  The Borough
currently appears as a hole in the nonattainment area recommended by
Pennsylvania, since it is surrounded by Maxatawny Township.  EPA agrees
with Pennsylvania that Fleetwood Borough should not be included in the
Lyons Nonattainment Area because it does not have any lead emitting
facilities and does not contribute to the nonattainment area.

Population Data

Table 6 shows the 2008 population for Berks County.  This data helps
assess the extent to which the concentration of human activities in the
area and concentration of population-oriented commercial development may
indicate emissions-based activity contributing to elevated ambient lead
levels.  This may include ambient lead contributions from activities
that would disturb lead that has been deposited on the ground or on
other surfaces.  Re-entrainment of historically deposited lead is not
reflected in the emissions inventory.

Table 6. Population Data

County	State Recommended Nonattainment?	2008 Population	2008

Population Density (pop/sq mi)	Population Change 2000-2008	Population %
Change 2000-2008

Berks County, PA	Yes (partial)	403,595	467	29,098	8%

Source of data: U.S. Census Bureau estimates for 2008 (  HYPERLINK
"http://www.census.gov/popest/datasets.html" 
http://www.census.gov/popest/datasets.html ) and estimation of the area
of U.S. Counties

Growth rates and patterns  

Berks County has an increasing population trend between 2000 and 2008. 
EPA has considered the population growth rate for this area and does not
believe that it affects the boundary recommendation.

Emissions Controls

Under this factor, the existing level of control of emission sources is
taken into consideration.  The emissions data used by EPA in this
technical analysis and provided in Table 3 and Table 4 represent
emissions levels taking into account any control strategies implemented
in the Lyons Nonattainment Area before 2007 on stationary sources.

East Penn Manufacturing Company operates a lead/acid storage battery
assembly facility and a secondary lead smelter.  The six battery
assembly plants and lead oxide plant account for most of the lead
emissions reported by the facility.  Each assembly plant consists of
four main operations that result in particulate and lead emissions
controlled by fabric collectors.  Most fabric filters are followed by a
HEPA filter to further reduce the emissions.  The entire facility is
subject to lead Reasonably Available Control Technology (RACT) in the
Pennsylvania State Implementation Plan (SIP).  It meets the requirements
of the National Emission Standards for Hazardous Air Pollutants (NESHAP)
subpart PPPPPP for the Lead and Acid Battery Manufacturing Area Sources
and New Source Performance Standards (NSPS) subpart KK for the Standards
of Performance for Lead-Acid Battery Manufacturing Plants.

Meteorology (weather/transport patterns)

For this factor, EPA considered data from National Weather Service
instruments and other meteorological monitoring sites in the area.  Wind
direction and wind speed data is from 1960-1992 Solar and Meteorological
Surface Observation Network information issued jointly by the U.S.
Department of Commerce:  National Climatic Data Center and the U.S.
Department of Energy:  National Renewable Energy Laboratory.  This data
is summarized in Figure 4 and Table 7, below.  This data may provide
evidence of the potential for lead emissions sources located upwind of a
violating monitor to contribute to ambient lead levels at the violation
location.

Figure 4. Wind directions summarized by season for Berks County, PA

 

Table 7. Top two prevailing wind directions by season for Berks County,
PA

Season	Wind direction 	Percent of wind at that direction

Winter	West, Northwest	32

Winter	West, Southwest	18

Spring	West, Northwest	24

Spring	West, Southwest	15

Summer	West, Northwest	21

Summer	West, Southwest	20

Autumn	West, Northwest	24

Autumn	West, Southwest	19



As shown in the graph in Figure 4 and Table 7, the prevailing surface
winds were predominantly from the west, northwest and west, southwest
for all four seasons.

Geography/topography (mountain ranges or other air basin boundaries)

The geography/topography analysis evaluates the physical features of the
land that might have an effect on the air shed and, therefore, on the
distribution of lead over the Lyon Nonattainment Area.

The Lyons Nonattainment Area does not have any geographical or
topographical barriers significantly limiting air pollution transport
within its air shed.  Therefore, this factor did not play a significant
role in determining the nonattainment boundary.

Jurisdictional boundaries 

Existing jurisdictional boundaries may be helpful in articulating a
boundary for purposes of nonattainment designations, and for purposes of
carrying out the governmental responsibilities of planning for
attainment of the lead NAAQS and implementing control measures.  These
boundaries may include an existing nonattainment or maintenance area
boundary, a county or township boundary, a metropolitan area boundary,
an air management district, or an urban planning boundary established
for coordinating business development or transportation activities.

The recommended Lyons Nonattainment Area is constructed using the
township/borough boundaries within Berks County.

Other Relevant Information

The Commonwealth provided modeling to show that the two areas, the Lyons
Nonattainment Area and the North Reading Nonattainment Area in Berks
County should be separate.  The Commonwealth recommended including in
the nonattainment area those townships and boroughs where the modeling
has shown a value of 0.075 µg/m3 or higher.  Additional review of the
modeling submitted by Pennsylvania can be found in Appendix A of this
technical analysis document.

Conclusion

After considering the factors and information described above, EPA has
determined that it is appropriate to designate portions of Berks County
listed in Table 1 as part of the Lyons Nonattainment Area for the 2008
Lead NAAQS.

EPA is changing Pennsylvania’s recommendation by adding the Borough of
Kutztown to the Lyons Nonattainment Area.  EPA’s nonattainment area
includes Kutztown Borough, Lyons Borough, Maxatawny Township, and
Richmond Township located with in Berks County.  The Kutztown Borough
has been added to Pennsylvania’s recommended Lyons Nonattainment Area.
 EPA determined that Kutztown Borough will be included in the
nonattainment area because it is entirely encompassed by the recommended
nonattainment area and it has 2 facilities that emit lead within its
boundaries and are in close proximity to the violating monitor.

Based on its consideration of all the relevant, available information,
as described above, EPA believes that the boundaries described herein
encompass the entire area that does not meet (or that contributes to
ambient air quality in a nearby area that does not meet) the 2008 Lead
NAAQS.

Technical Analysis for North Reading Nonattainment Area

Introduction  

This technical analysis for North Reading Nonattainment Area in Berks
County identifies the partial county with a monitor that violates the
2008 Lead NAAQS and evaluates nearby counties for contributions to lead
concentrations in the area.  EPA has evaluated these counties based on
the weight of evidence of the following factors recommended in previous
EPA guidance:  

Air quality in potentially included versus excluded areas;

Emissions and emissions-related data in areas potentially included
versus excluded from the nonattainment area, including population data,
growth rates and patterns and emissions controls;

Meteorology (weather/transport patterns);

Geography/topography (mountain ranges or other air basin boundaries);

Jurisdictional boundaries (e.g., counties, air districts, reservations,
etc.); and

Any other relevant information submitted to or collected by EPA (e.g.,
modeling where done appropriately).

On December 17, 2009, Pennsylvania recommended that parts of Berks
County be designated as nonattainment for the 2008 Lead NAAQS based on
air quality data from 2006-2008.  The Commonwealth’s recommendation
was based on data from FRM or FEM monitors located in the state.

Based on EPA's technical analysis described below, EPA is designating
parts of Berks County in Pennsylvania as nonattainment for the 2008 Lead
NAAQS as the North Reading Nonattainment Area, based upon currently
available information.  This county and the townships/boroughs included
in the nonattainment area are listed above in Table 1.

Detailed Assessment

Air Quality Data 

This factor considers the lead design values (in µg/m3) for air quality
monitors in North Reading Nonattainment Area in the Berks County and the
surrounding area based on data for the 2007 – 2009 period.  A
monitor’s design value indicates whether that monitor attains a
specified air quality standard.  The 2008 Lead NAAQS are met at a
monitoring site when the identified design value is valid and less than
or equal to 0.15 µg/m3.  A design value is only valid if minimum data
completeness criteria are met.  A lead design value that meets the NAAQS
is generally considered valid if it encompasses 36 consecutive valid
3-month site means (specifically for a 3-year calendar period and the
two previous months).  For this purpose, a 3-month site mean is valid if
valid data were obtained for at least 75 percent of the scheduled
monitoring days in the 3-month period.  A lead design value that does
not meet the NAAQS is considered valid if at least one 3-month mean that
meets the same 75 percent requirement is above the NAAQS.  That is, a
site does not have to monitor for three full calendar years in order to
have a valid violating design value; a site could monitor just three
months and still produce a valid (violating) design value.

The 2008 Lead NAAQS design values for Berks County in the North Reading
Area and surrounding area are shown in Table 8.

Table 8. Air Quality Data  

County	State Recommended Nonattainment?	Monitor Air Quality System ID
Monitor Location	Lead Design Value 2006-2008 (µg/m3)	Lead Design Value
2007-2009 (µg/m3)

Berks County, PA

	Yes (partial)

	420110005

	Lyons Area	0.10	0.07



420110717

	Lyons Area	0.21	0.21



420111717	North Reading Area	0.36	0.36

Monitors in Bold have the highest 2007-2009 design value in the
respective area.

Figure 5. Area analyzed showing the location of the air quality monitor.

The North Reading Nonattainment Area shows a violation of the 2008 Lead
NAAQS.  Therefore, some area in this county must be designated
nonattainment.  The design value for this nonattainment area is found at
the single monitor in Muhlenberg Township, as shown in Figure 5. 
However, the absence of a violating monitor alone is not a sufficient
reason to eliminate nearby areas as candidates for nonattainment status.
 Each area has been evaluated based on the weight of evidence of the
factors and other relevant information.

Emissions and Emissions-Related Data

Evidence of lead emissions sources surrounding a violating monitor is an
important factor for determining whether a nearby area is contributing
to a monitored violation.  For this factor, EPA evaluated county level
emission data for lead and population data.

Emissions 

Emissions data were derived from the 2005 NEI, version 2, which is the
most up-to-date version of the national inventory available when these
data were compiled for the designations process in 2009.  See  
HYPERLINK "http://www.epa.gov/ttnchie1/net/2005inventory.html" 
http://www.epa.gov/ttnchie1/net/2005inventory.html .  EPA recognizes
that for certain counties, emissions may have changed since 2005.  For
example, certain large sources of emissions in or near this area may
have installed emission controls or otherwise significantly reduced
emissions since 2005.  Some States provided updated information on
emissions and emission controls in their comments to EPA.  Pennsylvania
provided updated emissions information, shown in Table 9.  The data
provided by Pennsylvania is the most current emission information
available.  The lead inventory information from these years allows for a
direct comparison between the model results and the most recently
available design values since the emissions are from roughly the same
time periods; 2007 or 2008 for lead emissions and 2007-09 for monitor
design values.

Table 9 shows total emissions of lead (given in tons per year) in and
around the North Reading Area from sources emitting (or anticipate to
contribute) greater than 0.1 ton per year of lead according to the state
emission inventory (eF.A.C.T.S.) for the years 2007 and 2008.  See
http://www.dep.state.pa.us/dep/efacts/.  Facilities that are part of the
North Reading Nonattainment Area for the 2008 Lead NAAQS are shown in
boldface.  The facilities listed in Table 8 are mapped in Figure 6. 
Figure 6 shows the location of Exide Smelter and Yuasa Battery Inc.
within the Nonattainment Area boundary and the smaller facilities that
do not cause or contribute to the North Reading Nonattainment Area.  The
EPA has chosen to accept Pennsylvania’s use of the inventory, and also
accepts Pennsylvania’s use of the highest yearly emissions in its
modeling analysis as a conservative approach.  See Appendix A of this
document for modeling analysis.

Table 9. Facility lead emissions greater than 0.1 tons per year

County	Facility in State Recommended Nonattainment Area?	Facility Name
Facility – Total Air Emissions 

2007-eFacts Pennsylvania’s State inventory 

(tons per year)	Facility – Total Air Emissions 

2008-eFacts Pennsylvania’s State inventory 

(tons per year)	Facility Location

Berks County, PA	No	EastPenn Manufacturing Co. Inc/Battery Assembly	2.47
2.49	147 Deka Rd.







	Berks County, PA	No	EastPenn Manufacturing Co. Inc/ Smelter Plant	0.12
0.20	147 Deka Rd. 

Berks County, PA	Yes 	Exide Tech/ Reading Smelter	1.474	1.441	2nd &
Washington Sts.

Berks County, PA	Yes 	Yuasa Battery Inc/ Laureldale	0.14	0.15	2901
Montrose Ave

Berks County, PA	No	RRI Energy Mid Atlantic/Titus Gen. Station	0.12	0.12
296 Poplar Neck Rd

Berks County, PA	No	Lehigh Cement Co. LLC/ Evansville Cement Plant and
Quarry	0.119

537 Evansville Rd.

Berks County, PA	No	Boyertown Foundry Co./ FKA EAFCO

0.127	9th & Rothermal Sts.



There are approximately 20,000 airport facilities in the U.S. at which
leaded aviation gasoline is consumed.  To evaluate the potential impact
of emissions at and near these facilities, EPA recommends that states
use the draft 2008 NEI.  Data for airport facilities in Berks County
which use leaded aviation gasoline are included in Table 10.

Table 10. Airport Emissions greater than 0.1 tons per year in Berks
County, PA

County	Airport in State 

Recommended Nonattainment Area?	Airport Name	Airport – Total Air
Emissions 

Draft 2008 NEI 

(tons per year)	Airport Location

Berks County, PA 	No	Kutztown	0.12	CLOSED 

November 2008

Berks County, PA	No	Reading  Regional Airport (RDG)	0.24	2501 Bernville
Road



The RDG airport is located 3.75 kilometers from the violating monitor in
the North Reading Nonattainment Area.  The Commonwealth has not provided
analyses (such as air quality modeling) to examine the potential
contribution of lead emissions at RDG to the nonattainment identified by
the monitor in Muhlenberg Township.  EPA's preliminary modeling suggests
emissions from piston-engine aircraft operating out of RDG contribute
less than 1% of lead concentrations measured at the violating monitor.

Figure 6. North Reading Nonattainment Area with facility locations
identified by annual emissions in tons per year.

Population Data

Table 11 shows the 2008 population for each county in the area being
evaluated, as well as the population density for each county in that
area.  These data help assess the extent to which the concentration of
human activities in the area and concentration of population-oriented
commercial development may indicate emissions-based activity
contributing to elevated ambient lead levels.  This may include ambient
lead contributions from activities that would disturb lead that has been
deposited on the ground or on other surfaces.  Re-entrainment of
historically deposited lead is not reflected in the emissions inventory.

Table 11. Population Data

County	State Recommended Nonattainment?	2008 Population	2008

Population Density (pop/sq mi)	Population Change 2000-2008	Population %
Change 2000-2008

Berks County, PA	Yes (partial)	403,595	467	29,098	8%

Source of data: U.S. Census Bureau estimates for 2008 (  HYPERLINK
"http://www.census.gov/popest/datasets.html" 
http://www.census.gov/popest/datasets.html ) and estimation of the area
of U.S. Counties

Growth rates and patterns  

Berks County has an increasing population trend between 2000 and 2008. 
EPA has considered the population growth rate for this area and does not
believe that it affects the boundary recommendation.

Emissions Controls

Under this factor, the existing level of control of emission sources is
taken into consideration.  The emissions data used by EPA in this
technical analysis and provided in Table 9 represent emissions levels
taking into account any control strategies implemented in the North
Reading Nonattainment Area before 2007 on stationary sources.  

The Exide Facility operates a secondary lead smelter.  The facility
processes used lead/acid automotive and truck batteries and other lead
bearing scrap into metallic lead in one of the two smelting systems. 
Each system has an identical series of control devices.  The area that
reports the highest lead emissions is the raw material storage building,
which is exhausted to fabric collectors to control particulate and lead.
 The entire facility is subject to lead RACT in the Pennsylvania SIP. 

Yuasa Battery Inc. is a lead battery manufacturing facility.  It meets
the requirements of the NESHAP subpart PPPPPP for Lead and Acid Battery
Manufacturing Area Sources and the NSPS subpart KK Standards of
Performance for Lead-Acid Battery Manufacturing Plants. 

Meteorology (weather/transport patterns)

For this factor, EPA considered data from National Weather Service
instruments and other meteorological monitoring sites in the area.  Wind
direction and wind speed data was taken from 1960-1992 Solar and
Meteorological Surface Observation Network information issued jointly by
the U.S. Department of Commerce:  National Climatic Data Center and the
U.S. Department of Energy: National Renewable Energy Laboratory.  This
data is summarized in Figure 7 and Table 12, below.  This data may
provide evidence of the potential for lead emissions sources located
upwind of a violating monitor to contribute to ambient lead levels at
the violation location. 

Figure 7. Wind directions summarized by season for Berks County, PA

 

Table 12. Top two prevailing wind directions by season for Berks County,
PA

Season	Wind direction 	Percent of wind at that direction

Winter	West, Northwest	32

Winter	West, Southwest	18

Spring	West, Northwest	24

Spring	West, Southwest	15

Summer	West, Northwest	21

Summer	West, Southwest	20

Autumn	West, Northwest	24

Autumn	West, Southwest	19



As shown in the graph in Figure 7 and Table 12, the prevailing surface
winds were predominantly from the west, northwest and west, southwest
for all four seasons.

Geography/topography (mountain ranges or other air basin boundaries)

The geography/topography analysis evaluates the physical features of the
land that might have an effect on the air shed and, therefore, on the
distribution of lead over the North Reading Nonattainment Area.

The North Reading Nonattainment Area does not have any geographical or
topographical barriers significantly limiting air pollution transport
within its air shed.  Therefore, this factor did not play a significant
role in determining the nonattainment boundary.

Jurisdictional boundaries 

Existing jurisdictional boundaries may be helpful in articulating a
boundary for purposes of nonattainment designations, and for purposes of
carrying out the governmental responsibilities of planning for
attainment of the lead NAAQS and implementing control measures.  These
boundaries may include an existing nonattainment or maintenance area
boundary, a county or township boundary, a metropolitan area boundary,
an air management district, or an urban planning boundary established
for coordinating business development or transportation activities.

The recommended North Reading Nonattainment Area is constructed using
the township/borough boundaries within Berks County.

Other Relevant Information

The Commonwealth provided modeling to show that the two areas, the Lyons
Nonattainment Area and the North Reading Nonattainment Area, in Berks
County should be separate.  The Commonwealth recommended including in
the nonattainment area those townships and boroughs where the modeling
has shown a value of 0.075 µg/m3 or higher.  Additional review of the
modeling submitted by Pennsylvania can be found in Appendix A of this
technical analysis document.

Conclusion

After considering the factors and information described above, EPA has
determined that it is appropriate to include the portions of Berks
County listed in Table 1 as part of the North Reading Nonattainment Area
for the 2008 Lead NAAQS.  

EPA agrees with Pennsylvania’s recommendation for the North Reading
Nonattainment Area which includes Alsace Township, Laureldale Borough,
and Muhlenberg Township.  

Based on its consideration of all the relevant, available information,
as described above, EPA believes that the boundaries described herein
encompass the entire area that does not meet (or that contributes to
ambient air quality in a nearby area that does not meet) the 2008 Pb
NAAQS.

Technical Analysis for Lower Beaver Valley Nonattainment Area

Introduction  

This technical analysis for the Lower Beaver Valley Nonattainment Area
in Beaver County identifies the partial county with a monitor that
violates the 2008 Lead NAAQS and evaluates nearby counties for
contributions to lead concentrations in the area.  EPA has evaluated
these counties based on the weight of evidence of the following factors
recommended in previous EPA guidance:  

Air quality in potentially included versus excluded areas;

Emissions and emissions-related data in areas potentially included
versus excluded from the nonattainment area, including population data,
growth rates and patterns and emissions controls;

Meteorology (weather/transport patterns);

Geography/topography (mountain ranges or other air basin boundaries);

Jurisdictional boundaries (e.g., counties, air districts, reservations,
etc.); and

Any other relevant information submitted to or collected by EPA (e.g.,
modeling where done appropriately).

On December 17, 2009, Pennsylvania recommended that part of Beaver
County be designated as nonattainment for the 2008 Lead NAAQS based on
air quality data from 2006 - 2008.  Their recommendation was based on
data from FRM or FEM monitors located in the state.  

Based on EPA's technical analysis described below, EPA designating parts
of Beaver County in Pennsylvania as nonattainment for the 2008 Lead
NAAQS as the Lower Beaver Valley Nonattainment Area, based upon
currently available information.  This county and the townships/boroughs
included in the nonattainment area are listed above in Table 1. 

Detailed Assessment

Air Quality Data 

This factor considers the lead design values (in µg/m3) for air quality
monitors in Beaver County and the surrounding area based on data for the
2006-2008 and 2007-2009 periods.  A monitor’s design value indicates
whether that monitor attains a specified air quality standard.  The 2008
Lead NAAQS are met at a monitoring site when the identified design value
is valid and less than or equal to 0.15 µg/m3.  A design value is only
valid if minimum data completeness criteria are met.  A lead design
value that meets the NAAQS is generally considered valid if it
encompasses 36 consecutive valid 3-month site means (specifically for a
3-year calendar period and the two previous months).  For this purpose,
a 3-month site mean is valid if valid data were obtained for at least 75
percent of the scheduled monitoring days in the 3-month period.  A lead
design value that does not meet the NAAQS is considered valid if at
least one 3-month mean that meets the same 75 percent requirement is
above the NAAQS.  That is, a site does not have to monitor for three
full calendar years in order to have a valid violating design value; a
site could monitor just three months and still produce a valid
(violating) design value.

The 2008 Lead NAAQS design values for Beaver County in the Lower Beaver
Valley Area and surrounding area are shown in Figure 8 and Table 13.

Table 13. Air Quality Data  

County	State Recommended Nonattainment?	Monitor Air Quality System ID
Monitor Location	Lead Design Value 2006-2008 (µg/m3)	Lead Design Value
2007-2009 (µg/m3)

Beaver County, PA	Yes (partial)	420070505	TAMAQUI DR	0.20	0.17



Figure 8 is a map of the area analyzed showing the location of the air
quality monitor in relation to the Horsehead Facility.

The Lower Beaver Valley Area shows a violation of the 2008 Lead NAAQS. 
Therefore, some area in this county must be designated nonattainment. 
However, the absence of a violating monitor alone is not a sufficient
reason to eliminate nearby areas as candidates for nonattainment status.
 Each area has been evaluated based on the weight of evidence of the
factors and other relevant information.  

Beaver County will be reevaluated using the same technical analysis in
the second round of designations, since new source orientated monitors
were to be placed and operational by January 1, 2010 as a requirement of
the 2008 Lead NAAQS rule (73 FR 67059).  These sites for Beaver County
are shown in Figure 9 and listed in Table 14.  

Table 14. Location of Source specific monitors

Site Name	Physical Address	Lattitude	Longitude

Bruce Mansfield	206 Mowry Rd., Monaca, PA  15071	 40.638936°
80.365653°

Horsehead	Beaver Valley Mall, Monaca, PA  15071	 40.676592°	80.316369°

Vanport (original Horsehead monitor)	265 River Ave., Beaver, PA  15009	
40.685019°	80.324775°

New Monitors placed January 1, 2010 are in Bold. 

Figure 9. Map of current lead monitor locations as of January 1, 2010

Emissions and Emissions-Related Data

Evidence of lead emissions sources surrounding a violating monitor is an
important factor for determining whether a nearby area is contributing
to a monitored violation.  For this factor, EPA evaluated county level
emission data for lead and population data.

Emissions 

Emissions data were derived from the 2005 NEI, version 2, which is the
most up-to-date version of the national inventory available when these
data were compiled for the designations process in 2009.  See
http://www.epa.gov/ttnchie1/net/2005inventory.html.  EPA recognizes that
for certain counties, emissions may have changed since 2005.  For
example, certain large sources of emissions in or near this area may
have installed emission controls or otherwise significantly reduced
emissions since 2005.  Some States provided updated information on
emissions and emission controls in their comments to EPA.  Pennsylvania
provided updated emissions information, provided in Table 15.  The data
provided by Pennsylvania is the most current emission information
available.  The lead inventory information from these years allows for a
direct comparison between the model results and the most recently
available design values since the emissions are from roughly the same
time periods; 2007 or 2008 for lead emissions and 2007-09 for monitor
design values.

Table 15 shows total emissions of lead (given in tons per year) for
violating and potentially contributing townships/boroughs in and around
the Lower Beaver Valley Area and sources emitting (or anticipate to
contribute) greater than 0.1 ton per year of lead according to the state
emission inventory (eF.A.C.T.S.) for the years 2007 and 2008.  See
http://www.dep.state.pa.us/dep/efacts/.  Facilities that are part of the
Lower Beaver Valley Nonattainment Area for the 2008 Lead NAAQS are shown
in boldface.  The EPA has chosen to accept Pennsylvania’s use of the
inventory, and also accepts Pennsylvania’s use of the highest yearly
emissions in its modeling analysis as a conservative approach.  See
Appendix A of this document for modeling analysis.  Figure 10 below
shows the distance between the First Energy Generation Corp/ Bruce
Mansfield Plant and the Lower Beaver Valley Nonattainment Area.  During
the second round of designations in 2011, Beaver County will be
reevaluated with new data provided by the monitors placed in January
2010 to determine if the area should be expanded. 

Table 15. Facility lead emissions greater than 0.1 tons per year 

County	Facility in State 

Recommended Nonattainment	Facility Name	Facility – Total Air Emissions


2007-eFacts Pennsylvania’s State inventory 

(tons per year)	Facility – Total Air Emissions 

2008-eFacts Pennsylvania’s State inventory 

(tons per year)	Facility Location

Beaver County, PA	Yes (partial)	Horsehead Corp./Monaca Smelter	5.64	5.38
300 Frankfort Rd.







	Beaver County, PA	Yes (partial)	First Energy Gen. Corp/ Bruce Mansfield
Plant	1.20	0.70	State Route 168 South

Beaver County, PA 	Yes (partial)	Jewel Acquisition/ Midland Factory	0.30
0.10	12th St. & Midland Ave.



Figure 10. Lower Beaver Valley Nonattainment Area with facility
locations identified by annual emissions in tons per year. 

  

Population Data

Table 16 shows the 2008 population for Beaver County being evaluated, as
well as the population density for each county in that area.  These data
help assess the extent to which the concentration of human activities in
the area and concentration of population-oriented commercial development
may indicate emissions-based activity contributing to elevated ambient
lead levels.  This may include ambient lead contributions from
activities that would disturb lead that has been deposited on the ground
or on other surfaces.  Re-entrainment of historically deposited lead is
not reflected in the emissions inventory.

Table 16. Population Data

County	State Recommended Nonattainment?	2008 Population	2008

Population Density (pop/sq mi)	Population Change 2000-2008	Population %
Change 2000-2008

Beaver County, PA	Yes (partial)	172,476	389	-8,639	-5%

Source of data: U.S. Census Bureau estimates for 2008 (  HYPERLINK
"http://www.census.gov/popest/datasets.html" 
http://www.census.gov/popest/datasets.html ) and estimation of the area
of U.S. Counties

Growth rates and patterns  

Beaver County has a declining population trend between 2000 and 2008. 
EPA has considered the population growth rate for this area and does not
believe that it affects the boundary recommendation.

Emissions Controls

Under this factor, the existing level of control of emission sources is
taken into consideration.  The emissions data used by EPA in this
technical analysis and provided in Table 15 represent emissions levels
taking into account any control strategies implemented in the Lower
Beaver Valley Nonattainment Area before 2007 on stationary sources.  

Horsehead Corporation is a zinc processing facility which produces high
purity zinc oxide and high grade zinc metal using a two step
distillation process.  There are two sources responsible for the
majority of the lead emissions from the facility:  the sintering line
and the electrothermic furnace line.  Raw materials consisting of crude
zinc oxide and other secondary materials are fed to a sintering machine.
 Under high temperatures, air is drawn through the materials, resulting
in fused chunks that become feedstock for the electrothermic furnaces. 
Various impurities (such as lead) are volatilized during the processing.
 Emissions from this process are controlled by a baghouse.  According to
the company, 95 % of the lead emissions from the furnaces are emitted
through baghouses, and only 5% escapes as fugitive emissions. 

Meteorology (weather/transport patterns)

For this factor, EPA considered data from National Weather Service
instruments and other meteorological monitoring sites in the area.  Wind
direction and wind speed data 1960-1992 Solar and Meteorological Surface
Observation Network information issued jointly by the U.S. Department of
Commerce:  National Climatic Data Center and the U.S. Department of
Energy: National Renewable Energy Laboratory.  This data is summarized
in Figure 11, and Table 17, below.  This data may provide evidence of
the potential for lead emissions sources located upwind of a violating
monitor to contribute to ambient lead levels at the violation location.

Figure 11. Wind directions summarized by season for Beaver County, PA

  

Table 17. Top two prevailing wind directions by season for Beaver
County, PA

Season	Wind direction 	Percent of wind at that direction

Winter	West, Southwest	25

Winter	West, Northwest	22

Spring	West, Northwest	20

Spring	West, Southwest	16

Summer	West, Southwest	20

Summer	South, Southwest	18

Autumn	West, Southwest	19

Autumn	West, Northwest	18



As shown in the graph in Figure 11 and Table 17, the prevailing surface
winds are often from the west, southwest and west, northwest in most
seasons.  

Geography/topography (mountain ranges or other air basin boundaries)

The geography/topography analysis evaluates the physical features of the
land that might have an effect on the air shed and, therefore, on the
distribution of lead over the Lower Beaver Valley Nonattainment Area. 

The Lower Beaver Valley Nonattainment Area does not have any
geographical or topographical barriers significantly limiting air
pollution transport within its air shed.  Therefore, this factor did not
play a significant role in determining the nonattainment boundary.

Jurisdictional boundaries 

Existing jurisdictional boundaries may be helpful in articulating a
boundary for purposes of nonattainment designations, and for purposes of
carrying out the governmental responsibilities of planning for
attainment of the lead NAAQS and implementing control measures.  These
existing boundaries may include an existing nonattainment or maintenance
area boundary, a county or township boundary, a metropolitan area
boundary, an air management district, or an urban planning boundary
established for coordinating business development or transportation
activities.

The recommended Lower Beaver Valley Nonattainment Area is constructed
using the township boundaries within Beaver County. 

Conclusion

After considering the factors described above, EPA has determined that
it is appropriate to include the portion of Beaver County, PA listed in
Table 1 in the Lower Beaver Valley Nonattainment Area for the 2008 Lead
NAAQS.  

The air quality monitor in Beaver County shows a violation of the 2008
Lead NAAQS, based on 2007-2009 air quality data.  EPA agrees with
Pennsylvania’s recommendation to include Potter and Vanport Townships
in the Lower Beaver Valley Nonattainment Area, since the contributing
source and violating monitor are located within those townships. 

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ant, available information, as described above, EPA believes that the
boundaries described herein encompass the entire area that does not meet
(or that contributes to ambient air quality in a nearby area that does
not meet) the 2008 Pb NAAQS.

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