• £:~~~!~~E~A~~O~CTION SECRETARY 

October 28, 2014 

Mr. Shawn M. Garvin 

Regional Administrator 

U.S. Environmental Protection Agency, Region III 

1650 Arch Street (Mail Code: 3RAOO) 

Philadelphia, PA 19103-2029 

RE: EPA's 120-day Letter Concerning Proposed Designations for the 2012 Fine Particulate · 

Matter National Ambient Air Quality Standard 

Dear Mr. Garvin: 

This letter is in response to your August 19, 2014, letter to Governor Tom Corbett, providing the 

U.S. Environmental Protection Agency's (EPA) proposed modifications to Pennsylvania's 

designation recommendations for the 2012 annual fine particulate matter (PM2.5) National 

Ambient Air Quality Standard (NAAQS). As stated in your August 19 letter, EPA intends to 

modify Pennsylvania's recommended boundaries for the Cambria County (Johnstown), 

Liberty-Clairton (Allegheny County), and Northampton County (Allentown) areas. 

The Pennsylvania Department of Environmental Protection (DEP) appreciates EPA's 

concurrence with the majority of its designation recommendations dated December 10, 2013, and 

July 30, 2014. However, we urge EPA to reconsider its proposed PM2.5 nonattainment 

boundaries for Allegheny and Northampton Counties. To this end, DEP has completed 

additional analyses and requests the following changes to EPA's proposed designations for 

Pennsylvania: 

• Establish partial county designations for Allegheny County consistent with the 

nonattainment boundaries for the 1997 and 2006 PM2.

5 NAAQS. The nonattainment 

areas for the Liberty-Clairton area of Allegheny County should continue to be comprised 

of the City of Clairton and the Boroughs of Glassport, Liberty, Lincoln, and Port Vue. 

The remainder of Allegheny County, which is monitoring attainment of the 1997, 2006 

and 2012 PM2.s NAAQS, based on 2011-2013 design values, should be designated as an 

"unclassifiable/attainment" area. Historically, EPA has agreed that "a separate, 

distinctively local-source impacted, nonattainment area" is appropriate for the LibertyClairton area. Supporting documentation developed in consultation with the Allegheny 

County Health Department is outlined in Enclosure 1. 

Additionally, I have enclosed a recent letter (dated October 15, 2014) from Ken Zapinski, 

the Senior Vice President of Energy and Infrastructure for the Allegheny Conference on 

Community Development (ACCD), in support ofDEP's request for a partial county 

Rachel Carson State Office Building 1 P.O. Box 2063 1 Harrisburg, PA 17105-2063 

717.787.2814 (J2z_ Printed on Recycled Paper \6CJ www .depweb.state. pa. us 
Mr. Shawn M. Garvin -2- October 28, 2014 

Liberty-Clairton nonattainment area for the 2012 annual PM2.5 NAAQS (see 

Enclosure 2). ACCD expresses its concern that EPA has reversed its position that 

previously recognized the unique meteorology, topography and localized emissions in the 

Liberty monitoring area without reasonable justification. 

• Change the boundaries for the Allentown nonattainment area to include only 

Northampton County (see Enclosure 3). 

• Northampton County is expected to attain the PM2.5 standard, based on 2014 design 

values, prior to the effective date ofEPA's final designations (see Enclosure 4). 

The DEP respectfully requests that EPA modify its intended designations for the Allentown and 

Allegheny County areas, taking into consideration the significant air quality improvements and 

the additional documentation enclosed for your consideration. If any additional areas in 

Pennsylvania attain the PM2.5 NAAQS prior to the effective date of EPA's designations for the 

2012 PM2.s NAAQS, DEP will request withdrawal of the nonattainment designation for the area. 

Should you have questions or need additional information during the development of the final 

PM2.s NAAQS designations for Pennsylvania, please contact Joyce E. Epps, Director, Bureau of 

Air Quality, by e-mail atjeepps@pa.gov or by telephone at 717.787.9702. 

c;Ji(::bj 

Dana K. Aunkst 

Acting Secretary 

Enclosures 
Enclosure 1

The Commonwealth of Pennsylvania’s Response to the 

U.S. Environmental Protection Agency’s Proposed Designation of an 

Allegheny County Nonattainment Area for the 2012 Annual PM2.5

National Ambient Air Quality Standard

Bureau of Air Quality

Department of Environmental Protection
[This page intentionally left blank.]
- 1 -

The U.S. Environmental Protection Agency (EPA) promulgated the annual fine particulate 

matter (PM2.5) National Ambient Air Quality Standard (NAAQS) on December 14, 2012; the

standard was lowered to 12.0 micrograms per cubic meter (78 FR 3086; January 15, 2013). The 

Commonwealth of Pennsylvania submitted its recommendations to EPA, in accordance with 

Section 107 of the Clean Air Act, 42 U.S.C.A. § 7407, on December 10, 2013, and updated the

recommendation on July 30, 2014, based on 2011-2013 ambient air monitoring data.

In its August 19, 2014, letter to Governor Corbett, EPA noted that its intended designations 

concur with the DEP’s recommendations for Delaware and Lebanon County nonattainment 

areas. According to the August 19th letter, EPA intends to modify Pennsylvania's recommended 

boundaries for the Cambria County (Johnstown), Liberty-Clairton (Allegheny County), and 

Northampton County (Allentown) areas. Specifically, EPA intends to modify Pennsylvania’s 

designation recommendations by adding a portion of Indiana County to the Cambria County 

Area (referred to by EPA as the Johnstown Area), adding Lehigh County to the Northampton 

County Area (referred to by EPA as the Allentown Area), and expanding the Liberty-Clairton 

Area to include all, not just part, of Allegheny County. EPA also proposed to designate all other 

areas of the Commonwealth as unclassifiable/attainment areas.

In December 2013, Pennsylvania recommended a partial county Liberty-Clairton nonattainment 

area for the 2012 PM2.5 NAAQS consistent with the existing boundaries promulgated by EPA for 

the 1997 and 2006 PM2.5 NAAQS. The existing nonattainment boundaries for the LibertyClairton Area consist of the following municipalities in southeastern Allegheny County: the City 

of Clairton, Borough of Glassport, Liberty Borough, Borough of Lincoln and Port Vue Borough.

EPA concluded that the Commonwealth’s documentation support “a separate, distinctively localsource impacted, nonattainment area, within the Pittsburgh nonattainment area.”

1

In its August 19, 2014, letter to Governor Corbett, EPA proposed to expand the existing LibertyClairton nonattainment area to include all of Allegheny County for the 2012 annual PM2.5

National Ambient Air Quality Standard (NAAQS). However, an expansion of the boundaries of 

the existing Liberty-Clairton nonattainment areas for the 1997 and 2006 PM2.5 NAAQS is 

unwarranted.

The Pennsylvania Department of Environmental Protection (DEP) has conducted a 

comprehensive evaluation of EPA’s proposed designations for the 2012 annual PM2.5 NAAQS. 

Based on a further review and analysis of available data by DEP and the Allegheny County 

Health Department (ACHD), Pennsylvania disagrees with EPA’s enlargement of the proposed 

nonattainment area. The existing 1997 and 2006 PM2.5 NAAQS nonattainment boundaries for 

the Liberty-Clairton area should be retained for the 2012 annual PM2.5 standard.

The DEP worked in coordination with the ACHD to develop the supporting analysis in that 

justifies the partial county PM2.5 nonattainment area for the Liberty-Clairton Area. DEP

recommends that EPA designate five municipalities in southeastern Allegheny County, the City 

of Clairton, the City of McKeesport and the Boroughs of Glassport, Liberty, Lincoln and Port 

 

1

2006 24-Hour PM2.5 Standards – EPA response to Pennsylvania’s recommendations. Addendum 2 - “EPA 

Technical Analysis for Liberty-Clairton Area”. 

http://www.epa.gov/airquality/particlepollution/designations/2006standards/rec/letters/03_PA_EPAMOD3.pdf
- 2 -

Vue as a partial county nonattainment area. The remainder of Allegheny County should be 

designated as an unclassifiable/attainment area. The information contained in this enclosure 

supplements the information DEP submitted to EPA on December 10, 2013, and July 30, 2014.

BACKGROUND AND OVERVIEW

On July 1, 1987, EPA revised the NAAQS for particulate matter, replacing total suspended 

particulates as the indicator for particulate matter with a new indicator called PM10, or particles 

having a diameter less than or equal to 10 micrometers (μg/m3).

2

 The EPA divided the country 

into three categories, Groups I, II and III, based on their probability of violating the new 

NAAQS. On August 7, 1987, EPA classified Allegheny County as a Group II area.

3

 Later, the 

ACHD recommended a smaller Group II area consisting of the City of Clairton, the City of 

McKeesport and the Boroughs of Glassport, Liberty, Lincoln and Port Vue. EPA clarified the 

area as the City of Clairton and Boroughs of Glassport, Liberty, Lincoln and Port Vue.

4

EPA 

later referred to the same area as the “Clairton & 4 Boroughs area” or the “Liberty-Clairton 

area.” The City of McKeesport was not included in the Group II area for the 1987 PM10

NAAQS. Pursuant to Section 107(d)(4)(B) and 188(a) of the Clean Air Act, areas which had 

monitored violations of the PM10 NAAQS prior to January 1, 1989, were, by operation of law, 

upon enactment of the 1990 CAA amendments on November 15, 1990, designated 

nonattainment and classified as moderate for PM10.

On July 18, 1997, EPA published annual and 24-hour primary and secondary standards for fine 

particulate matter (PM2.5). In February 2004, DEP submitted a letter to EPA with area 

recommendations for the 1997 annual PM2.5 NAAQS, which included the recommendation that 

all of Allegheny County be included as part of the Pittsburgh-Beaver Valley nonattainment area. 

In August 2004, after further analysis and the issuance of new EPA guidance, DEP submitted a 

revised recommendation that EPA designate two separate partial county nonattainment areas

within Allegheny County: the Liberty-Clairton Area and a separate North Braddock Area. The 

Liberty-Clairton Area included the City of Clairton and the Boroughs of Glassport, Liberty, 

Lincoln, and Port Vue. The proposed North Braddock nonattainment area included Braddock 

Borough and North Braddock Borough. The separate area for Liberty-Clairton was justified by 

DEP as being necessary because it would take Liberty-Clairton Area longer to come into 

compliance than the rest of Allegheny County due to the localized influences of industry 

emissions, meteorology, and topography.

On January 5, 2005, EPA published a final rule that included the designation of the LibertyClairton Area as a separate partial county nonattainment area for the 1997 standard.

5

 EPA also 

established a separate nonattainment area for the Pittsburgh-Beaver Valley Area including 

Beaver, Butler, Washington and Westmoreland Counties and portions of Armstrong, Green and 

Lawrence Counties. The recommended North Braddock area was also included within the larger 

Pittsburgh-Beaver Valley Area.

 

2

52 FR 24,634; July 1, 1987

3

52 FR 29,383; August 7, 1987

4

55 FR 45,799; October 31, 1990

5

70 FR 944; January 5, 2005. Effective April 5, 2005.
- 3 -

On October 17, 2006, EPA lowered the 24-hour PM2.5 standard from 65 μg/m3to 35 μg/m3. On 

December 28, 2007, DEP submitted designation recommendations to EPA for the 2006 24-hour 

PM2.5 NAAQS. These recommendations included a recommendation for the same partial county

Liberty-Clairton nonattainment area for the 2006 PM2.5 NAAQS. As supporting factors for a 

separate Liberty-Clairton nonattainment area, DEP specifically noted in that submittal:

Annual and 24-hour PM2.5 design values are much higher, particularly at the Liberty 

monitor, than the surrounding areas. There are significant differences between the two 

monitors within the PM2.5 nonattainment area with the Liberty monitor being 

significantly over the annual standard and the Clairton monitor recently just meeting the 

annual standard... Twenty-four hour PM2.5 concentrations are also significantly 

different (~30 μg/m3). This steep gradient between these two nearby monitors suggests a 

local source with enhancements from local topography is contributing to the 

nonattainment area’s relatively high 24-hour and annual PM2.5 design values. A smaller 

nonattainment area is therefore justified.

EPA’s technical support document (TSD) analysis for the 2006 24-hour PM2.5 NAAQS for the 

Liberty-Clairton area notes on page 2 that,

For the designations for the 1997 PM2.5 NAAQS, the Commonwealth of Pennsylvania 

provided extensive documentation to support a recommendation that a separate, 

distinctively local-source impacted, nonattainment area be designated within the 

Pittsburgh nonattainment area. The recommended Liberty-Clairton area was specified as 

the five municipalities which comprise the area in the vicinity of the Clairton Coke 

Works which were previously designated nonattainment for PM-10 standard as the 

“Clairton & 4 Boroughs area.”

The Clairton Coke Works is a large and complex facility that emits a combination of 

particulates, sulfur dioxide, ammonia, and hundreds of volatile organic chemicals. 

Although the coke plant has numerous existing emission controls, the combination of a 

large amount of low-level emissions in a narrow river valley creates a local air quality 

problem which is uniquely different from the remainder of the area.

On page 3 of the EPA TSD analysis, the agency stated that monitors in Allegheny County 

correlate well, except for the Liberty monitor. EPA indicated that concentrations of carbon at the 

Liberty monitor far exceed those at other monitors in the area.

On October 20, 2008, DEP submitted a response to EPA’s proposed designations for the 2006 

24-hour PM2.5 NAAQS stating in part that,

DEP has demonstrated in the past that fine particle levels at the Liberty monitor do not 

correlate well with the monitors in the surrounding nonattainment area [the PittsburghBeaver Valley nonattainment area] due to local source influences. The Liberty-Clairton 

nonattainment area was created to allow DEP and the Allegheny County Health 

Department to address the local impacts that contribute to this area’s nonattainment.
- 4 -

On November 13, 2009, EPA published a final rule designating the same Liberty-Clairton Area 

as a separate nonattainment area for the 2006 24-hour PM2.5 NAAQS, with the remainder of 

Allegheny County again being included in the Pittsburgh-Beaver Valley Area (along with the 

Beaver, Butler, Washington and Westmoreland Counties and portions of Armstrong, Green and 

Lawrence Counties).

6

On December 13, 2012, EPA promulgated a primary annual PM2.5 NAAQS of 12.0 μg/m3. On 

December 10, 2013, DEP recommended that the Liberty-Clairton Area be designated as 

nonattainment for the 2012 annual PM2.5 NAAQS, based primarily on 2010-2012 air quality 

data. The DEP recommended that the remainder of Allegheny County, as well as Westmoreland 

County, establish boundaries for a Greater Pittsburgh nonattainment area, because this area 

contained three monitors that exceeded the new PM2.5 standard of 12.0 μg/m3. These monitors 

included Avalon and North Braddock in Allegheny County and Greensburg in Westmoreland 

County. The remainder of the former Pittsburgh-Beaver Valley Area (Beaver, Butler, 

Washington Counties and portions of Armstrong, Green and Lawrence Counties) was

recommended as either attainment or unclassifiable/attainment areas because the monitors

recorded PM2.5 concentrations below the standard. DEP determined that these areas were not

contributing to exceedances in a nonattainment area.

On July 30, 2014, DEP provided EPA with updated area recommendations for the 2012 PM2.5

NAAQS following the review of 2011-2013 air quality data. The 2013 design values for 

monitors in Allegheny County (except for the Liberty-Clairton Area) and Westmoreland County

are below 12.0 μg/m3. Therefore, DEP recommended that EPA designate these areas attainment 

areas.

On August 19, 2014, EPA sent Governor Corbett a 120-day letter and technical support 

document indicating the intent to modify Pennsylvania’s recommended area boundaries for the 

Liberty-Clairton Area, among others. EPA noted its intention to designate all of Allegheny 

County as the Allegheny County nonattainment area, expanding the existing partial county

Liberty-Clairton nonattainment area to include the entire county.

For the 1997 annual and 2006 24-hour standards, the Liberty-Clairton area is a separate 

nonattainment area from the remainder of Allegheny County. As explained above, the remainder

of Allegheny County is part of a separate Pittsburgh-Beaver Valley nonattainment area. EPA 

agreed with the DEP recommendation for separate partial county nonattainment areas because 

the Liberty monitor did not correlate well with the other monitors in the area. As expected, due 

to localized impacts and topography, the Liberty monitor is not attaining the 2006 or 2012 PM2.5

standards – the other monitors in Allegheny County are attaining the 1997, 2006 and 2012 PM2.5

standards. With the monitors in the Pittsburgh-Beaver Valley nonattainment area attaining the 

standards, including seven monitors in Allegheny County (the lone exception being the Liberty 

monitor), now is not the time for EPA to depart from its current designations for the LibertyClairton Area, which are “separate and distinct from the Pittsburgh-Beaver Valley PM2.5

nonattainment area.”

 

6

74 FR 58,688; November 13, 2009. Effective December 14, 2009.
- 5 -

1. AIR QUALITY DATA

1.1. PM2.5 Annual Mean and Design Value Data

Table 1.1 and Figure 1.1 of this analysis show the downward trend for annual PM2.5 mean values 

monitored in Allegheny County, with the Liberty monitor constantly at a higher value than the 

rest of the monitors in the region. In 2012, the only monitor with an annual mean above 

12.0 μg/m3 was the Liberty monitor. It should be noted that 2013 was the first year that all 

monitors within Allegheny County, except the Liberty monitor were below the 2012 annual 

PM2.5 NAAQS. This downward trend is expected to continue due to significant reductions in 

PM2.5 and precursor emissions including sulfur dioxide emissions. The data represents Federal 

Reference Method (FRM) monitored results, except for Federal Equivalent Method (FEM) 

monitored data at Avalon over the timeframe January 2010-May 2011.

Table 1.1. PM2.5 Annual Mean (in μg/m3) by Station, 2010-2013

Station AQS Code 2010 2011 2012 2013

Avalon 42-003-0002 16.34 13.11 10.89 10.24

Lawrenceville 42-003-0008 12.16 11.11 10.05 9.76

Liberty 42-003-0064 16.04 14.00 14.29 11.98

South Fayette 42-003-0067 11.67 10.59 9.16 8.93

North Park 42-003-0093 10.51 9.04 8.58 8.68

Harrison 2 42-003-1008 13.01 11.57 10.45 9.65

North Braddock 42-003-1301 13.71 12.27 11.51 11.22

Clairton 42-003-3007 12.47 10.72 9.39 9.41

Figure 1.1. PM2.5 Annual Mean by Station, 2001-2013

*Please note: The Avalon monitor was deployed in 2010; North Park monitor did not run in 2008.

6

8

10

12

14

16

18

20

22

24

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013

Concentration (μg/m3

)

Avalon

Lawrenceville

Liberty

South Fayette

North Park

Harrison 2

North Braddock

Clairton
- 6 -

Table 1.2 and Figure 1.2 show the downward trend for annual PM2.5 design values monitored in 

Allegheny County, with the Liberty monitor consistently at a higher value than the rest of the 

monitors in the area. Only two monitoring sites, in addition to Liberty, were above 12.0 μg/m3 

based on 2010-2012 data. In 2013, the only monitor with an annual PM2.5 design value (DV) 

above 12.0 μg/m3 was the Liberty monitor. Several sites have shown consecutive years of 

attainment of the 2012 annual PM2.5 NAAQS (discussed further in Section 1.2).

As the EPA TSD analysis points out,

The PM2.5 DVs at seven of the eight monitors correlate well. However, the PM2.5 DV at 

the Liberty monitor is considerably higher. The large local sources plus the unique 

topographical features in this location result in substantially higher PM2.5 monitored 

values at the Liberty monitor than the other monitors in Allegheny County.

Table 1.2. PM2.5 Annual Design Value (in μg/m3) by Station, 2010-2013

Station AQS Code 2010 2011 2012 2013

Avalon 42-003-0002 N/A N/A 13.4 11.4

Lawrenceville 42-003-0008 12.2 11.6 11.1 10.3

Liberty 42-003-0064 16.0 15.0 14.8 13.4

South Fayette 42-003-0067 11.1 11.0 10.5 9.6

North Park 42-003-0093 10.1 9.7 9.4 8.8

Harrison 2 42-003-1008 13.0 12.4 11.7 10.6

North Braddock 42-003-1301 13.3 12.7 12.5 11.7

Clairton 42-003-3007 12.4 11.5 10.9 9.8

Figure 1.2. PM2.5 Annual Design Value by Station, 2001-2013

*Please note: The Avalon monitor was deployed in 2010; North Park monitor did not run in 2008.

6

8

10

12

14

16

18

20

22

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013

Concentration (μg/m3

)

Avalon

Lawrenceville

Liberty

South Fayette

North Park

Harrison 2

North Braddock

Clairton
- 7 -

It is likely that the Liberty-Clairton Area could come into attainment in the near future, 

particularly since the higher annual PM2.5 mean values of 14.00 μg/m3in 2011 and 14.29 μg/m3

in 2012 will drop off of the 2015 design value calculation (the 2015 DV will be the 3- year 

average of the 2013, 2014 and 2015 annual mean). For the first time, in 2013, the LibertyClairton annual mean value was below the 2012 standard of 12.0 μg/m3

, with a value of 

11.98 μg/m3.

Table 1.3 provides quarterly PM2.5 emissions for Allegheny County in 2014 through the second 

quarter. Again, the data shows that the Liberty monitor is consistently higher than the rest of the

monitors in Allegheny County. This data should be viewed with caution, as one or two quarterly 

averages above 12.0 μg/m3does not equate to a violation of the standard. This information is 

only being provided to show the most recent monitoring data trends and to point out that the 

Liberty monitor is consistently monitoring PM2.5 concentrations above all other monitors in 

Allegheny County.

Table 1.3. Allegheny County PM2.5 Monitoring Station Data 

2014 Quarterly Averages to Date

Station AQS Code 1

st Quarter 

Average 

(μg/m3)

2

nd Quarter 

Average 

(μg/m3)

Avalon 42-003-0002 11.97 10.17

Lawrenceville 42-003-0008 11.03 9.93

Liberty 42-003-0064 14.73 12.50

South Fayette 42-003-0067 8.91 8.71

North Park 42-003-0093 8.91 8.75

Harrison 2 42-003-1008 10.17 10.25

North Braddock 42-003-1301 12.46 11.88

Clairton 42-003-3007 12.29 9.51

The Liberty monitor, in fact, shows noticeably higher PM2.5 concentrations than most of the 

design value monitors throughout the U.S. Figure 1.3 is a chart of annual PM2.5 design values 

for 2001-2013, averaged by region, comparing PM2.5 design values for Liberty-Clairton to other 

previously designated nonattainment areas.
- 8 -

Figure 1.3. Annual PM2.5 Design Value Trends for U.S. Regions, 2001-2013

Data taken from http://www.epa.gov/airtrends/pdfs/PM25_DesignValues_20112013_FINAL_08_28_14.xlsx

Region States Included in 

Areas Region States Included in Areas

California CA Midwest OH,IL,IN,MI

Liberty-Clairton PA Ohio Valley IN,KY,MO,OH,WV

Pittsburgh-Beaver PA Montana MT

Northeast CT,DE,MD,NY,NJ,PA Southeast AL,GA,NC

The Liberty-Clairton Area (driven by data from the Liberty monitor) shows historical and current 

PM2.5 design values that are above the rest of the country, with the exception of California; all 

other areas show similar design values, including the Pittsburgh-Beaver Valley area.

1.2. PM2.5 Monitor Network by Site

While PM2.5 concentrations at each site are used for comparison to the 2012 PM2.5 NAAQS, the 

individual site details should also be considered in making area designations. Details include 

factors such as monitor type, measurement scale, and dominant source(s) for each monitor. All 
- 9 -

monitors are sited according to EPA criteria and located in residential communities for the 

objective of population exposure.

Avalon PM2.5 Monitor (42-003-0002):

The Avalon PM2.5 monitor is located in a developed medium-intensity (by National Land Cover 

Database (NLCD) 2006 classification) suburb, downwind of the Neville Island industrial area, 

8.7 kilometers (km) to the northwest of downtown Pittsburgh. This monitor can be affected on a 

neighborhood scale (0.5-4.0 km) by industrial emissions from the DTE Energy Shenango plant, 

which is currently under a consent agreement with ACHD for emissions violations.

The Avalon PM2.5 monitor was one of two monitors other than Liberty that exceeded the 2012 

annual PM2.5 NAAQS based on 2010-2012 data. However, data for 2010 through May 2011 are 

biased by beta-attenuation monitor (BAM) data that was submitted prior to installation of the 

FRM monitor in June 2011. Although the BAM monitor is an equivalent method, concurrent 

BAM and FRM comparisons after June 2011 were found to be non-equivalent.

The FEM comparability results for the Avalon BAM, matched to FRM data from June 2011-

December 2012, are shown in Figure 1.3.

Figure 1.3. Avalon BAM/FRM Comparability

As a result, only the FRM data has been submitted since June 2011. While the BAM data is 

official data for January 2010-May 2011 with no collocated FRM for comparison, the Avalon 

BAM likely represents non-equivalent data to the FRM. DEP contends that the 2011-2013 
- 10 -

design value is the most appropriate design value for comparison to the 2012 annual PM2.5

NAAQS compared to previous 3-year periods.

North Braddock PM2.5 Monitor (42-003-1301):

The North Braddock PM2.5 Monitor is located in a developed medium-intensity suburb, 12.5 km 

to the east-southeast of downtown Pittsburgh, near the U.S. Steel Edgar Thomson Plant. This 

monitor can be affected on a neighborhood scale by industrial emissions from Edgar Thomson, 

and North Braddock was one of the two monitors aside from Liberty that exceeded the 2012 

annual PM2.5 NAAQS based on 2010-2012 data. U.S. Steel is currently under a Consent Order 

and Agreement with ACHD for emissions violations, which has contributed to a lower 2012 

PM2.5 design value at North Braddock below 12.0 μg/m3, based on 2011-2013 data.

Harrison PM2.5 Monitor (42-003-1008):

The Harrison PM2.5 Monitor is located in a developed medium-intensity suburb, 30.1 km to the 

northeast of downtown Pittsburgh, and may have been affected previously by the nearby 

Allegheny Ludlum facility on a neighborhood scale. Allegheny Ludlum performed major 

modifications to reduce emissions from the facility. Based on 2013 design values, the Harrison 

monitor shows attainment of PM2.5 NAAQS including the 2012 PM2.5 annual standard.

Clairton PM2.5 Monitor (42-003-3007):

The Clairton PM2.5 Monitor is located in a developed medium-intensity suburb, 18.8 km to the 

south-southeast of downtown Pittsburgh. This monitor is located within the Liberty-Clairton 

area, adjacent to the U. S. Steel Clairton Plant on a neighborhood scale. This site lies upwind of 

the Clairton Plant, however, and is not affected by nearby emissions in the same manner as 

Liberty. Based on 2011-2013 data, the current design value for the Clairton monitor is 9.8 μg/m3

– substantially lower than the 2012 PM2.5 NAAQS. Large differences between Clairton and 

Liberty (only 3.5 km away) on concurrent sample days indicate the extremely localized nature of 

PM2.5 at the Liberty monitor.

South Fayette PM2.5 Monitor (42-003-0067):

The South Fayette PM2.5 monitor is located in a developed low-intensity suburb, 16.1 km to the 

southwest of downtown Pittsburgh. South Fayette is a high-elevation site, considered to be 

representative of regional-scale background concentrations. This monitor has attained the 2012 

annual PM2.5 NAAQS. The monitor also meets the 1997 and 2006 standards.

North Park PM2.5 Monitor (42-003-0093):

The North Park PM2.5 monitor is located in a developed low-intensity suburb, 18.5 km to the 

north of downtown Pittsburgh. The PM2.5 concentrations for North Park are representative of 

northern suburb concentrations on a neighborhood scale, mostly from area and mobile source 

emissions. Based on a 2011-2013 design value of 8.8 μg/m3, this monitor has attained the 2012 

annual PM2.5 NAAQS.
- 11 -

Lawrenceville PM2.5 Monitor (42-003-0008):

The Lawrenceville PM2.5 monitor is located in a developed high-intensity district of the City of 

Pittsburgh, the only PM2.5 site within the city limits, 4.2 km from downtown Pittsburgh. It has 

been classified by EPA as an urban National Core (NCore) Monitoring site, with multiple 

pollutant monitors. It is the best representative monitor of urbanized emissions in Pittsburgh 

from mobile, area, and light industrial sources on an urban scale (4-50 km). Based on 2011-2013 

data, Lawrenceville is monitoring attainment (of 10.3 μg/m) of the 2012 annual PM2.5 NAAQS.

Liberty PM2.5 Monitor (42-003-0064):

The Liberty PM2.5 monitor is located in a developed low-intensity suburb, 17.1 km to the southsoutheast of downtown Pittsburgh. It is the driving design monitor within the Liberty-Clairton 

area, immediately downwind of the Clairton Coke Works Plant.

Concentrations are strongly affected by temperature inversions and complex river valley terrain, 

and PM2.5 concentrations for the Liberty can differ greatly from any other monitor in the county 

on concurrent sample dates. As seen in Table 1.4, the Liberty monitor shows the highest 

standard deviation in concentrations of the monitor network due to these higher values.

Table 1.4. PM2.5 Concentration Averages and Standard Deviations

Site

Average 

Concentration

2011-2013

Standard 

Deviation

2011-2013

Liberty 13.4 8.6

North Braddock 11.6 6.5

Avalon 11.1 5.7

Harrison 10.5 5.4

Lawrenceville 10.3 5.1

South Fayette 9.6 5.1

Clairton 9.8 4.7

North Park 8.8 4.6

The Liberty monitor is essentially a statistical outlier for PM2.5 compared to the rest of the 

monitoring network.

1.3. PM2.5 Monitor Network Assessment

As required by amended 40 CFR Part 58, a Monitor Network Assessment was completed for the 

Allegheny County PM2.5 network in July 2010. Although this assessment is now somewhat 

outdated, with the next assessment due July 2015, analyses provided in the assessment may still 

be relevant for the network. (Note that, at this time, the PC-based EPA network assessment tools 

cannot be updated by the user with more recent data.)
- 12 -

Correlation Matrix:

Correlation matrices were utilized in the network assessment to examine consistency and 

correlation of monitors with the network. Figure 1.5 shows the correlation matrix for PM2.5

FRM monitors based on 2006-2008 averages.

PM2.5 monitors from Beaver, Washington, and Westmoreland Counties (420070014, 421250005, 

421290008) were included to examine consistency throughout the Pittsburgh MSA. (Note: 

North Park and South Fayette were excluded from the EPA correlation matrix tool due to low 

data recovery in one or more calendar quarters.)

Figure 1.5. Correlation Matrix for PM2.5

The 2006-2008 matrices showed that the Lawrenceville PM2.5 monitor had the best overall 

correlation and lowest relative difference compared to other southwestern Pennsylvania (SWPA)

monitors, indicating consistency and representativeness within the network. The Liberty monitor 

shows the lowest correlation and highest relative difference to the rest of the network, indicating 
- 13 -

inconsistency with the network and supporting the appropriateness of a separate Liberty-Clairton 

nonattainment area.

Network Rankings:

Rankings values were compiled for the network assessment based on design values, site 

objectives, population densities, and other factors.

Rankings from the 2010 Network Assessment are shown in Table 1.5.

Table 1.5. PM2.5 FRM Rankings

Based on 2006-2008 factors, many of which are the same for 2011-2013 data, the Liberty PM2.5

monitor showed the highest rank for Allegheny County, mostly due to the highest design value. 

The Lawrenceville monitor was second in rank based on its importance to the network, including 

representativeness of the urban Pittsburgh area based on population density.
- 14 -

1.4. Multi-Pollutant Comparisons

PM2.5 shows a source-based relationship to SO2 at the Liberty monitor which is not seen at the 

Lawrenceville monitor. Elevated levels of PM2.5 often accompany SO2 exceedances at Liberty 

during poor dispersion conditions. Additionally, PM2.5 and SO2 exhibit different hourly behavior 

at Liberty compared to other sites.

Figures 1.6 and 1.7 are scatter plots for the Liberty and Lawrenceville monitors, SO2 vs. PM2.5, 

daily maximum 1-hour values, for 2011-2013. Hourly data for PM2.5 is measured by tapered 

element oscillating microbalance (TEOM) PM2.5 monitors at both Liberty and Lawrenceville.

Figure 1.6. SO2 vs. PM2.5 TEOM Daily Maximums, Liberty, 2011-2013
- 15 -

Figure 1.7. SO2 vs. PM2.5 TEOM Daily Maximums, Lawrenceville, 2011-2013

It should be noted that ‘r’ is the correlation coefficient, and ‘r2’ is the coefficient of 

determination. The correlation coefficient between two variables is measured by the strength 

and direction of a linear relationship. The coefficient of determination is indicative of how well 

the regression line represents the data. If the regression line would pass through each data point 

on a scatter plot, then this would explain all of the variation. The further away the line is from 

each of the points, the less that it is able to be explained.7

The Liberty monitoring site shows a “high positive correlation,” where r=0.72 (r2=0.52 in Figure 

1.6) for SO2 and PM2.5, while samplers at the Lawrenceville monitoring site show a “negligible 

correlation” of r=0.19 (r2=0.0345 in Figure 1.7) between the two pollutants. At the Liberty

monitoring site, for every increase in SO2 concentration, there is an increase in PM2.5 by 667.93 

times the value of SO2 plus 17.485 μg/m3.

8

Of the 37 exceedances of the SO2 daily maximum 2010 1-hour NAAQS at Liberty during 

2011-2013, over 80% occurred when the FRM 24-hour value was above 20 μg/m3, as shown 

below in Table 1-6.

 

7

http://mathbits.com/MathBits/TISection/Statistics2/correlation.htm

8

http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3576830/table/T1/
- 16 -

Table 1.6. FRM Ranges and SO2 Exceedances

FRM Range Number of SO2 

Exceedance Days

> 40 μg/m3 9

30-40 μg/m3 13

20-30 μg/m3 8

10-20 μg/m3 7

Figures 1.8 and 1.9 are hourly average charts for SO2 sites and continuous PM2.5 sites in 

Allegheny County.
- 17 -

Figure 1.8. Hourly Average SO2, Allegheny County Sites, 2011-2013

Figure 1.9. Hourly Average PM2.5 (TEOM), Allegheny County Sites, 2011-2013
- 18 -

The Liberty monitoring site shows nearly identical diurnal behavior on an hourly basis, with 

elevated levels occurring at night for both SO2 and PM2.5. This diurnal trend is unique to 

Liberty, as the other sites show peaks only during rush hour or daytime conditions.

1.5. Speciation Data

Raw speciation data was examined for tri-state monitoring sites for the period 2011-2013. These 

sites include Lawrenceville and Liberty in Allegheny County, Florence and Greensburg within 

the surrounding Pittsburgh MSA in PA, and rural federal sites at Quaker City, OH and 

Dolly Sods, WV.

The Florence (Washington Co.) and Greensburg (Westmoreland Co.) monitoring sites reside 

upwind and downwind of Allegheny County, respectively. These sites are 1-in-6 sites, operated 

by DEP.

The Quaker City monitoring site is a 1-in-3 CASTNET site operated by EPA, and Dolly Sods is 

a 1-in-3 IMPROVE site operated by the U.S. Forest Service. The Quaker City and Dolly Sods 

sites have been used by EPA as background speciation sites for the Pittsburgh area.

The Lawrenceville monitoring site is a 1-in-3 site, while Liberty is a 1-in-6 site. For sites with 

higher sampling frequencies (1-in-3), long-term averages represent a larger array of values. 

Figure 1.10 shows a map of these sites in Ohio, Pennsylvania and West Virginia.

Figure 1.10. Tri-State Speciation Sites

Long-term averages of the raw major species data for the tri-state sites are shown in cluster 

columns in Figure 1.11.
- 19 -

Figure 1.11. Tri-State Major Species Averages, 2011-2013

PM2.5 speciation data shows specific composition at the Liberty monitoring station that is not 

consistent with other SWPA (or tri-state) speciation monitors. Specific species such as sulfate 

show homogeneity throughout the MSA.

The raw data for speciation monitors are based on different analytical methods and can include 

some amount of error between the measurements. To relate the speciation monitor data to FRM 

data, EPA’s SANDWICH (Sulfate, Adjusted Nitrate, Derived Water, Inferred Carbon Hybrid) 

method was used to adjust the major species. The 2010-2012 timeframe was used for the 

SANDWICH data, since it was the most recent 3-year period available from EPA. (See EPA 

PM2.5 SANDWICH data at http://epa.gov/ttn/analysis/sandwich.htm)

Figure 1.12 shows the average tri-state species for 2010-2012 by SANDWICH method. Note 

that several assumptions are built into the SANDWICH technique:

 Retained nitrate (NO3r) is calculated by EPA from temperature, relative humidity, and 

dissociation constants;

 OCMmb is organic carbonaceous material by mass balance (total minus other species);

 Ammonium is calculated indirectly from sulfate and nitrate and degree of neutralization;

 Without measured ammonium at federal sites, ammonium is derived as fully neutralized 

sulfate;

 For cases where no FRM value is present, STN mass is used.
- 20 -

Figure 1.12. Tri-State SANDWICH Species Averages, 2010-2012

Legend: SO4 = sulfate ion; NO3r = retained nitrate ion; NH4r = retained ammonium ion (associated with sulfate and nitrate);

PBW_aim = particle-bound water (associated with sulfate and nitrate), calculated from the AIM model;

EC = elemental carbon; OCMmb = organic carbonaceous material by mass balance (FRM mass minus all other species);

Cr_alt = crustal material calculated from Ca, Fe, Si, Ti; Cl = elemental chlorine

The SANDWICH method transforms the species compositions into more probable components 

based on the FRM data. The Liberty monitor shows higher data than other sites for sulfate and 

elemental carbon, while other species such as organic carbonaceous material by mass balance are 

normalized throughout the Pittsburgh MSA by the SANDWICH calculations.

Assuming spatial homogeneity throughout the tri-state region, the SANDWICH data can also be 

lumped into average area contributions for each species. For this analysis, rural transported 

background is considered to be the average of the rural federal sites (Quaker City, OH and 

Dolly Sods, WV), surrounding MSA increment is the average of surrounding Pittsburgh MSA 

sites (Florence and Greensburg), Lawrenceville is the urban increment monitor for Allegheny 

County, and Liberty is a localized industrial excess monitor.

SANDWICH concentrations by area contribution/excess are shown in the stacked column chart 

in Figure 1.13.
- 21 -

Figure 1.13. SANDWICH Averages by Area Contribution, 2010-2012

Example calculation: Liberty Excess SO4 = Liberty SO4 – Lawrenceville SO4 – Avg(Florence SO4 + Greensburg SO4) –

Avg (Quaker City SO4+ Dolly Sods SO4)

Figure 1.13 indicates that Liberty monitoring site shows excess contributions of carbons and 

sulfate for the tri-state area, as well as the only source of excess elemental chlorine. These 

compounds are very specific to local source contributions.

The surrounding MSA shows a large increment of organic carbonaceous material, indicating that 

the larger metropolitan area contributes significant wide-spread area, mobile, and point source 

emissions. The rural background sites show large contributions for sulfate, nitrates, as well as a 

portion of the organic carbonaceous material, indicating a regionally transported nature for these 

species.

The City of Pittsburgh contributes only small amounts of urban increment for species, showing 

that Allegheny County is contributing minimal urban influence for PM2.5 in comparison to the 

surrounding area.

This can also be demonstrated by showing the area contributions by scaled pie charts, shown in 

Figure 1.14.
- 22 -

Figure 1.14. Pie Charts for SANDWICH Species by Area Contribution, 2010-2012

Pittsburgh urban increment is a minor component of PM2.5 in SWPA that is not contributing to 

exceedance levels of PM2.5. Other area components contribute significantly larger amounts and 

in varying overall composition.

Additionally, the amount of excess ammonium sulfate at the Lawrenceville site may not be due 

to additional contributions from Allegheny County, but rather the neutralization of upwind 

incoming sulfuric acid into the area.

The degree of neutralization (DON) is a measure of the amount of ammonium associated with 

sulfate, up to 0.375 (complete neutralization to (NH4)2SO4, based on molar ratios). Figure 1.15

shows the average DON for SWPA sites.
- 23 -

Figure 1.15. Average DON Values for SWPA Sites

The increasing DON ratios from west to east indicate that more acidic conditions are present 

with incoming air in the Pittsburgh region. Transported sulfuric acid (H2SO4) may be fresher or 

limited by NH3 and partially neutralizing to ammonium bisulfate (NH4HSO4). Sulfate may be 

higher at Lawrenceville due to the time and distance required to neutralize sulfur compounds 

from outside of the county.
- 24 -

2. EMISSIONS AND EMISSIONS-RELATED DATA

2.1. Allegheny County Emissions Inventory

The EPA TSD analysis on emissions data was based on the 2011 National Emissions Inventory 

(NEI). Table 2h on page 92 of EPA’s TSD analysis indicated major point source emissions from 

version 1 of the 2011 NEI, in tons per year. Table 2h listed facilities and facility-level emissions 

in the area of analysis for the Allegheny County area. In this table, EPA documented nine major

facilities in Allegheny County (in addition to facilities outside of the county) with emissions of 

direct PM2.5, components of direct PM2.5 and precursor pollutants. Table 2.1 shows the 2011 

NEI data for the nine Allegheny County facilities.

Table 2.1. Allegheny County Facilities Over 500 Tons of Emissions in 2011 NEI

Facility Name

(Facility ID)

Distance 

from 

violating 

monitor 

(miles)

NH3 NOX PM2.5 SO2 VOC Total

USS/Clairton Coke 

Works (4200300032) 1 123 3,075 500 1,468 336 5,502

Us Steel Corp/Irvin Plant 

(4200300203) 2 4 762 72 419 61 1,318

USS Corp/Edgar 

Thomson Works 

(4200300202)

5 22 275 633 1,279 41 2,250

Guardian Ind Corp

/Jefferson Hills 

(4200300342)

5 0 978 22 73 19 1,092

Bay Valley Foods LLC

/Pgh (4200300024) 11 0 212 20 313 1 546

Genon Energy Inc

/Cheswick Sta 

(4200300157)

15 3 3,294 498 9,290 10 13,095

Shenango Inc /Shenango 

Coke Plant (4200300022) 16 3 427 97 372 100 999

Allegheny Ludlum LLC

/Brackenridge 

(4200300093)

21 4 255 223 33 62 577

Pittsburgh International* 23 0 13 3 0 28 44

TOTAL 159 9,291 2,068 13,247 658 25,423

*Pittsburgh International was altered in the 2011 NEI from what PA submitted, which was 44 total tons for 2011. EPA’s TSD, 

Table 2h, listed Pittsburgh International as emitting 729 total tons per year.
- 25 -

The DEP reviewed these same nine facilities in its Air Information Management System (AIMS)

database for the 2013 calendar year. The 2013 emissions for each of the nine Allegheny County

facilities are provided below in Table 2.2.

Table 2.2. Facilities in Allegheny County with Emissions in Tons in 2013

Identified in PA DEP’s AIMS Database

Facility Name

(Facility ID)

Distance 

from 

violating 

monitor 

(miles)

NH3 NOX PM2.5 SO2 VOC Total

USS/Clairton Coke 

Works (4200300032) 1 145 3,761 327 1,637 307 6,177

Us Steel Corp/Irvin Plant 

(4200300203) 2 3 754 43 507 70 1,377

USS Corp/Edgar 

Thomson Works 

(4200300202)

5 22 320 43 1,454 40 1,879

Guardian Ind Corp

/Jefferson Hills 

(4200300342)

5 0 470 21 70 12 573

Bay Valley Foods LLC

/Pgh (4200300024) 11 1 145 2 209 2 359

Genon Energy Inc

/Cheswick Sta 

(4200300157)

15 1 5,333 88 1,686 11 7,119

Shenango Inc /Shenango 

Coke Plant (4200300022) 16 3 392 35 285 93 808

Allegheny Ludlum LLC

/Brackenridge 

(4200300093)

21 4 222 93 31 57 407

Pittsburgh International 23 0 10 3 0 21 34

TOTAL 179 11,407 655 5,879 613 18,733

Emission totals for the nine facilities in Allegheny County are compared between 2011 and 2013 

in Table 2.3.
- 26 -

Table 2.3. Emission Differences Between 2011 and 2013 for Facilities in Allegheny County

Facility Name (Facility ID) 2011 

Totals

2013 

Totals Difference Percent Change

USS/Clairton Coke Works (4200300032) 5,502 6,177 675 12.3%

Us Steel Corp/Irvin Plant (4200300203) 1,318 1,377 59 4.5%

USS Corp/Edgar Thomson Works 

(4200300202) 2,250 1,879 -371 -16.5%

Guardian Ind Corp/Jefferson Hills 

(4200300342) 1,092 573 -519 -47.5%

Bay Valley Foods LLC/Pgh (4200300024) 546 359 -187 -34.2%

Genon Energy Inc/Cheswick Sta (4200300157) 13,095 7,119 -5,976 -45.6%

Shenango Inc/Shenango Coke Plant 

(4200300022) 999 808 -191 -19.1%

Allegheny Ludlum LLC/Brackenridge 

(4200300093) 577 407 -170 -29.5%

Pittsburgh International* 44* 34* -10* -22.7%

GRAND TOTAL 25,423 18,733 -6,690 -26.3%

*Based on DEP databases. EPA adjusted the emission numbers submitted by PA for the 2011 NEI for 

Pittsburgh International. EPA’s calculation for 2013 would show a downward trend in emissions at the 

Pittsburgh International Airport.

As shown in Table 2.3, seven of the nine sources have decreased emissions 16.5% to 47.5% 

between 2011 and 2013, while the whole county had reduced emissions by more than 26% 

during the same time. Only two facilities increased emissions during the same period of time –

U.S. Steel Clairton Coke Works and U.S. Steel Irvin Plant. The Clairton Coke Works facility, 

the country’s largest coking operation, increased emissions by 675 tons, an increase of 12.3%.

The Cheswick Power Plant, the largest emissions source in Allegheny County (several 

kilometers away from either the City of Pittsburgh or Liberty-Clairton and downwind relative to 

prevailing wind directions) has decreased sulfur dioxide emissions significantly since 2009, due 

to the installation of a flue gas desulfurization (FGD) system. Sources outside of the LibertyClairton area, including the Cheswick plant and others, will be subject to controls required to 

meet the 2010 1-hour SO2 NAAQS.

It should be pointed out that the emission numbers Pennsylvania submitted for the 2011 NEI for 

Pittsburgh International Airport was later changed by EPA. Tables 2.1-2.3 include Pittsburgh 

International data as submitted by Pennsylvania for the 2011 NEI and in DEP’s AIMS database 

for 2013. Regardless of whether EPA’s adjusted numbers or Pennsylvania’s database numbers 

are used, both would should a downward trend between 2011 and 2013 at the Pittsburgh 

International Airport.

As noted in Figure C on page 78 of EPA’s TSD, the Clairton Coke Works facility is in the 

Monongahela Valley, in the area of Liberty-Clairton. This source is also the closest of the nine 

sources to the Liberty monitor, at a distance of one mile. Clairton Coke Works is located to the 

southwest of the Liberty monitor, where the emissions are frequently coming from. The US 
- 27 -

Steel Irvin Plant is the second closest of the nine sources, located two miles to the 

west/northwest of the Liberty monitor. The location of these sources in relation to the monitors 

in the Monongahela Valley can be seen in Figure 2.1.

Figure 2.1. The Liberty and Clairton Air Quality Monitors

Source: EPA’s August 19, 2014 intended designations letter, TSD Section 3.3, Allegheny County.

Additionally, several power plants outside of Allegheny County, which were included in the 

EPA TSD analysis, have deactivated since 2011:

 Washington County, PA – NRG Elrama (October 2012);

 Washington County, PA – Allegheny Energy Mitchell (October 2013);

 Greene County, PA – Allegheny Energy Hatfield’s Ferry (October 2013);

 Armstrong, PA – Allegheny Energy Armstrong (September 2012);

 Preston County, WV – Monongahela Power Albright (September 2012).

Additionally, the owner of the Homer City power plant in Indiana County is in the process of 

installing a desulfurization system, which is expected to come online in 2016; this system will 

significantly decrease sulfur dioxide emissions. The Homer City plant is located within the 

partial Indiana County area that is included in EPA’s intended Johnstown nonattainment area, 

which also includes all of Cambria County.
- 28 -

The urbanized area of Allegheny County (which is primarily the City of Pittsburgh) does not 

affect Liberty-Clairton, and vice-versa. Liberty shows extremely localized behavior and 

composition for PM2.5. This is also evident with the Clairton monitor, only a few kilometers 

away from Liberty, which can show much lower concentrations than Liberty as well as 

Lawrenceville. The urbanized area of Pittsburgh is well-characterized by population, modeling 

demonstrations, and other factors. It is best defined as the City of Pittsburgh extending into a 

few immediately adjacent municipalities and portions of the interstate parkway corridors. The 

Lawrenceville monitor is the best monitor to represent urbanized Pittsburgh. The Lawrenceville

monitor is influenced by urban emissions, but shows attainment of the 2012 annual PM2.5

NAAQS. The Liberty monitor is influenced by extreme localized industrial emissions, causing 

nonattainment. The remaining Allegheny County sites, while showing uniqueness on a 

neighborhood scale, are similar to other sites within the larger Pittsburgh MSA and are showing 

attainment.

The EPA TSD analysis attempted to relate emissions from Pittsburgh as an urban increment that 

can influence the violating monitor. EPA cited Pittsburgh International Airport as well as a few 

stationary sources as additional sources that could influence the Liberty monitor, despite the 

prevailing winds coming from the southwest. If EPA designates all of Allegheny County as a 

nonattainment area, as opposed to the Liberty-Clairton Area, this would result in making all of 

the sources subject to Reasonable Further Progress (RFP). The baseline for the RFP would be 

increased if this happened, resulting in a greater emission reduction required to meet the RFP. 

Since the ACHD does not have authority to control emissions from airports, there are no 

remaining CAA measures to implement for transportation emissions. In addition, most of the 

stationary sources are well controlled, resulting in few attainable RFP goals. Designating all of 

Allegheny County as a single nonattainment area could cause the area to fail to meet RFP. When 

finalizing a nonattainment designation, the potential for control is an important consideration that 

must be applied to sources of emissions.

In the past, EPA and DEP both agreed that this is a local problem, specific to the Monongahela 

Valley. All counties and municipalities surrounding the Liberty-Clairton area have attained the 

PM2.5 standards, and Liberty-Clairton lags behind, as was expected when EPA designated the 

1997 and 2006 PM2.5 nonattainment areas. 

2.2. PM2.5 SIP Modeling 

CAMx modeling and Modeled Attainment Test Software (MATS) unmonitored area tests 

performed for the 2006 24-hour PM2.5 NAAQS SIP shows much more refined gridded modeling 

results than shown in the EPA TSD analysis for the 2012 annual PM2.5 NAAQS.

Unmonitored area PM2.5 impacts are shown in Figure 2.2 for baseline year 2007 to future 

projected 2014 (see DEP’s June 21, 2013 State Implementation Plan (SIP) revision submittal 

pertaining to the attainment demonstration of the 2006 PM2.5 NAAQS for the Liberty-Clairton 

nonattainment area; herein referred to as the June 2013 SIP) at 0.8 km and 4 km resolution.
- 29 -

Figure 2.2. MATS Spatial PM2.5 Analysis, Baseline 2007 (left) and Projected 2014 (right), 

0.8 km Gridded Modeling Domain, from 2006 PM2.5 NAAQS SIP

These results show distinct borders for the extent of urban impacts compared to Liberty-Clairton 

area impacts. Furthermore, areas influenced by urban emissions are not showing county-wide 

modeled impacts. Urbanized PM2.5 emissions are highest at the urban core, extending into the 

parkway corridors of Interstates 279 and 376 (Note that near-road PM2.5 monitored results are 

not part of the current 2012 annual PM2.5 NAAQS designations.).

CAMx modeling performed for the June 2013 SIP revision also showed impacts by both local 

and regional contribution. The CAMx Particulate Matter Source Apportioning Technology 

(PSAT) tracked local source emissions in the model separately from regional impacts. The 

largest sources (>50 tons summed emissions) tracked locally are shown in Table 2.4.
- 30 -

Table 2.4. Local Sources Tracked by PSAT in CAMx, with Emissions (tons/year)

2007 Baseline

Facility SO2 NOX CO VOC NH3 PM2.5

EASTMAN CHEMICAL RESINS, INC. 4.4 73.2 29.8 177.7 0.1 17.6

GUARDIAN INDUSTRIES CORP. FLOREFFE 82.4 686.6 10.3 13.9 0.0 20.0

US STEEL CORP - EDGAR THOMSON PLANT 1868.6 318.1 1300.9 68.6 0.5 803.3

US STEEL CORP - IRVIN PLANT 456.0 694.5 194.0 71.8 0.7 51.1

US STEEL CORP - CLAIRTON PLANT 1739.9 4807.4 3559.3 570.6 18.4 929.2

ALLEGHENYENERGYSUPPLYCO/MITCHELL 637.9 1495.6 31.4 11.7 0.0 79.9

ORIONPOWERMIDWEST/ELRAMA 4267.4 6027.5 230.9 22.4 6.9 512.8

2014 Projected

Facility SO2 NOX CO VOC NH3 PM2.5

EASTMAN CHEMICAL RESINS, INC. 4.4 73.2 29.8 177.7 0.1 17.6

GUARDIAN INDUSTRIES CORP. FLOREFFE 82.4 686.6 10.3 13.9 0.0 20.0

US STEEL CORP - EDGAR THOMSON PLANT 1868.6 318.1 1300.9 68.6 0.5 803.3

US STEEL CORP - IRVIN PLANT 456.0 694.5 194.0 71.8 0.7 51.1

US STEEL CORP - CLAIRTON PLANT 1717.6 4312.8 4197.7 443.5 17.6 645.1

ALLEGHENYENERGYSUPPLYCO/MITCHELL 948.1 1335.0 44.1 17.3 0.0 102.1

ORIONPOWERMIDWEST/ELRAMA 1846.0 1943.0 99.7 9.7 3.0 221.5

Modeled impacts at Liberty from the June 2013 SIP are shown in Table 2.5, split into local and 

regional contributions. Local sources were those within a 20 km domain surrounding the Liberty 

monitor.

Table 2.5. Modeled CAMx Impacts, Local and Regional, Baseline 2007 and Projected 2014

Local CAMx Impacts at 

Liberty

SO4 NO3 NH4 POA SOA EC OTHER TOTAL

2007 0.442 0.010 0.137 0.219 0.000 0.282 2.274 3.363

2014 0.361 0.014 0.109 0.204 0.000 0.269 1.789 2.746

Regional CAMx Impacts at 

Liberty

SO4 NO3 NH4 POA SOA EC OTHER TOTAL

2007 4.517 1.031 1.346 2.287 0.036 1.192 3.189 13.597

2014 2.256 0.876 0.984 1.777 0.030 0.499 2.755 9.175

Legend: SO4 = sulfate ion; NO3 = nitrate ion; NH4 = ammonium ion; POA = primary organic aerosol; SOA = secondary 

organic aerosol; EC = elemental carbon; OTHER = unspeciated PM2.5.

CAMx modeling from the June 2013 SIP showed little transformation locally at Liberty, 

indicating that secondary compounds are not readily formed from precursor emissions from 
- 31 -

immediately upwind sources such as Eastman, Guardian, Elrama, or Mitchell. Most of the local 

impacts were from direct PM emissions (OTHER, POA, EC), while secondary components 

(SOA, NO3) contributed minimally to impacts at Liberty. It should be noted that Elrama and 

Mitchell were modeled at Cross-State Air Pollution Rule (CSAPR) emission levels for future 

case 2014. Both of these power plants are currently deactivated.

Local sulfate can be apportioned to either primary or secondary PM2.5, depending on the 

Standard Classification Code (SCC) code of the modeled source. Stack tests have shown 

significant amounts of primary sulfate for local sources near Liberty (Note: ammonium is mostly

associated with sulfate in the model.).

It should also be noted that modeled impacts for the PM2.5 SIP were used in a relative sense for 

future design value calculations (See PM2.5 modeling guidance, April 2007.). When applied to 

monitored data, the modeling projected future case annual values for 2014 (5-year weighted 

basis) below 12.0 μg/m3for Liberty.

2.3. PMF Source Apportionment

Positive Matrix Factorization (PMF) source apportionment receptor modeling referenced in the 

EPA TSD (based on 2005-2010 speciation data) represented a “best-guess” scenario of probable 

source factors. For many source factors, there is a mix of components that cannot be resolved by 

the model, and there is considerable uncertainty associated with the results. The PMF results 

should be considered “ballpark” estimates, with the importance lying in the factor types and the 

associated wind directions for each factor at Lawrenceville and Liberty. Subsequent modeling, 

control strategies, and past/current monitored data have shown that Clairton Coke Works is the 

main source contributing to exceedances at Liberty.

Updated PMF modeling (using PMF v5.0) was performed using more recent speciation data for 

2011-2013, including modeling for the additional tri-state sites (see Air Quality Data section). 

For this analysis, samples with missing species or exceptional outliers are removed from the 

model to provide a better fit.

Modeled source factor profiles from PMF are shown in Figures 2.3 and 2.4 for Lawrenceville 

and Liberty, respectively.
- 32 - 

Figure 2.3. Lawrenceville Source Factor Profiles 

Base Factor Profiles - Run 10 

Q 0 ~ : • • • • • • 

• 

00[J • (!) • .... . • D • • qp 

• 

. 0 . • 

. D!il ... • [J • • • 
- 33 - 

Figures 2.3 and 2.4 show some common factors between Lawrenceville and Liberty, with some 

distinct larger industrial source factors only evident at Liberty. Factor 11 Factor 1 0 Factor 9 Factor 8 Factor 7 Factor 6 Factor 5 Factor 4 Factor 3 Fac

Cone. Cone. Cone. Cone. Cone. Cone. Cone. Cone. Cone. Co

.. .. .. .. 

Offtpo Offf'?o Offe'?o Offe'?o Offf'?o Offtpo Offf'?o Offe'?o Offe'?o Off

I I I I II LLLL II LLI I II LLLL II CCLI II 

m 1 II J:!j:5111 I I I II LLLL II LLL

<ft 

,r:f!< -4 

:'/10 " ,0>' .,-4 

,<?> 

qf) 

{> 

{) 

<;f) 

<:;.0 

• • 

/-+ 

t 

0"" • 

'<? + ,. 

'11 'Y 

• 

. I 1. I 1. • • 

0 

0 0 0 0 0 0 0 0 0 

% % % % % % % % % % 

o 6 a 9 s c 

Jo
- 34 -

A comparison of source factors between the tri-state sites are given in Figure 2.6. Some of these 

factors are combinations of one or more profiles originating from similar sources for better 

comparison between sites (Note: source factors are assigned according to most prevalent 

indicator species for each source factor, but factors can contain amounts of other species.).

Figure 2.5. Stacked Common Source Factors, Tri-State Sites

The modeled source factors show consistency with the speciation analysis (see Air Quality Data 

section). Contributions from regional components such as ammonium sulfate and crustal 

component are fairly consistent through the tri-state area. Motor vehicles show higher 

contributions at more population sites such as Lawrenceville and Greensburg. Liberty shows a 

large contribution from carbon-rich industrial sources – not present at the other sites – that 

contribute carbons, primary sulfate, chlorine, and several trace elements.

Modeling and source apportionment analysis indicate that sources immediately upwind of the 

Liberty-Clairton area are showing minimal impacts on the area. Additionally, the two largest 

upwind sources within 15 km of Liberty (Elrama and Mitchell plants) have deactivated in 

2012-2013 (in addition to other nearby sources), while Liberty continues to exceed the annual 

NAAQS.

Additional ACHD speciation and PMF analysis can be found at www.achd.net/air/reports.html.
- 35 -

2.4. Allegheny County Population Data

Allegheny County population data, based on 2010 census data was examined for the extent of the 

urban Pittsburgh area. Figures 2.6 and 2.7 show population density and total population, 

respectively, by municipality. The City of Pittsburgh (in the middle of the maps) is the largest 

municipality by area.

Figure 2.6. Population Density by Allegheny County Municipality

Population density shows that the Pittsburgh urban core is best defined as the City of Pittsburgh 

along with a few immediately adjacent municipalities. The Greater Pittsburgh area is best 

defined as the Pittsburgh MSA.
- 36 -

Figure 2.7. Total Population by Allegheny County Municipality

Total population shows similar results to population density, indicating the city of Pittsburgh as 

the most urbanized area.

The EPA TSD analysis showed population growth and population density in terms of a fullcounty, Allegheny County, area. While the information was accurate, this data was not broken 

down any further than the county level, and a trend in the Liberty-Clairton area was not 

discussed.

On July 25, 2014, DEP submitted a revision to the June 21, 2013, SIP submittal, which was a 

supplement to the attainment demonstration for the Liberty-Clairton PM2.5 Nonattainment Area

2006 Standards. In Section 2.7 of the revision, it was pointed out that according to the 

U.S. Census Bureau, the five municipalities of the Liberty-Clairton area have decreased in 

population. From 2000 to 2010, the City of Clairton had a decrease in population of about 20%, 

the largest population decrease in the Liberty-Clairton nonattainment area. The other 

municipalities saw population decreases as follows: Borough of Glassport -10.2%; Liberty 

Borough -4.5%; Borough of Lincoln -12.0%, and Port Vue Borough -10.2%. In total, the 

nonattainment area had a decrease in population of 2,900 people, or a decrease of 13.4% from 

2000 to 2010. Due to a reduction of population, it would signal a reduction of the use of cars, 
- 37 -

school buses and other diesel-engine vehicles. Figure 2.8 shows the Allegheny County

population trend from the July 25, 2014, submittal.

Figure 2.8. Population Trends - Liberty-Clairton Area and Allegheny County, 2000-2010

Source: Allegheny County Health Department’s proposed SIP revision to the June 21, 2013 SIP, as submitted by 

DEP on July 25, 2014.

While EPA’s TSD analysis for the 2006 24-hour and 2012 PM2.5 annual standards both evaluated 

the Allegheny County population as a full-county, the analysis for the 2006 standard indicated 

that “because of the unique nature of the Liberty-Clairton area, with its local source and 

topography issues, this factor does not weigh heavily in this technical analysis.” The EPA TSD 

analysis for the 2012 PM2.5 annual standard did not include a similar statement, even though the 

factor of population was comparable and the local source and topography issues remained the 

same.
- 38 -

3. METEOROLOGY

3.1. Wind Rose Analysis 

The EPA TSD analysis excluded local meteorological sites from the analysis, only looking at 

airport data. Figure 3.1 shows the Liberty wind rose for 2009-2013 which clearly demonstrates 

the preponderance of winds from the south through west, especially southwest, at the Liberty 

Borough site.

Figure 3.1. Liberty Wind Rose, 2009-2013

3.2. Temperature Inversions

The EPA TSD states on page 109 that for Allegheny County,

EPA evaluated available meteorological data to determine how meteorological conditions, 

including but not limited to, weather, transport patterns, and stagnation conditions, could 

affect the fate and transport of directly emitted particulate matter and precursor emissions 

from sources in the area of analysis.

However, there is no evidence in EPA’s assessment that stagnation conditions were directly 

evaluated. Inversion statistics for 2009-2013 are shown in Table 3.1.
- 39 -

Table 3.1. Total Days of Inversions: 2009-2013, Derived from PIT NWS Soundings*

Month 2009 2010 2011 2012 2013 2009-2013

JAN 7 (23) 5 (16) 5 (16) 9 (29) 8 (26) 34 (22)

FEB 8 (30) 8 (30) 10 (36) 10 (36) 6 (21) 42 (30)

MAR 12 (43) 17 (55) 7 (23) 11 (35) 6 (19) 53 (35)

APR 11 (37) 20 (67) 6 (20) 12 (40) 10 (33) 59 (39)

MAY 18 (64) 16 (52) 13 (43) 14 (45) 9 (29) 70 (46)

JUN 14 (61) 14 (47) 8 (28) 13 (43) 13 (43) 62 (44)

JUL 16 (52) 17 (55) 18 (60) 15 (48) 9 (29) 75 (49)

AUG 16 (52) 15 (48) 21 (68) 19 (61) 16 (53) 87 (56)

SEP 15 (50) 20 (67) 12 (40) 14 (47) 14 (47) 75 (50)

OCT 15 (48) 16 (52) 11 (35) 15 (48) 18 (60) 75 (49)

NOV 14 (47) 17 (57) 12 (40) 17 (57) 10 (33) 70 (47)

DEC 8 (26) 6 (19) 11 (35) 9 (29) 8 (27) 42 (27)

Annual 154 (44) 171 (47) 134 (37) 158 (43) 127 (35) 744 (41)

* For morning (12Z) surface inversions of at least 1.0 °C in strength (shallow isothermal and/or unstable conditions may 

also be present below or within ground inversion). Percent based on available days of data is given in parenthesis.

As indicated by this Pittsburgh National Weather Service (PIT NWS) data obtained from 

sounding balloons released at more than 1170 feet mean sea level (MSL), Allegheny County 

experiences frequent surface temperature inversions. Yet, in the numerous low-lying river 

valleys within the county, inversion frequency is likely greater than that observed at PIT NWS. 

So, couple the high frequency of surface inversions with light winds typical of overnight 

conditions, and atmospheric mixing is expected to be quite limited on about half or more of the 

mornings in the county. Additionally, since much of the county’s large PM2.5 emitters are 

located in valleys, high concentrations are expected from local sources during times with 

substantial temperature inversions and light winds.

3.3. Back Trajectories

As stated on page 5 of the EPA TSD analysis,

Evaluating meteorological data helps to determine the effect on the fate and transport of 

emissions contributing to PM2.5 concentrations and to identify areas potentially 

contributing to the violations at monitoring sites. The factor 3 analysis includes assessing 

potential source-receptor relationships in the area identified for evaluation using 

summaries of air trajectories, wind speed, wind direction and other meteorological data as 

available.

In addition, a description of factor 3 on EPA’s website regarding “Area Designations for the 

2012 Annual Fine Particle (PM2.5) Standard -- Designations Guidance and Data,” states: “A 

more sophisticated assessment involves modeling air parcel trajectories.”

9

 

 

9

http://www.epa.gov/pmdesignations/2012standards/techinfo.htm#F3
- 40 -

Figures 3.2a – 3.2j provide a HYSPLIT model back-trajectory analysis with the top ten PM2.5

concentration days for 2011-2013 at Liberty Borough. The trajectory end point is at Allegheny 

County Airport. Surface temperature inversion conditions as observed by the 12Z and 00Z 

Pittsburgh National Weather Service soundings for the max days are included. During each of 

the days, substantial inversions existed (indicative of poor dispersion conditions) in the morning 

(12Z) while most of the ten days also recorded small evening (00Z) inversions. Note that the 

ending time, 0500 UTC, is midnight for the indicated day.

Figure 3.2a. 24-hr PM2.5 = 59.0 g/m3

(11/07/11 12Z Sfc. Inv. = 8.2oC, 251 m; 11/08/11 00Z Sfc. Inv. = 0.8oC, 77 m)
- 41 -

Figure 3.2b. 24-hr PM2.5 = 57.0 g/m3

(12/13/11 12Z Sfc. Inv. = 5.9oC, 162 m; 12/14/11 00Z Sfc. Inv. = None)
- 42 -

Figure 3.2c. 24-hr PM2.5 = 54.7 g/m3

(11/22/12 12Z Sfc. Inv. = 10.9oC, 194 m; 11/23/12 00Z Sfc. Inv. = 1.0oC, 68 m)
- 43 -

Figure 3.2d. 24-hr PM2.5 = 54.3 g/m3

(03/11/12 12Z Sfc. Inv. = 7.6oC, 530 m; 03/12/12 00Z Sfc. Inv. = None)
- 44 -

Figure 3.2e. 24-hr PM2.5 = 48.9 g/m3

(12/14/12 12Z Sfc. Inv. = 6.1oC, 388 m; 12/15/12 00Z Sfc. Inv. = 1.8oC, 82 m)
- 45 -

Figure 3.2f. 24-hr PM2.5 = 48.6 g/m3

(03/15/12 12Z Sfc. Inv. = 5.4oC, 222 m; 03/16/12 00Z Sfc. Inv. = None)
- 46 -

Figure 3.2g. 24-hr PM2.5 = 48.1g/m3

(11/26/11 12Z Sfc. Inv. = 1.4oC, 195 m; 11/27/11 00Z Sfc. Inv. = 0.4oC, 189 m)
- 47 -

Figure 3.2h. 24-hr PM2.5 = 47.1g/m3

(11/29/12 12Z Sfc. Inv. = 2.3oC, 121 m; 11/30/12 00Z Sfc. Inv. = 0.2oC, 116 m)
- 48 -

Figure 3.2i. 24-hr PM2.5 = 46.7g/m3

(12/12/11 12Z Sfc. Inv. = 8.5oC, 195 m; 12/13/11 00Z Sfc. Inv. = 0.6oC, 64 m)
- 49 - 

Figure 3.2j. 24-hr PM2.5 = 44.8g/m3 

(11/03/11 12Z Sfc. Inv. = 3.8oC, 411 m; 11/04/11 00Z Sfc. Inv. = 0.4oC, 157 m) 

$: 

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TrajectorY. Direction: Backward Duration: 24 hrs 

Vertical tVIotion Calculation Method: Model Vertical Velocity 

Meteorolo : ooooz 4 Nov 2011 - NAM1 2 
- 50 -

Furthermore, ENVIRON International, the PM2.5 modeling contractor for ACHD, performed 

extensive sophisticated air modeling for the June 2013 SIP revision that supports the claim that 

only locales in and around the Liberty Borough monitoring site should be included in the 

nonattainment area (see modeling analysis provided with June 2013 SIP).

3.4. Additional Information on Meteorology in Allegheny County

Meteorology is complex throughout all of Allegheny County. Wind roses can show very 

different results at sites only a few kilometers from one another and temperature inversions play 

a key role to elevated PM2.5 levels at Liberty. The strongest wind rose signals measured near the 

Liberty monitor indicate that the winds are primarily from the southwest. DEP’s analysis 

included in the designation recommendations showed that on the high days of PM2.5, that the 

wind signal comes from the southwest, with a lack of northwesterly winds from the city of 

Pittsburgh. The EPA TSD analysis included HYSPLIT data that is also weighted heavily in the 

southwesterly direction.

The EPA TSD analysis for Allegheny County appears to give contradictory information relating 

to emissions transport and meteorology. On the bottom of page 110, EPA talks about how 

terrain limits the transport of emissions, while earlier on the same page EPA claims that 

“northwesterly component [of the wind as indicated by the AGC sensor] indicates that the highly 

urbanized Pittsburgh area” contributes to PM2.5 concentrations at the Liberty monitor. The EPA 

TSD analysis used complex terrain to exclude sources with stack emissions in Washington 

County, yet did not use complex terrain to exclude ground-level emissions from Pittsburgh 

(which is further away from the Liberty monitor) in an attempt to link urban emissions to the 

Liberty monitor. In addition, figures 2d through 2g, 3c and 3d argue against large contributions 

from the direction of Pittsburgh. On page 112, EPA observes that “wind direction on the high 

PM2.5 days at the Liberty monitor is almost completely from the southwest.”
- 51 -

4. GEOGRAPHY/TOPOGRAPHY

4.1. Topography 

Figure 4.1 shows a shaded relief map from the U.S. Geological Survey (USGS) with elevation

contours for Allegheny County.

Figure 4.1. USGS Relief and Contour Map for Allegheny County

Topographical analysis reveals complex terrain throughout Allegheny County, which can act as 

natural barriers for low-level PM2.5 emissions. Direct PM2.5 from low level sources in river 

valleys have been the cause of localized exceedances at the Liberty monitor, as the terrain forms 

a “bowl” that traps pollutants during poor dispersion conditions. Taller stacks from sources, 

such as power plants, contribute to Allegheny County on a regional scale for secondary PM2.5. 

Emissions from area sources and mobile source emissions affect the county only in large 

volumes (i.e., closest to the City of Pittsburgh).

Figure 4.2 shows the National Land Cover Database’s (NLCD) land cover classifications map

for Allegheny County in 2011.
- 52 -

Figure 4.2. NLCD 2011 Land Cover Map for Allegheny County

Land use analysis shows that the most concentrated areas of developed high-intensity 

classification are nearest the City of Pittsburgh. Classifications of medium to high intensity in 

river valleys are mostly representative of industrial areas.
- 53 -

5. JURISDICTIONAL BOUNDARIES

While DEP is responsible for overseeing air quality throughout the Commonwealth, ACHD is

authorized by DEP to administer and enforce the local air quality management program in 

Allegheny County.

In EPA’s TSD analysis on page 118, it was indicated that based on a review of jurisdictional 

boundaries, “the same locally focused planning will bring the area into attainment for the 

2012 annual PM2.5 NAAQS.” DEP agrees. Maintaining the 1997 annual and 2006 24-hour 

PM2.5 NAAQS boundaries will allow for the continuity of planning. This preservation of the 

continuity of planning allows for DEP and ACHD to continue their strong working relationship 

in the partial county, Liberty-Clairton area to achieve and maintain the 1997, 2006 and 2012 

PM2.5 NAAQS. A partial county designation for the Liberty-Clairton should be applicable and 

appropriate for the consistent implementation of the standards.

The DEP proposes the same partial county designation within Allegheny County, the

Liberty-Clairton nonattainment area, as seen in Figure 5.1. This five-municipal area was 

previously designated as nonattainment for PM10 and PM2.5, as explained in the background 

section.

Figure 5-1. Allegheny County by Municipality, with Liberty-Clairton Nonattainment Area
- 54 -

CONCLUSION

After considering the facts as described above, DEP, in coordination with ACHD, is 

recommending the reduction of EPA’s proposed Allegheny County nonattainment area to a 

partial county Liberty-Clairton Area, consisting of the City of Clairton, Borough of Glassport, 

Liberty Borough, Borough of Lincoln and Port Vue Borough. This approach is consistent with 

existing nonattainment boundaries for the 1997 and 2006 PM2.5 NAAQS. The analysis supports

the conclusion that the size of the 2012 annual PM2.5 nonattainment area should be reduced from 

EPA’s proposed designation of Allegheny County, to a partial county designation for the 

Liberty-Clairton Area. The remainder of Allegheny County should be designated as attainment 

for the 2012 PM2.5 NAAQS.
Enclosure 2

The Commonwealth of Pennsylvania’s Response to the 

U.S. Environmental Protection Agency’s Proposed 

Designations for the 2012 Annual PM2.5 National Ambient Air 

Quality Standard

Letter of Support for Partial County Liberty-Clairton PM2.5

Nonattainment Area from the Allegheny Conference on 

Community Development

Bureau of Air Quality

Department of Environmental Protection
[This page intentionally left blank.]
Allegheny Conference 

on Community Development 

Greater Pittsburgh Chamber of Commerce I Pennsylvania Economy League of Greater Pittsburgh I Pittsburgh Regional Alliance 

October 15, 2014 

Acting Secretary Dana Aunkst 

Rachel Carson State Office Building 

400 Market St. 

Harrisburg, PA 17101 

Dear Acting Secretary Aunkst: 

11 Stanwix Street, 11'11 Aoor 

PITTSBURGH, PA 15222-1312 

T: 412.281.4783 

F: 412.281.1896 

A/kglm!JCO!{{emue.o~g 

The Allegheny Conference on Community Development has a history of supporting the strong 

enforcement of environmental regulations. The Conference was founded 70 years ago to improve 

environmental conditions impacting the quality of life of our region's citizens. We continue striving to 

be a leader in environmental stewardship by monitoring and engaging on a variety of environmental 

conditions in the region, including air quality. 

We are concerned with EPA's preliminary response to Pennsylvania's recommendation for area 

designations for the 2012 primary National Ambient Air Quality Standard for annual PM2.

5. EPA has 

inexplicably reversed its position recognizing the unique meteorology, topography and localized 

emissions in the Liberty monitoring area without reasonable justification. Simply put, EPA's proposal 

to designate all of Allegheny County as a non-attainment area is not supported by the evidence. 

We continue to be encouraged by the historical downward trend of all monitors in the region and the 

progress this region has made to meet air quality standards. 

Air quality attainment designations are an important factor when companies consider expanding or 

relocating to this region. While it is critical we continue to improve the air quality in areas not meeting 

the standards, it is just as important we do not place unwarranted requirements on areas that do meet 

them. 

On behalf of the Allegheny Conference, I strongly urge the non-attainment area be kept at its current 

size and not unnecessarily expanded. 

Sincerely, 

pi 1 

tee President, Energy and Infrastructure 

cc: Joyce E. Epps, Director, Bureau of Air Quality 
Enclosure 3

The Commonwealth of Pennsylvania’s Response to the 

U.S. Environmental Protection Agency’s Proposed Designation 

of an Allentown Nonattainment Area for the 2012 Annual PM2.5

National Ambient Air Quality Standard

Bureau of Air Quality

Department of Environmental Protection
[This page intentionally left blank.]
- 1 -

The U.S. Environmental Protection Agency (EPA) promulgated the annual fine particulate 

matter (PM2.5) National Ambient Air Quality Standard (NAAQS) on December 14, 2012; the 

standard was lowered to 12.0 micrograms per cubic meter (78 FR 3086; January 15, 2013). The 

Commonwealth of Pennsylvania submitted its recommendations to EPA, in accordance with 

Section 107 of the Clean Air Act, 42 U.S.C.A. § 7407, on December 10, 2013, and updated the

recommendation on July 30, 2014, based on 2011-2013 ambient air monitoring data.

In its August 19, 2014, letter to Governor Corbett, EPA proposed to expand the PA Department

of Environmental Protection’s (DEP) recommended Northampton County nonattainment area to 

include Lehigh County and Northampton County in an Allentown nonattainment area for the 

2012 annual PM2.5 National Ambient Air Quality Standard (NAAQS). Pennsylvania had 

recommended to EPA a smaller nonattainment area limited solely to Northampton County.

DEP has conducted a comprehensive evaluation of EPA’s proposed modifications to 

Pennsylvania’s designation recommendations. Based on a further review and analysis of 

available data, Pennsylvania disagrees with EPA’s enlargement of the recommended

nonattainment area for Northampton County. The final nonattainment area for the 2012 annual 

PM2.5 NAAQS should not include Lehigh County in its nonattainment area, but rather should 

remain the one-county area, of Northampton County that DEP initially recommended. The

information contained in this enclosure supplements the information DEP submitted to EPA on 

December 10, 2013, and July 30, 2014.

DEP has developed the following information to support the extreme local nature of this fine 

particulate problem in a limited nonattainment area of Northampton County, as initially 

recommended. DEP recommends that EPA designate the Northampton County area as a

separate nonattainment area, and designate Lehigh County as an unclassifiable/attainment area.

BACKGROUND AND OVERVIEW

On July 18, 1997, EPA published annual and 24-hour primary and secondary standards for fine 

particulate matter (PM2.5). In February 2004, DEP submitted a letter to EPA with area 

recommendations for the 1997 annual PM2.5 NAAQS, which included the recommendation that 

the Allentown-Bethlehem-Easton area (Northampton and Lehigh Counties) be designated as 

attainment, as both counties were monitoring attainment of the standard. On January 5, 2005, 

EPA published a final rule that included the designation of Lehigh and Northampton Counties as 

“unclassifiable/attainment” for the 1997 standard.

1

On October 17, 2006, EPA lowered the 24-hour PM2.5 standard from 65 μg/m3to 35 μg/m3. On 

December 28, 2007, DEP submitted designation recommendations to EPA for the 2006 24-hour 

PM2.5 NAAQS. These recommendations included an Allentown-Bethlehem-Easton 

nonattainment area, which comprised of Lehigh and Northampton Counties. As DEP’s 

designation recommendations pointed out in the submittal on pages 11-12:

 

1

70 FR 944; January 5, 2005. Effective April 5, 2005.
- 2 -

No area in this metropolitan area violates the 2012 annual PM2.5 standard. However, for 

the 24-hour standard, the Freemansburg monitor in Northampton County is violating the 

standard. The Allentown monitor in Lehigh County was discontinued at the end of 2005. 

Twenty-four hour PM2.5 design values in 2005, the last year both monitors were 

operating, for Allentown and Freemansburg were 36.4 μg/m3and 36.1 μg/m3

respectively.

On November 13, 2009, EPA published a final rule designating the Allentown Area, made up of 

Lehigh and Northampton Counties, as a nonattainment area for the 2006 24-hour PM2.5

NAAQS.

2

On December 13, 2012, EPA strengthened the primary annual PM2.5 NAAQS to 12.0 μg/m3. On 

December 10, 2013, DEP recommended that the Northampton County area be designated as 

nonattainment for the 2012 annual PM2.5 NAAQS, based primarily on 2010-2012 air quality 

data. The Freemansburg monitor exceeded the standard at 13.2 μg/m3, while the other monitor 

in the county, the Lehigh Valley monitor, attained the standard with a design value of 

10.6 μg/m

3

. The DEP recommended that Lehigh County be considered unclassifiable/attainment 

since the county does not have any monitors and was not determined to be contributing to the 

localized problem seen at the Freemansburg monitor in Northampton County.

On July 30, 2014, DEP provided EPA with updated area recommendations for the 2012 PM2.5

NAAQS following the review of 2011-2013 air quality data. These updated recommendations 

did not change the recommended Northampton County nonattainment area. The 2013 design 

values for monitors in Northampton County were 12.2 μg/m3at the Freemansburg monitor and 

10.6 μg/m3at the Lehigh Valley monitor.

On August 19, 2014, EPA sent Governor Corbett a 120-day letter and technical support 

document indicating the intent to modify Pennsylvania’s recommended area boundaries for the 

Northampton County area. EPA noted its intention to designate Northampton County, as well as 

Lehigh County, as an Allentown nonattainment area for the 2012 annual PM2.5 NAAQS, 

expanding DEP’s recommended smaller Northampton County nonattainment area.

 

2

74 FR 58,688; November 13, 2009. Effective December 14, 2009.
- 3 -

1. AIR QUALITY DATA

EPA’s technical support document (TSD) analysis for the 2012 annual PM2.5 NAAQS noted that

while Lehigh County does not have a monitor, the county contributes to the nearby violation at 

the Freemansburg monitor. While Lehigh County does not currently have a monitoring station, a 

monitor used to be located in Allentown until it ceased operation on December 31, 2005. The 

Allentown monitor was removed, because at the time it was considered to be a duplicative 

sampler. In 2010, the Lehigh Valley monitor was added to the Allentown-Bethlehem-Easton 

Metropolitan Statistical Area (MSA), in Northampton County, due to the requirement in 

40 CFR Part 58, Appendix, Table D-5, requiring that this area have two PM2.5 monitors.

Table 1.1 and Figure 1.1 show the trend for the annual mean values monitored in the Allentown 

area.

Table 1.1. Allentown Area PM2.5 Annual Mean (in μg/m3) by Station – 2010-2013

Station AQS Code 2010 2011 2012 2013

Freemansburg 42-095-0025 13.73 14.46 11.45 10.55

Lehigh Valley 42-095-0027 9.77 11.19 10.89 9.87

Difference 3.96 3.27 0.56 0.68

Figure 1.1. Allentown Area PM2.5 Annual Mean (in μg/m3) by Station - Since 2001

*The Allentown monitor ceased operation on 12/31/2005.

**The Lehigh Valley monitor commenced operation in 2010.

8

9

10

11

12

13

14

15

16

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013

Freemansburg

Lehigh Valley

Allentown
- 4 -

Figure 1.1 clearly illustrates a localized problem being observed at the Freemansburg monitor in

2010 and 2011, with the values seen at the Freemansburg monitor at least 3 μg/m3higher than 

the Lehigh Valley monitor. Information on the Allentown monitor was included in Figure 1.1 to 

illustrate how these monitors typically correlate well with one another. Other than 2010 and 

2011, the Allentown monitor (in 2001-2005) and the Lehigh Valley monitor (in 2012 and 2013), 

compared to the Freemansburg monitor, never had a difference of more than 1.08 μg/m3. The 

increase in the annual mean at the Freemansburg monitor in 2010 and 2011 is an anomaly 

specific to Freemansburg. If emissions from Lehigh County were causing this increase, the 

Lehigh Valley monitor also would have gone up significantly, which did not occur. This local 

issue is tied to construction activity on the land of the former Bethlehem Steel Corporation plant, 

just south of the Freemansburg monitor, as described in more detail in Section 4.

Table 1.2 and Figure 1.2 show that the trend for annual design values monitored in the 

Allentown area is downward, with the exception of an upward tick in Freemansburg for the 

2011-2013 time period. The Allentown monitor is included in Figure 1.2 to show the strong 

correlation in monitors in the Allentown area of Lehigh and Northampton Counties. This 

correlation is not evident in the 2010-2013 time frame, which is due to local construction 

activities in the vicinity of the Freemansburg monitor. Again, it should be noted that the 

Allentown monitor ceased operation on December 31, 2005, and the Lehigh Valley monitor 

began operation in 2010. Since the design value is the average of 3 years of data, Lehigh 

Valley’s design value was not calculated until 2012. Both 2012 and 2013 design values at the 

Lehigh Valley monitor were steady at 10.6 μg/m3, while the Freemansburg monitor design 

values were 13.2 μg/m3and 12.2 μg/m3respectively.

Table 1.2. Allentown Area PM2.5 Annual Design Value (in μg/m3) by Station – 2010-2013

Station AQS Code 2010 2011 2012 2013

Freemansburg 42-095-0025 12.6 13.4 13.2 12.2

Lehigh Valley 42-095-0027 N/A N/A 10.6 10.6
- 5 -

Figure 1.2. Allentown Area PM2.5 Annual Design Value (in μg/m3) by Station - Since 2001

*The Allentown monitor ceased operation on 12/31/2005.

**The Lehigh Valley monitor began operation in 2010, so the first design value was valid in 2012.

The downward trend since 2011, shown in the tables and figures above, is expected to continue, 

with the Freemansburg monitor likely attaining the 2012 annual PM2.5 NAAQS based on the 

2014 design value.

Table 1.3 shows the quarterly average for the Freemansburg and Lehigh Valley monitors for the 

first and second quarters of 2014. It should be noted that no single quarterly average above 

12.0 μg/m3is a violation of the standard. The annual mean is the average of the four quarterly 

averages, which is then averaged with the annual mean from each of the two previous years to 

obtain the current design value. In order to meet the 2012 annual PM2.5 NAAQS, the 

Freemansburg monitor would need a 2014 annual mean of 14.15 μg/m3. Currently, the average 

of the quarterly averages at both Lehigh Valley and Freemansburg monitors show a value of less 

than 11 μg/m3.

Table 1.3. Allentown Area Monitoring Station Data – 2014 Quarterly Averages to Date

Station AQS Code 1

st Quarter 

Average 

(μg/m3)

2

nd Quarter 

Average 

(μg/m3)

Average of 

1

st & 2nd

Quarters

Freemansburg 42-003-0002 13.76 7.98 10.87

Lehigh Valley 42-003-0008 13.67 7.72 10.70

8

10

12

14

16

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013

FREEMANSBURG

LEHIGH VALLEY

ALLENTOWN
- 6 -

A correlation analysis of the 2013 design value PM2.5 data was completed using a 24-hour daily 

average PM2.5 comparison of the values measured at Freemansburg compared to those at Lehigh 

Valley, Reading, Swiftwater, Bristol and Norristown. Figure 1.3 shows the location of these 

monitors in relation to the Freemansburg monitoring location. The associated chart provides the 

distance and direction from the Freemansburg monitoring location.

Figure 1.3. Monitoring Locations Related to the Freemansburg Monitor

Monitor DISTANCE 

(MILES) Degrees Direction Monitor DISTANCE (MILES) Degrees Direction

LEHIGH VALLEY 3.5 290.1 WNW BRISTOL 43.4 146.1 SE

SWIFTWATER 31.4 1.7 N NORRISTOWN 35.6 177.2 S

READING 37.0 242.8 WSW

Tables 1.4 and 1.5 provide the calculation of the correlation coefficient, ‘r’, and the coefficient of 

determination ‘r2,’ respectively, for the five monitoring locations compared to the Freemansburg 

monitor (based on the 2013 design value, for calendar years 2011, 2012 and 2013). The 

correlation coefficient between two variables is measured by the strength and direction of a 

linear relationship. The coefficient of determination is indicative of how well the regression line 

represents the data. If the regression line would pass through each data point on a scatter plot, 
- 7 -

then this would explain all of the variation. The further away the line is from each of the points, 

the less that it is able to be explained.3

Table 1.4. Calculation of r (Correlation Coefficient)

Lehigh Valley Reading Swiftwater Bristol Norristown

2011-13 0.828930077 0.787194606 0.613021262 0.735520741 0.742178037

2011 0.767578003 0.764991712 0.755702134 0.667923623 0.721879358

2012 0.827356044 0.747365310 0.617786461 0.727071440 0.704021058

2013 0.953881874 0.909063001 0.689684057 0.857663778 0.828215254

Table 1.5. Calculation of r2(Coefficient of Determination)

Lehigh 

Valley Reading Swiftwater Bristol Norristown

2011-13 0.687125073 0.619675348 0.375795068 0.540990760 0.550828239

2011 0.589175990 0.585212320 0.571085715 0.446121966 0.521109808

2012 0.684518024 0.558554907 0.381660112 0.528632878 0.495645650

2013 0.909890630 0.826395540 0.475664099 0.735587156 0.685940507

In analyzing Tables 1.4 and 1.5, Freemansburg correlates the best with Lehigh Valley (which is 

expected due the proximity of the sites to one another). Notice the “very high positive

correlation” in 2013 as opposed to 2011, which indicates the issue of local emissions near the 

Freemansburg monitor as opposed to Lehigh Valley.

4

Freemansburg correlates second best with Reading (due to the orientation of the valley from 

Reading and into the Allentown/Freemansburg area as seen in Figure 1.3). For instance, 

prevailing westerly flow would ensure that the air mass remains regionalized in nature (blowing 

from Reading toward Allentown). As was the case with Lehigh Valley, Reading correlates better 

with Freemansburg in 2013 than 2011.

Figures 1.4 through 1.8 present an illustration of the coefficient of determination, or r

2

values, as 

described above and seen in Table 1.5.

 

3

http://mathbits.com/MathBits/TISection/Statistics2/correlation.htm

4

http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3576830/table/T1/
- 8 -

Figure 1.4. Freemansburg vs. Lehigh Valley

Daily Average PM2.5 Concentrations, 2011 to 2013

Figure 1.5. Freemansburg vs. Reading

Daily Average PM2.5 Concentrations, 2011 to 2013

y = 0.6955x + 2.1708

R2 = 0.6871

0

10

20

30

40

50

60

0 10 20 30 40 50 60 70

Lehigh Valley Daily Average PM2.5 (ug/m3)

Freemansburg Daily Average PM2.5 (ug/m3)

Daily Average PM2.5

Concentrations (ug/m3)

Linear (Daily Average PM2.5

Concentrations (ug/m3))

y = 0.663x + 2.9512

R2 = 0.6197

0

10

20

30

40

50

60

0 10 20 30 40 50 60 70

Reading Daily Average PM2.5 (ug/m3)

Freemansburg Daily Average PM2.5 (ug/m3)

Daily Average PM2.5

Concentrations (ug/m3)

Linear (Daily Average PM2.5

Concentrations (ug/m3))
- 9 -

Figure 1.6. Freemansburg vs. Swiftwater

Daily Average PM2.5 Concentrations, 2011 to 2013

Figure 1.7. Freemansburg vs. Bristol

Daily Average PM2.5 Concentrations, 2011 to 2013

y = 0.405x + 3.1472

R2 = 0.3758

0

5

10

15

20

25

30

35

0 10 20 30 40 50 60 70

Swiftwater Daily Average PM2.5 (ug/m3)

Freemansburg Daily Average PM2.5 (ug/m3)

Daily Average PM2.5

Concentrations (ug/m3)

Linear (Daily Average PM2.5

Concentrations (ug/m3))

y = 0.6201x + 3.2149

R2 = 0.5410

0

5

10

15

20

25

30

35

40

45

50

0 10 20 30 40 50 60 70

Bristol Daily Average PM2.5 (ug/m3)

Freemansburg Daily Average PM2.5 (ug/m3)

Daily Average PM2.5

Concentrations (ug/m3)

Linear (Daily Average PM2.5

Concentrations (ug/m3))
- 10 -

Figure 1.8. Freemansburg vs. Norristown

Daily Average PM2.5 Concentrations, 2011 to 2013

y = 0.5526x + 3.0083

R2 = 0.5508

0

5

10

15

20

25

30

35

40

45

0 10 20 30 40 50 60 70

Norristown Daily Average PM2.5 (ug/m3)

Freemansburg Daily Average PM2.5 (ug/m3)

Daily Average PM2.5

Concentrations (ug/m3)

Linear (Daily Average PM2.5

Concentrations (ug/m3))
- 11 -

2. EMISSIONS AND MONITORING DATA

The EPA TSD analysis on emissions data was based on the 2011 National Emissions Inventory 

(NEI). Table 5 on page 138 of EPA’s TSD analysis indicated major point source emissions from 

version 1 of the 2011 NEI, in tons per year. Table 5 listed facilities and facility-level emissions 

in the area of analysis for the Allentown area. In this table, EPA documented six major facilities 

in Northampton County and one in Lehigh County (in addition to facilities outside of these 

counties) with emissions of direct PM2.5, components of direct PM2.5 and precursor pollutants. 

Table 2.1 shows the 2011 NEI data for the seven facilities.

Table 2.1. Allentown Area Facilities Over 500 Tons in 2011 NEI

County Facility Name

(Facility ID)

Distance 

from 

violating 

monitor 

(miles)

NH3 NOX PM2.5 SO2 VOC Total

Northampton Keystone Portland Cement

/East Allen (420950012) 7 2 828 57 984 7 1,878

Northampton Essroc/Nazareth Lower 

Cement Plant 1 (420950045) 7 68 1,804 522 722 62 3,177

Northampton Northampton Gen Co

/Northampton (420950536) 9 2 441 44 546 2 1,034

Northampton Hercules Cement Co LP

/Stockertown (420950006) 9 3 989 29 1,420 20 2,462

Lehigh Lafarge Corp/Whitehall Plant 

(420770019) 10 14 368 36 331 7 754

Northampton PPL Martins Creek LLC 

/Martins Creek (420950010) 17 13 943 37 274 30 1,297

Northampton Genon Rema LLC /Portland 

Generating Station

(420950011)

24 0 1,977 67 15,148 14 17,206

TOTAL 102 7,350 792 19,425 142 27,808

DEP reviewed these same seven facilities in its Air Information Management System (AIMS) 

database for the 2013 calendar year. The 2013 emissions for each of the seven facilities within 

Northampton and Lehigh Counties can be seen in Table 2.2.
- 12 -

Table 2.2. Allentown Area Facilities Over 500 Tons in 2013 in PA’s AIMS Database

County Facility Name 

(Facility ID)

Distance 

from 

violating 

monitor 

(miles)

NH3 NOX PM2.5 SO2 VOC Total

Northampton Keystone Portland Cement

/East Allen (420950012) 7 3 734 41 743 3 1,524

Northampton Essroc/Nazareth Lower Cement 

Plant 1 (420950045) 7 60 1,109 545 878 56 2,648

Northampton Northampton Gen Co

/Northampton (420950536) 9 2 366 15 455 6 844

Northampton Hercules Cement Co LP

/Stockertown (420950006) 9 4 1,405 30 1,418 26 2,883

Lehigh Lafarge Corp/Whitehall Plant 

(420770019) 10 12 257 36 273 5 583

Northampton PPL Martins Creek LLC

/Martins Creek (420950010) 17 14 770 16 161 34 995

Northampton Genon Rema LLC/Portland 

Generating Station

(420950011)

24 0 414 12 2,103 3 2,532

TOTAL 95 5,055 695 6,031 133 12,009

Emission totals for the seven Lehigh and Northampton County facilities are compared between 

2011 and 2013 in Table 2.3.

Table 2.3. Allentown Area Facility Emissions Difference Between 2011 and 2013

County Facility Name 

(Facility ID)

2011 

Totals

2013 

Totals Difference

Percent 

Change

Northampton Keystone Portland Cement/East Allen 

(420950012) 1,878 1,524 -354 -18.8%

Northampton Essroc/Nazareth Lower Cement Plant 1 

(420950045) 3,177 2,648 -529 -16.7%

Northampton Northampton Gen Co/Northampton 

(420950536) 1,034 844 -190 -18.4%

Northampton Hercules Cement Co LP/Stockertown 

(420950006) 2,462 2,883 421 17.1%

Lehigh Lafarge Corp/Whitehall Plant (420770019) 754 583 -171 -22.7%

Northampton PPL Martins Creek LLC/Martins Creek 

(420950010) 1,297 995 -302 -23.3%

Northampton Genon Rema LLC/Portland Generating Sta 

(420950011) 17,206 2,532 -14,674 -85.3%

GRAND TOTAL 27,808 12,009 -15,799 -56.8%

As can be seen in the charts above, significant progress has been made in the region, having 

reduced emissions by more than 56 percent between 2011 and 2013. 
- 13 -

3. GEOGRAPHY/TOPOGRAPHY

The EPA TSD analysis accurately describes the geography and topography associated with 

Lehigh and Northampton Counties. However, the last sentence of Factor 4 in EPA’s TSD 

analysis stated that, “EPA believes that these topographical barriers significantly affect the 

formation and distribution of PM2.5 concentrations in the area of analysis” without any further 

explanation. There was a large disparity of more than 3 μg/m3between the Lehigh Valley and 

Freemansburg monitors. DEP believes that the PM2.5 concentrations in the 

Bethlehem/Freemansburg area were being influenced by emissions south of the Freemansburg 

monitor.

The history of the Bethlehem Steel property, (approximately 1.5 miles south of the 

Freemansburg monitor) according to EPA’s Corrective Action Statement of Basis document for 

redevelopment at the former Bethlehem Steel property, is: 

From approximately 1899 to 1995, BSC [Bethlehem Steel Corporation] and its corporate 

predecessors manufactured steel at the approximately 1800-acre BSC Facility. In 1995, 

BSC discontinued steel manufacturing operations at the BSC Facility and in 2001, filed 

for bankruptcy under Chapter 7 of the United States Bankruptcy Code. In May 2003, 

with approval of the U.S. Bankruptcy Court for the Southern District of New York, 

International Steel Group Acquisition, Inc. (ISG) acquired substantially all of BSC's 

assets. Title to the BSC Facility was taken by Tecumseh Redevelopment, LLC 

(Tecumseh), a subsidiary of ISG. A 125-acre westernmost tract, the BW Tract, was sold 

to Sands Retail, LLC. In addition, Tecumseh sold approximately 1000 acres of the BSC 

Facility to Lehigh Valley Industrial Park (LVIP). That 1000-acre area is part of the 

parcel known as Bethlehem Commerce Center. In 2005, ISG merged with Mittal Steel 

USA, Incorporated (Mittal). Mittal sold 441 acres to Majestic Realty Company in 2007. 

Tecumseh, now a subsidiary of Mittal, retains the remaining acreage of the BSC Facility.5

Figures 3.1-3.6 show the nearly 1,800 acres of land formerly owned by Bethlehem Steel (along 

the southern edge of the Lehigh River). The land, subject to Resource Conservation and 

Recovery Act (RCRA) Corrective Action activities and DEP’s Land Recycling Program (Act 2), 

has been and continues to be redeveloped.6 These images, starting in 2008 (in Figure 3.1), show 

the land that was heavily developed south of the Freemansburg monitor.

In Figures 3.1, 3.5 and 3.6, the blue star ( ) depicts the location of the Freemansburg monitor; 

the green triangle ( ) is the location of the casino, hotel and shops which were built between 

late 2008 and mid 2011; the red circle ( ) is where warehouses and distribution centers were 

built between 2010 and 2013.

 

5

http://www.epa.gov/reg3wcmd/ca/pa/otherdocs/BethlehemSteelCommerceCtr_SB.pdf

6

http://www.epa.gov/reg3wcmd/ca/pa/reuse/lu_PAD990824161.pdf
- 14 -

Figure 3.1. Freemansburg, PA – May 2008

Source: Google Earth

Figure 3.2 shows the land formerly owned by Bethlehem Steel. This image, from June 2012, is 

taken from the northwest, looking southeast.
- 15 -

Figure 3.2. Former Property of Bethlehem Steel Corporation

Source: Liberty Property Trust – Lehigh Valley Industrial Park VII

http://www.gisplanning.net/photos/pa/2785%20Commerce%20Center%20Blvd%20LVIP%20VII.pdf

Figures 3.3 and 3.4 show the redevelopment projects on the old Bethlehem Steel property. The 

Lehigh Valley Industrial Park VII Land Development project is highlighted in orange in 

Figure 3.3. Please note that phases 1-4 appear to be completed, while phases 5 and 6 are still in 

progress.
- 16 -

Figure 3.3. Lehigh Valley Industrial Park VII Land Development Project

Source: Lehigh Valley Industrial Park, Inc. http://www.lvip.org/available-land

Figure 3.4 shows the redevelopment project by Majestic Realty on the property. The buildings 

proposed at the Majestic business park are seen in Figure 3.4, which includes the first completed 

structure, a warehouse and distribution center for Crayola, LLC. 

Figure 3.4. Majestic Bethlehem Center Business Park

Source: Majestic Realty. http://www.majesticrealty.com/downloads/beth/majesticbethlehem-bldg3_broch.pdf
- 17 -

Figures 3.5 and 3.6 show the Freemansburg area in 2010 and 2012, respectively.

Figure 3.5. Freemansburg, PA – May 2010

Source: Google Earth

Figure 3.6. Freemansburg, PA – May 2012

Source: Google Earth
- 18 -

As you can see, when comparing Figures 3.1-3.6, over time, the landscape of the old Bethlehem 

Steel plant has changed. In 2008, not much work was going on at the site due to economic 

conditions. However, starting in late 2008 and early 2009, land development including 

demolition, excavation of land and old foundations, and construction began to occur on various 

sections of 1,800 acres of land. This work, along with vehicular traffic on unpaved roads on the 

former Bethlehem Steel property, would likely cause dust to leave the premises. As seen in the 

Google Earth images, over time, development initially occurred from the western portion of the 

property and has moved east. Construction on the Bethlehem Sands Casino was completed in 

mid-2009; the Bethlehem Sands Hotel in mid-2011; and the Outlets at Sands Bethlehem in 

late 2011. Also note, in Figure 3.6, the Walmart warehouse was completed by May 2012 (with 

the Crayola warehouse, built immediately to the east of the Walmart warehouse (as indicated in 

Figure 3.4), being completed since this image). While construction is still ongoing, particularly 

for warehouses on the eastern-most portion of the property, the preparation and earthmoving is 

minimal compared to the late 2008-2012 timeframe.
- 19 -

4. JURISDICTIONAL BOUNDARIES

In Factor 5 of EPA’s TSD analysis, it is pointed out that, “examples of such jurisdictional 

boundaries include existing/prior nonattainment area boundaries for particulate matter, county 

lines, air district boundaries, township boundaries, areas covered by a metropolitan planning 

organization, state lines, and Reservation boundaries, if applicable.”

The EPA TSD analysis described the existing jurisdictional boundaries for the AllentownBethlehem-Easton MSA, Lehigh Valley Planning Commission (Metropolitan Planning 

Organization) and the previously established nonattainment boundary for the 2006 24-hour PM2.5

NAAQS. As noted in Section 1, the Freemansburg and Lehigh Valley monitors have typically 

correlated well. DEP’s analysis supports a single-county boundary finding due to a proven local 

issue caused between 2009 and 2011, by earth-moving activities just south of the Freemansburg 

monitor in Northampton County. DEP believes that in this case, a jurisdictional boundary of a 

single-county, Northampton County nonattainment area, is appropriate because the 

Freemansburg monitor is now showing a downward trend in PM2.5 concentrations.

CONCLUSION

After considering the facts as described above, and previously presented in the designation 

recommendations, DEP is recommending that EPA reduce the intended nonattainment area from 

the Allentown Area consisting of Lehigh and Northampton County to solely comprise of

Northampton County as the nonattainment area. The Allentown-Bethlehem-Easton Area was 

previously designated nonattainment for the 2006 24-hour PM2.5 NAAQS when the monitored 

24-hour values had extremely similar values, something that was not seen in 2010 and 2011 

between the Freemansburg and Lehigh Valley monitors.

DEP’s analysis shows that in 2010 and 2011, the Freemansburg monitor had an annual mean 

more than 3 μg/m

3

higher than the Lehigh Valley monitor. This difference was due to local 

projects just south of the monitor (where winds come from on the highest PM2.5 days, as 

analyzed in DEP’s designation recommendations). Due to higher annual mean values at the 

Freemansburg monitor in 2010 and 2011, the design values for 2010 through 2013 were also 

higher. Since the annual mean has dropped below the 2012 annual PM2.5 NAAQS, starting in 

2012, the annual design value is on the decline (which correlates with much of the demolition 

and earth-moving of land south of the monitor being completed) and is expected to achieve 

attainment of the 2012 annual PM2.5 NAAQS based on the 2014 design value. Although the 

EPA TSD analysis points to area and mobile source emissions due to a connection with 

population and population density within the Allentown area, the Lehigh Valley monitor is more 

indicative of the regional emissions. In addition, the seven major facilities referenced in Lehigh 

and Northampton Counties have reduced direct PM2.5 and precursor emissions by more than 

56 percent.

DEP’s analysis supports the conclusion that the size of the 2012 annual PM2.5 nonattainment area 

should be reduced from EPA’s proposed designation to a single-county nonattainment area. It is

strongly recommended that Northampton County area be designated as a separate PM2.5

nonattainment area and that Lehigh County be designated as an unclassifiable/attainment area.
Enclosure 4

The Commonwealth of Pennsylvania’s Response to the 

U.S. Environmental Protection Agency’s Proposed Designations for 

the 2012 Annual PM2.5 National Ambient Air Quality Standard

Request for Consideration of 2014 Design Values Prior to the 

Effective Date of Final Designations

Bureau of Air Quality

Department of Environmental Protection
[This page intentionally left blank.]
- 1 -

In its August 19, 2014, letter to Governor Corbett, EPA indicated plans to promulgate final 

annual PM2.5 designations in December 2014 for the 2012 annual PM2.5 NAAQS. EPA has 

indicated that the effective date of the final designations will likely be March 2015. Several 

areas in Pennsylvania that EPA proposed to designate as nonattainment areas may come into 

attainment of the NAAQS before March, based on the 2014 design value. Therefore, the PA 

Department of Environmental Protection (DEP) intends to complete early certification of the 

data for monitors within Pennsylvania. Once the 2014 data is received, DEP will submit a letter 

to EPA, prior to the effective date of the final designations, requesting withdrawal of any area 

showing attainment of the 2012 annual PM2.5 NAAQS. The DEP would also in that letter 

request that the designated nonattainment area(s) be reclassified as unclassifiable/attainment. 

Current air quality monitoring data for nonattaining monitors is provided below.

AIR QUALITY MONITORING DATA

The tables in this section include information for nonattaining monitors that are within EPA’s 

intended nonattainment areas, including the Allegheny County Area, Johnstown area (Cambria 

County and partial Indiana County), Delaware County Area, Lebanon County Area and 

Allentown Area (Northampton and Lehigh Counties). The purposes of these tables is to show 

what the monitors in the nonattainment areas have been monitoring and to point out the potential 

for one or more of these areas to attain the 2012 annual PM2.5 NAAQS, based on data as early as 

the 2014 design value.

Table 1.1 includes annual mean data for the five monitors located in EPAs proposed 

nonattainment areas. In 2013, all of these monitoring locations recorded an annual mean lower 

than the 2012 annual PM2.5 NAAQS of 12.0 μg/m3.

Table 1.1. PM2.5 Nonattaining Monitors - Annual Mean (in μg/m3)

County Station AQS Code 2010 2011 2012 2013

Allegheny Liberty 42-003-0064 16.04 14.00 14.29 11.98

Cambria Johnstown 42-021-0011 11.94 13.43 11.57 11.93

Delaware Chester 42-045-0002 13.51 12.94 12.81 11.47

Lebanon Lebanon 42-075-0100 N/A 11.43 14.25 11.22

Northampton Freemansburg 42-095-0025 13.73 14.46 11.45 10.55

Table 1.2 includes annual design value data for the five monitors located in EPA’s proposed 

nonattainment areas. The general trend for design values is downward across these monitors

since 2010. The Chester, Freemansburg and Liberty monitors had a difference in design value 

from 2012 to 2013 of 0.7 μg/m3, 1.0 μg/m3and 1.4 μg/m3, respectively.
- 2 -

Table 1.2. PM2.5 Nonattaining Monitors - Annual Design Value (in μg/m3)

County Station AQS Code 2010 2011 2012 2013

Allegheny Liberty 42-003-0064 16.0 15.0 14.8 13.4

Cambria Johnstown 42-021-0011 12.6 12.4 12.3 12.3

Delaware Chester 42-045-0002 13.3 12.9 13.1 12.4

Lebanon Lebanon 42-075-0100 N/A N/A N/A 12.3

Northampton Freemansburg 42-095-0025 12.6 13.4 13.2 12.2

Table 1.3 projects the annual mean necessary at the nonattaining monitors in the 2014 calendar 

year in order to meet or drop below the 2012 annual PM2.5 NAAQS of 12.0 μg/m3.

Table 1.3. PM2.5 Annual Mean Necessary in 2014 to Achieve Attainment (in μg/m3)

County Station AQS Code 2014

Allegheny Liberty 42-003-0064 9.88

Cambria Johnstown 42-021-0011 12.65

Delaware Chester 42-045-0002 11.87

Lebanon Lebanon 42-075-0100 10.68

Northampton Freemansburg 42-095-0025 14.15

Table 1.4 provides the first and second quarter values for 2014 at each of the five nonattaining 

monitors that are within EPA’s proposed nonattainment areas.

Table 1.4. PM2.5 Quarterly Values Through Second Quarter 2014 (in μg/m3)

County Station AQS Code 1

st Quarter 

Average

2

nd Quarter 

Average

Average of 

1

st & 2nd

Quarters

Allegheny Liberty 42-003-0064 14.73 12.50 13.61

Cambria Johnstown 42-021-0011 16.07 10.35 13.21

Delaware Chester 42-045-0002 15.07 10.95 13.01

Lebanon Lebanon 42-075-0100 17.22 10.95 14.09

Northampton Freemansburg 42-095-0025 13.76 7.98 10.87

CONCLUSION

Based on the information provided above, it appears probable that the Freemansburg monitor 

(for Northampton and Lehigh Counties) will be in attainment of the 2012 annual PM2.5 NAAQS

after calculation of the 2014 design value. It is also possible that the Johnstown monitor and/or 

the Chester monitor (for Cambria and Indiana Counties and Delaware County, respectively) will

achieve attainment of the standard, based on the 2014 design value. The Liberty and Lebanon 

monitors will likely take another year or two to come into attainment of the standard.

If any of these monitoring locations achieves a 2014 design value that is equal to or less than the 

2012 annual PM2.5 NAAQS of 12.0 μg/m3, then prior to the effective date of EPA’s final 

designations (effective date currently expected in March 2015), DEP will submit a letter to EPA

requesting withdrawal of the appropriate nonattainment area and requesting that the designated 

nonattainment area(s) be reclassified as unclassifiable/attainment.