### Commonwealth of Pennsylvania Bureau of Air Quality

Comments on Pennsylvania’s designation recommendations for the revised 2006 24-hour fine-particle (PM 2.5 

### ) National Ambient Air Quality Standard (NAAQS).

Enclosures

Enclosure 1: Technical Discussion

Enclosure 2: EPA Region II’s comments on designation of Warren County, New Jersey

Enclosure 3: Pennsylvania’s enclosure to EPA’s proposed June 29, 2004 designations for the 1997 PM2.5 NAAQS (2004)PA DEP Response to EPA PM 2.5 Designations
October 2008

Page 1 of 1 TECHNICAL DISCUSSION

Inclusion of Knowlton Twp, Warren County, NJ in the Allentown-Bethlehem-Easton

PM 2.5 Nonattainment Area:

The New Jersey Department of Environm ental Protection (NJ DEP) has recommended that a portion of Warren County be included as part of the Allentown-Bethlehem-Easton, PA, PM 2.5 nonattainment area. The Department responded to NJ DEP on December 10, 2007. We continue to believe that Knowlton Township in Warren County, NJ should not be included as part of the Allentown-Bethlehem-Easton, PA, PM 2.5 nonattainment area. The NJ DEP has not demonstrated with Federal Reference Method (FRM) monitoring
that PM 2.5 concentrations within the township exceed the 2006 PM 2.5 National Ambient Air Quality Standard (NAAQS). In fact, concentrations at the current monitoring site in Warren County (Phillipsburg) meet the 2006 PM 2.5 NAAQS. This supports positions taken by EPA Region II and EPA Region III that Warren County, NJ be designated as an attainment county. (See EPA Technical Support Documents, August 14, 2008.)

The use of modeling results to define nonattainment areas is not supported by current EPA guidance regarding the development of nonattainment area recommendations. While models have been used in the past to delineate nonattainment areas, as referenced in NJ DEP’s April 14, 2008 response to comments document, this technique is not specifically mentioned in the Robert Myers June 8, 2007 memorandum (Myers memo) regarding the factors that states and tribal organizations should consider when making their nonattainment area recommendations. The Myers memo outlined a set of nine factors that should be evaluated when developing PM 2.5 nonattainment recommendations. These were the factors the Commonwealth used to develop its original recommendations provided to EPA in December 2007 and were the same factors EPA reviewed when they issued their intended nonattainment recommendations in August 2008. Therefore, NJ DEP’s modeling results are irrelevant to the final nonattainment designations, a point echoed in EPA Region II’s August 14, 2008 technical analysis (Enclosure 1), which

states:

“[W]hile the analysis indicates an impact in the Knowlton Township area, EPA
has determined that there is insufficient information to conclude that the air quality violations of the fine particle NAAQS has occurred. Current regulations and policy require that violations of the PM 2.5 standards be determined on the basis of complete, quality-assured ambient air quality monitoring data at a monitor in the area. The regulations and policy do not provide for PM 2.5 violations to be determined through means other than ambient air quality monitoring.”

New Jersey could have installed FRM monitoring in the township to support its recommendation, but chose not to do so.

The American Lung Association, Earthj ustice, Environmental Defense Fund and the Natural Resources Defense Council Comments Regarding the Liberty-Clairton
Nonattainment Area:PA DEP Response to EPA PM 2.5 Designations
October 2008

Page 2 of 2 The Department agrees with EPA assessment that the Liberty-Clairton area should be its own separate area from the Pittsburgh-Beaver Valley nonattainment area. The nonattainment problem in the Liberty-Clairton region is a result of the complex interaction of a local emission source with meteorology and topography. The local source in question is the US Steel-Clairton Coke Works facility.

Figure 1 (courtesy of Google Maps) shows the US Steel – Clairton Coke Works facility with respect to the Liberty monitor.

Figure 1PA DEP Response to EPA PM 2.5 Designations
October 2008

Page 3 of 3 Figure 2 shows the terrain differences between the US Steel-Clairton Coke Works facility
and the hillside across the river.

Figure 2

Since the Clairton Coke Works plant is to the south of the Liberty monitor, the highest

PM 2.5 levels at Liberty occur when the winds are out of the south-southwest (when the winds can blow over the top of the Coke Works and northward toward the monitor). This was demonstrated in the support documents for the designations of the 1997 PM 2.5 NAAQS standards (see the excerpt of that assessment on pages 16 to 23 in the attached
Enclosure 3. This document can also be found on EPA’s website at http://www.epa.gov/pmdesignations/1997standards/rec/region3.htm under Appendix 1 of PA’s Remarks to EPA’s Response).

In addition, the American Lung Association comment referenced a report entitled The Particulate-Related Health Benefits of Reducing Power Plant Emissions . Their reference of this report was to compare the local source of US Steel-Clairton Coke Works to that of large sources of particulates, such as power plants. However, the emissions from the Clairton Coke Works are much less than those from a power plant. In addition, the Clairton Coke Works facility has stack heights that are lower than normal power plantPA DEP Response to EPA PM 2.5 Designations
October 2008

Page 4 of 4 stacks. This would mean that the effects of a source like the Coke Works would impact the ground at a much closer location locally than a power plant. Using Figure 2 above, one can see that when the plume rises above the plant (and a southwesterly wind is blowing across the region), it would impact the hillside and the Liberty monitor.

The highest fine particulate concentrations occur at Liberty when we see the southsouthwesterly winds along with a morning inversion. A morning inversion occurs when the ground is cooler than the air above it; normally at night, the area is under the control of high pressure and clear skies. With the warmer air being above the cooler air, vertical mixing is at a minimum. Therefore, anything exhausted in the boundary layer with an inversion in place will remain trapped in that layer. For example, as the Coke Works’ low level sources emit emissions, the plume of emissions will only rise to the top of the inversion layer. At that point, the pollution is spread out horizontally. These inversions usually set up only a few hundred feet above th e surface. Therefore, fine particulate levels can become very high near the surface. In this case, the plume impacts the hillside across the river as well; the plume is actually not traveling large distances. This is evident from the speciation data from two sites, Liberty and Lawrenceville. The Lawrenceville monitor is actually downwind from the Pittsburgh metro area (the monitor sits atop the Allegheny County Health Department building in Lawrenceville, which is to the west of the Allegheny River).

The figures below display the results of the 2003-05 speciated components of the fine particulates at these two monitors.

Figure 3: Lawrenceville Figure 4: LibertyPA DEP Response to EPA PM 2.5 Designations
October 2008

Page 5 of 5 Figure 5 looks at the difference between the Lawrenceville and Liberty monitors, also know as the Liberty Excess.

Figure 5: Liberty Excess

Regional pollutants, such as sulfates and nitrates, are not showing up in the Liberty Excess. In this case, carbon (elemental and organic) is playing a big role in the actual

PM 2.5 measurements at Liberty. The US Steel-Clairton Coke Works facility is a huge contributor to elemental and organic carbon.

Therefore, from the analysis above and from the analysis that EPA provided as part of their response to the PA DEP 2006 PM 2.5 designations recommendation, the Department agrees with EPA’s assessment that the Liberty-Clairton area should be a separate nonattainment area from the Pittsburgh-Beaver Valley area.

The American Lung Association, Earthj ustice, Environmental Defense Fund and the Natural Resources Defense Council Comments Regarding the Use of Metropolitan Statistical Areas (MSAs) in Defining PM 2.5 Nonattainment Areas:

The Department agrees with EPA’s use of the full nine-factor analysis when designating areas for nonattainment for fine particulates. One of the nine factors is the “population density and degree of urbanization” (the classi fication of Consolidated Statistical Areas, Core Based Statistical Areas and Metropolitan Statistical Areas (MSA) fall under this category). Consequently, MSA boundaries were indeed taken into consideration when EPA proposed the PM 2.5 nonattainment areas. However, other factors, such as meteorology, topography and emissions data, play an important role in limiting the size of the nonattainment areas. In addition, jurisdictional boundaries, such as existing nonattainment boundaries, and traffic and commuting patterns were also considered.Attachment 1

NEW JERSEY Area Designations For the
24-Hour Fine Particle National Ambient Air Quality Standard

The table below identifies the counties in New Jersey that EPA intends to designate as not attaining the 2006 24- hour fine particle (PM 2.5 ) standard. 1 A county will be designated as nonattainment if it has an air quality monitor that is violating the standard or if the county is determined to be c ontributing to the violation of the standard.

Area New Jersey Recommended
Nonattainment Counties EPA’s Intended
Nonattainment Counties
Allentown-BethlehemEaston PA-NJ area Warren County (partial) - Knowlton Township None

New York-Northern NewJersey-Long Island, NY-NJCT area Bergen County, Essex County, Hudson County, Mercer County, Middlesex County, Monmouth County, Morris County, Passaic County, Somerset County, and Union County No change

Philadelphia-Wilmington,
PA-NJ-DE area Burlington County, Camden County, and Gloucester County No change

EPA intends to designate the remaining counties in the state as
“attainment/unclassifiable.”

EPA Technical Analysis for the A llentown-Bethlehem-Easton PA-NJ area

Discussion

Pursuant to section 107(d) of the Clean Air Act, EPA must designa te as nonattainment
those areas that violate the NAAQS and those areas that cont ribute to violations. This technical analysis for the Allentown-Beth lehem-Easton PA-NJ (Allentown, PA-NJ) area

1 EPA designated nonattainment areas for the 1997 fine particle standards in 2005. In 2006, the 24-hour PM 2.5 standard was revised from 65 micrograms per cubic meter (average of 98 th percentile values for 3 consecutiv e years) to 35 micrograms per cubic meter; the level of the annual standard for PM 2.5 remained unchanged at 15 micrograms per cubic meter (average of annual av erages for 3 consecutive years).

1identifies the counties with mon itors that violate the 24-hour PM 2.5 standard and evaluates the counties that potentially cont ribute to fine particle con centrations in the area. EPA
has evaluated these counties based on the we ight of evidence of the following nine factors recommended in EPA guidance a nd any other relevant information:

- pollutant emissions - air quality data - population density and degree of urbanization - traffic and commuting patterns - growth - meteorology - geography and topography - jurisdictional boundaries
- level of control of emissions sources

Figure 1 is a map of the counties in the area and other relevant information such as the locations and design values of air quality monitors, the me tropolitan area boundary, and
counties recommended as nonattainment by the State.



### Allentown, PA

Counties labeled in bold reflect NAAs under 1997 NAAQS 34

Figure 1. Map of Allentown, PA area that includes Warren County, NJ

In December 2007, New Jersey recommended that Knowlton Township in Warren County be designated as “nonattainment” for the 2006 24-hour PM 2.5 standard based on

2modeled violations in the Knowlton Townsh ip area of Warren County. New Jersey’s recommendation was received by EPA on December 18, 2007.

Air quality monitoring data on the composition of fine particle mass are available from the EPA Chemical Speciation Network and the IMPROVE monitoring network. Analysis of these data indicates that the days with the highest fine pa rticle concentrations in the Allentown area occur pre dominantly in the warm season

. The PM 2.5 urban increment as noted in the below figures is dominated by total carbon in both the warm and cold season months (i.e. 79 percent in the warm season, and 90 percent in the cold season). Sulfates are above 20 percent in the warm season. Crustal components in the warm season, sulfates in the cold season, and nitrates were not found. Crustal was 10 percent of the cold season urban increment. Figures 2 and 3 show the “urban increment” to identify non-regional contribution of PM 2.5 on high days for the Allentown, PA-NJ

area.

Warm Season (May-Sept) Increments in ug/m3

Carbon - 6.5 ug/m3

79% Nitrate - 0.0 ug/m3

0% Sulfate - 1.7 ug/m3

21% Crustal -0 ug/m3

0%

Figure 2. PM 2.5 Compositional Analysis of Warm Season Urban Increment for Allentown, PA-NJ
area. Total Urban Increment = 8.2 ug/m 3

3Cold Season (Jan-Apr, Oct-Dec) Increments in ug/m3

Crustal - 0.1 ug/m3

10% Sulfate - 0 ug/m3

0%

Nitrate - 0 ug/m3

0%

Carbon - 0.9 ug/m3

90%

Figure 3. PM2.5 Compositional Analysis of Cold Season Urban Increment for Allentown, PA-NJ area. Total Urban Increment = 1 ug/m 3

Based on EPA's technical analysis describe d below, EPA proposes that Warren County, New Jersey, in its entirety, be designated a ttainment/ unclassifiable. EPA has taken the state’s request that Knowlton Township in Warren County be designated as
“nonattainment” on the basis of air quality modeling an alysis under consideration. However, current regulations for determini ng violations of the fine particle NAAQS 2 and current policy for designating nonattainm ent areas for the fine particle NAAQS 3 require
that violations of the PM 2.5 standards be determined on th e basis of complete, qualityassured ambient air quality monitoring data at a monitor in the area. These regulations and policy do not provide for PM 2.5 violations to be determin ed through means other than ambient air quality monitoring. Thus, EPA finds that the information provided to date by the State does not adequately support a pa rtial county nonattainment designation. EPA will consider any additional information provided by the State in making final decisions on the designations.

2 See the regulations on the revised standard at 40 CFR 50.13(c); 71 FR 61224, October 17, 2006. See also monitoring regulations at 40 CFR Part 58, as revised on October 17, 2006 (see 71 FR 61236); and procedures for using these data to determine whether a violation has occurred in 40 CFR Part 50 Appendix N, as revised on October 17, 2006 (see 71 FR 61144).

3 See “Area Designations for the 24-Hour Fine Particle National Ambient Air Quality Standard, “ signed by Robert J. Meyers, Acting Assistant Administrator, June 7, 2007; http://www.epa.gov/ttn/naaqs/pm/docs/june_200 7_guidance_for_area_designations_for_2006_24- hour_pm2.5.pdf

4Allentown, PA-NJ area State-Recommended
Nonattainment Counties EPA-Proposed
Nonattainment Counties New Jersey Warren County (Partial) - Knowlton Township None

The following is a summary of the technical an alysis, including 9-factor analysis, for the EPA Region 2 portion of the Allentown, PA-NJ area.

EPA is proposing attainment/ unclassifiable for Warren, Sussex, and Hunterdon counties. These counties had low emissions, low C ontributing Emission Scores (CES), low population, low commuting numbers, low growth, and low meteorological and geographical impact which indicates minimal contribution to viola ting monitors in the Allentown, PA-NJ area. These counties also do not have any violating ambient air quality monitors. Morris County has been recommended for inclusion in the Northern New Jersey-Long Island, NY-NJ-CT nonattainment area. Detailed information regarding the inclusion of Morris County into that ar ea can be found in EPA’s Technical Analysis for the Northern New Jersey-Long Is land, NY-NJ-CT nonattainment area.

Factor 1: Emissions data

For this factor, EPA evaluated county le vel emission data for the following PM 2.5 components and precursor pollutants: “PM 2.5 emissions total,” “PM 2.5 emissions carbon,”
“PM 2.5 emissions other,” “SO 2 ,” and “NO
x ”. “PM 2.5 emissions total” represents direct
emissions of PM 2.5 and includes: “PM 2.5 emissions carbon,” “PM 2.5 emissions other”, primary sulfate (SO 4 ), and primary nitrate. (Alt hough primary sulfate and primary nitrate, which are emitted directly from stacks rather than forming in atmospheric
reactions with SO 2 and NO
x , are part of “PM 2.5 emissions total,” they are not shown in Table 1 as separate items ). “PM 2.5 emissions carbon” repres ents the sum of organic carbon (OC) and elemental carbon (EC) emissions, and “PM 2.5 emissions other” represents other inorganic partic les (crustal). Emissions of SO 2 and NO
x , which are precursors of the secondary PM 2.5 components sulfate and nitrate, are also considered.

Emissions data were derived from the 2005 National Emissions Inventory (NEI), version
1. See http://www.epa.gov/ttn/naaqs/pm/pm25_2006_techinfo.html.

EPA also considered the Contributing Emi ssions Score (CES) for each county. The CES is a metric that takes into consideration emissions data, meteorological data, and air quality monitoring information to provide a re lative ranking of counties in and near an
area. Note that this metric is not the excl usive way for consideration of data for these factors. A summary of the CES is include d in Attachment 2, and a more detailed description can be found at http://www.epa.gov/ttn/naaqs/pm/pm25_2006_techinfo.html#C.

Table 1 shows emissions of PM 2.5 and precursor pollutants components (given in tons per year) and the CES for violating and potential ly contributing countie s in the Allentown,
PA-NJ area. Counties are listed in desce nding order by CES. The counties that are

5currently designated nonattainment area for the 1997 PM 2.5 NAAQS are shown in
boldface.

County State
Recommended
Non-attain
ment? CES PM 2.5 emissions
total (tpy) PM 2.5 emissions
carbon (tpy) PM 2.5 emissions
other (tpy) SO 2 (tpy) NOx (tpy)

Northampton, PA Yes 100 5,222 665 4,556 60,396 24,620 Lehigh, PA Yes 35 1,328 501 828 3,749 11,503 Berks, PA Yes-other 25 3,378 922 2,456 18,874 18,086 Montgomery, PA Yes-other 23 2, 597 1,118 1,47 7 5,411 23,306 Bucks, PA Yes-other 19 2,022 876 1,146 3,951 16,792

Warren, NJ Yes-Partial 12 1,105 588 517 563 5,088 Monroe, PA No 12 1,153 590 563 1,022 5,245 Hunterdon, NJ No 10 769 454 316 556 3,882 Schuylkill, PA No 10 1,247 547 700 7,239 6,219 Carbon, PA No 9 649 313 336 1,432 2,913 Morris, NJ Yes-other 5 1,498 953 545 1,177 13,774 Sussex, NJ No 3 1,270 744 526 669 2,726 Pike, PA No 1 802 419 384 266 2,353
Table 1. PM 2.5 Related Emissions and Contributing Emissions Score

Generally, New Jersey Counties have lowe r emissions than the other potentially contributing counties. CES scores were generally low for the New Jersey counties, which is indicative of low impact on th e violating monitors in the area.

Hunterdon County, NJ has especially low emissi ons in comparison to the other counties in the area. Hunterdon, NJ emissions account fo r slightly over three percent of the total

PM 2.5 emissions, four percent of the carbon emi ssions, and about half of one percent of
the total SO 2 emissions for the area. The CES sc ore of 10 was consistent with low
contribution.

Warren County, NJ also has relatively lower emi ssions than most of th e other counties in the area. 2005 carbon emissions were 588 tons, which represents about six percent of the
total emissions for the area under considerati on. In comparison, other counties had much higher carbon emissions in the area, in cluding Montgomery, PA (i.e. 1,118 tons), and Berks, PA (i.e. 922 tons). The CES score of 12 was consistent with lower contribution.

Morris County, New Jersey also had relativ ely higher carbon emissions (i.e. 953 tons)
than most of the other co unties in the area. Total PM 2.5 emissions were 1,498 tons, which was mid-range when compared to the other c ounties. However, the CES score was very low (5 on a scale of 100), and Morris Count y has been recommended for inclusion in the Northern New Jersey-Long Island, NY-NJ-CT ar ea. Morris County has been included in
this area for the current annual PM 2.5 standard and EPA believes that it is appropriate to keep Morris County in the Northern Ne w Jersey-Long Island, NY-NJ-CT nonattainment area. Detailed information regarding the in clusion of Morris County into the Northern New Jersey-Long Island, NY-NJ-CT nonattain ment area can be found in EPA’s

6Technical Analysis for the New York-N orthern New Jersey-Long Island, NY-NJ-CT

area.

Sussex County, NJ has very low SO 2 emissions in comparison to the other counties (less
than 1% of the total SO 2 emissions). Carbon emissions were 744 tons, and total PM 2.5 emissions were 1,270 tons, which was mid-range when compared to the other counties. However, the CES score was 3 on a scale of 100 indicating minimal contribution to the county with the violating monitor.

In their December 2007 recommendation to EP A, New Jersey used 2002 emissions and projected 2009 emissions from the 2002 MANE -VU Modeling Inventory. New Jersey evaluated the same New Jersey Counties in their analysis (i.e. Warren, Hunterdon, Sussex, and Morris). New Jersey also showed relatively lower emissions than the other
counties in the area.

Factor 2: Air quality data

This factor considers the 24-hour PM 2.5 design values (in μg/m 3 ) for air quality monitors in counties in the Allentown, PA -NJ based on data for the 2005-2007 period. A monitor’s design value indicates whether that monitor attains a specified air quality
standard. The 24-hour PM 2.5 standards are met when the 3-year average of a monitor’s
98 th percentile values are 35 μg/m 3 or less. A design value is only valid if minimum data completeness criteria are met.

The 24-hour PM 2.5 design values for counties in the Allentown, PA-NJ area are shown in
Table 2.

County State Recommended Nonattainment? Design Values
2005-07 (μg/m 3 )

Northampton, PA Yes 37 Lehigh, PA Yes No monitor Berks, PA Yes-other 40 Montgomery, PA Yes-other No monitor Bucks, PA Yes-other 35

Warren, NJ Partial 34 Monroe, PA No No monitor Hunterdon, NJ No No monitor Schuylkill, PA No No monitor Carbon, PA No No monitor Morris, NJ Yes-other 32 Sussex, NJ No No monitor Pike, PA No No monitor Table 2. Air Quality Data

In EPA Region 2, there are no New Jersey counties in the Allentown, PA-NJ area that
show a violation of the 24-hour PM 2.5 standard as determined by air monitoring. The

72005-2007 design values for Warren and Morris counties are 34 μ g/m 3 and 32 μ g/m 3

, respectively. The counties of Hunt erdon, and Sussex, do not have monitors.

Northampton and Berks Counties in Pennsylvani a, which are located in Region 3, violate
the 24-hour PM 2.5 standard. The proximity of the Northampton, PA and Warren County, NJ is presented in Figure 4. Figure 5 s hows the results of New Jersey’s modeling analysis. Figures 6 and 7 show the simila rity between the data collected from the monitors located in Northampt on County, PA and Warren County, NJ.

Figure 4. Map showing Freemans burg, PA and Phillipsburg, NJ.

8Figure 5. Map of the Allentown- Bethlehem-Easton PA -NJ area. The map insert shows modeling results provided by New Jersey, wh ich the State identifies as information indicating a violation in Warren County.

9

## 2004 PM2.5 Data

0 10 20 30 40

1 7 13 19 25 31 37 43 49 55 61 67 73 79 85 91 97 103



### Common Sampling Daysug/m 3



### Warren (Phillipsburg) Northampton (Freemansburg)

Figure 6. Comparison of 2004 Phillipsbur g and Freemansburg Monitoring data



## 2005 PM2.5 Data

0 10 20 30 40 50

1 8 15 22 29 36 43 50 57 64 71 78 85 92 99 106



### Common Sampling Daysug/m3



### Warren (Phillipsburg) Northampton (Freemansburg)

Figure 7. Comparison of 2005 Phillipsbur g and Freemansburg Monitoring data

10Note: Eligible monitors for providing de sign value data generally include State and Local Air Monitoring Stations (SLAMS) at popu lation-oriented locations with a FRM or FEM monitor. All data from Special Purpos e Monitors (SPM) using an FRM, FEM, or Alternative Reference Method (ARM) which ha s operated for more than 24 months is eligible for comparison to the relevant NAAQS , subject to the requi rements given in the October 17, 2006 Revision to Ambient Air M onitoring Regulations (71 FR 61236). All monitors used to provide data must meet the monitor siting and eligibility requirements given in 71 FR 61236 to 61328 in order to be acceptable for comparison to the 24-hr

PM 2.5 NAAQS for designation purposes.

Factor 3: Population density and degree of urbanization (including commercial development)

Table 3 shows the 2005 population for each County in the area being evaluated, as well as the population density for each County in that area. Population data gives an indication of whether it is likely that population-based emissions might contribute to violations of
the 24-hour PM 2.5 standards.

Morris County ranks high in population and pop ulation density in comparison to other counties in the Allentown, PA-NJ Area. Mo rris County has been included in the New York City Metropolitan nonattainment area.

Hunterdon and Sussex County rank low in population and population density in comparison to other counties in the area. Hunterdon County has less than half the population and population density of the violating county of Northampton, PA. Sussex County also has less than half the population density and ap proximately half (53%) the population of Northampton, PA.

Warren County ranks low in terms of populati on and in population density in comparison
to counties located near the vi olating monitor in Northampt on. In comparison to the two
counties that have been recommend as nona ttainment for the A llentown, PA-NJ area, Warren County’s population and population dens ity is below 50% that of Lehigh and Northampton.

Population density and degree of urba nization for Hunterdon, Sussex, and Warren counties are low for the area of analysis. P opulation-based emissions did not play a role in designation.

County State Recommended Nonattainment 2005 Population 2005 Population Density (pop/sq mi)

Montgomery,
PA Yes-other 774,666 1591

Bucks, PA Yes-other 619,772 998

11Morris, NJ Yes-other 490,084 1019

Berks, PA Yes-other 396,236 458

Lehigh, PA Yes 330,168 948

Northampton, PA Yes 287,334 762

Monroe, PA No 162,415 264

Sussex, NJ No 152,726 285

Schuylkill, PA No 146,996 188

Hunterdon, NJ No 130,042 297

Warren, NJ Yes-Partial 110,317 305

Carbon, PA No 61,876 160

Pike, PA No 56,180 99

The counties that are currently designated nonattainment for the 1997 PM 2.5 NAAQS are shown in boldface

. Table 3. Population

Factor 4: Traffic and commuting patterns

This factor considers the nu mber of commuters in each county who drive to another county within the Allentown-Bethlehem-Easton CBSA

, the percent of total commuters in each county who commute to other coun ties within the Allentown, PA-NJ area

, as well as the total Vehicle Miles Traveled (VMT) for each county in millions of miles (see Table 4). A county with numerous commuters is genera lly an integral part of an urban area and could be an appropriate county for imple menting mobile-source emission control strategies, thus warra nting inclusion in the nonattainment area.

County State
Recommended

Nonattainment? 2005 VMT (million miles) Number Commuting
to any violating
counties Percent Commuting
to any violating
counties Number Commuting
into
statistical

area Percent Commuting
into
statistical

area

Berks, PA Yes-other 3,320 147,990 83 7,250 4

12Lehigh, PA Yes 3,374 131,610 89 129,570 88

Northampton,
PA Yes 2,399 99,230 79 106,210 85

Schuylkill, PA No 1,353 7,790 12 3,030 5

Carbon, PA No 699 6,900 27 19,070 74

Montgomery,
PA Yes-other 7,527 6,660 2 2,480 1

Monroe, PA No 1,556 5,140 8 7,060 11

Bucks, PA Yes-other 5,250 3,980 1 3,870 1

Warren, NJ Yes-Partial 1,342 2,410 5 23,440 47

Hunterdon, NJ No 929 520 1 1,630 3

Pike, PA No 584 200 1 360 2

Morris, NJ Yes-other 5,398 130 0 1,760 1

Sussex, NJ No 889 40 0 1,440 2

The counties that are in the currently designated nonattainment for the 1997 PM 2.5 NAAQS are shown in boldface.
Table 4. Traffic an d Commuting Patterns

The listing of counties on Table 4 reflects a ranking based on the number of people commuting to other violating counties.

The VMT for the residents of Wa rren County is low relative to other counties in the area. 47% of the commuting from Warren County commu te into the statistic al area. The total number of Warren County commuters into the st atistical area and violating counties is in the middle range of all the counties consider ed for contribution to the Allentown, PA-NJ area. Based on Factor 4, Warren County is a low traffic and commu ting contributor to the Allentown, PA-NJ area. Warren County, NJ does not rank high with respect to this
factor.
For other counties in the A llentown, PA area, Morris, H unterdon, and Sussex counties
rank in the lower third for the number of commute rs into the statistical area, and into the violating counties. Sussex and Hunterdon c ounties also have low VMT. Morris County, which is included as part of the New York City Metropolitan nona ttainment area, has a high amount of VMT, but the low number of commuters into the Allentown-BethlehemEaston CBSA precludes the inclusion of Morri s into the Allentown, PA nonattainment

area.

13Projections from the Federal Highway Admi nistration show that average annual daily truck traffic is projected to increase in the area through 2020 for two roads that run though Warren County (Interstate 78 and Inters tate 80). Morris, Hunterdon, and Sussex counties are also projected to have increases in truck traffic. The projected increase for all of the counties considered was not signifi cant enough to play a role in the designation of the counties Figure 8 shows projecte d 2020 annual average daily truck traffic.

Figure 8. Estimated Average Annu al Daily Truck Traffic in 2020

Note: The 2005 VMT data used for Table 4 and 5 of the 9-factor analysis has been derived using methodology simila r to that described in “Documentation for the final 2002 Mobile National Emissions Inventory, Version 3, September 2007, prepared for the Emission Inventory Group, U.S. EPA. This document may be found at: ftp://ftp.epa.gov/EmisInventory/2002finalne i/documentation/mobile/2002_mobile_nei_ve rsion_3_report_092807.pdf
The 2005 VMT data were taken from documen tation which is still draft, but which
should be released in 2008.

Factor 5: Growth rates and patterns

This factor looks at expected populati on for 2000-2005 and VMT from 1996-2005 in the Allentown, PA-NJ area, as well as pa tterns of population and VMT growth. A county

14with rapid population or VMT gr owth is generally an integral part of an urban area and could be an appropriate county for imple menting mobile-source and other emissioncontrol strategies, thus warranting inclusion in the nonattainment area.

Table 5 below shows population, population growth, VMT and VMT growth for counties
that are included in the Alle ntown, PA-NJ area. Counties ar e listed in descending order based on VMT growth between 1996 and 2005.

County 2005 Population Percent Population

Change (2000-05) Vehicle Miles
Traveled in 2005 (millions annually) Percent VMT Growth (1996-2005)

Montgomery, PA 77 4,666 3 7,527 73 Morris, NJ 490,084 4 5,398 56 Bucks, PA 619,772 3 5,250 49 Lehigh, PA 330,168 6 3,374 34 Northampton, PA 287,334 7 2,399 21 Monroe, PA 162,415 16 1,556 19 Berks, PA 396,236 6 3,320 11 Warren, NJ 110,317 7 1,342 2 Carbon, PA 61,876 5 699 0 Schuylkill, PA 146,996 -2 1,353 -1 Pike, PA 56,180 20 584 -8 Sussex, NJ 152,726 6 889 -22 Hunterdon, NJ 130,042 6 929 -42 The counties that are currently designated nonattainment in Table 5 for the 1997 PM 2.5 NAAQS are shown in boldface. Table 5. Population, VMT Growth , and Percent VMT Growth Change

Warren County experienced 7% growth from 2000-2005. The growth rate for Warren County is average in comparis on to other counties in th e area and equivalent to Northampton and Lehigh. On a per person ba sis, the growth in the number of people residing in Warren County is low. Only Carbon and Schuylkill ha d a lower percentage of population change. Montgomery, Berks, and Mo nroe County had the largest growth in population from 2000-2005.

VMT by the residents of Warren County are low in comparison with other counties in the area. The growth in VMT from 1996-2005 fo r Warren County is low in comparison with Northampton and Lehigh (21% and 34%, re spectively). Hunterdon and Sussex counties had low population and negative VMT growth. The counties of Morris, Montgomery, and Bucks, had the highest percentage of growth from 1996-2005. Morris County is being included in the New York City Metr opolitan nonattainment area. .

Factor 6: Meteorology (weather/transport patterns) For this factor, EPA considered the most representative National Weather Service wind direction and speed data throughout th e year, with an emphasis on “high PM 2.5 days” for each of two seasons (an October-April “cold” season and a May-September “warm” season). These high days are defined as days where any FRM or FEM air-quality
monitors had 24-hour PM 2.5 concentrations above 95% on a frequency distribution curve
of PM 2.5 24-hour values.

15For each air quality monitoring site, EPA de veloped a “pollution rose” to understand the prevailing wind direction and wind speed on the days with highest fine particle
concentrations. The Fi gure 9 identifies 24-hour PM 2.5 values by color; days exceeding 35 ug/m 3 are denoted with a red or black icon. A dot indicates the day occurred in the warm season; a triangle indicates the day occurred in the cool season. The center of the figure
indicates the location of the ai r quality monitoring site, a nd the location of the icon in
relation to the center indicates the directi on from which the wind was blowing on that day. An icon that is close to the center in dicates a low average wind speed on that day. Higher wind speeds are indicated when the icon is further away from the center. For this factor, EPA also considered each C ounty’s CES, which includes an analysis of trajectories of air masses for high PM 2.5 days.

Figure 9. Pollution Rose for Northampton County, PA

Table 6 shows the average prevailing surface wind directions for high PM 2.5 days by quadrant for the proposed nonattaining counties in the Allentown, PA-NJ area, as well as Warren County, NJ. The data shows that 24-hour PM 2.5 concentrations are influenced by emissions in any direction at various times a nd the data also suggest that emissions in
some directions relative to th e violation are more likely to contribute than emissions in
other directions.

16County Prevailing Wind Direction (%)

NW SW SE NE

Northhampton County, PA 4% 74% 3% 19%

Lehigh County,
PA 11% 78% 0% 11%

Warren County,

NJ 0% 70% 10% 20%

Table 6. Prevailing Wind Direct ions for High PM2.5 Days.

EPA’s analysis of meteorology shows that PM 2.5 emissions during high PM 2.5 days in 2004-2006 primarily originated and/or passed through locations from a southwesterly direction. This is also evident upon examin ation of the pollution rose for Northampton County (see Figure 9). Since the winds are se ldom from the Northeast, the emissions from Morris, Hunterdon, Sussex and Warren co unties would have little or no impact on
the PA counties.

Based on our analysis, this factor does not support incl uding Morris, Hunterdon, Sussex and Warren County in the Allent own, PA-NJ nonattainment area.

Note: the meteorology factor is also consid ered in each county’s Contributing Emissions Score because the method for deriving this metr ic included an analysis of trajectories of air masses for high PM 2.5 days.

Factor 7: Geography/topography (mountai n ranges or other air basin boundaries)

The geography/topography analysis looks at physical features of the land that might have an effect on the air shed and, th erefore, on the distribution of PM 2.5 over the Allentown,
PA-NJ area.

The Allentown, PA-NJ area does not have any geographical or topographical barriers significantly limiting air pollution transport w ithin its airshed. The Delaware River separates Hunterdon and Warren counties from the other counties in the Allentown, PANJ area, however this is not a significant barrier th at would influence the airshed. Morris and Sussex counties do not have any geographi cal or topographical ba rriers that could significantly limit air pollution transport. This factor did not play a significant role in the decision-making process

.

Factor 8: Jurisdictional boundaries (e.g., existing PM and ozone areas)

In evaluating the jurisdictiona l boundary factor, consideratio n should be given to existing boundaries and organizations that may f acilitate air quality planning and the implementation of control measures to at tain the standard. Areas designated as

17nonattainment (e.g for PM 2.5 or 8-hour ozone standard) represent important boundaries for state air quality planning.

The major jurisdictional boundary in the Allentown, PA-NJ nonattainment area is the State line between Pennsylvani a and New Jersey.

While all of New Jersey has been previous ly designated nonattainment for 8-hour ozone, the New Jersey counties in the Allentown, PA-NJ area are not in the same 8-hour ozone
nonattainment area as the countie s from Pennsylvania. .

The Allentown, PA-NJ area is also not an existing nona ttainment area for the 1997 PM 2.5 NAAQS. In EPA’s June 2007 Guidance for Area Designations for the 24-hr PM 2.5 NAAQS, EPA had indicated that we expected that the boundaries for the existing 1997

PM 2.5 nonattainment areas would have been a ppropriate for the boundaries of the new
nonattainment areas for the 2006 PM 2.5 NAAQS.

Although we considered this informati on regarding jurisdic tional boundaries, the jurisdictional boundaries factor did not influence heavily in our decision-making for the

area.

Factor 9: Level of control of emission sources

This factor considers emissi on controls currently implemented in the Allentown, PA-NJ area. This factor analysis ge nerally considered the emissions controls currently in place.

The emission estimates on Table 1 (under Fact or 1) include any control strategies implemented by the States in the Allentow n, PA-NJ area before 2005 that may influence emissions of any component of PM 2.5 emissions (i.e., total carbon, SO 2 , NOx, and crustal

PM 2.5 ). Since we believe that the emissi ons listed in Table 1 have not changed significantly since 2005, this factor does not influence heavily in our decision-making.

In considering county-level emissions, EP A considered 2005 emissions data from the National Emissions Inventory. EPA recognizes that certain po wer plants or large sources of emissions in this potential nonattainment area may have installed emission controls or otherwise significantly reduced emissions sin ce 2005 and that this information may not be reflected in this analysis. EPA will consider additional information on emission controls in making final desi gnation decisions. In cases where specific plants already have installed emission controls or plan to in stall such controls in the near future, EPA requests additional information on:

- the plant name, city, count y, and township/tax district
- identification of emission units at the plant, fuel use, and megawatt capacity - identification of emission units on which controls will be installed, and units on which
controls will not be installed

18- identification of the type of emission contro l that has been or will be installed on each unit, the date on which the control device became / will become operational, and the emission reduction efficiency of the control device - the estimated pollutant emissions for each unit before and after implementation of
emission controls - whether the requirement to operate the emission contro l device will be federally enforceable by December 2008, and the instrume nt by which federal enforceability will be ensured (e.g. through source-specific SI P revision, operating permit requirement, consent decree)

Other Relevant Information

The New Jersey Department of Environmental Protection (DEP) has performed an analysis using the CALPUFF air quality model, which indicates modeled violations in the Knowlton Township area of Warren County. The DEP analysis concluded that the Reliant power plant in Northampton County, PA is the cause of this modeled violation. New Jersey seeks to have only the K nowlton Township area of Warren County designated as nonattainment.

While the analysis indicates an impact in the Knowlton Township area, EPA has
determined that there is insufficient informati on to conclude that the air quality violations of the fine particle NAAQS has occurred.. Cu rrent regulations and policy require that
violations of the PM 2.5 standards be determined on the basis of complete, quality-assured ambient air quality monitoring data at a mon itor in the area. The regulations and policy do not provide for PM 2.5 violations to be determined through means other than ambient air quality monitoring. Current ly there is no violating mon itor present in Warren County.

EPA recognizes that an air quali ty monitor located in the area of impact as determined by air quality modeling could show a violation of the 24-hour PM2.5 standard. For this reason, EPA strongly advises that New Jersey pl ace an air quality monitor in the vicinity of Knowlton Township, which is downwind of the Reliant power plant in Northampton County, to support the state’s de termination that Warren County (or portions thereof) is violating the 24-hour PM 2.5 standard.

EPA is recommending that the entire c ounty of Warren be designated attainment/
unclassifiable for the 24-hour PM 2.5 standard

191 

## ENCLOSURE

The Commonwealth of Pennsylvania’s Response to the U.S. Environmental Protection Agency’s Proposed PM 2.5 Designations

Executive Summary.
The Governor of the Commonwealth of Penns ylvania (Commonwealth or Pennsylvania), Edward G. Rendell, received notification via letter dated June 29, 2004 of the U.S. Environmental Protection Agency’s (EPA ’s) modifications to Pennsylvania’s recommendations for particulate matter (PM 2.5 ) nonattainment area boundaries. EPA’s proposed modifications add Lawrence, Butle r, Armstrong and Greene counties to the Pittsburgh nonattainment area and add Merc er County to the Youngstown nonattainment area. The proposed modifications add three attainment counties (Indiana, Armstrong and Greene) to adjacent nonattainment areas sole ly because of the emissions from power plants located in Indiana, Armstrong and Greene counties. EPA’s modifications add Lebanon, Bucks and Montgomery counties to n onattainment areas, based primarily on Metropolitan Area definitions, despite the f act that the data strongly supports a designation of attainment for th ese counties.” (See Figure 1)

The Pennsylvania Department of Environmen tal Protection (DEP or Department) has conducted a comprehensive evaluation of EPA’s proposed recommendations. Based on (1) further review and analysis of availabl e data by the Department and the Allegheny County Health Department, (2) public input , and (3) EPA criter ia regarding the designation process, Pennsylvania finds it necessary to amend our recommendations for the Pittsburgh area. The analysis shows that unique, local PM 2.5 problems exist in the vicinities of the Liberty Bo rough, Clairton and North Braddock monitors. Pennsylvania
recommends creation of two additional nonattainment areas within the Pittsburgh
nonattainment area to address the uni que needs of these two local areas.

Liberty Borough, Clairton a nd North Braddock monitors. Allegheny County Health Department staff and Pennsylva nia Bureau of Air Quality st aff have been investigating

PM 2.5 concentrations in the vi cinities of the Liberty Borough, Clairton and North
Braddock monitors to assess ev idence of localized air qua lity issues that are not representative of the conditions present in the rest of the Pittsburgh area. These two areas have had a history of PM 10 nonattainment and are clearly impacted by nearby industrial sources that are already extensively controll ed. Therefore, bringing this area into attainment will take longer than the rest of the Pittsburgh area. These factors necessitate
creation of two additional nonattainment areas within the Pittsburgh nonattainment area. The attainment status of the entire EPA pr oposed eight-county Pittsburgh area must not be tied to unique, local problems that will re quire development of highly specialized local solutions in addition to any regional contro ls that are applied throughout the area. Additional analysis of the monitoring and me teorology data to support two partial county
nonattainment areas for these communities has been conducted. The details of the analysis and recommendations for the boundari es of the two areas can be found on pages
15 - 25 of this document.2 In addition to the necessary amendment to Pennsylvania’s recommendations for the Pittsburgh area, Pennsylvania has three majo r areas of concerns with EPA’s proposed modifications. EPA’s proposed modifications:

• Append Mercer, Lawrence and Butler Coun ties to adjacent nonattainment areas

• Designate counties as nonattainment solely due to the presen ce of a power plant

• Include Lebanon, Bucks and Montgomery Counties in nonattainment areas, despite data that strongly suppor ts a designation of attainment.

Mercer, Lawrence, and Butler Counties. EPA’s proposed designations would include Mercer County as part of the Youngstown nonattainment area and Butler and Lawrence Counties as part of the Pittsburgh nonattain ment area. Mercer County is monitoring attainment, has low population density and lo w vehicle miles traveled (VMT). In addition, Mercer County has low emissions wh ich are also predominantly downwind of the nonattaining monitors and would contribut e very little to nonattainment in the Youngstown area. More information about DEP’s analysis of Mercer County can be found on pages 27 - 28 of this document.

Butler County has low emissions, low populatio n density and low VMT. Butler County scores very low in EPA’s own weighted em issions analysis. There is no reason to conclude that this county s hould be nonattainment. DEP st rongly believes that it is inappropriate to designate Butler County as nonattainment of the PM 2.5 standard.

Lawrence County has historically not been a part of the Pittsburgh planning area for ozone. Lawrence County has relatively low emissions. More information about DEP’s analysis of Butler and Lawrence Counties can be found on page 26 - 27 of this document.

Power Plant Counties. EPA included Indiana, Armstrong and Greene Counties as
nonattainment for PM 2.5 solely because of the emissions from coal-fired power plants that are located in these counties. Pennsylvania st rongly opposes this approach. It has been our position throughout this process that emi ssions from large point sources, including power plants must be addressed by national or regional legislation or regulation. More detailed discussion about Pennsylvania’s co ncerns about the proposed nonattainment designation of these counties can be found on page 7 for Indiana County, page 26 for Armstrong County and on page 25 for Greene County.

Lebanon, Bucks and Montgomery Counties. Pennsylvania does not believe Lebanon County should be included in the Harrisbur g nonattainment area. Lebanon County has low emissions and will have little or no effect on design values in the nonattainment area since Lebanon County is generally downwi nd of Cumberland and Dauphin counties. A more detailed discussion about Pennsyl vania’s recommendation of Lebanon County as attainment can be found on pages 5 - 6.

The Pennsylvania DEP disagrees with EPA’s recommendation to expand the Philadelphia nonattainment area to include Montgomery a nd Bucks Counties. Montgomery and Bucks Counties are monitoring attainment of the PM 2.5 standard. In addi tion, it appears that3 EPA did not take into account the level of controls in th e five-county Philadelphia region. Strict emission control programs have reduced nitrogen oxide (NO x) and volatile organic compound (VOC) emissions by 35% when the region’s population has increased by nearly half a million people. Our analysis indicates that the Philadelphia region’s PM 2.5 nonattainment problem is more local in sc ope and expanding the nonattainment area to include Bucks and Montgomery Counties will not help the region attain the annual PM 2.5 standard. For a more detailed discussion, see pages 7 - 14.

Figure 2 provides annual wind roses for thes e areas demonstrating the downwind location
of these counties to the core urban areas. Figure 3 shows the location and name of monitors throughout Pennsylvania and adjoining states . Figure 4 shows the design values for these monitors based on monitored data from 2001, 2002 and 2003.4 Background. In February 2004, Pennsylvania submitted r ecommendations to the EPA to designate
attainment and nonattainment areas fo r the fine particulate matter (PM 2.5 ) national ambient air quality standard. At that tim e, Pennsylvania recommended 16 counties for nonattainment based on air quality monitori ng data and other available information, including emissions, meteorology and de mographics. Those counties included Philadelphia, Delaware, Chester, Bucks, M ontgomery, Berks, Lancaster, York, Dauphin, Cumberland, Lebanon, Cambria, Westmoreland, Washington, Allegheny and Beaver. In June 2004, Pennsylvania revised the recommen dations to exclude Bucks, Montgomery
and Lebanon from that list based on furthe r analysis and EPA’s recently established “weighted emissions scoring” guidance and da ta concerning the desi gnation process.

As required by the federal Clean Air Act, EP A notified Pennsylvania, in a letter dated June 29, 2004, of its intention to modify Pennsylvania’s recommendations for some counties. While the Clean Air Act requires that states be provided a 120-day opportunity to demonstrate why any proposed modification is inappropriate, EPA has requested state comments by September 1, 2004, effectively gi ving Pennsylvania only half of the 120 days provided in the Act. Pennsylvania reserves the right to submit additional information through out the entire 120-day pe riod required by law pr ior to promulgation by EPA.

The June 29 th letter to Governor Rendell id entified 22 counties as proposed PM 2.5 nonattainment in Pennsylvania. In add ition to the 13 counties identified in Pennsylvania’s revised recommendations , EPA proposed the addition of Lebanon, Indiana, Montgomery, Bucks, Butler, Ar mstrong, Greene, Lawrence and Mercer as
nonattainment areas.

Pennsylvania’s recommendations were devel oped with consideration given to EPA guidance. The first guidance memo (d ated April 1, 2003) from EPA Assistant Administrator Jeffrey R. Holmstead outlined EP A’s intention to apply a presumption that
the boundaries for urban nonattainment area s should be based on Metropolitan Area boundaries, as defined by the Office of Ma nagement and Budget (OMB) and published on June 30, 1999. The guidance memo listed fact ors that EPA will consider if states request nonattainment area boundaries that ar e different from OMB’s metropolitan area
definitions. These factors are:

• Emissions in areas potentia lly included versus excluded from the nonattainment

area

• Air quality in potentially included versus excluded areas

• Population density and degree of urbani zation including commercial development
in included versus excluded areas

• Traffic and commuting patterns

• Expected growth (including extent , pattern and rate of growth)

• Meteorology (weather/transport patterns)

• Geography/topography (mountain ranges or other air basin boundaries)5 • Jurisdictional boundaries (e.g., counties, air districts, Reservations, etc.)

• Level of control of emission sources

EPA issued additional guidance on February 12, 2004 on the PM 2.5 designation process,
in the form of a memo from Lydia N. Wegman. The additi onal guidance indicated that OMB’s revised Metropolitan Area boundaries , issued June 10, 2003, should also be
considered in States’ recommendations and in EPA’s review and determination of PM 2.5 designation boundaries.

Pennsylvania remains convinced that th e 13 counties identified by both EPA and Pennsylvania as nonattainment are the only counties in Pennsylvania that should be designated nonattainment with regard to the PM 2.5 standard. ( emphasis added )Pennsylvania’s analysis and recommendations were completed in accordance with EPAissued guidance. EPA’s newly developed “weighted emissions” scoring process is arbitrary and appears to e xpand nonattainment areas to include counties monitoring attainment solely because of the relative emi ssion levels without any demonstration of air quality impact. This process was never publis hed for review and comment. It has long been Pennsylvania’s position that it is impera tive that emissions from large point sources, including power plants, be addressed through a consistent national or regional control program. EPA’s recently proposed Clean Air Interstate Rule (CAIR) would be an appropriate mechanism for addressing these em issions provided more stringent emission caps and timely compliance schedules are promulgated.

The following discussion provides releva nt analysis and our comments on EPA’s intended designations for each area:

HARRISBURG AREA

In the June 29, 2004 “120-day letter”, EPA gave notice of its intention to expand the Harrisburg nonattainment area to include Cumberland, Dauphin and Lebanon counties. Pennsylvania recommends that only Cumberland and Dauphin counties be included in the Harrisburg nonattainment area. Table 1 summarizes 2001-03 annual PM 2.5 concentrations in the Harrisburg region.

Table 1.

Harrisburg Region 2001-03 PM 2.5 Annual Design Value

Site County 2001-03 design Value ( μ g/m3) Annual Standard ( μ g/m3)
Carlisle Cumberland 15.1** 15.0 Harrisburg Dauphin 15.7 15.0 Little Buffalo SP Perry 13.0 15.0

**Combined data from two monitors6 There is a discrepancy between Cumberland Co unty’s design value cited in EPA’s June 29, 2004 letter and what’s listed in Table 1. EPA listed Cumberland County’s design

value as 17.6 μ g/m 3 , but noted that the data for the county was incomplete. The Carlisle monitor was moved at the end of the first qua rter of 2001. It appears EPA used the old monitoring site’s 1 st quarter 2001 PM 2.5 concentration as the county’s annual design value. Pennsylvania combined data from both sites to calcul ate the 2001-03 annual PM 2.5 design value for Cumberland County. Both s ites are within 3 mile s of each other (see Appendix II, Figure 5).

EPA’s Analysis in Support of an Expanded Nonattainment Area

In its June 29, 2004 letter to Pennsylvania, EP A outlined its intentions for the Harrisburg
nonattainment area. EPA cited lack of em issions and the county’s low annual design value as supporting factors for this deci sion. Lebanon County, however, was added to the nonattainment area; Pennsylvania had re quested that only Dauphin and Cumberland counties be included in the Harrisburg nonatta inment area. EPA cited Lebanon County’s location adjacent to several other nonattainme nt counties as supporting evidence for its position. Including Lebanon County “...co mpletes a contiguous nonattainment boundary.”

Pennsylvania’s Comments Regarding EPA’s Analysis

Pennsylvania concurs with EPA’s proposed de signation of attainment for Perry County.

Pennsylvania opposes the inclusion of Leba non County in the Harri sburg nonattainment area. Emissions from Lebanon County are roug hly two thirds (2/3) of emissions from either Cumberland or Dauphin counties. Any emission controls imposed on Lebanon County will have little or no effect on design values in the nonattainment area since Lebanon County is generally downwind of Cumberland and Dauphin counties. The proposed inclusion of Lebanon County solely to establish a c ontiguous nonattainment
area seems more of an aesthetic exercise rather than assisting the nonattainment area to
attain the annual PM 2.5 standard. Figure 4 shows that while the cities of Harrisburg, Lancaster and Reading show nonattainment, surrounding countie s, particularly to the north such as most of Lebanon County, show attainment.

JOHNSTOWN AREA

In the June 29, 2004 letter, EPA gave notice of its intention to expand the Johnstown
nonattainment area to include Cambria and I ndiana. Pennsylvania recommends that the nonattainment area include only Cambria.

There is a discrepancy in the Johnstown PM 2.5 annual design value. EPA’s analysis

indicates the 2001-03- design value is 15.8 μ g/m 3 . Our analysis indicates Johnstown’s design value is slightly lower, 15.6 μ g/m 3

.7 Pennsylvania’s Comments Regarding EPA’s Analysis

Pennsylvania remains convinced that Indiana County should be designa ted attainment for
the PM 2.5 standard. Indiana is a rura l, non-industrial county that is not associated with any Metropolitan Statistical Area (MSA). Indiana has relatively high emissions, but these are mainly attributable to the county’s three power stations – accounting for 99.4% of the sulfur dioxide (SO 2 ) and 91.5% of the nitrogen oxide (NOx) emissions. These are Seward Station, Conemaugh Station and Homer City Station. The Seward Station was recently shut down and replaced with modern well-controlled fluidized bed units, representing state of the ar t controls. The Conemaugh St ation is equipped with SO 2 scrubbers and electrostatic precipitators (E SPs) on both units. The Homer City Station
has one of its three units equipped with SO 2 scrubbers and all three units are equipped with selective catalytic reducers (SCR), low NOx burners and ESPs. The remainder of emissions from Indiana would have a negligible impact on either the nonattainment area. Subjecting the entire county to nonattainment status due to speculation that these sources for which additional controls will be require d under the Clean Air Act regional haze rule and proposed CAIR is inappropriate.

LANCASTER AREA

Pennsylvania concurs with EPA’s proposed nonattainment designation for Lancaster County.

NEW YORK AREA

Pennsylvania concurs with EPA’s proposed de signation of attainment for Pike County.

PHILADELPHIA AREA

In the June 29, 2004 letter to Pennsylvania, EPA gave notice of its intention to expand the Philadelphia nonattainment area to include five counties: Bucks, Chester, Delaware, Montgomery and Philadelphia. Penn sylvania’s proposed Philadelphia PM 2.5 nonattainment area did not include Bucks or Montgomery counties (June 1, 2004 Revised

PM 2.5 Designation Recommendations). Both of these counties have 2001-2003 design

values below the annual PM 2.5 standard (15.0 μ g/m 3 ). Table 2 lists the annual design values for the counties in Pennsylvania included in EPA’s proposed Philadelphia
nonattainment area.

The five-county Philade lphia region’s 2001-03 PM 2.5 design value is 15.5 μ g/m 3 , slightly

above the annual standard of 15.0 μ g/m 3 . Both Bucks and Montgomery counties have design values less than the annual standard. Additionally, these counties are thought to be generally downwind and/or not significantly contributing to monitors exceeding the
annual standard.8 Table 2.

2001-03 PM 2.5 Design Values in the Five-County Philadelphia Region

Site County 2001-03 design Value ( μ g/m3) Annual Standard ( μ g/m3)

Bristol Bucks 14.4 15.0

New Garden Chester 15.2** 15.0

Chester Delaware 15.5 15.0 Norristown Montgomery 14.3 15.0 AMS Lab Philadelphia 15.2 15.0 Belmont Philadelphia 14.3 15.0 N/E Airport Philadelphia 13.8 15.0 Broad Street Philadelphia “Middle-scale” monitor Compare to 24-hr standard

Elmwood Philadelphia 14.9 15.0 MLK New Castle, DE 16.2 15.0 Camden Camden, NJ 14.6 15.0 Gibbstown Gloucester, NJ 13.8 15.0

From EPA letters to Delaware and New Jersey, ** Incomplete data set (2002-03)

EPA’s Analysis in Support of an Expanded Nonattainment Area

Technical justifications for expanding the Philadelphia PM 2.5 nonattainment area were
included in Enclosure B of EP A’s June 29, 2004 letter sent to Pennsylvania. EPA used
nine criteria to determine which counties should be included in the Philadelphia
nonattainment area. These crit eria included emissions, air quality, population, traffic and commuting patterns, expected growth, mete orology, geography/topogr aphy, jurisdictional boundaries, and level of emission controls.

EPA placed a high emphasis on weighted countywide emissions in its supporting document. EPA concluded its weighted emi ssions analysis showed Montgomery County and Bucks County significantly contributed to the region’s nona ttainment problem. Additional analysis factors including populat ion density, growth and commuting, were also cited in support for e xpanding the Philadelphia nonattainment area to include Bucks and Montgomery counties.

Pennsylvania’s Comments Regarding EPA’s Analysis

Philadelphia Annual PM 2.5 Design Value: PM 2.5 design values listed in EPA’s June 29, 2004 designation letter are di fferent than those complied by Pennsylvania and listed in Table 2. The five-county Philadelphia region’s design value is less than the value listed in EPA’s designation letter (16.4 μ g/m 3 ). Less than half of the monitors in the fivecounty Philadelphia region exceed the annual PM 2.5 standard. Expanding the nonattainment area would place counties measuri ng attainment into a nonattainment area.9 EPA’s Weighted Emissions Analysis: EPA’s use of weighted emission scores is problematic. This recently developed met hod cannot gauge how emissions are affecting a particular monitor’s desi gn value. EPA’s method does not differentiate between
different emission sources. A modeling analysis would be more helpful in determining if emissions from a particular county or a particular source type are significantly contributing to a monitor’s design value.

EPA’s Sector Wind Frequency/We ighted Emissions Analysis: EPA’s attempt to use sector wind frequency and distance to the de sign monitor to determine emission transport is over simplified. The methodology uses 10 year s of wind direction data to gauge were emissions may be transported. This me thod does not take into account other meteorological factors such as wind speed and atmospheric stability, which influence atmospheric dispersion. This method also ignores source character istics that affect emission dispersion such as release height, pl ume temperature, plume velocity and does not account for chemical transformation pro cesses. The analysis does not make a determination if the meteorological data used in the analysis is representative over the
entire nonattainment area in accordance w ith Section 3 of EPA’s Meteorological Monitoring Guidance for Regulatory Modeling Applications (EPA-454/R-99-005). Distance to the design monitor may be incorr ect since there is a discrepancy between EPA’s regional design value and what is listed in Table 1.

EPA’s VMT Analysis: EPA considered VMT in its anal ysis but did not establish a clear relationship between VMT and monitored PM 2.5 design values. VMT in the Philadelphia region is much higher than any other region in Pennsylvania yet its design value is only slightly above the annual PM 2.5 standard. Furthermore, monitors in Bucks and Montgomery counties are located near major highways yet both monitors’ 2001-03 PM 2.5 design values are less than the annual standar d. If a definitive li nk exists between VMT
and PM 2.5 design values, one would expect higher va lues for monitors in the Philadelphia region than portions of centra l and western Pennsylvania.

Table 3 summarizes VMT-PM 2.5 correlation coefficients for all Pennsylvania counties. VMT and design monitor concentrations are weak ly correlated with one another. If an average value is substituted for a county’s design value (counties with multiple monitoring sites) there is no VMT-PM 2.5 correlation.

Table 3.

VMT-PM 2.5 Correlation Coefficients for th e Commonwealth of Pennsylvania

2001-03 Annual PM2.5 Design Value * 2001-03 Average PM2.5 Design Value **

VMT 0.6557 0.3119
* County Design Value (Max) ** Average Design Value for counties with multiple monitors10 Stringent Emission Control Programs/Population Growth/Density: EPA’s analysis failed to account for stringent emission cont rol programs implemented in the five-county Philadelphia region. Air contamination sour ces in Southeast Pennsylvania and most of the metropolitan regions along th e I-95 corridor must comply with some of the most stringent emission control requirements in th e nation. These controls were enacted to bring the Ozone Transport Region (OTR) into at tainment of the one-hour ozone standard.
Controls on NO
x and VOC-emitting sources have undoubtedly helped reduce PM 2.5 concentrations. The Department estimates NO
x and VOC emissions will be reduced by
35% between 1990 and 2005 in the five-coun ty Philadelphia region. These emission reductions have occurred even though th e region’s population has increased by 10.4% (half a million people) between 1980 and 2000.

Table 4 summarizes population density-PM 2.5 correlation coefficients for all Pennsylvania monitors. The results show there is no correlation between a county’s population density and it’s design value.

Table 4.

Population Density-PM 2.5 Correlation Coefficients for the Commonwealth of Pennsylvania

2001-03 Annual PM2.5 Design Value * 2001-03 Average PM2.5 Design Value ** Population Density 0.2373 0.0860
* County Design Value (Max) ** Average Design Value for counties with multiple monitors

Design Value Contribution Analysis

Overview

The Department has completed a design valu e contribution analysis for all of the PM 2.5 monitors in the five-county Philadelphia regi on. Our analysis attempts to determine a monitor sample’s contribution to its annual PM 2.5 design value. Samples are grouped into
different PM 2.5 concentration ranges. An analysis of each range’s contribution can then be examined to determine which samples are contributing to the mon itor’s design value. Sample dates can then be further analy zed to determine if there are specific meteorological conditions or sources that ar e adversely affecting the monitor’s design value. Results from our design value analys is for southeast Pennsylvania are summarized
in Table 5.

Our design value contribution analysis indica tes the two monitors in the five-county Philadelphia region that exceeded the annua l standard, Chester and PHL-Lab, have relatively few “clean” days (0-7.5 μ g/m 3 ). Their design value contributions from this11 range are less than the statewide average and less than other monitors in the Philadelphia region. Graph 1 confirms Ches ter has fewer “clean” days, PM 2.5 concentrations in the 0

to 7.5 μ g/m 3 range. Table 5.

Southeast Pennsylvania PM-2.5 Annual Design Value Contribution Analysis

Add “Sum” to 15.0 to get moni tor’s annual design value.

Additional analyses were done to try and dete rmine what was contributing to the lack of “clean” days at Chester. To do this we identified days when Chester’s PM 2.5 concentrations were relatively high but regi onal monitoring concentr ations were low. Between 2001 and 2003 we identified 72 days where Chester’s PM 2.5 concentrations were 25% or greater than the regional average. The most extreme events were examined further to determine why Chester’s con centrations were high when regional
concentrations were low. Site Name 0-7.5 7.5-15 15-22.5 22.5-30 30-37.5 37.5-45 45-52.5 52.5-60 60-67.5 67.5-75 Sum

Bristol -2.1945 -1.6299 0.7112 0.9525 0.8442 0.3879 0.2026 0.1363 0.0000 0.0000 -0.59

Chester -1.4321 -1.6780 0.8684 1.0791 0.8254 0.4275 0.0894 0.1239 0.1470 0.0000 0.45

Norristown -2.2976 -1.7091 0.6782 0.9489 0.8432 0.1636 0.3095 0.1467 0.1775 0.0000 -0.74

PHL-Belmont -2.1229 -1.6089 0.8339 0.9816 0.6281 0.2920 0.1906 0.1157 0.0000 0.0000 -0.69

PHL-Elmwood -1.8026 -1.6580 0.8068 0.9680 0.8544 0.3010 0.2685 0.1737 0.0000 0.0000 -0.09

PHL-LAB -1.7461 -1.6521 0.7268 1.1130 0.9363 0.5302 0.2413 0.0890 0.0000 0.0000 0.24 PHL-Northeast Airport -2.4223 -1.6391 0.6829 0.8288 0.7105 0.3262 0.1097 0.2540 0.0000 0.0000 -1.15 New Garden (incomplete) -1.9109 -1.4315 0.7571 0.9206 1.0716 0.3139 0.0000 0.1918 0.0000 0.2421 0.15

Five-County Phila Avg -1.9911 -1.6258 0.7582 0.9741 0.8392 0.3428 0.1765 0.1539 0.0406 0.0303 -0.30 State Average -1.8539 -1.6112 0.7704 0.9833 0.7858 0.4223 0.2478 0.2103 0.0464 0.0527 0.0512 Graph 1.

Analysis of Speciated Data

Speciated data for Chester and New Garden, a monitoring site ~21 miles west of Chester,
were examined to determine if there were any significant differences on days when regional concentrations were lo w but Chester’s were high. A total of eleven (11) days were examined. Data was missing for most of the more extreme events. Table 6 lists standard deviations, correlation coefficients and correlations of divergence for these eleven days. These analyses indicate major di fferences in sulfate and crustal components
between the two sites.

Table 6.

Statistical Analysis Chester/New Garden Speciated Data 

### PM-2.5 Category Breakdown
2001-2003: SE Pennsylvania

0.0% 5.0% 10.0% 15.0% 20.0% 25.0% 30.0% 35.0% 40.0% 45.0%

0-7.5

7 . 5-

1 5

1 5-

22.5

2 2 .5

- 30 30-37.5

3 7.

5 -45

4 5 -52.5

5 2.

5 -60

6 0-

67.

5

6 7 .5

- 75 Bristol

Chester

Norristown

Nitrate Sulfate Ammonium Organic Carbon Elemental Carbon Crustal Other

Standard Deviation 1.2748 1.6022 0.7094 1.4553 0.3444 0.9071 2.7151

Correlation Coefficient 0.9725 -0.3467 0.8875 0.8247 0.6032 0.4838 0.1228 Coefficients of Divergence 0.0684 0.5048 0.3261 0.1237 0.2325 1.2103 1.479313 Criteria Pollutant/Meteor ological Data Analysis

Twenty-four hour averaged wind direction, wind speed, PM 10 and sulfur dioxide concentrations for Chester, Norristown and Bristol were compared for nineteen days
when PM 2.5 concentrations at Chester were signifi cantly higher than regional averages. On a majority of these days, sixteen, Ch ester’s surface winds had strong easterly components. Chester’s PM 10 and sulfur dioxide levels were also significantly higher than Norristown and Bristol on these days. Th ese values are summarized in Table 7.

Quarterly PM 2.5 Concentration Analysis

Regional 2001-03 annual design values we re influenced by unusually high PM 2.5 concentrations during the firs t quarter of 2001 (Table 8). Quarterly averages were well
above normal across the Commonwealth. The cau se of this anomaly is not known but is probably not due to sources solely w ithin the five-county Philadelphia region.

Table 7.

Nineteen-Day Summary Chester/Bristol/Norristown

Date Chester Bristol Norristown Chester Bristol Norristown Chester Bristol Norristown Chester Bristol Norristown

9/12/03 53 22 18 10 4 0 81 45 104 8.5 7.3 4.4

12/14/03 58 7 5 8 11 1 119 102 107 8.8 5.5 2.7

4/18/03 49 23 23 1 0 1 87 313 111 9.5 9.0 5.0

3/19/03 33 23 26 2 5 0 103 274 126 11.6 9.0 7.5

2/26/03 36 13 15 7 9 11 74 34 93 6.6 4.3 3.2

1/3/03 19 7 5 9 17 9 75 62 7.2 7.5

10/29/02 27 12 10 5 15 1 81 46 146 6.0 2.8 1.8

4/9/03 26 10 9 6 6 2 32 326 64 6.9 5.4 3.1

11/16/02 26 13 11 10 8 3 55 51 93 5.9 6.3 4.3

9/18/03 44 21 19 13 3 1 72 67 94 11.4 11.3 6.4

11/5/03 23 13 10 3 8 2 113 82 145 4.4 2.8 1.3

1/19/01 23 11 8 11 12 3 91 57 175 4.1 0.6 1.7

3/5/01 18 6 5 7 6 4 225 208 232 8.2 0.7 4.3

4/16/01 24 11 10 6 1 195 195 209 5.7 4.6 4.3

9/9/03 27 16 14 3 1 0 82 54 103 9.2 5.7 3.9

9/26/02 35 13 11 4 8 0 52 41 78 5.9 4.3 2.4

9/3/03 22 11 11 3 2 0 93 77 123 4.9 3.1 2.8

10/11/02 20 5 5 2 11 0 94 58 100 7.2 4.6 3.8

7/17/03 22 21 16 4 5 2 293 281 322 5.4 2.5 3.7 PM-10 SO2 VWD SWS14 Table 8.

Statewide/SE PA Quarterly PM 2.5 Statistics

Summary

EPA’s designation proposal expands the Ph iladelphia nonattainment area to include Bucks and Montgomery counties. EPA us ed an analysis of 2001-03 regional PM 2.5 annual design values, a weighted emissions anal ysis, an analysis of population density, an analysis of population growth and an analysis of commuting patterns as the basis for the expansion.

The Pennsylvania DEP disagrees with EPA’s proposed PM 2.5 designation for Philadelphia nonattainment area. EPA’s expans ion of the area will include a number of
counties that are a ttaining the annual PM 2.5 standard. As shown in Appendix III, Figures 6 and 7, attainment is monitored at all si tes downwind of ”Cente r City” and Northeast Philadelphia. Also, a number of flaws with EPA’s analysis supporting expansion of the Philadelphia nonattainment area have been identified. EPA’s methodology does not establish a definitive relationship between countywide emissions and the region’s design value monitor. In addition, it appears that EPA did not take into account the level of controls in the five-county Philade lphia region that have reduced NO
x and VOC emissions by 35% even as the region’s popula tion has increased by half a million people
since 1980.

A review of monitoring data in the five-count y Philadelphia region indicates the region’s peak monitor, Chester, is being adversely affected by local sources. Unusually high quarterly PM 2.5 concentrations in the 1 st Quarter of 2001 have also affected regional design values. This anomaly was observed across the Commonwealth making it unlikely that sources in the five-county Philadelphia region were solely responsible. Both of these
observations indicate th e Philadelphia regions PM 2.5 nonattainment problem is more local in scope and expanding the nonattainment area to include Bucks and Montgomery counties will not help the region attain the annual PM 2.5 standard. Avg StDev Max Min >15.0 Sites Bris Ches BEL-F ELM-FD LAB-FD NEA-F ROX-F SOA-F VET-F Norr NewG 1st Q 2001 15.6 2.328 21.3 11.9 22 41 15.18 17.40 16.93 19.11 18.70 16.48 15.60 2nd Q 2001 16.5 2.278 25.6 13.0 32 41 15.28 17.63 15.57 16.85 16.05 14.53 15.17 3rd Q 2001 17.2 2.155 25.6 13.5 36 41 13.87 16.37 16.41 16.29 16.18 15.34 16.94 4th Q 2001 13.2 1.949 21.4 10.4 5 41 13.99 12.47 12.57 14.67 15.12 12.31 12.70 1st Q 2002 12.6 1.813 18.3 9.2 4 43 14.29 13.23 12.67 13.81 14.21 12.71 13.44 12.87 13.83 2nd Q 2002 14.5 1.931 22.1 11.4 17 44 12.23 14.16 13.44 13.61 12.81 12.73 13.63 14.73 12.85 13.32 3rd Q 2002 18.5 2.457 25.2 13.5 41 44 15.20 16.00 15.30 15.90 17.00 14.90 14.30 22.00 15.40 17.20 4th Q 2002 12.7 2.097 18.2 8.6 6 44 14.84 15.15 13.81 12.74 13.51 14.47 14.58 11.32 13.83 14.60 1st Q 2003 14.8 2.042 20.7 10.0 21 43 15.13 16.61 13.79 16.13 16.70 13.05 11.95 14.84 16.98 2nd Q 2003 14.6 1.592 19.5 11.8 12 42 14.28 16.18 13.61 13.27 13.64 12.36 14.52 13.60 15.41 3rd Q 2003 17.8 2.303 23.0 14.5 40 42 15.47 17.19 16.06 14.52 15.60 16.36 15.08 15.58 16.48 4th Q 2003 12.3 2.198 21.3 9.0 3 42 13.13 12.99 11.58 12.05 13.33 10.98 11.55 11.75 13.4115 PITTSBURGH AREA

In the June 29, 2004 letter, EPA proposed to expand the Pittsburgh nonattainment area to include eight counties: Allegheny, B eaver, Butler, Westmoreland, Washington, Armstrong, Greene and Lawrence. Pennsylvania recommends that this area be limited to Allegheny, Beaver, Westmoreland and Washingt on counties. In addition, Pennsylvania strongly recommends the creation of two nonatta inment areas within the Pittsburgh area based on strong evidence of a localized problem affecting each of these monitors. These
two locations are the area surrounding the Libe rty monitor and th e area surrounding the North Braddock monitor. An analysis of the monitoring data shows that these two monitors correlate poorly with the other monitors sited in the region.

EPA’s Analysis in Support of an Expanded Nonattainment Area

Technical justifications for expanding the Pittsburgh PM 2.5 nonattainment area were
included in Enclosure B of EP A’s June 29, 2004 letter sent to Pennsylvania. EPA used
nine criteria to determine which counties should be included in the Pittsburgh
nonattainment area. These crit eria included emissions, air quality, population, traffic and commuting patterns, expected growth, mete orology, geography/topogr aphy, jurisdictional boundaries, and level of emission controls.

EPA placed a high emphasis on the weighted em issions score in its supporting document. EPA concluded its weighted emissions analys is showed Butler Count y and three adjacent counties, Armstrong, Greene and Lawrence, si gnificantly contribute to the region’s nonattainment problem. Additional analysis factors including population density, growth and commuting, were also cited in support for expanding the Pittsburgh nonattainment
area to include these counties.

Pennsylvania Recommends the Creati on of Two Separate and Smaller Nonattainment Areas within the Larger Proposed Pittsburgh Nonattainment Area

Figure 8 shows a display of the PM 2.5 monitor locations in EPA’s proposed Pittsburgh
nonattainment area. Take note of the thr ee monitor names with the blue background. The three monitors in questi on are the Clairton, Liberty and North Braddock. These three monitors have the highest PM 2.5 design values in the proposed area, as can be seen on Figure 9. The Liberty monitor has the highest design value in the entire Northeastern US at 21.2 μg/m 3 . The Clairton monitor at 17.3 μg/m 3 and the North Braddock monitor at 16.9 μg/m 3 are the next highest desi gn values in the region and have values at least 1 μg/m 3 higher than the next highest in the proposed nonattainment area (Harrison at 15.9 μg/m 3 ). PM 2.5 concentrations of monitors surroun ding the three liste d above show only levels at or slightly above the 15.0 μg/m 3 standard. After further evaluation of the data, we have concluded that the resulting design va lues at each of the three high monitors
indicated above are due to local influe nces. Consequently, Pennsylvania is recommending that two additional, smaller nonattainment areas inside of the bigger Pittsburgh nonattainment area be established. These areas will consist of the five16 municipalities in the Liberty area and the tw o municipalities in the North Braddock area, as shown in Figure 10.

Liberty

The proposed Liberty nonattainment area consists of five municipali ties (City of Clairton, Borough of Glassport, Liberty Borough, Bo rough of Lincoln, and Port Vue Borough).
This area consists of the same five muni cipalities designated by the US EPA and thus
codified in 40 CFR Part 81 on November 6, 1991 for being in nonattainment of the PM 10 24-hour and annual standards. This area incl udes the Total Suspended Particulate (TSP) nonattainment area #8 designated in 1981. It was not yet redesignated when the PM 10 standards replaced the TSP standards in 1987.

The complexity of the largest metallurgical c oke plant in the United States contributes a combination of particulates, sulfur dioxide , ammonia, and literally hundreds of volatile organic chemicals, in an atmosphere actually created by this large plant – high humidity, gases and materials discharged at temperat ures well above 1000 degrees. Due to the complexity of this local area, the PM 10 State Implementation Plan (SIP) required the development of a hybrid model. The PM 10 standards were met beginning in 1998, and the area redesignated in 2003.

The Liberty area will include bot h the Clairton (in the City of Clairton) and Liberty (in Liberty Borough) PM 2.5 monitors. An analysis was comp leted to help demonstrate that local influences are having an effect on the PM 2.5 concentrations measured at each one of the monitors. Pennsylvania completed a cont ribution assessment analysis to try to
characterize in what concentra tion range most of the contri bution to the design value is occurring.

An analysis of the data for the Libert y area revealed the following contribution assessment (expressed in PM 2.5 in μg/m 3 ).

Site Name 0-7.5 7.5-15 15-22.5 22.5-30 30-37.5 37.5-45 45-52.5 52.5-60 60-67.5 67.5-75 Sum

Liberty -1.2230 -1.2147 0.6456 1.4657 1.6840 1.1766 1.4001 0.8007 0.6910 0.7319 6.16

The design value for each day was placed in on e of the categories above. For example, on January 1, 2003, the PM 2.5 measured at Liberty was 5.6 μg/m 3 . Since this value falls in between 0-7.5 in the above chart, the type of contribution this da ily value had on the 3- year design value (by compar ing this value to 15 μg/m 3 , the current annual standard for

PM 2.5 ) was determined. Since there were 86 me asurements recorded at Liberty between January 1 and March 31, 2003 and knowing there are 12 quarters (12 3-month periods) in order to calculate the 3-year design value, th e Department determined that the January 1,
2003 contribution assessment to the 2003 design value was –0.00911 μg/m 3 . If this type of analysis is completed for every day of measurements from January 1, 2001 through December 31, 2003, the values set forth in the above table will be derived. The sum of
all values in the above table equals 6.16 μg/m 3 , which shows that the design value should be 6.16 μg/m 3 above 15 μg/m 3 . See Figure 9 for verification.17 Subsequently, this contribution assessment an alysis was completed for every site in the proposed Pittsburgh nonattainment area. Th e contribution assessm ent average for all sites, not including the Libert y, Clairton, and North Braddock monitors is set forth below:

Site Name 0-7.5 7.5-15 15-22.5 22.5-30 30-37.5 37.5-45 45-52.5 52.5-60 60-67.5 67.5-75 Sum

All Sites -1.6630 -1.6763 0.7806 0.8994 0.7594 0.3327 0.2024 0.2752 0.0174 0.0000 -0.07

For comparison, the results from Liberty analysis are shown again as follows:

Site Name 0-7.5 7.5-15 15-22.5 22.5-30 30-37.5 37.5-45 45-52.5 52.5-60 60-67.5 67.5-75 Sum

Liberty -1.2230 -1.2147 0.6456 1.4657 1.6840 1.1766 1.4001 0.8007 0.6910 0.7319 6.16

These data show the following:

1. The heavy contribution of Libe rty’s design value from 22.5 μg/m 3 and up as is significantly larger than the regional average. 2. There are a lot more days when th e regional concentration is at 15 μg/m 3 as compared with the Liberty monitor. 3. The regional average sum shows that the regional values have a negative impact on the design value, which, in turn, would allow the monitor to be below the 15 μg/m 3 annual threshold.

The main question remains: Why is the Libert y monitor so much higher than the regional average? Graph 2 below shows Liberty’ s categorical breakdown, compared with Clairton, North Braddock and the regional aver age. As can be seen from the above analysis and Graph 2, the answers sh ould lie in the range of 22.5 μg/m 3 and higher range
of concentrations. The remainder of the c ontribution assessment analysis will focus on the higher range of concentrations.18 Graph 2

The Department also completed a day-to -day comparison of actual measured PM 2.5 concentrations at Liberty to the regional aver age. This range was selected to focus on the Liberty’s values that were considerably hi gher than the regional av erage to in order to determine what was contributing to Liberty’s high values. The day-to-day variance in
standard deviation was determined and the dail y difference in the Libe rty value to that of the region was also calculated. The analysis also evaluated a certain number of days set to the criteria above (days where Liberty was at least one standard deviation greater than the regional average) and days when the regional levels were above 15 μg/m 3 and the Liberty values were above 22.5 μg/m 3

.

In addition, the meteorology that was occurri ng at the monitor was also examined. The Liberty monitor measures meteorological parameters, including wind speed and wind direction. In fact, Figure 11 shows a wind ro se at the Liberty monitor from January 1, 2001 through December 31, 2003. The daily aver age wind direction over the three-year period was compared to those values with the daily PM 2.5 concentrations at the Liberty monitor. Subsequently, this wind data was linked to the corresponding high days for Liberty as compared with the regional aver age. Based on the Department’s analysis, there were over 200 days during the three- y ear period where the Liberty concentrations
were at least one standard devi ation over the regional average. It is important to note that samples are taken at Liberty every day (1 in 1 monitor). However, the wind analysis on the top 50 days (top 25% of the 200 days) with regards to the days being ranked from highest to lowest with respect to the difference of Liberty’s concentration to the rest of the region. Figure 12 shows the wind directi ons for these top 50 days plotted in a geographic information system (GIS) applicati on. On more than 80% of the days, the19 wind flow from the southwest, flowing right over top an industrial source is observed. This source is a possibl e contributor to the PM 2.5 problem being experienced in Liberty, with the following emissions (direct PM emissions from filterable and condensable
measurements and SO 2 and NOx emissions that form sulfates and nitrates, constituents in secondary PM 2.5 formation):

Source Name Inventory Year NO2 PM2.5 PM10 PT PM
Cond SO2 Liberty Area Industrial Source 2002 5764.22 319.04 740.52 2461.20 109.06 1251.56

In November 1999, the Allegheny County Health Department (ACHD) began conducting
continuous PM 2.5 sampling at the Liberty monitor. Back in October 2003, the ACHD began conducting speciation monitoring at the Liberty monitor (a monitor which was moved from the Hazlewood monitoring location) . An analysis was completed with the eight months (October 2003 thr ough May 2004) of data that cu rrently exists for Liberty monitor and then compared with other region al urban and rural sites. In fact, the PM 2.5 being measured at the Liberty monitor is unique since it is unlik e any other urban and
rural PM 2.5 monitor. The details of the analysis are below.

First, we examined the PM 2.5 continuous data from multiple monitoring locations across
the Mid-Atlantic into the Northeast. We were able to look at the 2002 average diurnal cycle of PM 2.5 at each of those monitors. Graph 3 displays the result.

Graph 3

The black line (with the white circles) displays the plot for the Libe rty monitor. All of
the other monitors are labe led on the right with their respective AIRS code as designation. The analysis immediately shows th at the diurnal cycle displayed at Liberty is unlike that displayed at other monitore d locations. The average difference between nighttime Liberty measurements and the other monitors’ measurements is on the order of 10 to 15 μg/m 3 higher. This is mainly because of the river valley that encompasses the20 Liberty monitor. The higher peaks in th e overnight hours are likely a result of a meteorological phenomenon known as an inversion. An inversion sets up as a result of high pressure positioned over the area or clear nights allowing the radiational cooling of
the earth’s surface. When these inversions form, vertical mixing of air masses ceases. Since the cool air is displaced below the warmer air, the air will be unable to rise. In air quality terms, the PM 2.5 concentrations will be concentrat ed near the surface. A local emission source, such as that seen in Figur e 12, will then play an even bigger role in affecting air quality since most of the emi ssion sources at the facility are unable to penetrate the inversion, thus rema ining trapped near the surface.

The second part of our analysis dea lt with the speciated components of PM 2.5 at the Liberty monitor compared with values at the ACHD operated Lawrenceville monitor. Only utilizing the data from October 2003 to May 2004, we were able to create graphs displaying the distribution of the major components of PM 2.5 (sulfates, nitrates, carbons and ammonium). The Lawrenceville monitor is placed in a more urban environment than the Liberty monitor.

Our analysis first focused on the sulfates and ni trates. For the most part, the sulfates and nitrates matched up pretty well, as can be see in Graph 4 for sulfates and Graph 5 for
nitrates.

Graph 421 Graph 5

These speciated values are fairly consistent with the sulfates and nitrates experienced across the other regional speciated monitors.

The second part of our speciated analysis cons isted of carbon (element al and organic) and ammonium. Overall, vast differences be tween the Liberty and Lawrenceville were monitored. Graph 6 displays the elementa l carbon, Graph 7 shows the organic carbon, and Graph 8 shows the ammonium.

Graph 622 Graph 7

Graph 8

The three graphs above display the varia tion of the carbon and ammonium portion of

PM 2.5 . On the days when the Liberty mon itor was high, the ammonium, organic and elemental carbon peak to levels higher than the Lawrenceville mon itor. These graphs display that there is some sort of local phenomenon (most likely a local emission source) that is influencing the PM 2.5 concentrations being reporte d at the Liberty monitor.23 Therefore, we strongly recommend that the proposed Liberty area be designated as a separate PM 2.5 nonattainment area. Local influences, such as those from the industrial source labeled above, are contributing to the additional PM 2.5 being measured at the Liberty monitor.

North Braddock

The proposed North Braddock nonattainment area consists of two municipalities (Braddock Borough and North Braddock Bor ough). The proposed North Braddock area includes the TSP nonattainment area designa ted as area #6 in 1981. It was not yet redesignated when the PM 10 standards replaced the TSP standards in 1987. It was also listed as a Group II PM 10 area in 1987, “where attainme nt of the PM10 NAAQS is uncertain,” likely due to th e emission of the local stee l plant. A Group II area SIP was submitted in 1988. The primary source of emissions in this area is a steel plant that is
sited on a riverfront and affects the comm unities along the river and up the hillside.

The North Braddock area will include the North Braddock (in North Braddock Borough)

PM 2.5 monitor. The analysis that the Departme nt has completed demonstrates that local influences are having an effect on the PM 2.5 concentrations measured at each one of the monitors. Pennsylvania completed a contribu tion assessment analysis to characterize in what concentration range most of the contribution to the design value is occurring.

The Department initially evaluated data fo r the North Braddock area and observed the following contribution asse ssment expressed in PM 2.5 in μg/m 3 ).

Site Name 0-7.5 7.5-15 15-22.5 22.5-30 30-37.5 37.5-45 45-52.5 52.5-60 60-67.5 67.5-75 Sum

North
Braddock -1.2247 -1.3675 1.0383 1.2770 0.9955 0.5594 0.2116 0.2683 0.1497 0.0000 1.91

The design value for each day is included in one of the above categories. For example, on January 4, 2003, the PM 2.5 measured at North Braddock was 11.7 μg/m 3 . Since this value falls in between 0-7.5 in the above chart, the type of contribution this daily value had on the 3-year design value (by comparing this value to 15 μg/m 3 , the current annual
standard for PM 2.5 ) was calculated. Since there were 20 measurements recorded at North Braddock between January 1 and March 31, 2003 and knowing there are 12 quarters (12 3-month periods) in order to calculate th e 3-year design value, the Department determined that the January 4, 2003 cont ribution assessment to the 2001-2003 design value was –0.01375 μg/m 3 . If this type of analysis is completed for every day of measurements from January 1, 2001 through D ecember 31, 2003, the values set forth in
the above table will be achieved. The sum of all values in the above table equals 1.91 μg/m 3 , which shows that the design value should be 1.91 μg/m 3 above 15 μg/m 3 . See Figure 9 for verification.

The Department also completed this contributio n assessment analysis for every site in the proposed Pittsburgh nonattainment area. Th e contribution assessm ent average for all sites, not including the Libert y, Clairton, and North Braddock monitors is set forth below:24 Site Name 0-7.5 7.5-15 15-22.5 22.5-30 30-37.5 37.5-45 45-52.5 52.5-60 60-67.5 67.5-75 Sum

All Sites -1.6630 -1.6763 0.7806 0.8994 0.7594 0.3327 0.2024 0.2752 0.0174 0.0000 -0.07

The following results from North Braddock anal ysis are provided below for comparison

purposes.

Site Name 0-7.5 7.5-15 15-22.5 22.5-30 30-37.5 37.5-45 45-52.5 52.5-60 60-67.5 67.5-75 Sum

North
Braddock -1.2247 -1.3675 1.0383 1.2770 0.9955 0.5594 0.2116 0.2683 0.1497 0.0000 1.91

Based on the data in these two tables the following should be noted:

1. The heavy contribution of North Braddock’s design value from 15 μg/m 3 through to 45 μg/m 3 as compared to regional average. 2. There are a lot more days when th e regional concentration is at 15 μg/m 3 as compared with the Liberty monitor. 3. The regional average sum shows that the regional values have a negative impact on the design value, which, in turn, would allow the monitor to be below the 15 μg/m 3 annual threshold.

The main question remains: Why is the Nort h Braddock monitor so much higher than the regional average? Graph 2 (in the Liberty section) shows North Braddock’s categorical breakdown, compared with Clairt on, Liberty and the regional av erage. As can be seen from the above analysis and Graph 2, the an swers should lie in th e range of 15 and 45 μg/m 3 concentrations. The remainder of the contribution assessment analysis will focus in the 15 – 45 μg/m 3 range.

The Department also completed a day-to -day comparison of actual measured PM 2.5 concentrations at North Braddock to the regional average. The range of North Braddock’s values that were considerably higher than the regional average were evaluated to determine, if possible, the factors contribu ting to North Braddock’s high values. During this analysis the day-to-day variance in standard deviation and the daily difference in the North Braddock value to that of the region were determined. Subsequently, an analysis on a certain number of days set to the criteria above (days
where North Braddock was at l east one standard deviation greater than the regional average) was considered as well as the da ys when the regional levels were above 15 μg/m 3 and the Liberty values ranged from 15 to 45 μg/m 3

.

The Department also evaluated the meteorological conditions occurring at the monitor.
The North Braddock monitor used to measur e meteorological parameters, including wind speed and wind direction, between 1990 and 2000. For this portion of the analysis, the Department considered two of the years: 1999 and 2000 since both of these years have measured PM 2.5 and meteorological paramete rs. Figure 13 shows a wind rose at the North Braddock monitor from January 1, 1999 through December 31, 2000. The general wind flow through the river valley should be noted. There is a substantial amount of wind flow from the northwest and again out of the southeast. The Department calculated25 the daily average wind direction over the thr ee-year period and compared those values with the daily PM 2.5 concentrations at the Liberty. This wind data was linked to corresponding high days for Liberty as compar ed with the regional average. Based on the analysis, there were 45 days during the two-year period where the Liberty
concentrations were at least one standard deviation over th e regional average. It is important to note that samples are taken at Li berty every third day (1 in 3 monitor). Therefore, the wind analysis is based on the top 12 days (top 25% of the 45 days) with regards to the days being ranked from highest to lowest with respect to the difference of Liberty’s concentration to the rest of the region. Figure 14 shows th e wind directions for these top 12 days plotted in a GIS application. On more th an 80% of the days, the wind flow from the southeast, flow ing right over top an industria l source is observed. This source is a possible c ontributor to the PM 2.5 problem being experienced in North Braddock, with the following emissions (direct PM emissions from filterable and
condensable measurements and SO 2 and NOx emissions that fo rm sulfates and nitrates, constituents in secondary PM 2.5 formation):

Source Name Inventory
Year NO2 PM2.5 PM10 PT PMCond SO2

North Braddock Industrial Source 2002 298.17 291.23 359.47 494.71 671.03 1356.49

Unfortunately, the North Braddock monitor lacks continuous and speciated monitored data so that the same type of comparison, as was concluded with the Liberty monitor above, cannot be completed. The Department feels that if the c ontinuous and speciated data were to exist, it would show a similar re sult as that displayed at the Liberty monitor.

Based on this analysis, the proposed North Br addock area should be designated as a separate PM 2.5 Nonattainment area. Local influences , such as those from the industrial source labeled above, are contributing to the additional PM 2.5 being measured at the
North Braddock monitor.

Pennsylvania’s Additional Comme nts Regarding EPA’s Analysis

Greene County. Greene County is adjacent to the Pittsburgh MSA. Greene County is a rural, non-industrial county with very lo w population data and VMT. Emissions from Greene County are dominated by a single pow er plant, Allegheny Energy Supply’s Hatfield’s Ferry Power Station that is e quipped with low NOx cell burners and ESPs. One of the units has rotating over-fire air a nd selective non-cataly tic reducer (SNCR). Emissions from this single facility account for 99.5% of the county’s SO 2 emissions and 86.1% of the NOx emissions. This plant will also be subject to the Best Available Retrofit Technology (BART) requirement under th e regional haze program. As discussed previously, Pennsylvania believes that a nati onal or regional multi-pollutant rule is the appropriate mechanism to address emissions from large point sources. Adding Greene County to the Pittsburgh nonattainment area is not a logical or efficient way to address the emissions from the county’s power plan t. Pennsylvania recommends that EPA designate Greene County as attainment.26 Butler County. Butler County contains no significan t sources of emissions. Therefore,
it does not contribute to the PM 2.5 nonattainment levels monitored elsewhere in the Pittsburgh MSA. Based on monitored PM 2.5 levels in similar non-urban, non-industrial counties, there is no reasonable basis to conclude that this county should be nonattainment. Figure 9 demonstrates monitore d attainment in the adjacent counties of Mercer and Indiana. In addition adjacent monitors in Allegheny County also show attainment. After reviewing EPA’s weighted emissions scoring data for the Pittsburgh Area, it is apparent that Butler County scor es very low in EPA’s own emission-weighting scheme. Additionally, the county has low popul ation density and VMT. Based on all of these factors, DEP remains convinced that it is inappropriate to designate Butler as
nonattainment for the PM 2.5 standard.

Armstrong County. Armstrong County was not include d in the Pittsburgh MSA as defined by OMB in the June 30, 1999 definitions. It was added to the Pittsburgh MSA in the June 2003 OMB report. Armstrong C ounty has very low population density and VMT. County population is projected to dec line substantially over the next decade. In addition, DEP has collected monitoring data from a TEOM monitor in the Kittanning area. This monitor averaged 14.3 ug/m 3 (2001 – 2003 data) demonstrating that the county has PM 2.5 levels that achieve the standa rd. Armstrong County does have
substantial emissions of sulfur dioxide (SO 2 ) and nitrogen oxides (NOx). However, virtually all (99.8 % of the SO 2 and 86.4% of the NOx) of these emissions can be attributed to the county’s two large po wer plants, Armstrong and Keystone. The Armstrong plant is equipped with rotating ove r-fire air, ESPs and low NOx burners. The larger of these two plants, Keystone, is located on Armstrong County’s eastern border and is equipped with SCR on both units to reduce emissions of nitrogen oxides. An examination of the wind rose from Pittsburgh supports the conclusi on that these emission sources would have virtually no impact on th e monitors in the Pittsburgh area that are monitoring nonattainment of the PM 2.5 standard. In addition, it has long been Pennsylvania’s position that it is imperative that emissions from large point sources including power plants, be addressed through a consistent national or regional control program. EPA’s recently proposed CAIR w ould be an appropriate mechanism for addressing these emissions provided more st ringent emission caps and timely compliance schedules are promulgated.

Examining EPA’s weighted emissions scor ing process for Armstrong and Washington
demonstrates that absurd conclusions can be drawn from EPA’s ranking process. Washington County rates a weighted emi ssions score of 10.6. Depending on the “cut point” chosen, this would normally indicate th at based on emissions this county could be
excluded from the nonattainment area. Ar mstrong County had a weighted emissions score of 60.6 making it higher than Alleghe ny County, where the major nonattainment values exist. The problem is, interestingly, that Armstr ong County monitors attainment while Washington County, with a five-fold lo wer weighted emissions score, monitors nonattainment. Clearly, the recently develope d weighed emissions scoring rating process must be employed with extreme caution or merely disregarded.27 Lawrence County. Lawrence County was not included in the Pittsburgh MSA in the June 30, 1999 OMB definitions. OMB’s June 10, 2003 report added Lawrence County to the Pittsburgh MSA. For ozone, Lawrence C ounty has historically been a stand-alone planning area not included in the Pitts burgh nonattainment area. Lawrence County has relatively low and declining population density. Lawrence County also has relatively low
emissions and the bulk of the SO 2 emission (81%) would be addressed by EPA’s proposed CAIR provided more stringent emi ssion caps and timely compliance schedules are promulgated. These emissions are from the older, small New Castle power plant located in the county and covered by BART. All three of the units at the plant are controlled by SNCR and ESPs. Based on a re view of the available data, DEP believes
that attainment is the correct designation for Lawrence County.

READING AREA

Pennsylvania concurs with EPA’s proposed nonattainment designation for Berks County.

YORK AREA

There is a discrepancy in the York PM 2.5 annual design value. EP A’s analysis indicates the 2001-03-design value is 17.3 μ g/m 3 . Our analysis indicate s York’s design value is slightly lower, 17.1 μ g/m 3

.

Pennsylvania concurs with EPA’s proposed nonattainment designation for York County.

YOUNGSTOWN AREA

On June 29, 2004 EPA released their intended PM 2.5 designations for Pennsylvania. EPA expanded the Youngstown, Ohio nonattainment to include Mercer County. Three other Ohio counties, Columbiana, Mahoning and Tr umbull, were included in the Youngstown nonattainment area. The design monitor fo r the Youngstown nonatta inment area is in Mahoning County and has an annual PM 2.5 design value of 15.2 μ g/m 3 . EPA’s report lists Mercer County’s design value as 14.3 μ g/m 3 . Pennsylvania’s records indicate Mercer County’s design value is slightly lower at 14.2 μ g/m 3

.

EPA’s Analysis in Support of an Expanded Nonattainment Area

EPA noted a couple of factors supporting the addition of Merc er County into the Youngstown nonattainment area. The first wa s the inclusion of Mercer County in the
2003 MSA. Additional factors include mode rate contributions from population and commuting.

Pennsylvania’s Comments Regarding EPA’s Analysis

Mercer County should not be included in the Youngstown nonattainment area. The following comments to EPA’s analysis:28 Youngstown MSA: EPA’s primary reason for including Mercer County in the Youngstown nonattainment area was its incl usion in the Youngstown MSA. MSA boundaries were not restricting factors in other nonattainment areas in Pennsylvania. This application appears inconsistent.

Monitored Values: The Mercer County monitor is well below the annual PM 2.5 standard. Placing a county that’s monitoring attainment into a nonattainment area will
cause difficulties in communication and em ission control program implementation. Local officials and citizens will question the legitimacy of imposing control measures on an area that is attaining the st andard and has not been shown definitely to be contributing to a nonattainment problem.

Mercer County Emissions: Emissions from Mercer Count y are significantly less than the emissions of either Trumball or Mahoning c ounties. The same is true for Columbiana County in Ohio. In fact, the combined emi ssions of Mercer and Columbiana counties are well below the emissions of either Trumball or Mahoning counties. Emissions from Mercer County will have little or no effect on the design monitor since predominant winds place the county downwind of the Youngstown region.

Mercer County’s Population: Mercer County’s population trends do not support adding this Pennsylvania county to the Youngs town nonattainment area. Census figures indicate the county’s populat ion has decreased over the last 20 years, though numbers
seem to have stabilized in the 1990s.

Mercer County VMT: Mercer County’s VMT is approxi mately half of either Mahoning or Trumbull counties. Demographics show Mercer County’s work-age population (15-64 year olds) has decreased by 1.5% between 1990 and 2000. This should place a ceiling on future VMT, if it is directly related.