DATE: 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION III 

1650 Arch Street 

Philadelphia, Pennsylvania 19103 

SUBJECT: Technical Support Document: Pennsylvania: North Reading; Control Strategies, 

Reasonable Further Progress, and Contingency Measures 

FROM: Ellen Schmitt, Life Scientist 

Office of Air Program Planning 

TO: 

THRU: · Cristina F emandez, Associate Director 

Office of Air Program Planning 

A. INTRODUCTION 

This document provides a technical review of the control strategies, reasonable further 

progress (RFP), and contingency measures used in the attainment plan for the 2008 lead North 

Reading nonattainment area. This document is to support the Environmental Protection 

Agency's (EPA's) proposed approval ofthe attainment plan for the North Reading 

nonattainment area. 

B. BACKGROUND 

On November 12, 2008 (73 FR 66964), EPA established a 2008 primary and secondary lead 

NAAQS at 0.15 micrograms per cubic meter (11g/m3

) based on a maximum arithmetic 3-month 

mean concentration for a 3-year period. See 40 CFR 50.16. On November 22,2010 (75 FR 

7103 3 ), EPA published its initial air quality designations and classifications for the 2008 lead 

NAAQS based upon air quality monitoring data for calendar years 2007-2009. The November 

22, 2010 Federal Register publication included the nonattainment designation of an area located 

within Berks County, Pennsylvania (including Laurendale Borough, Muhlenberg Township and 

Alsace Township) and which will hereby be referred to as "North Reading Area" or "Area." See 

40 CFR 81.339. The initial2008 lead NAAQS designations, including the North Reading Area 

nonattainment designation, became effective on December 31, 2010. 1 

1 EPA completed a second and fmal round of designations for the 2008 lead NAAQS on November 22, 2011. See 

76 FR 72097. No additional areas in Pennsylvania were designated as nonattainment for the 2008 lead NAAQS 
Sta~es with nonattainment areas, such as Pennsylvania, are required by section 172 of the 

Clean Air Act (CAA) to submit a plan that demonstrates attainment of the applicable ambient air 

quality standard as expeditiously as practicable, but no later than the specified attainment date. 

Specifically, section 172(c) ofthe CAA indicates that these attainment SIPs must, among other 

things, include an RFP plan, contain contingency measures, and include provisions, such as 

emissions limitations and control measures that are necessary to provide for the attainment of the 

nonattainment area. In addition to the requirements set forth in section 172 of the CAA, specific 

attainment plan requirements for lead nonattainment areas are outlined in 40 CFR 51.117. 

C. CAA ATTAINMENT DEMONSTRATION REQUIREMENTS 

1. Control Strategies 

Section 172(c)(1) of the CAA indicates that attainment plans must provide "for the 

implementation of all reasonably available control measures as expeditiously as practicable 

(including such reductions in emissions from existing sources in the area as may be obtained 

through the adoption, at a minimum, of reasonably available control technology) and shall 

provide for the attainment of the national primary ambient air quality standards." EPA 

believes that in determining appropriate emission control levels, the state should consider 

the collective public health benefits that can be realized in the area due to projected 

improvements in air quality. 

In accordance with section 172(c)(l), lead nonattainment area SIPs must contain reasonably 

available control measures (RACM), including reasonably available control techniques 

(RACT), that address existing sources of ambient air lead concentrations. EPA defines 

RACM as measures that a state finds to be reasonably available and to contribute to 

attainment as expeditiously as practicable in its nonattainment area. RACT applies to the 

"existing sources" of lead in an area including stack emissions, industrial process fugitive 

emissions, and industrial fugitive dust emissions (e.g., on-site haul roads, unpaved staging 

areas at the facility). EPA's previous guidance for implementing the pre-existing lead 

NAAQS recommends that stationary sources which emit a total of five (5) tons per year 

(tpy) of lead or lead compounds, measured as elemental lead, be the minimum starting point 

for RACT analysis. See 58 FR 67750 (December 22, 1993). Further, EPA's existing 

guidance recommends that available control technology be applied to those existing sources 

in the nonattainment area that are reasonable to control in light of the attainment needs of 

the area and the feasibility of such controls. Thus, a state's control technology analysis may 

need to include sources which actually emit less than five (5) tpy oflead in the area, or other 

sources in the area that are reasonable to control, 'in light of the attainment needs and 

feasibility of control for the area. 

In its 2008 final rule, EPA recommended a threshold for RACT analysis such that at least all 

stationary sources emitting 0.5 tpy or more should undergo a RACT review. However, EPA 

believes that a state's control technology analysis should potentially include sources which 

emit less than the threshold level of 0.5 tpy of lead in the area, or other sources in the area 

during this second round of designations. 

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that are reasonable to control, depending upon the attainment needs and feasibility of 

controls in the nonattainment area.2 

EPA has historically defined RACT as the lowest emission limitation that a particular 

source is capable of meeting by the application of control technology that is reasonably 

available considering technological and economic feasibility. EPA suggests that the first 

step in addressing RACM/RACT for lead is identifying the potential measures for 

controlling lead emissions from sources of lead in the nonattainment area, and evaluating 

each measures for reasonableness, considering their technological and economic feasibility 

in the nonattainment area. 3 

According to sections 172( c)( 6) and 11 0( a)(2)(A) of the CAA, once the process of 

determining RACM/RACT for an area is completed, the individual measures should then be 

converted into a legally enforceable vehicle such as a regulation or permit. The regulations 

or other measures submitted should meet EPA's criteria regarding the enforceability of SIPs 

and SIP revisions.4 

2. Reasonable Further Progress 

Section 172(c)(2) ofthe CAA provides that SIP provisions in nonattainment areas must 

require reasonable further progress. Historically, for some pollutants, RFP has been met by 

showing annual incremental emission reductions generally sufficient to maintain linear 

progress toward attainment by the applicable attainment date. SIPs for lead nonattainment 

areas should provide for the implementation of control measures for point and area sources 

oflead emissions which demonstrate attainment of the lead NAAQS as expeditiously as 

practicable, but no later than the applicable statutory attainment date for the area. If a state 

adopts less than all available measures in an area but demonstrates, adequately, that RFP, 

and ·attainment of the lead NAAQS are assured, and the application of all such available 

measures would not result in attainment any faster, then a plan which.requires 

implementation of less than all technologically and economically available measures may be 

approved. See 44 FR 20375 (April4, 1979) and 56 FR 5460 (February 11, 1991). EPA 

believes that it would be unreasonable to require that a plan which demonstrates attainment 

include all technologically and economically available control measures even though such 

measures would not expedite attainment. 5 Thus, for some sources in areas which 

demonstrate attainment, it is possible that some available control measures may not be 

reasonably available because their implementation would not expedite attainment of the 

affected area. 

2 Final rule for the 2008 lead NAAQS. 73 FR 66964 (November 12, 2008). Located in EPA's SIP Toolkit at 

www3 .epa.gov/airquality/lead/pdfs/20 12ImplementationGuide. pdf 3 "Implementation of the 2008 Lead National Ambient Air Quality Standards Guide to Developing Reasonably 

Available Control Measures (RACM) for Controlling Lead Emissions" March 2012, which is included in EPA's 

SIP Toolkit located at www3.epa.gov/airquality/lead/pdfs/20 121mplementationGuide.pdf 4 An explanation ofthe enforceability of SIPs can be found in a September 23, 1987 memorandum (with 

attachments) entitled "Review of State Implementation Plans and Revisions of Enforceability and Legal 

Sufficiency" from J. Craig Potter, Assistant Administrator for Air and Radiation, et a!. 5 73 FR 66964 (November 12, 2008). 

3 
3. Contingency Measures 

Section 172( c )(9) of the CAA provid~s that SIPs in nonattainment areas "shall provide for 

the implementation of specific measures to be undertaken if the area fails to make 

reasonable further progress, or to attain the [NAAQS] by the attainment date applicable 

under this part. Such measures shall be included in the plan revision as contingency 

measures to take effect in any such case without further action by the State or [EPA]." 

Contingency measures are implemented if RFP targets are not achieved, or if attainment is 

not realized by the attainment date. 

The key requirements associated with contingency measures are: 

(1) Contingency measures must be fully adopted rules or control measures that are 

ready to be implemented as expeditiously as practicable upon a determination by 

EPA that the area has failed to achieve, or maintain RFP, or attain the lead 

NAAQS by the applicable statutory attainment date; 

(2) The SIP should contain trigger mechanisms for the contingency measures and 

specify a schedule for implementation; and 

(3) The SIP must indicate that the measures will be implemented without further 

action (or only minimal action) by the state or by EPA Administrator. The 

contingency measures should also consist of control measures for the area that are 

not already included in the control strategy for the attainment demonstration of 

the SIP. 

As mentioned above, section 172( c )(9) of the CAA provides that contingency measures 

should be included in the state SIP for a lead nonattainment area and shall take effect 

without further action by the state or the Administrator. EPA interprets this requirement to 

mean that no further rulemaking actions by the state, or EPA, would be needed to 

implement the contingency measures. EPA recognizes that certain actions, such as the 

notification of sources, modification of permits, etc., may be needed before a measure could 

be implemented. However, states must show that their contingency measures can be 

implemented with only minimal further action on their part and with no additional 

rulemaking actions such as public hearings or legislative review. The state should ensure 

that the measures are fully implemented as expeditiously as practicable after the requirement 

takes effect. 

D. PENNSYLVNIA SUBMITTAL 

1. Control Strategies 

Exide Plan Approval No. 06-050331 

Federal regulations establishing performance or emission standards under section 112 of the 

CAA at 40 CFR part 63 are incorporated by reference into PADEP's air quality permitting 

program under section 6.6 of Pennsylvania's Air Pollution Control Act, 35 P.S. §4006;6, 

4 
' ! 

·I 

i 

and under Pennsylvania's air quality permitting regulations at 25 Pa. Code§ 127.35(b) 

(1997). One such federal regulation is the National Emission Standards for Hazardous Air 

Pollutants for Secondary Lead Smelting sources (Secondary Lead Smelting NESHAP) ( 40 

CFR part 63, subpart X), which EPA promulgated revised requirements for on January 5, 

2012.6 

After the effective date of a performance or emission standard, such as the Secondary Lead 

Smelting NESHAP, the owners and operators of new, reconstructed, modified and existing 

sources must comply with the performance or emission standards pursuant to the 

compliance schedule established under section 112 of the CAA and the regulations 

thereunder. 

As a secondary lead smelter facility, Exide is-subject to the NESHAP and the requirements 

are incorporated into Plan Approval No. 06-050661, a pre-construction permit, which was 

issued by PADEP on August 31,2012. Plan Approval No. 06-050661 authorizes 

modifications to the existing configuration. of the Ex ide facility in order to achieve 

compliance with the revised Secondary Lead Smelting NESHAP. 

Once implemented, Plan Approval No. 06-050661 measures would totally enclose existing 

buildings, add new control equipment, redirect emissions from existing named sources to 

new or differently named control devices, eliminate some existing control devices and 

modify the refining kettles. 

See table 9 in the Pennsylvania attainment plan submittal for a list control measures that 

Plan Approval No. 06-050661 authorizes Exide to implement before the facility can resume 

its secondary lead smelting operations.7 Also included in PADEP's table 9 are the 

RACM/RACT measures that each Plan Approval No. 06-050661 control measure is 

associated with. 

As the NESHAP requirements are incorporated by reference into Pennsylvania regulations, 

they are state and federally enforceable. 8 

Additionally, a consent order and agreement (COA) between Exide and PADEP requires 

Exide to be in compliance with Plan Approval No. 06-050661 and NESHAP requirements in 

order to restart the facility's lead smelting operations. 

Exide COA 

Exide entered into a COA with PADEP on June 15,2015, which included the following 

legally-binding orders: 

a) Exide shall not resume operation of any portion of its facility until it has completed 

all the Exide facility modification work proposed in Exide Plan Approval I. 

6 77 FR 556 (January 5, 2012). 7 The Exide facility has been in an idling state, with no active lead smelting operations, since February 2013 . 8 Pennsylvania's plan approvals are federally enforceable under 40 CFR section 52.2062(a). 

5 
b) Exide shall comply with all emission, testing, monitoring, recordkeeping, 

reporting, work practice, and additional requirements in Exide Plan Approval I. 

c) IfExide elects to implement the Exide Facility modification work proposed in 

Exide Plan Approval I, in preparation for resuming operation of the Exide Facility, 

Exide shall nevertheless only proceed with the work at such times as the Exide 

Plan Approval I, or an extension thereof, remains valid, or at such times as the 

Plan Approval Work is authorized by some other quality plan approval. 

d) Exide shall submit an application to extend Plan Approval I by no later than June 

30, 2015.9 

e) Exide shall not permit exceedances ofthe following stack emission limits for lead: 

Stack 

S55 

S62 

Sl3 

S63 

S19 

S23A 

S64 

S47 

S70 

Emissions Limit for lead -

grams per second (gls) 

0.00502732 

0.00226500 

0.000398590 

0.00604100 

0.00191900 

0.00108700 

0.00604100 

0.00185900 

0.000158760 

For any Exide sources affected by the emission limits above, which would not 

otherwise be scheduled to be stack tested as part of the Exide Plan Approval I 

requirements, Exide shall, unless otherwise approved in writing by PADEP, 

perform stack testing of such sources within 180 days of startup of such sources, to 

demonstrate compliance with the emission limitations found above. 

Additionally, for all affected sources, Exide shall comply with all the provisions of 

40 CFR part 63, subpart X, including, but not limited to testing, monitoring, 

recordkeeping and reporting provisions. 

f) By no later than August 24, 2015, Exide shall ensure that a fence limiting public 

access to the Exide Facility is installed and/or maintained as per the diagram in 

Attachment A in the COA. 10 

Yuasa COA 

Yuasa entered into a COA with PADEP on June 12,2015, which included the following 

9 On January 31, 2014, the Department extended Plan Approval No. 06-050661 to remain effective until July 31, 

2015. Following this, PADEP approved another extension request from Exide which made Plan Approval 06-

050661 effective until January 31, 2017. 10 The fence was installed on August 21, 2015. 

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legally-binding orders:. 

a) By no later than December 31, 2015, Yuasa shall complete any facility 

modifications projected to be necessary in order to meet the following lead stack 

emission limits: 

Stack 

SOl 

S03 

S06 

S07 

S15 

S20 

Emissions Limit for lead -

grams per second (g/s) 

0.000687948 

0.000459000 

0.000352794 

0.000352794 

0.000174986 

0.000252000 

Yuasa shall comply with those limits at all times after December 31,2015, and 

shall demonstrate compliance with those limits by reference method stack testing 

by no later than June 30, 2016. Additionally, unless otherwise approved in writing 

by PADEP, Yuasa shall conduct stack testing on all the stacks listed above in 

2020, and thereafter in any year that is divisible, with remainder, by five. 

For all affected sources at the Yuasa facility, Yuasa shall comply with all the 

applicable provisions of 40 CFR part 63, subpart PPPPPP, including, but not 

limited to applicable monitoring, recordkeeping, and reporting provisions. 

b) By no later than August 24, 2015, Yuasa shall ensure that a fence limiting public 

access to the Yuasa Facility is installed and/or maintained with respect to the 

property owned by Yuasa as per the diagram in Attachment A of the CO A. 11 

2. Reasonable Further Progress 

In their August 12, 2015 attainment plan SIP submittal for the North Reading Area, PADEP 

provided the following measures, which are part of the control strategy for meeting 

attainment ofthe 2008 lead NAAQS, and which the Commonwealth asserts sufficiently 

demonstrate progress towards reducing lead emissions and attainment in the Area. 

T a bl e 1 0 RFP M'l 1 es t ones (! or t h N e or th R ea d' mg A rea 

Action Facility Implementation Date 

Updated fugitive dust control Exide PADEP approved measure on 

operating procedures March 30,2011 

Installation and maintenance of Exide No later than August 24, 2015 fence line 

Installation and maintenance of Yuasa No later than August 24, 2015 fence line 

Stack emission limitations Yuasa No later than December 31 , 2015 

11 Fence installment was completed by July 24, 2015. 

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3. Contingency Measures 

In the North Reading Area attainment plan submittal, the Commonwealth clarified that the 

lead emission reductions from their proposed contingency measures are surplus to those 

included and calculated in the attainment demonstration. In its August 2015 submittal, 

PADEP indicated that Exide and/or Yuasa will be required to implement at least one 

contingency measure if P ADEP determines in writing: 

(1) That the facility's ongoing emissions caused or significantly contributed to an 

exceedance ofthe 2008lead NAAQS at a PADEP monitor, and 

(2) That specific contingency measures are necessary and appropriate to abate the 

emissions which P ADEP determined are causing or significantly contributing to 

the 2008 lead NAAQS exceedance. 

PADEP will notify Exide and Yuasa when a monitored violation of the 2008 lead NAAQS 

occurs at a PADEP monitor. In the notification, P ADEP will identify the necessary and 

appropriate contingency measure( s) to be implemented. 

Exide Contingency Measures 

The following are contingency measures that PADEP, in consultation with Exide, 

developed in the case that the facility's ongoing emissions are determined to have 

caused or significantly contributed to an exceedance of the 2008 lead NAAQS at a 

PADEP monitor and for which P ADEP has determined as necessary or appropriate to 

abate such emissions. 

Upgrade Existing Fugitive Dust Control Devices 

Within 60 days after written a notice from PADEP, Exide shall submit to 

P ADEP for approval, a plan regarding the installation of high-efficiency 

particulate air (HEP A) filters on any or all of the following baghouses located 

within the facility: C19, C23A and C47. Upon PADEP approval, Exide shall 

install and begin operating the HEPA filters within 180 days, unless otherwise 

proposed in the investigative study detailed below. After implementing this 

measure Exide or P ADEP shall collect and review air quality data for lead in 

order to determine if attainment of the 2008 lead NAAQS has been restored. 

Increase Existing Lead Emission Stack Heights 

If, following implementation of the Exide contingency measure listed above fails 

to restore attainment ofthe 2008 lead NAAQS, Exide shall, within 60 days after 

the: receipt ofwritten notice from PADEP, submit to PADEP a request or plan 

application for an increase in the stack height for any or all of the following 

stacks within the facility: S 13, S23A and S70. Exide shall complete 

construction ofthe higher stacks within 180 days ofPADEP approval, unless 

otherwise proposed in the investigative study detailed below. 

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Increased Plant Roadway Cleaning Frequency 

Within one (1) day after the receipt of written P ADEP notice, Exide shall 

increase the in-plant road cleaning at the Exide facility to 10 hours each working 

day, and shall continue in-plant road cleaning activities at this frequency unless 

and until otherwise approved in writing by PADEP. 

Investigative Study 

By no later than 180 days after the receipt ofwritten PADEP notice, Exide shall 

submit to PADEP an investigative study identifying the potential or likely 

source(s) of emissions principally contributing to the exceedance so that a 

strategy may be developed to eliminate the likelihood of another exceedance. 

The study will list all best practices and best available technologies identified 

from industrial smelter or metal manufacturing facilities with similar fugitive 

emissions control challenges, and, for each technology or practice, will: 1) 

identify those technologies and/or practices that Exide deems technically feasible 

and cost effective, 2) quantify associated emissions reductions expected to result 

from the use of the practices or technologies, and 3) provide a time fram~ for 

implementation of each in a manner that allows attainment of the NAAQS in the 

most cost-effective manner and schedule. 

Upon P ADEP approval or modification of study aspects, the items so approved 

or modified shall be deemed incorporated by reference as Order items in the 

COA between Exide and P ADEP and shall be completed by the approved 

deadlines. 

Other Equivalent Measures 

lfExide identifies and demonstrates to the Commonwealth's satisfaction 

alternative control measures(s) that would achieve equal or greater lead emission 

reductions than the contingency measures identified above, Exide may the new 

control measure(s) for the contingency measure(s) identified above upon 

PADEP's prior written approval. 

Yuasa Contingency Measures 

PADEP, in consultation with Yuasa, developed the following contingency measure in 

the case that the facility's ongoing emissions are determined to have caused or 

significantly contributed to an exceedance ofthe 2008lead NAAQS at a PADEP 

monitor and for which P ADEP has determined as necessary or appropriate to abate such 

emissions. 

Investigative Study 

By no later than 180 days after the receipt of a written P ADEP notice, Yuasa 

shall submit to P ADEP an investigative study identifying the potential or likely 

source(s) of emissions principally contributing to the exceedance so that a 

strategy may be developed to eliminate the likelihood of another exceedance. 

The study will list all best practices and best available technologies identified 

from industrial smelter or metal manufacturing facilities with similar fugitive 

9 
emissions control challenges, and, for each technology or practice, will: 1) 

identify those technologies and/or practices that Yuasa deems technically 

feasible and cost effective, 2) quantify associated emissions reductions expected 

to result from the use of the practices or technologies, and 3) provide a time 

frame for implementation of each in a manner that allows attainment of the 

NAAQS in the most cost-effective manner and schedule. 

Upon P ADEP approval or modification of study aspects, the items so approved 

or modified shall be deemed incorporated by reference as Order items in the 

COA between Yuasa and PADEP and shall be completed by the approved 

deadlines. 

Contingency Measure Triggers 

The need for contingency measures will be triggered by an exceedance or violation of 

the 2008 lead NAAQS at a PADEP monitor, by an emissions event, or by missing an 

RFP milestone. If during any 3-month rolling period, two (2) samples at the same lead 

monitor in the North Reading Area are reported to exceed 0.15 J..lg/m3

, PADEP will 

double the sampling frequency at that monitor to once every three (3) days for a period 

of30 days. 

Additionally, if during any 3-month rolling period, three (3) samples at the same lead 

monitor in the North Reading Area are reported to exceed 0.15 J..lg/m3

, P ADEP will 

conduct daily sampling at that monitor for a period of 30 days. 

Finally, if during any 3-month rolling period, four (4) or more sample results at the same 

lead monitor in the North Reading Area are reported to exceed 0.15 J..lg/m3

, P ADEP 

would initiate additional lead ambient air monitoring in the area. A sampling plan 

would be developed within 15 days and monitors would be deployed as soon as 

possible. 

Contingency measures would also be implemented if a violation of the 2008 lead 

NAAQS occurs. A violation of the 2008 lead NAAQS occurs wh~m, based on data 

collected and quality-assured by PADEP, the design value of any rolling 3-month 

averaging period exceeds 0.15 J..lg/m3. 

Further details regarding the contingency measures and their triggers can be found in the 

COAs between Exide and PADEP, and Yuasa and PADEP which were included in 

PADEP's August 12,2015 SIP submittal and, upon approval by EPA, will be 

incorporated by reference into the Pennsylvania SIP. 

E. EPA'S ANALYSIS 

1. Control Strategies 

As Exide is the only source in the North Reading Area with potential emissions greater than 

0.5 tpy, it was the only source in the Area responsible for meeting the RACM/RACT 

requirements. Specifically, Plan Approval No. 06-05066I authorizes Exide to implement 

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measures consistent with the Secondary Lead Smelting NESHAP. As a secondary lead 

smelter facility, Exide is subject to the NESHAP and the requirements are incorporated into 

Plan Approval No. 06-05066! which was issued by PADEP on August 31,2012. 

The primary permanent and enforceable control measures that enable the North Reading 

Area to demonstrate attainment of the 2008 lead NAAQS include implementation of, and 

compliance with, the Secondary Lead Smelting NESHAP at the Exide facility upon 

reactivation of the currently idled lead operations. These measures include totally enclosing 

existing buildings, adding new control equipment, redirecting emissions from existing 

named sources to new or differently named control devices, eliminating some existing 

control devices and modifying the refining kettles. 

Additionally, COAs between the Commonwealth and Exide, and the Commonwealth and 

Yuasa provide additional measures for both facilities and will assist the North Reading Area 

in attaining the 2008 lead NAAQS. 

The 2015 projected lead emissions from Exide and Yuasa were based on a combination of 

NESHAP and COA limits. Based on implementation of these projected operations at Exide 

and Yuasa, the modeled projected lead concentration is 0.129107 ~-tglm . Adding to this, 

0.012 ~-tglm , the representative background concentration of lead in the region, and the total 

projected lead concentration in the North Reading Area is 0.141107 ~-tglm , below the 2008 

leadNAAQS. 

The emission reductions that allowed for the projected 2015 emissions calculation are 

dependent upon a combination ofCOA and NESHAP limits, ofwhich many will only be in 

place ifExide begins its smelting operations again. However, as Exide has been idling with 

no lead smelting operations ongoing since February 2013, Exide's actual lead emissions 

have been 0.00004 tpy, much lower than the projected 2015 lead emissions of0.8991 tpy 

which was used in modeling attainment. Therefore, the idled state of the Exide facility is a 

more conservative scenario for lead emissions in the North Reading Area than the NESHAP 

control strategy scenario, which has been modeled to show attainment. 

EPA believes that the Commonwealth has evaluated all control measures for Exide and 

Yuasa, the two stationary lead sources in the nonattainment area. The selected control 

measures were modeled and show attainment, thus no further measures need to be 

considered for RACM/RACT. The North Reading Area shows it will attain with the 

measures that were included in the Commonwealth's August 12,2015 submittal. EPA finds 

these control measures reasonable for the Area to attain based on modeling and analysis 

completed by Pennsylvania. 

Additionally, these control measures were also determined by the Commonwealth to be 

feasible for the two stationary lead sources to implement given that they are technically 

feasible and cost effective. Therefore, EPA finds that Pennsylvania adheres to existing 

guidance which recommends that available control technology be applied to those existing 

sources in the nonattainment area that are reasonable to control in light of the attainment 

needs of the area and the feasibility of such controls. 

11 
EPA proposes to approve Pennsylvania's North Reading attainment plan SIP as meeting 

section 172( c )(1) of the CAA. 

2. Reasonable Further Progress 

The North Reading Area is on track to meet the 2008 lead NAAQS. Although historically, 

for some pollutants, RFP has been met by showing annual incremental emission reductions 

generally sufficient to maintain linear progress toward attainment by the applicable 

attainment date, this does not always need to be the case. 

EPA expects that some nonattainment area designations were for the most part attributable 

to a single stationary source and that these areas would not necessarily show a linear 

progress towards attainment. Where one source is the major cause of nonattainment, EPA 

would not expect linear progress towards attainment. Rather, there may be relatively less 

progress while the source adopts non-technological control measures and begins to install 

necessary technological controls, and then significant progress towards attainment in a short 

period of time once all the controls are operational. This is true for the North Reading Area 

whose major lead source has traditionally been Exide. 

The modeling Pennsylvania included in its attainment demonstration show that the North 

Reading Area will attain the 2008lead NAAQS. In its August 12,2015 submittal, 

Pennsylvania explained the control measures selected for both Exide and Yuasa, the two 

lead sources in the Area, and determined that there are no additional measures which will 

sufficiently advance the attainment date. Thus, the RFP plan found in Pennsylvania's Nmih 

Reading attainment plan is reasonable and meets CAA requirements for RFP. 

EPA proposes to approve Pennsylvania's SIP as meeting section 172(C)(2) of the CAA. 

3. Contingency Measures 

Contingency measures for attainment demonstrations with non-linear RFP should still 

include key requirements, which are, in summary: Fully adopted and ready for 

implementation, contain trigger mechanisms and a schedule, be implemented without 

further action, and consist of control measures not already in the control strategy. However, 

for the requirement of one year's worth ofRFP, a more qualitative approach would be 

appropriate. In the scenario where there is one main source, a violation of the 2008 lead 

NAAQS could be caused by a malfunction, so a more stringent control may not even solve 

the problem. Fle~ibility, while still necessitating auto-trigger mechanisms, is more 

appropriate for single major source scenarios with non-linear RFP. 

In its submittal, P ADEP provided two types of triggers, with increased monitoring for every 

single sample exceeding 0.15 !lg/m3. The contingency measures for Exide include a variety 

of measures for controlling area source fugitive emissions as well as process-related fugitive 

emissions. The SIP submittal also includes as a contingency measure, an option to complete 

an investigative study to identify the potential or likely source(s) of emissions principally 

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contributing to the exceedance so that a strategy may be developed to eliminate the 

likelihood of another exceedance. 

The contingency measures for both Exide and Yuasa are located in the portions of the COAs 

that, upon EPA approval, will be incorporated in the Pennsylvania SIP, thereby making 

them federally enforceable. 

The contingency measures that Pennsylvania included in its August 12, 2015 SIP submittal 

are contained in the COAs in specific detail~ and are measures not already in the control 

strategy. Additionally, the submittal indicates the trigger mechanisms for the contingency 

measures and the measures can be implemented with minimal to no action by the state or 

EPA. EPA concludes that the measures Pennsylvania included in the attainment plan SIP 

are reasonable as contingency measures to address any attainment challenges the area may 

encounter. 

EPA is proposing to determine that the Commonwealth of Pennsylvania has met it 

obligations pursuant to 172(c)(9) of the CAA. 

F. CONCLUSIONS AND RECOMMENDED AGENCY ACTIONS 

EPA has evaluated the control strategy, RFP, and contingency measures information provided in 

PADEP's North Reading attainment plan submittal and believes that the SIP submitted by the 

Commonwealth satisfies requirements of sections 172( c)( 1 ), (2), and (9) of the CAA. 

EPA is proposing to approve that the North Reading Area has met the CAA requirements of an 

attainment demonstration that pertain to adopting emissions reduction measures with schedules 

for implementation and meet EPA's criteria for the enforceability. 

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