Technical Support Document (TSD) for the Base Year Inventory for the North Reading, Berks County, 2008 LeadNAAQS Nonattainment Area

SubmittedAugust 2015 by the PennsylvaniaDepartment ofEnvironmental Protection
TSD Prepared October 2015 by Jessica L. Fry Office ofAirMonitoring and Analysis, 3AP40 U.S. Environmental Protection Agency, Region 3 1650 Arch Street Philadelphia, Pennsylvania 19103

Reviewed by Alice H. Chow, Associate Director Office ofAirMonitoring and Analysis (3AP40)

### I. Introduction
The purpose ofthis document is to provide a technical summary ofthe Office ofAir Monitoring and Analysis (OAMA) review ofthe emissions inventories submitted with the Pennsylvania State Implementation Plan (SIP) Revision: Attainment Demonstration and Base Year Inventory, North ReadingNonattainment Area (NAA), Berks County for the 2008 LeadNAAQS. Underthe Clean Air Act (CAA) sections 172(c)(3) states are required to submit emissions inventory information for all relevant sources for the areas that are designated nonattainment. The Pennsylvania Department ofEnvironmental Protection (PADEP) has submitted a 2010 Base Year Inventory for the North Reading 2008 Lead NAAQS Nonattainment Area in order to fulfill the CAA requirements. Any questions pertaining to this technical summary should be directed to Alice H. Chow, Associate Director, Office ofAir Monitoring and Analysis, at 215-814-2144 orvia email at chow.alice@epa.gov.


### II 2010 Base Year Inventory
Under section 172(c)(3) states are required to submit a comprehensive, accurate, current accounting ofactual emissions from all sources (point, nonpoint, nomoad, and omoad) in the nonattainment area. This inventory contains actual annual emissions of lead

. The base year inventory (typically one ofthe years in which the area was designated for the standard) includes emissions estimates from stationary point and nonpoint sources. There are no omoad and nomoad source emissions in the NAA, mainly due to the ban on leaded gasoline in highway vehicles. Another source ofmobile lead emissions are airports and landing strips. The NAA does not contain any ofthese sources. The areas in Berks County that are included in the NAA are Laureldale Borough, Muhlenberg Township, and Alsace Township.
PADEP submitted a 2010 inventory for the point sources in the NAA. EPA guidance for emissions inventory developmentprovides that actual emissions should be used for purposes ofthe base year inventory. There are two sources oflead emissions in the NAA, Exide Technologies and Yuasa Battery, Inc. PADEP requires larger emitting facilities to report production figures and emission calculations annually. Throughput data are multiplied by emission factors based on source classification codes (SCC) to develop emission estimates.
For the nonpoint source emissions, also known as "area sources," PADEP submitted EPA's 2011 NEI v2 as a surrogate for the 2010 inventory. To calculate nonpoint values for the portion ofBerks County included in the NAA, PADEP used county data apportioned bypopulation, ofwhich 6.6% ofthe population ofBerks County is included in the NAA. The nonpoint source emissions are insignificant when compared to the point source emissions inthe NAA. After reviewing the nonpoint emissions, EPA found the use ofthe NEI acceptable.
OAMA staffreviewed the results, procedures, and methodologies for the SIP base year, and found them to be acceptable.