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Technical Support Document

Definition of important terms used in this document:

1) Designated “unclassifiable” – an area where Environmental Protection Agency (EPA) could 

not determine if there was a violation of the 2008 Lead National Ambient Air Quality Standard 

(NAAQS) or a contribution to a violation in a nearby area, because there was insufficient air 

quality data for both 2006-2008 and 2007-2009 and where additional monitoring data for 2010 

could not result in a different designation.

2) Designated “attainment” – an area which EPA has determined, based on the most recent 3 

years of certified air quality data from 2006-2008 or 2007-2009, has no violations of the 2008 

Lead NAAQS during 36 consecutive valid 3-month site means; and which EPA has further 

determined does not contribute to a violation of the 2008 Lead NAAQS in a nearby area and that 

additional monitoring data from 2010 could not result in a different designation.

3) Designated nonattainment area – an area which EPA has determined, based on a State 

recommendation and/or on the technical analysis included in this document, has a violation of 

the 2008 Lead NAAQS during the most recent three consecutive years of quality-assured, 

certified air quality data.

4) Prior nonattainment area – an area that is currently designated as nonattainment or 

maintenance for the 1978 Lead NAAQS (including both current nonattainment areas and 

maintenance areas).

5) Recommended nonattainment area – an area a State or Tribe has recommended to EPA be 

designated as nonattainment.

6) Violating monitor – an ambient air monitor whose design value exceeds 0.15 micrograms per 

cubic meter (μg/m3). As described in Appendix R of part 50, a violation can be based on either 

Pb-Total Suspended Particulate (TSP) or Pb-Particulate Matter 10 microns or smaller in size 

(PM10) data and only three months of data are necessary to produce a valid violating design 

value.

7) 1978 Lead NAAQS – 1.5 μg/m3, NAAQS for lead promulgated in 1978. Based on the leadtotal suspended particulate (Pb-TSP) indicator and averaged over a calendar quarter.

8) 2008 Lead NAAQS - 0.15 μg/m3, NAAQS for lead promulgated in 2008. Based on the PbTSP indicator and a three-month rolling average. Data for the Pb-PM10 (lead-particles smaller 

than 10 micrometers) indicator may be used in limited instances, including to show 

nonattainment.
2

Pennsylvania

Area Designations For the 

2008 Lead National Ambient Air Quality Standards

EPA has revised the level of the primary (health-based) standard from 1.5 micrograms per cubic 

meter (μg/m3) to 0.15 μg/m3 measured as total suspended particles (TSP). EPA has revised the 

secondary (welfare-based) standard to be identical in all respects to the primary standard.

Pursuant to section 107(d) of the Clean Air Act, EPA must designate as “nonattainment”

those areas that violate the NAAQS and those nearby areas that contribute to violations. 

The table below identifies the counties or portions of counties in the Commonwealth of 

Pennsylvania that EPA is designating “nonattainment” for the 2008 lead national ambient air 

quality standard (2008 Lead NAAQS).

Table 1. Nonattainment Areas

Area (listed 

alphabetically)

Pennsylvania’s 

Recommended 

Nonattainment 

Counties

Pennsylvania’s 

Recommended

Nonattainment 

Townships/Boroughs

EPA’s 

Designated 

Nonattainment 

Counties

EPA’s Designated 

Nonattainment 

Townships/Boroughs

Lower Beaver 

Valley Area

Beaver County

(partial) 

Potter and Vanport Beaver County 

(partial)

Potter and Vanport

Lyons Area Berks County 

(partial)

Maxatawny, 

Richmond, and Lyons

Berks County 

(partial)

Maxatawny, 

Richmond, Lyons,

and Kutztown

North Reading 

Area

Berks County 

(partial)

Muhlenberg, 

Laureldale, and 

Alsace

Berks County 

(partial)

Muhlenberg, 

Laureldale, and 

Alsace

Figure 1. Map of Beaver and Berks Counties in relation to the rest of the Commonwealth 

of Pennsylvania.
3

Technical Analysis for Lyons Nonattainment Area

Introduction 

This technical analysis for Lyons Nonattainment Area in Berks County identifies the partial 

county with a monitor that violates the 2008 Lead NAAQS and evaluates nearby counties for 

contributions to lead concentrations in the area. EPA has evaluated these counties based on the 

weight of evidence of the following factors recommended in previous EPA guidance: 

 Air quality in potentially included versus excluded areas;

 Emissions and emissions-related data in areas potentially included versus excluded from 

the nonattainment area, including population data, growth rates and patterns and 

emissions controls;

 Meteorology (weather/transport patterns);

 Geography/topography (mountain ranges or other air basin boundaries);

 Jurisdictional boundaries (e.g., counties, air districts, reservations, etc.); and

 Any other relevant information submitted to or collected by EPA (e.g., modeling where 

done appropriately).

On December 17, 2009, Pennsylvania recommended that parts of Berks County be designated as 

nonattainment for the 2008 Lead NAAQS based on air quality data from 2006-2008. The

Commonwealth’s recommendation was based on data from Federal Reference Method (FRM) or 

Federal Equivalent Method (FEM) monitors located in the state. As part of Pennsylvania’s 

recommendation they used modeling for drawing the nonattainment area boundaries in Berks 

County. EPA’s review of this modeling can be found in Appendix A of this document. This 

modeling supports Pennsylvania’s recommendation that the Lyons Nonattainment Area and the 

North Reading Nonattainment Area in Berks County should be two separate nonattainment 

areas. A conservative approach was used by Pennsylvania, where it included the whole township 

or borough that contained any part of the contours of the modeling results at or above half the 

2008 Lead NAAQS or 0.075 μg/m3. A map of these contour lines showing the two separate 

nonattainment areas can be found in Figure A-2 in Appendix A of this document.

Based on EPA's technical analysis described below, EPA is designating parts of Berks County in 

Pennsylvania as nonattainment for the 2008 Lead NAAQS as the Lyons Nonattainment Area, 

based upon currently available information. This county and the townships/boroughs included in 

the nonattainment area are listed above in Table 1.

Detailed Assessment

Air Quality Data 

This factor considers the lead design values (in μg/m3) for air quality monitors in Berks County

in the Lyons Area and the surrounding areas based on data for the 2006-2008 and 2007-2009

periods. A monitor’s design value indicates whether that monitor attains a specified air quality
4

standard. The 2008 Lead NAAQS are met at a monitoring site when the identified design value 

is valid and less than or equal to 0.15 μg/m3. A design value is only valid if minimum data 

completeness criteria are met. A lead design value that meets the NAAQS is generally 

considered valid if it encompasses 36 consecutive valid 3-month site means (specifically for a 3-

year calendar period and the two previous months). For this purpose, a 3-month site mean is 

valid if valid data were obtained for at least 75 percent of the scheduled monitoring days in the 3-

month period. A lead design value that does not meet the NAAQS is considered valid if at least 

one 3-month mean that meets the same 75 percent requirement is above the NAAQS. That is, a 

site does not have to monitor for three full calendar years in order to have a valid violating 

design value; a site could monitor just three months and still produce a valid (violating) design 

value.

The 2008 Lead NAAQS design values for Berks County in the Lyons Nonattainment Area and 

surrounding area are shown in Table 2.

Table 2. Air Quality Data 

County State 

Recommended 

Nonattainment?

Monitor Air 

Quality 

System ID

Monitor 

Location

Lead 

Design 

Value 2006-

2008 

(μg/m3)

Lead 

Design 

Value 2007-

2009 

(μg/m3)

Berks 

County, PA

Yes (partial) 420110005 Lyons Area 0.10 0.07

420110717 Lyons Area 0.21 0.21

420111717 North 

Reading Area

0.36 0.36

Monitors in Bold have the highest 2007-2009 design value in the respective nonattainment area.
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Figure 2. Lyons Nonattainment Area with Monitors

The Lyons Nonattainment Area shows a violation of the 2008 Lead NAAQS. Therefore, some 

area in this county must be designated nonattainment. However, the absence of a violating 

monitor alone is not a sufficient reason to eliminate nearby areas as candidates for nonattainment 

status. Each area has been evaluated based on the weight of evidence of the factors and other 

relevant information.

Figure 2 is a map of the area analyzed showing the locations of air quality monitors in the

nonattainment area. Currently, in the Lyons Nonattainment Area, there are two monitors. Of 

these two monitors, one is violating the 2008 Lead NAAQS and the other is not violating, as 

shown in Table 2. The monitor that is within Lyons Borough in Figure 2 is the design monitor

and is exceeding the 2008 Lead NAAQS. The monitor to the south, located in Richmond 

Township, is attaining the 2008 Lead NAAQS, therefore, EPA agrees with Pennsylvania that no 

other townships/boroughs to the East of Richmond Township should be included into the Lyons 

Nonattainment Area.

Emissions and Emissions-Related Data

Evidence of lead emissions sources surrounding a violating monitor is an important factor for 

determining whether a nearby area is contributing to a monitored violation. For this factor, EPA 

evaluated county level emission data for lead and population data.
6

Emissions 

Emissions data were derived from the 2005 National Emissions Inventory (NEI), version 2, 

which was the most up-to-date version of the national inventory available when these data were 

compiled for the designations process in 2009. See 

http://www.epa.gov/ttnchie1/net/2005inventory.html. EPA recognizes that for certain counties, 

emissions may have changed since 2005. For example, certain large sources of emissions in or 

near this area may have installed emission controls or otherwise significantly reduced emissions 

since 2005. Some States provided updated information on emissions and emission controls in 

their comments to EPA. Pennsylvania provided updated emissions information. This updated

data is provided in Table 3 below. The data provided by Pennsylvania is the most current 

emission information available. The lead inventory information from these years allows for a 

direct comparison between the model results and the most recently available design values since 

the emissions are from roughly the same time periods; 2007 or 2008 for lead emissions and 

2007-09 for monitor design values.

Table 3 shows total emissions of lead (given in tons per year) in and around the Lyons 

Nonattainment Area for sources emitting (or anticipate to contribute) greater than 0.1 ton per 

year of lead according to the state emission inventory (Environment Facility Application 

Compliance Tracking System (eF.A.C.T.S.)) for the years 2007 and 2008. See 

http://www.dep.state.pa.us/dep/efacts/. Facilities that are part of the Lyons Nonattainment Area 

for the 2008 Lead NAAQS are shown in boldface. Additional facilities whose annual emissions 

are less than 0.1 ton per year of lead and within the Lyons Nonattainment Area are listed in 

Table 4 below. The EPA has chosen to accept Pennsylvania’s use of the inventory, and also 

accepts Pennsylvania’s use of the highest yearly emissions in its modeling analysis as a 

conservative approach. See Appendix A of this document for modeling analysis.
7

Table 3. Facility lead emissions greater than 0.1 tons per year

County Facility in State 

Recommended 

Nonattainment 

Area?

Facility Name Facility – Total 

Air Emissions 

2007-eFacts 

Pennsylvania’s 

State inventory 

(tons per year)

Facility – Total 

Air Emissions 

2008-eFacts 

Pennsylvania’s 

State inventory 

(tons per year)

Facility Location

Berks 

County, PA

Yes 

EastPenn 

Manufacturing Co. 

Inc/Battery 

Assembly

2.47 2.49 147 Deka Rd.

Berks 

County, PA

Yes EastPenn 

Manufacturing Co. 

Inc/ Smelter Plant

0.12 0.20 147 Deka Rd. 

Berks 

County, PA

No Exide Tech/ Reading 

Smelter

1.474 1.441 2

nd & Washington 

Sts.

Berks 

County, PA

No Yuasa Battery Inc/ 

Laureldale

0.14 0.15 2901 Montrose 

Ave

Berks 

County, PA

No RRI Energy Mid 

Atlantic/Titus Gen. 

Station

0.12 0.12 296 Poplar Neck 

Rd

Berks 

County, PA

No Lehigh Cement Co. 

LLC/ Evansville 

Cement Plant and 

Quarry

0.119 537 Evansville Rd.

Berks 

County, PA

No Boyertown Foundry 

Co./ FKA EAFCO

0.127 9

th & Rothermal 

Sts.

Table 4. Facility lead emissions less than 0.1 tons per year

County Facility in State 

Recommended 

Nonattainment 

Area?

Facility Name Facility – Total 

Air Emissions 

2007-eFacts 

Pennsylvania’s 

State inventory 

(tons per year)

Facility – Total 

Air Emissions 

2008-eFacts 

Pennsylvania’s 

State inventory 

(tons per year)

Facility Location

Berks 

County, PA No

EastPenn 

Manufacturing Co. 

INC/ Kutztown

0.01 0.01 191 Willow St.

Berks 

County, PA

No Kutztown University 

of Pennsylvania

0.0092 Hinterliten Rd.

Berks 

County, PA

No McConway & Torley 

LLC/Kutztown 

Foundry

0.0051 230 Railroad St.

There are approximately 20,000 airport facilities in the U.S. at which leaded aviation gasoline is 

consumed. To evaluate the potential impact of emissions at and near these facilities, EPA 

recommends that states use the draft 2008 NEI. Data for airport facilities in Berks County which 

use leaded aviation gasoline are included in Table 5.
8

Table 5. Airport Emissions greater than 0.1 tons per year in Berks County, PA

County Airport in State 

Recommended 

Nonattainment

Area?

Airport Name Airport – Total Air 

Emissions 

Draft 2008 NEI 

(tons per year)

Airport Location

Berks County, PA No Kutztown 0.12 CLOSED 

November 2008

Berks County, PA No Reading Regional 

Airport (RDG)

0.24 2501 Bernville Road

Figure 3. Lyons Nonattainment Area with facility locations identified by annual emissions 

in tons per year.

In Pennsylvania’s recommendation, the facilities in Table 4 were not mentioned. It is EPA’s 

determination that Kutztown Borough should be included as part of the Lyons Nonattainment 

Area because although small in size it does have lead emitting facilities. The locations of the 

facilities in Kutztown Borough are shown in Figure 3. The Borough currently appears as a hole 

in the nonattainment area recommended by Pennsylvania, since it is surrounded by Maxatawny

Township. EPA agrees with Pennsylvania that Fleetwood Borough should not be included in the 
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Lyons Nonattainment Area because it does not have any lead emitting facilities and does not 

contribute to the nonattainment area.

Population Data

Table 6 shows the 2008 population for Berks County. This data helps assess the extent to which 

the concentration of human activities in the area and concentration of population-oriented 

commercial development may indicate emissions-based activity contributing to elevated ambient 

lead levels. This may include ambient lead contributions from activities that would disturb lead 

that has been deposited on the ground or on other surfaces. Re-entrainment of historically

deposited lead is not reflected in the emissions inventory.

Table 6. Population Data

County State 

Recommended 

Nonattainment?

2008 

Population

2008

Population 

Density 

(pop/sq mi)

Population 

Change 

2000-2008

Population 

% Change 

2000-2008

Berks 

County, 

PA

Yes (partial)

403,595 467 29,098 8%

Source of data: U.S. Census Bureau estimates for 2008 

(http://www.census.gov/popest/datasets.html) and estimation of the area of U.S. Counties

Growth rates and patterns 

Berks County has an increasing population trend between 2000 and 2008. EPA has considered 

the population growth rate for this area and does not believe that it affects the boundary

recommendation.

Emissions Controls

Under this factor, the existing level of control of emission sources is taken into consideration. 

The emissions data used by EPA in this technical analysis and provided in Table 3 and Table 4

represent emissions levels taking into account any control strategies implemented in the Lyons 

Nonattainment Area before 2007 on stationary sources.

East Penn Manufacturing Company operates a lead/acid storage battery assembly facility and a 

secondary lead smelter. The six battery assembly plants and lead oxide plant account for most of 

the lead emissions reported by the facility. Each assembly plant consists of four main operations 

that result in particulate and lead emissions controlled by fabric collectors. Most fabric filters are 

followed by a HEPA filter to further reduce the emissions. The entire facility is subject to lead 

Reasonably Available Control Technology (RACT) in the Pennsylvania State Implementation 

Plan (SIP). It meets the requirements of the National Emission Standards for Hazardous Air 

Pollutants (NESHAP) subpart PPPPPP for the Lead and Acid Battery Manufacturing Area 

Sources and New Source Performance Standards (NSPS) subpart KK for the Standards of 

Performance for Lead-Acid Battery Manufacturing Plants.
10

Meteorology (weather/transport patterns)

For this factor, EPA considered data from National Weather Service instruments and other 

meteorological monitoring sites in the area. Wind direction and wind speed data is from 1960-

1992 Solar and Meteorological Surface Observation Network information issued jointly by the 

U.S. Department of Commerce: National Climatic Data Center and the U.S. Department of 

Energy: National Renewable Energy Laboratory. This data is summarized in Figure 4 and Table 

7, below. This data may provide evidence of the potential for lead emissions sources located 

upwind of a violating monitor to contribute to ambient lead levels at the violation location.

Figure 4. Wind directions summarized by season for Berks County, PA

Table 7. Top two prevailing wind directions by season for Berks County, PA

Season Wind direction 

Percent of 

wind at that 

direction

Winter West, Northwest 32

Winter West, Southwest 18

Spring West, Northwest 24

Spring West, Southwest 15

Summer West, Northwest 21

Summer West, Southwest 20

Autumn West, Northwest 24

Autumn West, Southwest 19
11

As shown in the graph in Figure 4 and Table 7, the prevailing surface winds were predominantly

from the west, northwest and west, southwest for all four seasons.

Geography/topography (mountain ranges or other air basin boundaries)

The geography/topography analysis evaluates the physical features of the land that might have an 

effect on the air shed and, therefore, on the distribution of lead over the Lyon Nonattainment 

Area.

The Lyons Nonattainment Area does not have any geographical or topographical barriers 

significantly limiting air pollution transport within its air shed. Therefore, this factor did not 

play a significant role in determining the nonattainment boundary.

Jurisdictional boundaries 

Existing jurisdictional boundaries may be helpful in articulating a boundary for purposes of 

nonattainment designations, and for purposes of carrying out the governmental responsibilities of 

planning for attainment of the lead NAAQS and implementing control measures. These 

boundaries may include an existing nonattainment or maintenance area boundary, a county or 

township boundary, a metropolitan area boundary, an air management district, or an urban 

planning boundary established for coordinating business development or transportation activities.

The recommended Lyons Nonattainment Area is constructed using the township/borough 

boundaries within Berks County.

Other Relevant Information

The Commonwealth provided modeling to show that the two areas, the Lyons Nonattainment 

Area and the North Reading Nonattainment Area in Berks County should be separate. The 

Commonwealth recommended including in the nonattainment area those townships and 

boroughs where the modeling has shown a value of 0.075 μg/m3or higher. Additional review of 

the modeling submitted by Pennsylvania can be found in Appendix A of this technical analysis 

document.

Conclusion

After considering the factors and information described above, EPA has determined that it is 

appropriate to designate portions of Berks County listed in Table 1 as part of the Lyons

Nonattainment Area for the 2008 Lead NAAQS.

EPA is changing Pennsylvania’s recommendation by adding the Borough of Kutztown to the 

Lyons Nonattainment Area. EPA’s nonattainment area includes Kutztown Borough, Lyons 

Borough, Maxatawny Township, and Richmond Township located with in Berks County. The 
12

Kutztown Borough has been added to Pennsylvania’s recommended Lyons Nonattainment Area. 

EPA determined that Kutztown Borough will be included in the nonattainment area because it is 

entirely encompassed by the recommended nonattainment area and it has 2 facilities that emit 

lead within its boundaries and are in close proximity to the violating monitor.

Based on its consideration of all the relevant, available information, as described above, EPA 

believes that the boundaries described herein encompass the entire area that does not meet (or 

that contributes to ambient air quality in a nearby area that does not meet) the 2008 Lead

NAAQS.
13

Technical Analysis for North Reading Nonattainment Area

Introduction 

This technical analysis for North Reading Nonattainment Area in Berks County identifies the 

partial county with a monitor that violates the 2008 Lead NAAQS and evaluates nearby counties 

for contributions to lead concentrations in the area. EPA has evaluated these counties based on 

the weight of evidence of the following factors recommended in previous EPA guidance: 

 Air quality in potentially included versus excluded areas;

 Emissions and emissions-related data in areas potentially included versus excluded from 

the nonattainment area, including population data, growth rates and patterns and 

emissions controls;

 Meteorology (weather/transport patterns);

 Geography/topography (mountain ranges or other air basin boundaries);

 Jurisdictional boundaries (e.g., counties, air districts, reservations, etc.); and

 Any other relevant information submitted to or collected by EPA (e.g., modeling where 

done appropriately).

On December 17, 2009, Pennsylvania recommended that parts of Berks County be designated as 

nonattainment for the 2008 Lead NAAQS based on air quality data from 2006-2008. The

Commonwealth’s recommendation was based on data from FRM or FEM monitors located in the 

state.

Based on EPA's technical analysis described below, EPA is designating parts of Berks County in 

Pennsylvania as nonattainment for the 2008 Lead NAAQS as the North Reading Nonattainment 

Area, based upon currently available information. This county and the townships/boroughs 

included in the nonattainment area are listed above in Table 1.

Detailed Assessment

Air Quality Data 

This factor considers the lead design values (in μg/m3) for air quality monitors in North Reading 

Nonattainment Area in the Berks County and the surrounding area based on data for the 2007 –

2009 period. A monitor’s design value indicates whether that monitor attains a specified air 

quality standard. The 2008 Lead NAAQS are met at a monitoring site when the identified design 

value is valid and less than or equal to 0.15 μg/m3. A design value is only valid if minimum data 

completeness criteria are met. A lead design value that meets the NAAQS is generally 

considered valid if it encompasses 36 consecutive valid 3-month site means (specifically for a 3-

year calendar period and the two previous months). For this purpose, a 3-month site mean is 

valid if valid data were obtained for at least 75 percent of the scheduled monitoring days in the 3-

month period. A lead design value that does not meet the NAAQS is considered valid if at least 

one 3-month mean that meets the same 75 percent requirement is above the NAAQS. That is, a 
14

site does not have to monitor for three full calendar years in order to have a valid violating 

design value; a site could monitor just three months and still produce a valid (violating) design 

value.

The 2008 Lead NAAQS design values for Berks County in the North Reading Area and 

surrounding area are shown in Table 8.

Table 8. Air Quality Data 

County State 

Recommended 

Nonattainment?

Monitor Air 

Quality 

System ID

Monitor 

Location

Lead 

Design 

Value 2006-

2008 

(μg/m3)

Lead 

Design 

Value 2007-

2009 

(μg/m3)

Berks 

County, PA

Yes (partial) 420110005 Lyons Area 0.10 0.07

420110717 Lyons Area 0.21 0.21

420111717 North 

Reading 

Area

0.36 0.36

Monitors in Bold have the highest 2007-2009 design value in the respective area.

Figure 5. Area analyzed showing the location of the air quality monitor.
15

The North Reading Nonattainment Area shows a violation of the 2008 Lead NAAQS. 

Therefore, some area in this county must be designated nonattainment. The design value for this 

nonattainment area is found at the single monitor in Muhlenberg Township, as shown in Figure 

5. However, the absence of a violating monitor alone is not a sufficient reason to eliminate 

nearby areas as candidates for nonattainment status. Each area has been evaluated based on the 

weight of evidence of the factors and other relevant information.

Emissions and Emissions-Related Data

Evidence of lead emissions sources surrounding a violating monitor is an important factor for 

determining whether a nearby area is contributing to a monitored violation. For this factor, EPA 

evaluated county level emission data for lead and population data.

Emissions 

Emissions data were derived from the 2005 NEI, version 2, which is the most up-to-date version 

of the national inventory available when these data were compiled for the designations process in 

2009. See http://www.epa.gov/ttnchie1/net/2005inventory.html. EPA recognizes that for certain 

counties, emissions may have changed since 2005. For example, certain large sources of 

emissions in or near this area may have installed emission controls or otherwise significantly

reduced emissions since 2005. Some States provided updated information on emissions and 

emission controls in their comments to EPA. Pennsylvania provided updated emissions 

information, shown in Table 9. The data provided by Pennsylvania is the most current emission 

information available. The lead inventory information from these years allows for a direct 

comparison between the model results and the most recently available design values since the 

emissions are from roughly the same time periods; 2007 or 2008 for lead emissions and 2007-09 

for monitor design values.

Table 9 shows total emissions of lead (given in tons per year) in and around the North Reading 

Area from sources emitting (or anticipate to contribute) greater than 0.1 ton per year of lead 

according to the state emission inventory (eF.A.C.T.S.) for the years 2007 and 2008. See 

http://www.dep.state.pa.us/dep/efacts/. Facilities that are part of the North Reading

Nonattainment Area for the 2008 Lead NAAQS are shown in boldface. The facilities listed in 

Table 8 are mapped in Figure 6. Figure 6 shows the location of Exide Smelter and Yuasa 

Battery Inc. within the Nonattainment Area boundary and the smaller facilities that do not cause 

or contribute to the North Reading Nonattainment Area. The EPA has chosen to accept 

Pennsylvania’s use of the inventory, and also accepts Pennsylvania’s use of the highest yearly 

emissions in its modeling analysis as a conservative approach. See Appendix A of this document 

for modeling analysis.
16

Table 9. Facility lead emissions greater than 0.1 tons per year

County Facility in State 

Recommended 

Nonattainment 

Area?

Facility Name Facility – Total 

Air Emissions 

2007-eFacts 

Pennsylvania’s 

State inventory 

(tons per year)

Facility – Total 

Air Emissions 

2008-eFacts 

Pennsylvania’s 

State inventory 

(tons per year)

Facility Location

Berks

County, PA No

EastPenn 

Manufacturing Co. 

Inc/Battery Assembly

2.47 2.49 147 Deka Rd.

Berks

County, PA

No EastPenn 

Manufacturing Co. 

Inc/ Smelter Plant

0.12 0.20 147 Deka Rd. 

Berks

County, PA

Yes Exide Tech/ 

Reading Smelter

1.474 1.441 2

nd & Washington 

Sts.

Berks

County, PA

Yes Yuasa Battery Inc/ 

Laureldale

0.14 0.15 2901 Montrose 

Ave

Berks 

County, PA

No RRI Energy Mid 

Atlantic/Titus Gen. 

Station

0.12 0.12 296 Poplar Neck 

Rd

Berks 

County, PA

No Lehigh Cement Co. 

LLC/ Evansville 

Cement Plant and 

Quarry

0.119 537 Evansville Rd.

Berks 

County, PA

No Boyertown Foundry 

Co./ FKA EAFCO

0.127 9

th & Rothermal 

Sts.

There are approximately 20,000 airport facilities in the U.S. at which leaded aviation gasoline is 

consumed. To evaluate the potential impact of emissions at and near these facilities, EPA 

recommends that states use the draft 2008 NEI. Data for airport facilities in Berks County which 

use leaded aviation gasoline are included in Table 10.

Table 10. Airport Emissions greater than 0.1 tons per year in Berks County, PA

County Airport in State 

Recommended 

Nonattainment

Area?

Airport Name Airport – Total Air 

Emissions 

Draft 2008 NEI 

(tons per year)

Airport Location

Berks County, PA No Kutztown 0.12 CLOSED 

November 2008

Berks County, PA No Reading Regional 

Airport (RDG)

0.24 2501 Bernville Road

The RDG airport is located 3.75 kilometers from the violating monitor in the North Reading 

Nonattainment Area. The Commonwealth has not provided analyses (such as air quality 

modeling) to examine the potential contribution of lead emissions at RDG to the nonattainment 

identified by the monitor in Muhlenberg Township. EPA's preliminary modeling suggests 

emissions from piston-engine aircraft operating out of RDG contribute less than 1% of lead 

concentrations measured at the violating monitor.
17

Figure 6. North Reading Nonattainment Area with facility locations identified by annual 

emissions in tons per year.

Population Data

Table 11 shows the 2008 population for each county in the area being evaluated, as well as the 

population density for each county in that area. These data help assess the extent to which the 

concentration of human activities in the area and concentration of population-oriented 

commercial development may indicate emissions-based activity contributing to elevated ambient 

lead levels. This may include ambient lead contributions from activities that would disturb lead 

that has been deposited on the ground or on other surfaces. Re-entrainment of historically

deposited lead is not reflected in the emissions inventory.

Table 11. Population Data

County State 

Recommended 

Nonattainment?

2008 

Population

2008

Population 

Density 

(pop/sq mi)

Population 

Change 

2000-2008

Population 

% Change 

2000-2008

Berks 

County, 

PA

Yes (partial)

403,595 467 29,098 8%

Source of data: U.S. Census Bureau estimates for 2008 

(http://www.census.gov/popest/datasets.html) and estimation of the area of U.S. Counties
18

Growth rates and patterns 

Berks County has an increasing population trend between 2000 and 2008. EPA has considered 

the population growth rate for this area and does not believe that it affects the boundary

recommendation.

Emissions Controls

Under this factor, the existing level of control of emission sources is taken into consideration. 

The emissions data used by EPA in this technical analysis and provided in Table 9 represent 

emissions levels taking into account any control strategies implemented in the North Reading 

Nonattainment Area before 2007 on stationary sources. 

The Exide Facility operates a secondary lead smelter. The facility processes used lead/acid 

automotive and truck batteries and other lead bearing scrap into metallic lead in one of the two 

smelting systems. Each system has an identical series of control devices. The area that reports 

the highest lead emissions is the raw material storage building, which is exhausted to fabric 

collectors to control particulate and lead. The entire facility is subject to lead RACT in the 

Pennsylvania SIP. 

Yuasa Battery Inc. is a lead battery manufacturing facility. It meets the requirements of the

NESHAP subpart PPPPPP for Lead and Acid Battery Manufacturing Area Sources and the 

NSPS subpart KK Standards of Performance for Lead-Acid Battery Manufacturing Plants. 

Meteorology (weather/transport patterns)

For this factor, EPA considered data from National Weather Service instruments and other 

meteorological monitoring sites in the area. Wind direction and wind speed data was taken from 

1960-1992 Solar and Meteorological Surface Observation Network information issued jointly by

the U.S. Department of Commerce: National Climatic Data Center and the U.S. Department of 

Energy: National Renewable Energy Laboratory. This data is summarized in Figure 7 and Table 

12, below. This data may provide evidence of the potential for lead emissions sources located 

upwind of a violating monitor to contribute to ambient lead levels at the violation location.
19

Figure 7. Wind directions summarized by season for Berks County, PA

Table 12. Top two prevailing wind directions by season for Berks County, PA

Season Wind direction 

Percent of 

wind at that 

direction

Winter West, Northwest 32

Winter West, Southwest 18

Spring West, Northwest 24

Spring West, Southwest 15

Summer West, Northwest 21

Summer West, Southwest 20

Autumn West, Northwest 24

Autumn West, Southwest 19

As shown in the graph in Figure 7 and Table 12, the prevailing surface winds were

predominantly from the west, northwest and west, southwest for all four seasons.

Geography/topography (mountain ranges or other air basin boundaries)

The geography/topography analysis evaluates the physical features of the land that might have an 

effect on the air shed and, therefore, on the distribution of lead over the North Reading 

Nonattainment Area.
20

The North Reading Nonattainment Area does not have any geographical or topographical 

barriers significantly limiting air pollution transport within its air shed. Therefore, this factor did 

not play a significant role in determining the nonattainment boundary.

Jurisdictional boundaries 

Existing jurisdictional boundaries may be helpful in articulating a boundary for purposes of 

nonattainment designations, and for purposes of carrying out the governmental responsibilities of 

planning for attainment of the lead NAAQS and implementing control measures. These 

boundaries may include an existing nonattainment or maintenance area boundary, a county or 

township boundary, a metropolitan area boundary, an air management district, or an urban 

planning boundary established for coordinating business development or transportation activities.

The recommended North Reading Nonattainment Area is constructed using the 

township/borough boundaries within Berks County.

Other Relevant Information

The Commonwealth provided modeling to show that the two areas, the Lyons Nonattainment 

Area and the North Reading Nonattainment Area, in Berks County should be separate. The 

Commonwealth recommended including in the nonattainment area those townships and 

boroughs where the modeling has shown a value of 0.075 μg/m3or higher. Additional review of 

the modeling submitted by Pennsylvania can be found in Appendix A of this technical analysis 

document.

Conclusion

After considering the factors and information described above, EPA has determined that it is 

appropriate to include the portions of Berks County listed in Table 1 as part of the North Reading 

Nonattainment Area for the 2008 Lead NAAQS. 

EPA agrees with Pennsylvania’s recommendation for the North Reading Nonattainment Area 

which includes Alsace Township, Laureldale Borough, and Muhlenberg Township. 

Based on its consideration of all the relevant, available information, as described above, EPA 

believes that the boundaries described herein encompass the entire area that does not meet (or 

that contributes to ambient air quality in a nearby area that does not meet) the 2008 Pb NAAQS.
21

Technical Analysis for Lower Beaver Valley Nonattainment Area

Introduction 

This technical analysis for the Lower Beaver Valley Nonattainment Area in Beaver County

identifies the partial county with a monitor that violates the 2008 Lead NAAQS and evaluates 

nearby counties for contributions to lead concentrations in the area. EPA has evaluated these 

counties based on the weight of evidence of the following factors recommended in previous EPA 

guidance: 

 Air quality in potentially included versus excluded areas;

 Emissions and emissions-related data in areas potentially included versus excluded from 

the nonattainment area, including population data, growth rates and patterns and 

emissions controls;

 Meteorology (weather/transport patterns);

 Geography/topography (mountain ranges or other air basin boundaries);

 Jurisdictional boundaries (e.g., counties, air districts, reservations, etc.); and

 Any other relevant information submitted to or collected by EPA (e.g., modeling where 

done appropriately).

On December 17, 2009, Pennsylvania recommended that part of Beaver County be designated as 

nonattainment for the 2008 Lead NAAQS based on air quality data from 2006 - 2008. Their 

recommendation was based on data from FRM or FEM monitors located in the state. 

Based on EPA's technical analysis described below, EPA designating parts of Beaver County in 

Pennsylvania as nonattainment for the 2008 Lead NAAQS as the Lower Beaver Valley

Nonattainment Area, based upon currently available information. This county and the 

townships/boroughs included in the nonattainment area are listed above in Table 1. 

Detailed Assessment

Air Quality Data 

This factor considers the lead design values (in μg/m3) for air quality monitors in Beaver County

and the surrounding area based on data for the 2006-2008 and 2007-2009 periods. A monitor’s 

design value indicates whether that monitor attains a specified air quality standard. The 2008 

Lead NAAQS are met at a monitoring site when the identified design value is valid and less than 

or equal to 0.15 μg/m3. A design value is only valid if minimum data completeness criteria are 

met. A lead design value that meets the NAAQS is generally considered valid if it encompasses 

36 consecutive valid 3-month site means (specifically for a 3-year calendar period and the two 

previous months). For this purpose, a 3-month site mean is valid if valid data were obtained for 

at least 75 percent of the scheduled monitoring days in the 3-month period. A lead design value 

that does not meet the NAAQS is considered valid if at least one 3-month mean that meets the 

same 75 percent requirement is above the NAAQS. That is, a site does not have to monitor for 
22

three full calendar years in order to have a valid violating design value; a site could monitor just 

three months and still produce a valid (violating) design value.

The 2008 Lead NAAQS design values for Beaver County in the Lower Beaver Valley Area and 

surrounding area are shown in Figure 8 and Table 13.

Table 13. Air Quality Data

County State 

Recommended 

Nonattainment?

Monitor 

Air Quality 

System ID

Monitor 

Location

Lead 

Design 

Value 2006-

2008 

(μg/m3)

Lead 

Design 

Value 2007-

2009 

(μg/m3)

Beaver 

County, 

PA

Yes (partial) 420070505 TAMAQUI DR 0.20 0.17

Figure 8 is a map of the area analyzed showing the location of the air quality monitor in relation 

to the Horsehead Facility.

The Lower Beaver Valley Area shows a violation of the 2008 Lead NAAQS. Therefore, some 

area in this county must be designated nonattainment. However, the absence of a violating 

monitor alone is not a sufficient reason to eliminate nearby areas as candidates for nonattainment 
23

status. Each area has been evaluated based on the weight of evidence of the factors and other 

relevant information. 

Beaver County will be reevaluated using the same technical analysis in the second round of 

designations, since new source orientated monitors were to be placed and operational by January

1, 2010 as a requirement of the 2008 Lead NAAQS rule (73 FR 67059). These sites for Beaver 

County are shown in Figure 9 and listed in Table 14. 

Table 14. Location of Source specific monitors

Site Name

Physical 

Address Lattitude Longitude

Bruce Mansfield

206 Mowry 

Rd., Monaca, 

PA 15071 40.638936° 80.365653°

Horsehead

Beaver Valley 

Mall, Monaca, 

PA 15071 40.676592° 80.316369°

Vanport (original 

Horsehead monitor)

265 River 

Ave., Beaver, 

PA 15009 40.685019° 80.324775°

New Monitors placed January 1, 2010 are in Bold. 

Figure 9. Map of current lead monitor locations as of January 1, 2010
24

Emissions and Emissions-Related Data

Evidence of lead emissions sources surrounding a violating monitor is an important factor for 

determining whether a nearby area is contributing to a monitored violation. For this factor, EPA 

evaluated county level emission data for lead and population data.

Emissions

Emissions data were derived from the 2005 NEI, version 2, which is the most up-to-date version 

of the national inventory available when these data were compiled for the designations process in 

2009. See http://www.epa.gov/ttnchie1/net/2005inventory.html. EPA recognizes that for certain 

counties, emissions may have changed since 2005. For example, certain large sources of

emissions in or near this area may have installed emission controls or otherwise significantly

reduced emissions since 2005. Some States provided updated information on emissions and 

emission controls in their comments to EPA. Pennsylvania provided updated emissions 

information, provided in Table 15. The data provided by Pennsylvania is the most current 

emission information available. The lead inventory information from these years allows for a 

direct comparison between the model results and the most recently available design values since 

the emissions are from roughly the same time periods; 2007 or 2008 for lead emissions and 

2007-09 for monitor design values.

Table 15 shows total emissions of lead (given in tons per year) for violating and potentially 

contributing townships/boroughs in and around the Lower Beaver Valley Area and sources 

emitting (or anticipate to contribute) greater than 0.1 ton per year of lead according to the state 

emission inventory (eF.A.C.T.S.) for the years 2007 and 2008. See 

http://www.dep.state.pa.us/dep/efacts/. Facilities that are part of the Lower Beaver Valley

Nonattainment Area for the 2008 Lead NAAQS are shown in boldface. The EPA has chosen to 

accept Pennsylvania’s use of the inventory, and also accepts Pennsylvania’s use of the highest 

yearly emissions in its modeling analysis as a conservative approach. See Appendix A of this 

document for modeling analysis. Figure 10 below shows the distance between the First Energy

Generation Corp/ Bruce Mansfield Plant and the Lower Beaver Valley Nonattainment Area. 

During the second round of designations in 2011, Beaver County will be reevaluated with new 

data provided by the monitors placed in January 2010 to determine if the area should be 

expanded. 
25

Table 15. Facility lead emissions greater than 0.1 tons per year

County Facility in State 

Recommended 

Nonattainment

Facility Name Facility – Total 

Air Emissions 

2007-eFacts 

Pennsylvania’s 

State inventory 

(tons per year)

Facility – Total 

Air Emissions 

2008-eFacts 

Pennsylvania’s 

State inventory 

(tons per year)

Facility 

Location

Beaver 

County, PA Yes (partial)

Horsehead 

Corp./Monaca 

Smelter

5.64 5.38 300 Frankfort 

Rd.

Beaver 

County, PA

Yes (partial) First Energy Gen. 

Corp/ Bruce 

Mansfield Plant

1.20 0.70 State Route 168 

South

Beaver 

County, PA

Yes (partial) Jewel Acquisition/ 

Midland Factory

0.30 0.10 12th St. & 

Midland Ave.

Figure 10. Lower Beaver Valley Nonattainment Area with facility locations identified by 

annual emissions in tons per year. 

Population Data

Table 16 shows the 2008 population for Beaver County being evaluated, as well as the 

population density for each county in that area. These data help assess the extent to which the 

concentration of human activities in the area and concentration of population-oriented 

commercial development may indicate emissions-based activity contributing to elevated ambient 
26

lead levels. This may include ambient lead contributions from activities that would disturb lead 

that has been deposited on the ground or on other surfaces. Re-entrainment of historically

deposited lead is not reflected in the emissions inventory.

Table 16. Population Data

County State 

Recommended 

Nonattainment?

2008 

Population

2008

Population 

Density 

(pop/sq mi)

Population 

Change 

2000-2008

Population 

% Change 

2000-2008

Beaver 

County, 

PA

Yes (partial)

172,476 389 -8,639 -5%

Source of data: U.S. Census Bureau estimates for 2008 

(http://www.census.gov/popest/datasets.html) and estimation of the area of U.S. Counties

Growth rates and patterns 

Beaver County has a declining population trend between 2000 and 2008. EPA has considered 

the population growth rate for this area and does not believe that it affects the boundary

recommendation.

Emissions Controls

Under this factor, the existing level of control of emission sources is taken into consideration. 

The emissions data used by EPA in this technical analysis and provided in Table 15 represent 

emissions levels taking into account any control strategies implemented in the Lower Beaver

Valley Nonattainment Area before 2007 on stationary sources. 

Horsehead Corporation is a zinc processing facility which produces high purity zinc oxide and 

high grade zinc metal using a two step distillation process. There are two sources responsible for 

the majority of the lead emissions from the facility: the sintering line and the electrothermic 

furnace line. Raw materials consisting of crude zinc oxide and other secondary materials are fed 

to a sintering machine. Under high temperatures, air is drawn through the materials, resulting in 

fused chunks that become feedstock for the electrothermic furnaces. Various impurities (such as 

lead) are volatilized during the processing. Emissions from this process are controlled by a 

baghouse. According to the company, 95 % of the lead emissions from the furnaces are emitted 

through baghouses, and only 5% escapes as fugitive emissions. 

Meteorology (weather/transport patterns)

For this factor, EPA considered data from National Weather Service instruments and other 

meteorological monitoring sites in the area. Wind direction and wind speed data 1960-1992 

Solar and Meteorological Surface Observation Network information issued jointly by the U.S. 

Department of Commerce: National Climatic Data Center and the U.S. Department of Energy: 

National Renewable Energy Laboratory. This data is summarized in Figure 11, and Table 17, 

below. This data may provide evidence of the potential for lead emissions sources located 

upwind of a violating monitor to contribute to ambient lead levels at the violation location.
27

Figure 11. Wind directions summarized by season for Beaver County, PA

Table 17. Top two prevailing wind directions by season for Beaver County, PA

Season Wind direction 

Percent of 

wind at that 

direction

Winter West, Southwest 25

Winter West, Northwest 22

Spring West, Northwest 20

Spring West, Southwest 16

Summer West, Southwest 20

Summer South, Southwest 18

Autumn West, Southwest 19

Autumn West, Northwest 18

As shown in the graph in Figure 11 and Table 17, the prevailing surface winds are often from the 

west, southwest and west, northwest in most seasons. 
28

Geography/topography (mountain ranges or other air basin boundaries)

The geography/topography analysis evaluates the physical features of the land that might have an 

effect on the air shed and, therefore, on the distribution of lead over the Lower Beaver Valley

Nonattainment Area. 

The Lower Beaver Valley Nonattainment Area does not have any geographical or topographical 

barriers significantly limiting air pollution transport within its air shed. Therefore, this factor did 

not play a significant role in determining the nonattainment boundary.

Jurisdictional boundaries 

Existing jurisdictional boundaries may be helpful in articulating a boundary for purposes of 

nonattainment designations, and for purposes of carrying out the governmental responsibilities of 

planning for attainment of the lead NAAQS and implementing control measures. These existing 

boundaries may include an existing nonattainment or maintenance area boundary, a county or 

township boundary, a metropolitan area boundary, an air management district, or an urban 

planning boundary established for coordinating business development or transportation activities.

The recommended Lower Beaver Valley Nonattainment Area is constructed using the township 

boundaries within Beaver County.

Conclusion

After considering the factors described above, EPA has determined that it is appropriate to 

include the portion of Beaver County, PA listed in Table 1 in the Lower Beaver Valley

Nonattainment Area for the 2008 Lead NAAQS. 

The air quality monitor in Beaver County shows a violation of the 2008 Lead NAAQS, based on 

2007-2009 air quality data. EPA agrees with Pennsylvania’s recommendation to include Potter 

and Vanport Townships in the Lower Beaver Valley Nonattainment Area, since the contributing 

source and violating monitor are located within those townships. 

Based on its consideration of all the relevant, available information, as described above, EPA 

believes that the boundaries described herein encompass the entire area that does not meet (or 

that contributes to ambient air quality in a nearby area that does not meet) the 2008 Pb NAAQS.