Technical SupportDocument (TSD) for the Base Year Inventory Forthe Lyons 2008 LeadNAAQS NonattainmentArea

Submitted December 2014 by the PennsylvaniaDepartment ofEnvironmental Protection

TSD Prepared April 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 atechnical summary ofthe Office ofAir Monitoring and Analysis (OAMA) review ofthe emissions inventories submitted with the Pennsylvania State ImplementationPlan (SIP) Revision: Attainment Demonstration and Base Year Inventory, Lyons Nonattainment Area (NAA) 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 PennsylvaniaDepartment ofEnvironmental Protection (PADEP) has submitted a 2011 Base Year Inventory for the Lyons 2008 LeadNAAQS Nonattainment Area in orderto fulfill the CAArequirements. Any questions pertainingto this technical summary shouldbe directedto Alice H. Chow, Associate Director, Office ofAir Monitoring and Analysis, at 215-814-2144 or via email at chow.alice@epa.gov.

II 2011 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, nonroad, and onroad) 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 as attaining the standard) includes emissions estimates from stationary point and nonpoint sources. There are no onroad and nonroad 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. TheNAA does not contain any ofthese
sources. The areas in Berks County that are included in the NAA are Kutztown Borough, Lyon Borough, Maxatawny Township, and Richmond Township.

PADEP submitted a 2011 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 three sources ofleademissions in the NAA, the East PennManufacturing Company's Richmond Township Facility, the East Penn Manufacturing Company's Kutztown Facility and McConway &Torley Kutztown Foundry. 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.

Forthe nonpoint source emissions, also known as "area sources," PADEP submitted EPA's 2011 NEI v2. To calculate nonpoint values for the portion ofBerks County included intheNAA, PADEP used county data apportioned by population, of which 4.1% ofthe population ofBerks County is included in the NAA.

OAMA staffreviewed the results, procedures, and methodologies for the SIP base year, and found themto be acceptable.