Technical Support Document (TSD) for the 

Base Year Inventory for the 

North Reading, Berks County, 2008 Lead NAAQS Nonattainment Area 

Submitted August 2015 by the 

Pennsylvania Department of Environmental Protection 

TSD Prepared October 2015 by 

Jessica L. Fry 

Office of Air Monitoring and Analysis, 3AP40 

U.S. Environmental Protection Agency, Region 3 

1650 Arch Street 

Philadelphia, Pennsylvania 19103 

Reviewed by Alice H. Chow, Associate Director 

Office of Air Monitoring and Analysis (3AP40) 
I. Introduction 

The purpose of this document is to provide a technical summary of the Office of Air 

Monitoring and Analysis (OAMA) review of the emissions inventories submitted with 

the Pennsylvania State Implementation Plan (SIP) Revision: Attainment Demonstration 

and Base Year Inventory, North Reading Nonattainment Area (NAA), Berks County for 

the 2008 Lead NAAQS. Under the 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 of Environmental 

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 of Air Monitoring and Analysis, at 215-814-2144 or via 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 of actual 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 of the 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 of mobile lead 

emissions are airports and landing strips. The NAA does not contain any of these 

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 development provides that actual emissions should be 

used for purposes of the base year inventory. There are two sources oflead emissions in 

the NAA, Exide Technologies and Yuasa Battery, Inc. P ADEP 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 of Berks County included in the NAA, P ADEP used 

county data apportioned by population, of which 6.6% of the population of Berks County 

is included in the NAA. The nonpoint source emissions are insignificant when compared 

to the point source emissions in the NAA. After reviewing the nonpoint emissions, EPA 

found the use of the NEI acceptable. 

OAMA staff reviewed the results, procedures, and methodologies for the SIP base 

year, and found them to be acceptable.