**Commonwealth of Pennsylvania**

**Department of Environmental Protection**

#########  

###### Request for Redesignation 

###### As Attainment 

**[Reading\
Eight-Hour Ozone Nonattainment Area]{.smallcaps}**

#######  January 2007

Bureau of Air Quality

Pennsylvania Department of Environmental Protection

P.O. Box 8468

Harrisburg, PA 17105-8468

717-787-9495

**www.depweb.state.pa.us**

Blank page inserted for copying purposes

TABLE OF CONTENTS

Introduction 1

Section 1 Demonstration of Attainment and Air Quality Trends Analysis

A. Design Value Determination 3

B. Air Quality Trends Analysis 4

C. Climate Trends Analysis 7

D. Additional Trends 11

E. Ozone Transport 13

F. Modeling Analysis 14

Section 2 SIP Approvals and Applicable Requirements

A. Regulatory Requirements 16

B. Nonregulatory Requirements 17

Section 3 Demonstration of Permanent and Enforceable Improvement

A. Base Year (2002) Emission Inventory 19

B. Attainment Year (2004) Emission Inventory 20

C. Control Measures 21

Section 4 Maintenance Plan 25

Acronyms and

Abbreviations 26

TABLES, CHARTS AND FIGURES

TABLE

1-1 Eight-Hour Ozone Statistics 4

1-2 Trajectory Start Points 14

3-1 VOC and NOx Emissions Summary: 2002 and 2004 20

3-2 Highway Vehicles: VMT and Emissions 22

CHARTS

1-1 Eight-Hour Ozone Design Values 5

1-2 Exceedance Day Count 6

1-3 Fourth High Eight-Hour Ozone Values 7

1-4 Relationship between Ozone Exceedances, Solar Insolation and
Temperature 8

1-5 Average Temperatures 9

1-6 Number of 90 degree days 10

1-7 Precipitation Totals 11

1-8 Berks County Population and Labor Force 12

1-9 Pennsylvania Economic Activity Index 13

FIGURE

1-1 HYSPLIT Back Trajectory Analysis 14

INTRODUCTION

Maintaining concentrations of ground-level ozone below the health-based
standard is important because ozone is a serious human health threat,
and also can cause damage to important food crops, forests, and
wildlife.

Repeated exposure to ozone pollution may cause a variety of adverse
health effects for both healthy people and those with existing
conditions including difficulty in breathing, chest pains, coughing,
nausea, throat irritation, and congestion. It can worsen bronchitis,
heart disease, emphysema, and asthma, and reduce lung capacity. Asthma
is a significant and growing threat to children and adults. Ozone can
aggravate asthma, causing more asthma attacks, increased use of
medication, more medical treatment and more frequent visits to hospital
emergency clinics. Because ozone pollution usually forms in hot weather,
anyone who spends time outdoors in the summer may be affected,
particularly children, the elderly, outdoor workers and people
exercising. Children are most at risk from exposure to ozone because
they are active outside, playing and exercising, during the summertime
when ozone levels are highest.

Ozone is one of the most pervasive and detrimental pollutants known to
affect vegetation, causing more injury to trees and crops than any other
air pollutant in the United States. Ozone interferes with
photosynthesis, the process by which plants convert water and sunlight
to food. Ozone makes plants more susceptible to disease, insects, other
pollutants, and harsh weather. It damages the foliage of trees and other
plants, ruining the landscape of cities, parks and forests, and
recreation areas. Research has shown that current ozone concentrations
result in reductions in wood growth in forests of the Northeast of over
10 percent. There is strong scientific evidence showing that current
levels of ozone are reducing crop yields, particularly in sensitive
species - soybean, cotton, and peanuts. Annual crop loss from ozone for
soybeans alone in Illinois, Indiana and Ohio has been calculated to fall
between \$199 million and \$345 million. The U.S. Environmental
Protection Agency (EPA) has estimated national crop yield losses due to
ozone in excess of \$1 billion annually. One of the key components of
ozone, oxides of nitrogen (NO~x~), contributes to fish kills and algae
blooms in sensitive waterways, such as the Chesapeake Bay.

Ozone is not emitted directly to the atmosphere, but is formed by
photochemical reactions between volatile organic compounds (VOCs) and
NO~x~ in the presence of sunlight. The long, hot, humid days of summer
are particularly conducive to ozone formation, so ozone levels are of
concern primarily during the months of May through September. The
primary sources of man-made VOCs and NO~x~, the ozone precursors, are
the evaporation of fuels and solvents (gasoline and consumer products),
combustion of fuels (motor vehicles, power plants and non-road engines),
and industrial processes.

The EPA has established the maximum limit for ozone pollution allowed in
the ambient air. EPA's National Ambient Air Quality Standard (NAAQS) for
ozone is 0.08 parts per million (ppm) averaged over eight hours.

In June 2004, EPA designated the Reading Area as nonattainment for the
eight-hour ozone NAAQS based on data from 2001-2003. The subsequent
analyses clearly demonstrate that the ambient air quality in the Reading
Area nonattainment area now meets the eight-hour ozone NAAQS and that
the emission reductions responsible for the air quality improvement are
both permanent and enforceable. This analysis and the maintenance plan
submitted concurrently demonstrates that the Reading Area nonattainment
area satisfies all criteria set forth in Section 107(d)(3)(E) of the
Clean Air Act (CAA) and should be officially redesignated as attainment.

Section 107(d)(3)(E) of the CAA states that an area can be redesignated
to attainment if the following conditions are met:

-   The NAAQS has been attained; (Section 1)

-   The applicable implementation plan has been fully approved under
    Section 110(k) and the state has met all applicable requirements for
    the area under Section 110 and Part D; (Section 2)

-   The improvement in air quality is due to permanent and enforceable
    reductions in emissions; and (Section 1 and Section 3)

-   A maintenance plan with contingency measures has been fully approved
    under Section 175A. (Section 4)

This redesignation request describes how the Reading Area eight-hour
ozone nonattainment area satisfies each of the Clean Air Act's Section
107(d)(3)(E) criteria for redesignation to attainment.

Requirements for a public comment process are set forth in Section
110(a)(2) of the CAA and 40 CFR Section 51.102(d). The Department of
Environmental Protection (the Department) held a public hearing on the
maintenance plan, 2002 base year inventory and the request to
redesignate the Reading Area to attainment for the eight-hour ozone
standard on Tuesday, December 19, 2006. The public comment period closed
on December 22, 2006.

#### SECTION 1

# AMBIENT AIR QUALITY ANALYSIS

On April 30, 2004, the EPA promulgated its final nonattainment
designations for the eight-hour ozone NAAQS. (69 *Fed. Reg*. 23858).
Seventeen areas in Pennsylvania were designated as eight-hour ozone
nonattainment areas. These nonattainment areas include 37 counties in
Pennsylvania as well as additional counties in Delaware, Maryland, New
Jersey and Ohio. The eight-hour ozone designations became effective on
June 15, 2004.

The Reading Area was classified as a "basic" nonattainment area based on
one-hour and eight-hour ozone concentrations. EPA designations were
based on air quality monitoring data for 2001, 2002 and 2003. Air
quality in the Reading Area nonattainment area has improved since the
EPA's original designations. The Reading Area's 2005 design value (based
on data from 2003, 2004 and 2005) is 80 parts per billion (ppb).
Following EPA criteria a design value below 85 ppb is considered to be
attainment. The Reading Area's design value of 80 ppb thus is below the
85 ppb threshold for attainment of the eight-hour ozone standard.
Concentrations are expected to remain below 85 ppb over the next decade.

In 2006, the Department's lease for the Reading ozone monitoring site
was terminated. The monitor was relocated to the Reading Department of
Public Safety, North 6^th^ Street in Reading, Pennsylvania. During 2006,
the monitoring station had 93% data availability exceeding EPA 90%
minimum data requirement. The Department believes this monitoring data
continues to represent ozone air quality levels in the Reading Area.

## **A. DESIGN VALUE DETERMINATION**

The ambient air-quality analysis is based on ozone data measured at two
sites in Berks County. The Reading monitor (42-011-0009) operated
continuously from 1974 through early 2006. This site is currently being
redeployed to Berks County's Spaatz Field, just west of the city of
Reading. One other monitor (42-011-0001) was operated at Kutztown
University between 1980 and 2003. The ambient air-quality data analysis
for ozone was completed using the appropriate regulations and guidance
documents. Monitoring procedures were determined in accordance with 40
CFR, Part 58 (40 CFR 1992a). Eight-hour ozone design values were
calculated in accordance with EPA's [Guideline on Data Handling
Conventions for the Eight-Hour Ozone NAAQS]{.underline} (1998).

## **B. TRENDS ANALYSIS**

1\. Design Values

The Reading ozone monitor began operations during the 1974 ozone season.
A second ozone monitor was added at Kutztown University in 1980. Two
ozone monitors operated in the Reading Area from 1980 through 2003.
Trends in ozone design values (April 1st through October 31st) were
analyzed from 1985 through 2005. These were all of the years that the
monitor met EPA's completeness requirements.

Table 1-1 lists the Reading monitors eight-hour ozone design values from
1988 through 2005. The Reading monitor has the current design value for
the entire nonattainment area. Both sites are presented in graphic form
in Chart 1-1. Design values have generally fallen over the entire time
period (\~20% overall) with a significant decrease occurring over the
last five years.

2\. Exceedances

Exceedance trends were examined over the 1986-2005 time period. An
exceedance is defined as any day a Berks County monitor recorded a valid
eight-hour ozone concentration greater than 84 ppb. The time period
examined met the 90% valid days requirement outlined in the EPA
guideline. Exceedance days for the Reading monitor are listed in Table
1-1 and graphed in Chart 1-2. Exceedance days have generally declined
over the 1986-2005 time period. The Reading monitor has on average 9.7
exceedance days per ozone season. This average was taken for ozone
seasons that generally had at least 90% valid data over the entire
season.

Table 1-1

Reading Monitor ( the Reading Area Nonattainment Area)

Eight-Hour Ozone Statistics

+------+-------------+-----------------+-------------+---------------+
| Year | \% Valid    | Design Value    | 4^th^ High  | Exceedance    |
|      | Days        |                 |             | days          |
|      |             | (PPM)           | (ppm)       |               |
+------+-------------+-----------------+-------------+---------------+
| 1985 | 84.1%       |                 | 0.095       | 8             |
+------+-------------+-----------------+-------------+---------------+
| 1986 | 93.0%       |                 | 0.091       | 9             |
+------+-------------+-----------------+-------------+---------------+
| 1987 | 91.1%       |                 | 0.104       | 12            |
+------+-------------+-----------------+-------------+---------------+
| 1988 | 93.9%       | 0.104           | 0.119       | 30            |
+------+-------------+-----------------+-------------+---------------+
| 1989 | 94.4%       | 0.105           | 0.094       | 11            |
+------+-------------+-----------------+-------------+---------------+
| 1990 | 96.3%       | 0.102           | 0.093       | 14            |
+------+-------------+-----------------+-------------+---------------+
| 1991 | 96.3%       | 0.096           | 0.102       | 19            |
+------+-------------+-----------------+-------------+---------------+
| 1992 | 94.4%       | 0.093           | 0.084       | 3             |
+------+-------------+-----------------+-------------+---------------+
| 1993 | 88.8%       | 0.090           | 0.085       | 4             |
+------+-------------+-----------------+-------------+---------------+
| 1994 | 92.1%       | 0.084           | 0.085       | 4             |
+------+-------------+-----------------+-------------+---------------+
| 1995 | 95.3%       | 0.088           | 0.095       | 11            |
+------+-------------+-----------------+-------------+---------------+
| 1996 | 96.3%       | 0.089           | 0.088       | 4             |
+------+-------------+-----------------+-------------+---------------+
| 1997 | 96.7%       | 0.092           | 0.095       | 10            |
+------+-------------+-----------------+-------------+---------------+
| 1998 | 96.7%       | 0.091           | 0.092       | 16            |
+------+-------------+-----------------+-------------+---------------+
| 1999 | 97.7%       | 0.096           | 0.102       | 14            |
+------+-------------+-----------------+-------------+---------------+
| 2000 | 96.3%       | 0.092           | 0.084       | 3             |
+------+-------------+-----------------+-------------+---------------+
| 2001 | 98.1%       | 0.095           | 0.099       | 8             |
+------+-------------+-----------------+-------------+---------------+
| 2002 | 96.3%       | 0.092           | 0.095       | 13            |
+------+-------------+-----------------+-------------+---------------+
| 2003 | 98.1%       | 0.091           | 0.080       | 3             |
+------+-------------+-----------------+-------------+---------------+
| 2004 | 98.6%       | 0.083           | 0.076       | 1             |
+------+-------------+-----------------+-------------+---------------+
| 2005 | 99.5%       | 0.080           | 0.085       | 4             |
+------+-------------+-----------------+-------------+---------------+

Chart 1-1

**Eight-Hour Ozone Design Values (ppm)**

![](media/image3.wmf){width="6.208333333333333in"
height="3.917361111111111in"}

### ![](media/image4.wmf){width="6.21875in" height="3.9270833333333335in"}Chart 1-2

3\. 4^th^ High Eight-Hour Ozone Trends

Eight-hour ozone design values are based on the 4^th^ highest
concentrations at a particular monitor over a three-year time period. An
analysis of yearly "4^th^ highs" yields an understanding of why design
values change over time. Chart 1-3 shows the 4^th^ high values for the
two Reading Area monitors. Both monitors had over 90% data capture
during the period (1986-2005). 4^th^ high values for the Reading monitor
are listed in Table 1-1.

![](media/image5.wmf){width="6.28125in" height="3.9270833333333335in"}

Chart 1-3

**4^th^ High Eight-Hour Ozone Values for the Reading Area Nonattainment
Area (ppm)**

## 

## **C. CLIMATE TRENDS ANALYSIS**

Daily ozone concentrations are heavily influenced by local
meteorological conditions. Ozone is a secondary pollutant formed from
oxides of nitrogen (NO~x~) and volatile organic compounds (VOCs) in the
presence of sunlight. Since ozone chemistry is driven by solar
insolation, peak ozone concentrations generally occur when solar
insolation values are the strongest (mid summer). Chart 1-4 illustrates
the relationship between solar insolation, ozone exceedances and average
monthly temperatures. Exceedances in the the Reading Area nonattainment
area occur most frequently in the months of June, July and August (JJA)
when peak solar insolation values and peak temperatures occur.

Chart 1-4

Relationship between Eight-Hour Ozone Exceedances, Solar Insolation and
Temperature

![](media/image6.wmf)

![](media/image7.wmf)![](media/image8.wmf)

1\. Temperature Trends

Temperature trends were examined over the same time period as the ozone
trends to determine if there were similar trends in temperatures and
ozone concentrations. Average temperatures as well as the number of 90º
days from the Reading, PA National Weather Service Cooperative Observer
Program (COOP) station were examined. Reading provides a consistent
reporting site that had proper instrument siting and QA/QC activities
during the time period in question. Data is publicly available from the
National Climatic Data Center.

Chart 1-5 shows Reading's average temperatures from 1987 through 2005.
Average temperature charts for the entire ozone season (April 1 through
October 21) and JJA are shown. Long-term averages are also included on
the charts to help define which years were warmer or cooler than normal.

Chart 1-5\
Average Temperatures at Reading COOP Station

![](media/image9.wmf)

![](media/image10.wmf)

Ozone concentrations tend to peak during periods of extreme heat. One
way to gauge this effect is to examine the number of 90º days. The more
90º days that occur during an ozone season the better the chance that
ozone concentrations will be high. Higher ozone concentrations could
lead to more exceedances and influence a monitor's 4^th^ high and
consequently its eight-hour ozone design value.

Chart 1-6 graphically displays the number of 90º days at Reading over
the 1987-2005 time period. Two graphs are included; one for the entire
ozone season and one for the JJA time frame. For the time period in
question, if the season had an above average number of 90º days, then it
had an above average number of 90º days during the JJA time period and
visa versa.

Chart 1-6\
Number of 90 Degree Days at Reading, PA

![](media/image11.wmf)

![](media/image12.wmf)

2\. Precipitation Trends

Precipitation trends at Reading were analyzed over the 1987-2005 time
period. Precipitation amounts for the entire ozone season and the JJA
time periods were examined. Chart 1-7 graphically shows precipitation
amounts over the 1987-2005 time period.

Chart 1-7

Precipitation Totals (inches) at Reading, PA

![](media/image13.wmf)

![](media/image14.wmf)

## 

## 

## **D. ADDITIONAL TRENDS**

1\. Population Trends

Berks County has had significant population growth over the last several
decades. Berks County's population has increased approximately 20%
between the 1980 and 2000 Census. It ranks 17^th^ in the Commonwealth
for percentage increase and 7^th^ overall in terms of gross population
change adding 61,129 people between the 1980 and 2000 Censuses.
According to the Bureau of the Census, Berks County's 2005 estimated
population is 396,314 people, ranking the county 10^th^ in the
Commonwealth of Pennsylvania.

2\. Economic Trends

Economic trends could have impacts on emissions and thus ozone
concentrations in the Reading Area and Pennsylvania. The two factors
considered here include estimated labor force changes in Berks County
(provided by the Pennsylvania Labor Department) and overall economic
activity in Pennsylvania (measured by the Economic Activity Index
published by the Philadelphia Reserve Bank and shown in Chart 1-9).

Berks County's estimated labor force has grown a bit slower than its
population over the last 25 years. Chart 1-8 shows Berks County's
population change and estimated labor force change since 1980. A larger
labor force could lead to more driving and increased infrastructure
demands. This in turn could lead to higher emissions. Increases in the
county's labor force also contribute to overall increases in economic
activity (greater family income/spending).

Chart 1-8

Berks County Population and Estimated Labor Force

![](media/image15.wmf){width="6.761111111111111in"
height="3.7819444444444446in"}

Chart 1-9

![](media/image16.wmf){width="5.8125in"
height="3.436111111111111in"}**Pennsylvania Economic Activity Index from
the Philadelphia Federal Reserve Bank**

## 

## 

## **E. OZONE TRANSPORT**

[]{.mark}

Ozone transport has a significant affect on the Berks County eight-hour
ozone nonattainment area. Ozone transport, however, is highly variable
and gauging the affects on design values, exceedances and peak ozone
concentrations is quite difficult because of the large amount of data
that would have to be analyzed.

Berks County, like most areas of eastern Pennsylvania, is affected by
several types of ozone transport working on different distance and time
scales. These include large-scale regional transport, short-term local
transport and transport via low-level jets (thin streams of fast-moving
air). Our analysis will look at regional and short-term transport. The
affects of low-level jets are generally not well understood, though
studies in the Philadelphia region have indicated low-level jets have
the potential to transport ozone over significant distances and
influence local ozone concentrations (North East Oxidant and Particle
Study, 2003).

## **1. HYSPLIT Trajectory Analysis**

One way to gauge the Reading Area's ozone transport possibilities is to
examine air-parcel trajectories during periods of elevated ozone
concentrations. Trajectories from National Oceanic Atmospheric
Administration's HYSPLIT Trajectory model were run for each exceedance
day between 1997 and 2005. Twenty-four hour back trajectories were run
for 21Z (4 PM EDT) at 500 meters. Twenty-four hour trajectories for all
of the 500-meter trajectories (78 days) were plotted on a map of the
northeastern states (Figure 1-1). The points are color coded according
to the eight-hour ozone concentration on the day of the trajectory.

Trajectory results indicate a substantial number of upwind trajectories
originated outside of Pennsylvania and the Ozone Transport Region (OTR)
on days when the Reading Area's ozone concentrations exceed the
eight-hour ozone standard (see Table 1-2). The bulk of the upwind
trajectory starting points lie to the west and south of the Reading
Area. A couple of the trajectories exceed 500 kilometers in length. This
indicates the potential for substantial contributions from areas well
upwind from the Reading Area.

### Table 1-2 Summary of the Reading Area Trajectory Start Points

**All Exceedance days 1997 through 2005 (78 days)**

  ------------------------------- ------------------------ ---------------
                                  **500 meter**            **%**

  Outside OTR                     11                       14%

  Outside PA                      59                       76%
  ------------------------------- ------------------------ ---------------

### Figure 1-1

**HYSPLIT Back Trajectory Analysis**

![](media/image17.png){width="5.997916666666667in"
height="4.625694444444444in"}

## **F. MODELING ANALYSIS**

Modeling results for the EPA's Clean Air Interstate Rule (CAIR) were
examined to determine if the results support redesignating the Reading
Area to attainment. These modeling results were outlined by the EPA in
its technical support document (TSD for Final CAIR, Air Quality
Modeling, 2005) for CAIR. Results for the Reading Area indicate that
modeled ozone concentrations are below the eight-hour ozone standard.
According to appendix E, the Reading Area's modeled ozone concentrations
are \~82 ppb for both the 2010 Base and 2015 CAIR runs. These results
support redesignating the Reading Area to attainment for the eight-hour
ozone NAAQS.

**SECTION 2**

#### SIP APPROVALS AND APPLICABLE REQUIREMENTS

In order for EPA to approve a redesignation of a nonattainment area to
attainment, the applicable State Implementation Plan (SIP) revision must
be fully approved under Section 110(k) of the CAA. In addition, the
state must have met all requirements applicable to the area under CAA
Section 110 and Part D Plan Requirements for Nonattainment Areas. The
specific requirements applicable to the Reading Area can be found in
sections 110(a)(2), and Part D sections 172(c), 173(a), 176 and 182(a)
of the CAA.

In 1991, the Reading Area was designated as a moderate area for the
one-hour ozone NAAQS. A Maintenance Plan and redesignation request was
approved by EPA in 1997 and then amended, due to updates in highway
vehicle emission methodology, in 2004 (Federal Register: May 7, 1997 62
FR 24826 and 69 FR 8822). The Maintenance Plan demonstrated that the
Reading Area could maintain the one-hour ozone standard through 2007. In
addition, a Maintenance Plan SIP revision for the Reading Area is being
submitted to EPA for approval as a SIP revision concurrently with this
request for redesignation. This Maintenance Plan also fulfills any
maintenance plan requirements due under section 175A(b) of the CAA with
respect to the one-hour ozone maintenance plan update.

All requirements for redesignation have thus been fulfilled for the
Reading Area. The dates of EPA approval for regulatory requirements are
indicated in parentheses.

A. REGULATORY REQUIREMENTS

The Commonwealth's regulations for Air Resources can be found in 25 *Pa.
Code* Subpart C, Article III. Sections are specified below. EPA's
approval of these regulations is codified in 40 CFR Part 52, Subpart NN,
section 52.2020.

-   Correction of deficiencies in pre-1990 existing rules for several
    VOC sources (surface coating, pneumatic rubber tire manufacturing,
    graphic arts and Synthetic Organic Chemical Manufacturing Industry
    equipment leaks) as part of the Reasonably Available Control
    Technology (RACT) fix-up requirement of Section 182. EPA determined
    that Pennsylvania corrected all deficiencies in a December 22, 1994
    final rule (59 FR 65971).

-   Implementation of RACT for all major sources of VOCs not covered by
    the guideline documents for which EPA has defined RACT. Such sources
    included the manufacture of surface-active agents, organic liquid
    cargo vessel loading and ballasting and others. These sources are
    covered by Standards for Sources, Stationary Sources of NOx and
    VOCs, (25 Pa. Code Sections 129.91-129.95)

-   Implementation of RACT for all major sources of NOx. These sources
    of covered by Standards for Sources, Stationary Sources of NOx and
    VOCs, (25 Pa. Code Sections 129.91-129.95).

-   Stationary air pollution sources are subject to the regulations of
    the Commonwealth of Pennsylvania, Pennsylvania Code in Title 25
    Environmental Resources (25 Pa. Code Chapters 121-145). These
    regulations include:

```{=html}
<!-- -->
```
-   Standards of Performance for New Stationary Sources promulgated by
    EPA under the Clean Air Act;

-   Standards for Contaminants (25 Pa. Code Chapter 123)

-   National Emission Standards for Hazardous Air Pollutants (25 Pa.
    Code Chapter 124);

-   Construction, Modification, Reactivation and Operation of Sources,
    including plan approval, prevention of significant deterioration,
    new source review, operating permit program (25 Pa. Code Chapter
    127);

-   Standards for Sources (25 Pa. Code Chapter 129)

-   Annual Emission Statements and required reporting to the Department,
    (25 Pa. Code Chapter 135)

> These permitting, stationary source monitoring and reporting,
> preconstruction review, offset ratios and enforceable emission
> limitations requirements were adopted to implement the federally
> mandated requirements in sections 110, 172, 173 and 182(a) of the CAA.
> EPA has approved all of these regulations as SIP revisions as
> indicated.

-   The Reasonable Available Control Technology (RACT) provisions in 25
    Pa. Code sections 129. 91-129.95 (relating to Stationary Sources of
    NOx and VOCs) continues to have "limited approval." The Department
    of Environmental Protection ("Department") has submitted SIP
    revisions to EPA for all subject RACT sources. On June 16, 2006, EPA
    proposed to convert this "limited approval" to a full approval. (71
    FR 34864)

-   The Department adopted and incorporated EPA's general conformity
    rule (40 CFR Part 93, Subpart B) by reference in its entirety. The
    general conformity regulation describes procedures to determine if
    federally-financed, non-transportation projects are in conformity
    with air quality plans (25 Pa. Code Section 127.802).

##### B. NONREGULATORY REQUIREMENTS

-   EPA and the U.S. Department of Transportation (DOT) have issued
    regulations regarding criteria and procedures for demonstrating and
    assuring conformity of transportation improvement programs (TIP or
    program), long range plans (LRP or plan), and individual
    transportation projects with the requirements of the CAA and the SIP
    for the specific nonattainment area. Affected transportation
    planning organizations are complying with all federal laws,
    regulations and guidance for transportation conformity.

-   The Department has an ongoing program to monitor and analyze ambient
    air quality and submits ambient air quality to EPA as required. The
    program is conducted in accordance with regulations in 40 CFR Part
    58.

-   The Department conducts and submits periodic inventories in
    accordance with EPA's Consolidated Emission Reporting Rule (40 CFR
    Part 51, Subpart A).

-   The Department has adequate personnel funding and authority to carry
    out the implementation of all applicable requirements and provisions
    of its SIP.

# The Reading Area thus has no pending SIP requirement or obligations for a requirement applicable in this area. In consideration of the above, the applicable implementation plan will have been fully approved by EPA under Section 110 of the CAA and all applicable requirements are fulfilled. 

SECTION 3

DEMONSTRATION OF PERMANENT AND ENFORCEABLE IMPROVEMENT

This section provides an assessment of the ozone precursor emissions at
the time the Berks area was originally designated as nonattainment for
ozone, and at the time when this area attained the 8-hour ozone NAAQS. A
2002 (base year) inventory of VOC and NO~x~ emissions is used to
represent emissions during the ozone nonattainment designation period. A
2004 inventory of VOC and NO~x~ emissions is used to identify ozone
precursor emissions during the period when the Berks area demonstrated
that it attained the 8-hour ozone NAAQS. Detailed information is
presented in the Maintenance Plan by sector.

The section first describes these ozone precursor emission estimates for
this area. These inventories have been developed in accordance with EPA
emission inventory preparation guidance. Then, it presents information
about the permanent and enforceable control measures that have been
implemented in the Berks area to produce the VOC and NO~x~ emission
reductions that have occurred between these years.

## **A. BASE YEAR (2002) EMISSION INVENTORY**

An emissions inventory for the base year, 2002, was developed for ozone
precursors in accordance with EPA guidance. This year represents the
emissions present when the Reading Area did not meet the ozone standard.
The inventory contains information for these sectors:

-   "Stationary sources" (or "point" sources) refer to those sources for
    which the Department collects individual emissions-related
    information. Generally they represent major stationary sources but
    may be smaller.

-   "Stationary area sources" are industrial/commercial/residential
    sources too small or too numerous to be handled individually, such
    as commercial and residential open burning, architectural and
    industrial maintenance coatings application and clean-up, consumer
    product use, and vehicle refueling at service stations. Where there
    is overlap between stationary point sources and stationary area
    sources, the area source values are adjusted to remove any double
    counting.

-   "Highway vehicles" include passenger cars and light-duty trucks,
    other trucks, buses and motorcycles.

-   "Nonroad" covers a diverse collection of engines including outdoor
    power equipment, recreational vehicles, farm and construction
    machinery, lawn and garden equipment, industrial equipment,
    recreational marine, commercial marine vessels, locomotives, ships,
    aircraft and many other applications.

Table 3-1 below summarizes emissions for the 2002 base year. The
Technical Appendices to the Maintenance Plan contain more detailed
information for each sector the emissions for 2002 by source category.

**B. ATTAINMENT YEAR (2004) EMISSION INVENTORY**

A 2004 inventory of VOC and NO~x~ emissions for the Reading Area is used
to identify ozone precursor emissions during the period when attainment
of the 8-hour ozone NAAQS was demonstrated for the Reading Area.
Stationary area sources were estimated based on 2002 emissions because
factors used to develop emissions were not yet available for 2004.

**Table 3-1**

**VOC and NO~x~ Emissions Summary: 2002 and 2004**

#### (tons per summer day)

[]{.mark}

+---------------------------------+-------------+---------------------+
|                                 | **VOC       |                     |
|                                 | Emissions** |                     |
+---------------------------------+-------------+---------------------+
|                                 | **2002**    | **2004**            |
+---------------------------------+-------------+---------------------+
| Stationary Point Sources        | 4.7         | 4.7                 |
+---------------------------------+-------------+---------------------+
| Stationary Area Sources         | 21.8        | 21.7                |
+---------------------------------+-------------+---------------------+
| Highway Vehicles                | 20.1        | 17.0                |
+---------------------------------+-------------+---------------------+
| Nonroad Engines/Vehicles        | 8.4         | 8.1                 |
+---------------------------------+-------------+---------------------+
| #####                           | **55.0**    | **51.5**            |
|                                 |             |                     |
| #####  TOTAL                    |             |                     |
+---------------------------------+-------------+---------------------+
|                                 |             |                     |
+---------------------------------+-------------+---------------------+
|                                 | **NOx       |                     |
|                                 | Emissions** |                     |
+---------------------------------+-------------+---------------------+
|                                 | **2002**    | **2004**            |
+---------------------------------+-------------+---------------------+
| Stationary Point Sources        | 14.5        | 16.0                |
+---------------------------------+-------------+---------------------+
| Stationary Area Sources         | 2.1         | 2.1                 |
+---------------------------------+-------------+---------------------+
| Highway Vehicles                | 34.1        | 29.8                |
+---------------------------------+-------------+---------------------+
| Nonroad Engines/Vehicles        | 10.9        | 10.3                |
+---------------------------------+-------------+---------------------+
| **TOTAL**                       | **61.6**    | **58.3**            |
+---------------------------------+-------------+---------------------+

[]{.mark}

[]{.mark}

The Maintenance Plan describes how the 2004 inventory was compiled. The
Technical Appendices to the Maintenance Plan contain more detailed
information for each sector.

**C. Control Measures**

Along with the analysis of ambient air quality and contributing factors
in Section 1 of the redesignation request, this section describes the
measures to which decreases in emissions and thus ozone concentrations
can be attributed from 2002 to 2004. From 2002 to 2004, VOC emissions
decreased by 6.3 percent. From 2002 to 2004, NOx emissions decreased by
5.4 percent.

**1. Stationary Point Sources**

**Interstate Pollution Transport Reduction.** In response to the Federal
NOx SIP call rule, the Department (and other covered states) adopted NOx
control regulations for large industrial boilers and internal combustion
engines, electric generating units, and cement plants. The regulation
covering industrial boilers and electric generators required emission
reductions to commence May 1, 2003, while the regulation covering large
internal combustion engines and cement plants required emission
reductions to commence May 1, 2005.

## **2. Stationary Area Source Measures**

Solvent Cleaning. The Department adopted revisions to the volatile
organic compound (VOC) requirements for solvent cleaning operations in
25 *Pa. Code* Section 129.63 (relating to degreasing operations) that
became effective beginning on December 22, 2001. For heated solvent
cleaning machines, in most respects the provisions of 25 Pa. Code
Section 129.63 reflect the technology and operating requirements in the
federal maximum achievable control technology (MACT) requirements for
solvent cleaning machines. Inasmuch as essentially all of the heated
solvent cleaning machines in the Commonwealth use solvents regulated
under the MACT, only a slight VOC emission reduction was achieved by the
requirements for heated solvent cleaning machines. The more important
emission reduction component of the revised solvent cleaning regulation
was the requirement related to solvent vapor pressure for solvent used
in cold cleaning machines. This component of the revised solvent
cleaning requirements resulted in an estimated 66 percent reduction of
the VOC emissions from this category of sources. The provisions
requiring the use of low vapor pressure solvents in cold cleaning
machines became effective on December 22, 2002. The emission reductions
resulting from this requirement would be reflected in the 2004
inventory. The regulation was submitted to EPA as a SIP revision on
February 13, 2002. EPA approved the program on January 16, 2003 (68 FR
2206).

Portable Fuel Containers. The Department adopted a portable fuel
container regulation, 25 Pa. Code Chapter 130, Subchapter A, to address
VOC loss resulting from permeation through portable gasoline containers,
evaporative loss through container openings, and from spillage during
the filling of small tanks on machines such as lawn mowers, chain saws,
jet skis and the like. Thise regulation requires that portable fuel
containers manufactured after January 1, 2003 for sale in Pennsylvania
meet certain requirements. (A "sell-through" provision allowed the sale
during 2003 of containers manufactured before January 1, 2003.) The
Department predicted, as part of ozone one-hour SIP demonstrations for
the Southeast Pennsylvania area, that the portable fuel container
regulation would be fully phased in over a 10-year period, i.e.
approximately 10 percent of the existing containers would be replaced
each year. Emission reduction estimates for the program reflect this
phased-in replacement of the containers. The regulation was submitted to
EPA as a SIP revision on March 26, 2003 and approved on December 8, 2004
(69 FR 70983).

**3. Highway Vehicle Sources**

While vehicle miles traveled (VMT) increased between 2002 and 2004,
highway vehicle emissions decreased. These decreases can be attributed
to the Federal Motor Vehicle Control Programs (an increased proportion
of cleaner (federal Tier 1) light-duty vehicles in the fleet, an
increased proportion of cleaner heavy-duty highway vehicles (federal
1998+ and 2002/2004 standards)) and implementation of the vehicle
emission inspection program.

**Table 3-2**

**VMT and Emissions**

+-----------------+-----------------+-----------------+-----------------+
| #### YEAR       | **VMT**         | **VOC\          | **NOX\          |
|                 |                 | (tpsd)**        | (tpsd)**        |
+-----------------+-----------------+-----------------+-----------------+
| **2002**        | 9,704,569       | 20.1            | 34.1            |
+-----------------+-----------------+-----------------+-----------------+
| **2004**        | 10,059,035      | 17.0            | 29.8            |
+-----------------+-----------------+-----------------+-----------------+

**Federal Motor Vehicle Control Programs (FMVCP).** The emission
reductions from the programs covering fleet turnover are permanent
reductions. The effects of fleet turnover between 2002 and 2004 (that
is, more vehicles subject to tighter tailpipe standards became part of
Pennsylvania's fleet) produced emission reductions between 2002 and
2004.

Tier 1 tailpipe standards established by the CAA Amendments of 1990
include NOx and VOC limits for light-duty gasoline vehicles and
light-duty gasoline trucks. These standards began to be phased in
starting in 1994. Evaporative VOC emissions are also being reduced in
gasoline-powered cars starting with model year 1998. In 1999, more
stringent new light-duty vehicle standards became effective in the Ozone
Transport Region in 1999 with the National Low Emission Vehicle (NLEV)
Program. The Department's New Motor Vehicle Control Program regulations
(25 Pa. Code Chapter 126, Subchapter D (relating to new motor vehicle
emissions control program) were approved by EPA on December 28, 1999 (64
FR 72564). These regulations allowed automobile manufacturers to comply
with NLEV instead of the incorporated California Low Emission Vehicle
(CA LEV) requirements through model year 2005. These regulations
affected vehicles 6,000 pounds and less and were the ones in effect for
new motor vehicles in the baseline year, 2002.

In 1999, EPA promulgated regulations more stringent than NLEV (Tier 2),
which were effective starting with the 2004 model year. The New Motor
Vehicle Control Program (25 Pa. Code Section 126 Subchapter D) adopted
in 1998 includes the Pennsylvania Clean Vehicles Program which
incorporated the California Low Emission Vehicle Program by reference.
The regulation allowed automakers to comply with the NLEV program as an
alternative to this Pennsylvania program until MY 2006. In order to
participate in NLEV, Pennsylvania was required to adopt language that
extended its "commitment" to NLEV until MY 2006. Because automobile
manufacturers had to comply with the more stringent regulations (NLEV
vs. Tier 2), the federal Tier 2 program governs new vehicles sold in
Pennsylvania in the attainment year, 2004.

The same EPA regulation required the reduction of sulfur in gasoline
beginning in 2004. In the first year of the program, sulfur levels are
capped at 300 parts per million (ppm) and annual refinery corporate
averages must be no more than 120 ppm. This analysis uses the default
assumptions provided in MOBILE6 for all gasoline parameters for
conventional fuel.

EPA has promulgated national regulations for heavy-duty engines and
vehicles (over 14,000 pounds) starting with model year 2004. In
addition, a consent decree with the major heavy-duty engine
manufacturers required, among other terms, that diesel engines made by
these companies comply with these 2004 standards two model years early,
in model year 2002. The Department includes these programs, as provided
in the MOBILE model, for the base year 2002 and for 2004.

**Vehicle Emission Inspection/Maintenance Program.** In February 2004,
Pennsylvania expanded its Vehicle Emission Inspection/Maintenance (I/M)
Program into Berks County. The program applies to gasoline-powered
vehicles 9,000 pounds and under, model years 1975 and newer. For
vehicles 1996 and newer, the program consists of an annual on-board
diagnostics test and a gas cap pressure test. For subject vehicles 1995
and older, the program consists of an annual visual inspection of
pollution control devices to ensure they are present, connected and the
proper type for the vehicle and a gas cap pressure test. These
regulations can be found in 67 *Pa. Code* Chapter 177. The Department
submitted the expanded emissions program as a revision to its State
Implementation Plan on December 1, 2003. EPA approved the SIP revision
on October 6, 2005 (70 FR 58313).

**4. Nonroad Sources**

EPA has adopted a series of regulations affecting new diesel-powered
("compression ignition") and gasoline-powered ("spark ignition") nonroad
engines of various sizes (horsepower) and applications. Information on
these federal rules, including their implementation dates, can be found
at www.epa.gov/nonroad . The Department used the federal control measure
assumptions built into the NONROAD model to estimate emissions for all
milestone years. No control programs were anticipated to affect aircraft
and railroad locomotive emissions between 2002 and 2004. These
requirements are codified at 40 CFR Parts 89-91.

SECTION 4

MAINTENANCE PLAN

The Maintenance Plan for the Reading Area is being submitted to EPA for
approval as a SIP revision concurrently with this request for
redesignation. The Maintenance Plan shows that the NAAQS for eight-hour
ozone will be maintained for at least 10 years after redesignation.
Eight years following redesignation, the Commonwealth will submit a
revised plan that ensures attainment through 2028.

In accordance with EPA guidance, the Maintenance Plan shows that
emission levels over the 10 years following redesignation will remain
below the emissions level in 2004, while allowing for growth in
population and vehicle miles traveled. The following state and federal
programs will ensure the continuing decline of VOC and NOx emissions:

-   Clean Air Interstate Rule (CAIR)

-   Interstate Pollution Transport Reduction

-   Portable Fuel Containers

-   Consumer Products

-   Architectural and Industrial Maintenance coatings

-   Federal Motor Vehicle Control Programs (light-duty and heavy-duty)

-   Vehicle emission inspection/maintenance program

-   Cleaner gasoline (federal program)

-   Cleaner highway diesel (federal program)

-   Cleaner nonroad diesel (federal program)

-   Pennsylvania Clean Vehicles Program

##### Pennsylvania Heavy-Duty Diesel Emissions Control Program

-   Federal programs for nonroad engines

The Department has provided assurances that it will continue to operate
the ambient air quality monitoring network in order to track maintenance
of the standard and to evaluate emissions inventories periodically
compared to the projections provided in the plan. The Department has
also provided a list of potential contingency measures that it would
consider to correct any violation of the eight-hour ozone NAAQS that
occurs after redesignation of the area.

## **ACRONYMS AND ABBREVIATIONS**

CAA Clean Air Act

CAIR Clean Air Interstate Rule

CA LEV California Low Emission Vehicle (program)

DOT Department of Transportation (U.S.)

EPA U.S. Environmental Protection Agency

FMVCP Federal Motor Vehicle Control Program

I/M Inspection and Maintenance

JJA June, July and August

NAAQS National Ambient Air Quality Standard

NLEV National Low Emission Vehicle (program)

NEOPS North East Oxidant and Particle Study

NO~x~ Oxides of Nitrogen

OTR Ozone Transport Region

ppb parts per billion

ppm parts per million

RACT Reasonably Available Control Technology

SIP State Implementation Plan

TSD Technical Support Document

tpsd tons per summer day

VMT Vehicle Miles Traveled

VOC Volatile Organic Compound