# •

# £:~~~!~~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 (PM 2

. 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 PM 2

. 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 PM 2

. 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_

Pr i nted on Recycled Paper 

### \6CJ www .depweb.state. pa. usMr. Shawn M. Garvin -2- October 28, 2014

Liberty-Clairton nonattainment area for the 2012 annual PM 2

. 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 PM 2

. 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 PM 2

. 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 PM 2.5



## 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 (E PA ) promulgated the annual fine particulate matter ( PM 2.5 ) 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 submit ted 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 19 th letter, EPA intends to modify Pennsylvania's recommended

boundaries for t he Cambria County (Johnstown), Liberty

- Clairton (Allegheny County), and Northampton County (Allentown) areas. Specifically, EPA inten ds 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 des ignate all other

areas of the Commonwealth as u nclassifiable/attainment areas.

In December 2013, Pennsylvania recommended a partial county Liberty

- Clairton nonattainment

area for the 2012 PM 2.5 NAAQS consistent with the existing boundaries promulgated by EPA for

the 1997 and 2006 PM 2.5 NAAQS. The existing nonattainment boundaries for the Liberty

Clairton 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 local

source impacted, nonattainment area, within the Pittsburgh nonattainment area

. ” 1

In its August 19, 2014

, letter to Governor Corbett

, EPA proposed to expand the existing Liberty

Clairton nonattainment area to include all of Allegheny County for the 2012 annual PM 2.5 National Ambient Air Quality Standard (NAAQS)

. However, an expansion of the boundaries of the existing Liberty

- Clairton nonattainment areas for the 1997 and 2006 PM 2.5 NAAQS is

unwarranted.

The Pennsylvania Department of Environmental Protection ( DEP ) has conducted a comprehensive evaluation of EPA’s proposed des ignations for the 2012 annual PM 2.5 NAAQS

. Based on a further review and analysis of available data by DEP and the Allegheny County Health Department (ACHD) , Pennsylvania disagree s with EPA’s enlargement of the proposed

nonattainment area

. T he existing 1 997 and 2006 PM 2.5 NAAQS nonattainment boundaries for

the Liberty

- Clairton area should be retained for the 2012 annual PM 2.5 standard.

The DEP worked in coordination with the ACHD to develop the supporting analysis in that justifies the partial county PM 2.5 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 PM 2.5 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 pa rtial county nonattainment area

. T he remainder of Allegheny County should be designated a s an unclassifiable/attainment area. Th e information contained in this enclosure supplements the information DEP submitted to EPA on December 10, 2013

, and July 30, 2014.

B ACKGROUND 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 PM 10 , or particles having a diameter le ss than or equal to 10 micrometers (μg/m 3 )

. 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, t he

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

. ” T he City of McKeesport was not included in the Group II area for the 1987 PM 10 NAAQS. Pursuant to S ection 107(d)(4)(B) and 188(a) of the Clean Air Act, areas which had

monitored violations of the PM 10 NAAQS prior to January 1, 1989, were, by operation of law,

upon enact ment of the 1990 CAA amendments on November 15, 1990 , designated

nonattainment and classified as moderate for PM 10

.

On July 18, 1997

, EPA published annual and 24

- hour primary and secondary standards for fine particulate matter (PM 2.5 )

. In February 2004, DEP submitted a letter to EPA with area

recommendations for the 1997 annual PM 2.5 NAAQS

, which included the recommendation that all of Allegheny C ounty 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 C ounty : the Liberty

- Clairton A rea and a separate North Braddock Area

. The Liberty

- Clairton Area include d 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 tha n 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 L iberty

Clairton A rea 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 includ ing 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 A rea

.

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 PM 2.5 standard from 65 μg/m 3 to 35 μg/m 3

. On December 28, 2007, DEP submitted designation recommendations to E PA for the 2006 24

- hour

PM 2.5 NAAQS . These recommendations includ ed a recommendation for the same partial county Liberty

- Clairton nonattainment area for the 2006 PM 2.5 NAAQS . As supporting factors for a

separate Liberty

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

Annual and 24

- hour PM 2.5 design values are much higher, particularly at the Liberty monitor, than the surrounding areas. There are significant differences between the two

monitors within the PM 2.5 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 PM 2.5 concentrations are also significantly different (~30 μg/m 3 ). This steep gradient between the se 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 PM 2.5 design values. A smaller nonattainment area is therefore justified.

EPA’s technica l support document (TSD) analysis for the 2006 24

- hour PM 2.5 NAAQS for the Liberty

- Clairton area note s on page 2 that,

For the designations for the 1997 PM 2.5 NAAQS, the Commonwealth of Pennsylvania provided extensive documentation to support a recommenda tion 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

correla te well

, except for the Liberty monitor

. EPA indicated that concentrations of carbon at the Liberty monitor far exceed those at othe r monitors in the area.

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

24

- hour PM 2.5 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 Pittsburgh

Beaver 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 A rea

as a separate nonattainment area for the 2006 24

- hour PM 2.5 NAAQS , with the remainder of

Al legheny 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 1 3 , 2012 , EPA promulgated a primary annual PM 2.5 NAAQS of 12.0 μg/m 3

. On December 10, 2013, DEP recommended that the Liberty

- Clairton Area be designated as

nonattainment for the 2012 annual PM 2.5 NAAQS

, based primarily on 2010

- 2012 air quality

data

. The DEP recommended that the remainder of Alleg heny County, as well as Westmoreland County, establish boundaries for a Greater Pittsburgh nonattainment a rea, because th is area contained three monitors that exceeded the new PM 2.5 standard of 12 .0 μg/m 3

. 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 Count ies) w as recommended as either attainment or unclassifiable/attainment areas because the monitors

recorded PM 2.5 concentrations below the standard

. DEP dete rmined 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 PM 2.5 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

ar e below 12 .0 μg/m 3

. 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 th e remainder of Allegheny County . As explained above, th e 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 th e area

. As expected, due to localized impacts and topography

, the Liberty monitor is not attaining the 2006 or 2012 PM 2.5 standards

– the other monitors in Allegheny County are attaining the 1997, 2006 and 2012 PM 2.5 standards. W ith the monitors in the Pittsburgh

- Beaver Valley no nattainment area attaining the

standard s , including seven monitors in Allegheny County ( the lone exception being the Liberty monitor)

, now is not the time for EP A to depart from its current designations for the Liberty

Clairton A rea, which are “separate and distinct from the Pittsburgh

- Beaver Valley PM 2.5 nonattainment area.”

6 74 FR 58,688; November 13, 2009. Effective December 14, 2009.- 5

-

1. AIR QUALITY DATA

1.1. PM

2.5 Annual Mean and Design Value Data

Table 1.1 and Figure 1.1 of this analysis show the downward trend for annual PM 2.5 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/m 3 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

PM 2.5 NAAQS. This downward trend is expected to continue due to significant reductions in

PM 2.5 and precursor emissions including sul fur dioxide emissions

. The data represents Federal Reference Method (FRM) monitored results

, except for Federal Equivalent Method (FEM)

monitored data at Avalon over the timeframe Jan uary 2010

- May 2011.

Table 1.1

. PM 2.5 A nnual Mean (in μg/m 3 ) b y 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

. PM 2.5 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/m 3 ) 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 PM 2.5 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 PM 2.5 design value (DV)

above 12 .0 μg/m 3 was the Libe rty monitor. Several sites have shown consecutive years of

attainment of the 2012 annual PM 2.5 NAAQS (discussed further in Section 1.2)

.

As the EPA TSD analysis points out

,

T he PM 2.5 DVs at seven of the eight monitors correlate well. However, the PM 2.5 DV at the Liberty monitor is considerably higher. The large local sources plus the unique topographical features in this location result in substantially higher PM 2.5 monitored values at the Liberty monitor than the othe r monitors in Allegheny County.

Table 1.2

. PM 2.5 Annual Design Value (in μg/m 3 ) 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

. PM 2.5 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/m 3 ) Avalon

Lawrenceville

Liberty

South Fayette

North Park

Harrison 2

North Braddock

Clairton- 7

-

It is likely that the Liberty

- Clairton A rea could come into attainment in the near future

, particularly since the higher annual PM 2.5 mean values of 14.00 μg/m 3 in 2011 and 14.29 μg/m 3
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 Liberty

Clairton annual mean value was below the 2012 standard of 12 .0 μg/m 3 , with a value of 11.98 μg/m 3

.

Table 1.3 provides quarterly PM 2.5 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/m 3 does not equate to a violation of the standard

. This information is only being provided to show the most recent monitori ng data trends and to point out that the Liberty monitor is consistently monitoring PM 2.5 concentrations above all other monitors in Allegheny C ounty

.

Table 1. 3

. Allegheny County PM 2.5 Monitoring Station Data

2014 Quarterly Averages to Date

Station AQS Code 1 st Quarter Average (μg/m 3 ) 2 nd Quarter

Average (μg/m 3 )

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 noticeabl y higher PM 2.5 concentrations than most of the design value monitors throughout the U.S. Figure 1

. 3 is a chart of annual PM 2.5 design values

for 2 001

- 2013, averaged by region, comparing PM 2.5 design values for Liberty

- Clairton to other previously designated nonattainment areas.- 8

-

Figure 1. 3 . Annual PM 2.5 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

Ar eas 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 A rea (driven by data from the Liberty monitor) shows historical and current

PM 2.5 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. PM

2.5 Monitor Network by Site

While PM 2.5 concentrations at each site are used for comparison to the 2012 PM 2.5 NAAQS, the

individual site details should also be considered in making area designation s . 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 PM 2.5 Mo nitor (42

- 003

- 0002):

The Avalon PM 2.5 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 k ilometers (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 ag reement with ACHD for emissions violations.

The Avalon PM 2.5 monit or was one of two monitors other than Liberty that exceeded the 2012

annual PM 2.5 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 we re found to be non

- equivalent.

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

- Dec ember 2012, are shown in Figure 1

. 3.

Figure 1

. 3. Avalon BAM/FRM Comparability

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

official data for Jan uary 2010

- May 2011 with no collocated FRM for comparison, t he Avalon BAM likely represents non

- equivalent data to the FRM. DEP contends that t he 2011

- 2013- 10

-

design value is the most appropriate design value for comparison to the 2012 annual PM 2.5 NAAQS compared to previous 3

- year periods

.

North Braddock PM 2.5 Monitor (42

- 003

- 1301):

The North Braddock PM 2.5 Monitor i s located in a developed medium

- intensity suburb, 12.5 km

to the east

- southeast of d owntown 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 PM 2.5 NAA QS based on 2010

- 2012 d ata. U. S. Steel is currently under a C onsent Order

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

PM 2.5 design value at North Braddock below 12.0 μg/m 3

, based on 2011

- 2013 data.

Harrison PM 2.5 Monitor (42

- 003

- 1008):

The Harrison PM 2.5 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 ma j or modifications to reduce emissions from the facility. Based on 2013 design values, the Harrison

monitor shows attainment of PM 2.5 NAAQS including the 2012 PM 2.5 annual standard.

Clairton PM 2.5 Monitor (42

- 003

- 3007):

The Clairton P M 2.5 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, t he current design value for the Clairton monitor is 9.8 μg/m 3

– substantially lower than the 2012 PM 2.5 NAAQS. Large differences between Clairton and Liberty (only 3.5 km away) on concurrent sample days indicate the extremely localized nature of

PM 2.5 at the Liberty monitor.

South Fayette PM 2.5 Monitor (42

- 003

- 0067):

The South Fayette PM 2.5 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 PM 2.5 NAAQS

. The monitor also mee ts the 1997 and 2006 standards.

Nor th Park PM 2.5 Monitor (42

- 003

- 0093):

The North Park PM 2.5 monitor is located in a developed low

- intensity suburb, 18.5 km to the

north of downtown Pittsburgh. The PM 2.5 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/m 3

, this monitor has attained the 2012

annual PM 2.5 NAAQS

.- 11

-

Lawrenceville PM 2.5 Monitor (42

- 003

- 0008):

The Lawrenceville PM 2.5 monitor is located in a developed high

- intensity district of the City of Pittsburgh, the only PM 2.5 site within the city limits, 4.2 km from downtown Pittsburgh. It has been classified by EPA as an urban National Co re ( 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 monitor ing attainment (of 10.3 μg/m) of the 2012 annual PM 2.5 NAAQS

.

Liberty PM 2.5 Monitor (42

- 003

- 0064):

The Liberty PM 2.5 monitor is located in a developed low

- intensity suburb, 17.1 km to the south

southeast 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 PM 2.5 concentrations for the Liberty can differ greatly from any other monitor in the county on concurrent sample dates. As seen in Table 1.4, t he Liberty monitor shows the highest standard deviation in concentrations of the monitor network due to these higher values.

Table 1 .4

. PM 2.5 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 PM 2.5 compared to the rest of the monitoring network.

1.3. PM

2.5 Monitor Network Assessment

As required by amended 40 CFR Part 58, a Monitor Network Assessment was completed for the Allegheny County PM 2.5 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 netw ork. (Note that, at this time, the PC

- based EPA network assessment tools cannot be updated by the user with more recent data

. )- 12

-

Correlation Matri x :

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 PM 2.5 FRM monitors based on 2006

- 200 8 averages.

PM 2.5 m onitors from Beaver, Wash ington, and Westmoreland Counties (420070014, 421250005, 421290008) we re 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 PM 2.5

The 200 6

- 200 8 matri ces show ed that the Lawrenceville PM 2.5 monitor ha d the best overall

correlation and lowest relative difference compared to other s outhwestern Pennsylvania ( SW PA ) monitors, indicating co nsistency 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 appropri ateness 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 Assess ment are shown in Table 1

. 5

.

Table 1 .5

. PM 2.5 FRM Rankings

Based on 2006

- 2008 factors, many of which are the same for 2011

- 2013 data, the Liberty PM 2.5 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

PM 2.5 shows a source

- based relationship to SO 2 at the Liberty monitor which is not seen at the

Lawrenceville monitor . Elevated levels of PM 2.5 often accompany SO 2 exceedances at Liberty during poor dispersion conditions. Additionally, PM 2.5 and SO 2 exhibit different hourly behavior at Liberty compar ed to other sites.

Figures 1

. 6 and 1

. 7 are scatter plots for the Liberty and Lawrenceville monitors , SO 2 vs. PM 2.5 , daily maximum 1

- hour values, for 2011

- 2013. Hourly data for PM 2.5 is measured by tapered element oscillating microbalance (TEOM) PM 2.5 monitors at both Liberty and Lawrenceville.

Figure 1 .6 . SO 2 vs. PM 2.5 TEOM Daily Maximums, Liberty, 2011

- 2013- 15

-

Figure 1

. 7 . SO 2 vs. PM 2.5 TEOM Daily Maximums, L awrenceville , 2011

- 2013

It should be noted that ‘r’ is the correlation coefficient, and ‘r 2 ’ 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 r egression 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 SO 2 and PM 2.5 , 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 SO 2 concentration, there is an increase in PM 2.5 by 667.93

times the value of SO 2 plus 17.485 μg/m 3

. 8

Of the 37 exceedances of the SO 2 daily maximum 2010 1

- hour NAAQS at Liberty during

2011

- 2013, over 80% occurred when the FRM 2 4

- hour value was above 20 μg/m 3 , 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 SO 2 Exceedances

FRM Range Number of SO 2 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 SO 2 sites and continuous PM 2.5 sites in Allegheny County.- 17

- Figure 1 .8 . Hourly Average SO 2 , Allegheny County Sites, 2011

- 2013

Figure 1 .9 . Hourly Average PM 2.5 (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 SO 2 and PM 2.5 . This diurnal trend is unique to Liberty, as the other sit es show peaks only during rush hour or daytime conditions.

1.5

. Speciation Data

Raw speciation data was examined for tri

- state monitoring si tes 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 Quake r City, OH and Dolly Sods, WV.

The Florence (Washington Co.) and Greensburg (Westmoreland Co.) monitoring sites reside upwind and downwind of Allegheny County, respec tively. 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 freque ncies (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

PM 2.5 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 o f 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

S ANDWICH data, since it was the most recent 3

- year period available from EPA. (See EPA

PM 2.5 SANDWICH data at http://epa.gov/ttn/analysis/sandwich.htm )

Figure 1 .12 shows the average tri

- state species for 2010

- 2012 b y SANDWICH method. Note that several assumptions are built into the SANDWICH technique:

 Retained nitrate (NO 3 r ) is calculated by EPA from temperature, relative humidity, and

dissociation constants ;

 OCMmb is organic carbonaceous mat erial 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 i s derived as fully neutralized

sulfate ;

 For cases where no FRM valu e is present, STN mass is used

.- 20

- F igure 1 .12 . Tri

- State SANDWICH Species Averages, 2010

- 2012

Legend: SO 4 = sulfate ion ; NO 3 r = retained nitrate ion ; NH 4 r = 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 su ch 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, t he SANDWICH data can also be lumped into average area contributio ns for each species. For this analysis, rural transported background is considered to be the average of the rural federal sit es (Quaker City , OH and Dolly Sods , WV ), s urrounding 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 F igure 1 .13

.- 21

- Figure 1 .13 . SANDWICH Averages by Area Contribution, 2010

- 2012

Example calculation: Liberty E xcess SO 4 = Liberty SO 4 – Lawrenceville SO 4 – Avg(Florence SO 4 + Greensburg SO 4 )

– Avg (Quaker City SO 4 + Dolly Sods SO 4 )

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 u rban influence for PM 2.5 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 PM 2.5 in SWPA that is not contributing to

exceedance levels of PM 2.5 . 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 (NH 4 ) 2 SO 4 , 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 (H 2 SO 4 ) may be fresher or limited by NH 3 and partially neutralizing to ammonium bisulfate (NH 4 HS O 4 ). 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 list ed facilities and facility

- level emis sions

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 PM 2.5 , components of direct PM 2.5 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) NH 3 NO X PM 2.5 SO 2 VOC Total

USS/Clairton Coke Works (4200300032) 1 123 3,075 500 1,468 336 5,502

Us Steel Corp/Irvin Pl an t (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 Pl an t (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 A llegheny County with Emissions in Tons in 2013

Identified in PA DEP ’s AIMS Database

Facility Name (Facility ID) Distance

from violating

monitor (miles) NH 3 NO X PM 2.5 SO 2 VOC Total

USS/Clairton Coke Works (4200300032) 1 145 3,761 327 1,637 307 6,177

Us Steel Corp/Irvin Pl an t (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 Pl an t (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

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

in Table 2.3

.- 26

-

Table 2

. 3

. Emission Difference s 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 Pl an t (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 Pl an t (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 , w hile 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 Work s and U

. S . Steel Irvin Plant . The C lairton Coke Works facility, the country’s largest coking operation, increased emissions b y 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 Liberty

Clairton area, including the Cheswick plant and others, will be subject to controls required to

meet the 2010 1

- hour SO 2 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 P ennsylvania 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

Internation al Airport

.

As noted i n Figure C on page 78 of EPA’s TSD, t he Clairton Coke Works facilit y is in the Monongahela Valley, in the area of Liberty

- Clairton . T his 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 locatio n 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 parti al 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 PM 2.5 . 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 u rbanized 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 corri dors. 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 PM 2.5 NAAQS. The Liberty monitor is influenced by extreme localize d 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 A rea, 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 ha ve 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

All egheny 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

PM 2.5 standards , and Liberty

- Clairton lags behind , as was expected when EPA designat ed the

1997 and 2006 PM 2.5 nonattainment areas

.

2.2. PM

2.5 SIP Modeling

CAMx modeling and Modeled Attainment Test Software (MATS) unmonitored area tests performed for the 2006 24

- hour PM 2.5 NAAQS SIP shows much more refined gridded modeling

results than shown in the EPA TSD analysis for the 2012 annual PM 2.5 NAAQS

.

Unmonitored area PM 2.5 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 PM 2.5 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 PM 2.5 Analysis, Baseline 2007 (left) and Projected 2014 (right),

0.8 km Gridded Modeling Domain, from 2006 PM 2.5 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 PM 2.5 emissions are highest at the urban core, extending into the parkway corridors of Interstates 279 and 376 (Note that near

- road PM 2.5 monitored r esults are not part of the current 2012 annual PM 2.5 NAAQS designations.)

.

CAMx m odeling 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 SO 2 NO X CO VOC NH 3 PM 2.5
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 SO 2 NO X CO VOC NH 3 PM 2.5 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 withi n 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

SO 4 NO 3 NH 4 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

SO 4 NO 3 NH 4 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 : SO 4 = sulfate ion ; NO 3 = nitrate ion ; NH 4 = ammonium ion ; POA = primary organic aerosol ; SOA = secondary organic aerosol ; EC = elemental carbon ; OTHER = unspeciated PM 2.5

.

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 source s such as Eastman, Guardian, Elrama, or Mitchell. Most of the local impacts were from direct PM emissions (OTHER, POA, EC) , while secondary components (SOA, NO 3 ) contributed minimally to impacts at Liberty

. It should be noted that Elrama and

Mitchell were modeled at Cross

- State Air Pollution Rule (CSAPR) emis sion levels for future case 2014. Both of these power plants are currently deactivated.

L ocal sulfate can be apportioned to either primary or secondary PM 2.5 , 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: a mmonium is mostly

associated with sulfate in the model

. )

.

It should also be noted that modeled impacts for the PM 2.5 SIP were used in a relative sense for

future desi gn value calculations ( See PM 2.5 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/m 3 for 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 can not 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

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

main source contribu ting 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.

M odeled 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

B as e F act or Pr ofil es

- R u n 1 0



### Q 

# 0

# ~ : • 

## • • 

## • 

## • 

## •

• 

# 0 0 [J

• (!) • 

# . ... . • D • • qp



## •



# . 0

. •



# . D !il

... • [J 

## • • •- 33

- Figure 2.4. Liberty Source Factor Profiles

Fig ures 2.3 and 2.4 show some common factors between Lawrenceville and Liberty, with some distinct larger industrial source factors only evident at Liberty.Factor11Factor10Factor9Factor8Factor7Factor6Factor5Factor4Factor3Factor2Factor1Cone.Cone.Cone.Cone.Cone.Cone.Cone.Cone.Cone.Cone.Cone.........,.__,__,OfftpoOfff'?oOffe'?oOffe'?oOfff'?oOfftpoOfff'?oOffe'?oOffe'?oOfff'?oIIIIIILLLLIILLIIIILLLLIICCLIIIm1IIJ:!j:5111IIIIILLLLIILLLiIIIIIII<ft•,r:f!<-4:'/10",0>'.,-4,<?>qf){>•"---'I{)<;f)<:;.0••/-+t0""•'<?+,.'11'Y•.I1.I1.••m.,"'...,.,!l0<D"':0c:::Jw.-,g!!!;0·'i1*::>0o-·VJO"0;;;giJi0000000000% %% % %% %% % % %o6a9scJope,- 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 f actors 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 contr ibution 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

Liber ty

- 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 ex ceed 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 c ity of Pittsburgh as

the most urbanized area.

The EPA TSD analysis showed population growth and population density in terms of a full

county, 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
discus sed

.

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 PM 2.5 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 de crease 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 PM 2.5 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 PM 2.5 annual standard did not include a similar statement, even though the factor of popu lation 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 met eorological 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 trans port of directly emitted particulate matter and precursor emissions

from so urces 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 i n Table 3

. 1.- 39

-

T able 3

. 1. Total Days of Inversions: 2009

- 2013, D erived from PIT NWS S oundings *

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 inve rsions. 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 atmosph eric 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 PM 2.5 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 da ta helps to determine the effect on the fate and transport of emissions contributing to PM 2.5 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 trajectorie s, wind speed, wind direction and other meteorological data as

available.

In addition, a description of f actor 3 o n EPA’s website regarding “Area Designations for the 2012 Annual Fine Particle (PM 2.5 ) 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 PM 2.5 concentration days for 2011

- 2013 at Liberty Borough. The trajectory end point is at Allegheny County Airport. S urface 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 PM 2.5 = 59.0  g/m 3

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

- Figure 3

. 2b. 24

- hr PM 2.5 = 57.0  g/m 3

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

- Figure 3

. 2c. 24

- hr PM 2.5 = 54.7  g/m 3

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

- Figure 3

. 2d. 24

- hr PM 2.5 = 54.3  g/m 3

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

- Figure 3

. 2e. 24

- hr PM 2.5 = 48.9  g/m 3

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

- Figure 3

. 2f. 24

- hr PM 2.5 = 48.6  g/m 3

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

- Figure 3

. 2g. 24

- hr PM 2.5 = 48.1  g/m 3

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

- Figure 3

. 2h. 24

- hr PM 2.5 = 47.1  g/m 3

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

- Figure 3

. 2i. 24

- hr PM 2.5 = 46.7  g/m 3

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

- Figure 3. 2j. 24-hr PM 2.5 = 44.8  g/m 3

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



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-

Furthermore, ENVIRON International, the PM 2.5 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 Info rmation 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 PM 2.5 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 PM 2.5 , that the

win d 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.

T he EPA TSD analysis for Allegheny County appears to give contradictory information relating to emissions transport and meteorology. On the bottom of p age 110, EPA talks about how

terrain limits the transport of emissions, while earlier on th e same page EPA claim s that “northwesterly component [of the wi nd as indicated by the AGC sensor] indicates that the highly urbanized Pittsburgh area” contributes to PM 2.5 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, f igures 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

PM 2.5 days at the Liberty monitor is alm os t 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 PM 2.5 emissions . D irect PM 2.5 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 PM 2.5

. 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

- F igure 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 p rogram 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 PM 2.5 NAAQS

. ” DEP agrees. Ma intaining the 1997 annual and 2006 24

- hour

PM 2.5 NAAQS boundar ies 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, Liber ty

- Clairton area to achieve and maintain the 1997, 2006 and 2012

PM 2.5 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 desi gnation within Allegheny County, the

Libert y

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

- municipal area was previously designated as nonattainment for PM 10 and PM 2.5 , 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 19 97 and 2006 PM 2.5 NAAQS. T he analysis support s the conclusion that the size of the 2012 annual PM 2.5 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 PM 2.5 NAAQS.

## Enclosure 2

The Commonwealth of Pennsylvania’s Response to the U.S. Environmental Protection Agency’s Proposed Designations for the 2012 Annual PM 2.5 

## National Ambient Air

Quality Standard

Letter of Support for Partial County Liberty

- Clairton PM 2.5 

## 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 PM 2

. 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 PM 2.5



## 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 (E PA ) promulgated the annual fine particulate matter ( PM 2.5 ) 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 submit ted 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 PM 2.5 National Ambient Air Quality Standard (NAAQS)

. Pennsylvania had

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

D EP 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 are a for the 2012 annual

PM 2 .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

. Th e information contained in this enclosure supplements the i nformation DEP submitted to EPA on December 10, 2013

, and July 30, 2014.

DEP ha s 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

r ecommended. DEP re commends that EPA designate the Northampton County a rea as a separate nonattainment area, and designate Lehigh County as an unclassifiable/attainment area.

B ACKGROUND AND OVERVIEW

On July 18, 1997

, EPA published annual and 24

- hour primary and secondary standards for fine particulate matter (PM 2.5 )

. In February 2004, DEP submitted a letter to EPA with area

recommendations for the 1997 annual PM 2.5 NAAQS

, which included the recommendation that

the Allentown

- Bethle hem

- Easton a rea ( Northampton and Lehigh Counties ) be designated as attainment, as both counties were monitoring attainment of the standard. On January 5, 2005, EPA pu blished 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 PM 2.5 standard from 65 μg/m 3 to 35 μg/m 3

. On December 28, 2007, DEP submitted designation recommendations to EPA for the 2006 24

- hour

PM 2.5 NAAQS . These recommendation s included an Allentown

- Bethlehem

- Easton

nonattainment area , which comprised of Lehigh and Northampton Counties

. As DEP ’s designatio n recommendation s 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 th e 2012 annual PM 2.5 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 PM 2.5 design values i n 2005, the last year both monitors were operating, for Allentown and Freemansburg were 36.4 μg/m 3 and 36.1 μg/m 3
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 PM 2.5 NAAQS

. 2

On December 1 3 , 2012 , EPA strengthened the primary annual PM 2.5 NAAQS to 12.0 μg/m 3

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

nonattainment for the 2012 annual PM 2.5 NAAQS, based primarily on 2010

- 2012 air quality

data. The Freemansburg monitor exceeded the standard at 13.2 μg/m 3 , 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 J uly 30, 2014, DEP provided EPA with updated area recommendations for the 2012 PM 2.5 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/m 3 at the Freemansburg monitor and 10.6 μg/m 3 at 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 PM 2.5 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 PM 2.5 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. Th e Allentown monitor was removed

, because at the ti me 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, re quiring that this area have two PM 2.5 monitors.

Table 1 .1 and Figure 1 .1 show the trend for the annual mean values mo nitored in the Allentown

area.

Table 1 .1

. Allentown Area PM 2.5 A nnual Mean (in μg/m 3 ) 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 PM 2.5 Annual Mean (in μg/m 3 ) 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/m 3 higher 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, t he 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/m 3

. The increase in the annual mean at the Freemansburg mo nitor 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. T his local

issue is tied to construction acti vity 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 do wnward, 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

correlat ion 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 mo nitor 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/m 3 , while the Freema nsburg monitor design values were 13.2 μg/m 3 and 12.2 μg/m 3 respectively.

Table 1 .2

. Allentown Area PM 2.5 Annual Design Value (in μg/m 3 ) 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 PM 2.5 Annual Design Value (in μg/m 3 ) 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 PM 2.5 NAAQS b ased 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/m 3 is a violation of the standard. The annual mean is the average of the four quarterly

average s , 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 PM 2.5 NAAQS, the Freemansburg monitor would need a 2014 annual mean of 14.15 μg/m 3

. C urrently, the average of the quarterly averages at both Lehigh Valley and Freemansburg monitors show a value of less than 11 μg/m 3

.

Table 1

. 3

. Allentown Area Monitoring Station Data

– 2014 Quarterly Averages to Date

Station AQS Code 1 st Quarter Average ( μg/m 3 ) 2 nd Quarter

Average (μg/m 3 ) Average of

1 st & 2 nd

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 PM 2.5 data was completed using a 24

- hour daily average PM 2.5 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 F reemansburg 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 ‘r 2

, ’ 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 meas ured 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 0.74736531 0 0.617786461 0.72707144 0 0.704021058

2013 0.953881874 0.909063001 0.689684057 0.857663778 0.828215254

Table 1.5

. Calculation of r 2 (Coefficient of Determination) Lehigh Valley Reading Swiftwater Bristol Norristown

2011

- 13 0.687125073 0.619675348 0.375795068 0.54099076 0 0.550828239

2011 0.58917599 0 0.58521232 0 0.571085715 0.446121966 0.521109808

2012 0.684518024 0.558554907 0.381660112 0.528632878 0.49564565 0

2013 0.90989063 0 0.82639554 0 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

correlat ion ” in 2013 as opposed to 2011

, which indicates the issue of local emissions near the

Freemansbu rg monitor as opposed to Lehigh Vall ey

. 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 bett er 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 PM 2.5 Concentrations

, 2011 to 2013

Figure 1.5

. Freemansburg vs. Reading Daily Average PM 2.5 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 PM 2.5 Concentrations

, 2011 to 2013

Figure 1.7

. Freemansburg vs. Bristol Daily Average PM 2.5 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 PM 2.5 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 P M 2.5 , components of direct PM 2.5 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) NH 3 NO X PM 2.5 SO 2 VOC Total

Northampton Keystone Portland Cement

/East Allen (420950012) 7 2 828 57 984 7 1,878

Northampton Essroc/Nazareth Lower

Cement Pl an t 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 L P

/Stockertown (420950006) 9 3 989 29 1,420 20 2,462

Lehigh Lafarge Corp/Whitehall Pl an t

(420770019) 10 14 368 36 331 7 754

Northampton P PL Martins Creek L LC

/Martins Creek (420950010) 17 13 943 37 274 30 1,297

Northampton Genon Rema L LC /Portland

Generating Sta tion (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) NH 3 NO X PM 2.5 SO 2 VOC Total

Northampton Keystone Portland Cement

/East Allen (420950012) 7 3 734 41 743 3 1,524

Northampton Essroc/Nazareth Lower Cement

Pl an t 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 L P

/Stockertown (420950006) 9 4 1,405 30 1,418 26 2,883

Lehigh Lafarge Corp/Whitehall Pl an t

(420770019) 10 12 257 36 273 5 583

Northampton P PL Martins Creek L LC

/Martins Creek (420950010) 17 14 770 16 161 34 995

Northampton Genon Rema L LC /Portland

Generating Sta tion (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 P lant 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 L P /Stockertown (420950006) 2,462 2,883 421 17.1%

Lehigh Lafarge Corp/Whitehall P lant (420770019) 754 583

- 171

- 22.7%

Northampton P PL Martins Creek L LC /Martins Creek (420950010) 1,297 995

- 302

- 23.3%

Northampton Genon Rema L LC /Portland Generating Sta (420950011) 17,206 2,532

- 14,674

- 85.3%

GRAND TOTAL 27,808 12,009

- 15,799

- 56.8%

As c an 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

. G EOGRAPHY/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 PM 2.5 concentrations in the area of analysis” without any further explanatio n. There was a large disparity of more than 3 μg/m 3 between the Lehigh Valley and Freemansburg monitors. DEP believes that the PM 2.5 concentrations in the Bethlehem/Freemansburg area were being influenced by emissions sou th 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 189 9 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 unde r 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 BS C 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 Indus trial 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 M ittal, retains the remaining acreage of the BSC Facility. 5

Figure s 3 .1

- 3

. 6 show the nearly 1,800 acres of land formerly owned by Bethlehem Steel ( along

the south ern 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 devel oped 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 201 0 and 2013.

5 http://www.epa.gov/reg3wcmd/ca/pa/otherdocs/BethlehemSteelCommerceCtr_SB.pdf

6 http://www.epa.gov/reg3wcmd/ca/pa/reuse/lu_PAD9908 24161.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

- Fi gure 3

. 2

. Former Property of Bethlehem Steel Corporation

Source: Liberty Property Trust

– Le high Valley Industrial Park VII http://www.gisplanning.net/photos/pa/2785%20Commerce%20Center%20Blvd%20LVIP%20VII.pdf

Fig ures 3 .3 and 3 .4 show the redevelopment projects on t he 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 ar e 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 i n 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

Ste el 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 initia lly occurred from the western portion of the property and has moved east. Construction on t he Bethlehem Sands Casino was completed in

mid

- 2009 ; t he Bethlehem Sands Hotel in mid

- 20 11; 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 t his image ). While construction is still ongoing, particularly

for warehouses on the eastern

- most portion of the property, the preparation and earthmoving is

minim al compared to the late 2008

- 2012 timeframe

.- 19

-

4 . JURISDICTIONAL BOUNDARIES

In Factor 5 of EPA’s TSD analysis, it is pointed out that, “e xamples of such juris dictional 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. ”

T he EPA TSD analysis described the existing jurisdictional boundaries for the Allentown

Bethlehem

- Easton MSA, Lehigh Valley Planning Commission (Metropolitan Planning Organization) and the previously established nonattainment boundary for the 2006 24

- hour PM 2.5 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

- m oving activities just south of the Freemansburg

monitor in Northampton County

. D EP believes that in this case, a jurisdictional boundary of a single

- county, Northampton County nonattainment area

, is appropriate because the Freemansburg monitor is now show ing a downward trend in PM 2.5 concentrations

.

CONCLUSION

After considering th e facts as described above, and previously presented in the designation recommendations, DEP is recommending that EPA reduc e the intended n onattainment area from the Allentown Area consisting of Lehigh and Northampton County to solely comprise of Northampton County as the nonattainment area

. T he Allentown

- Bethlehem

- Easton A rea was previously designated nonattainment for the 2006 24

- hour PM 2.5 NAAQS when the m onitored

24

- hour values had extremely similar values

, something that was not seen in 2010 and 2011

between the Freemansbu rg and Lehigh Valley monitors.

DEP’s analysis shows that in 2010 and 2011, t he 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 PM 2.5 days, as analyzed in DEP’s designation recommendations)

. Due to higher annual mean values at the

Fre emansburg 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 PM 2.5 NAAQS, starting in 2012, the annual design value is on the decline (which correlates with much of t he demolition

and earth

- moving of land south of the monitor being completed ) and is expected to achieve

attainment of the 2012 annual PM 2.5 NAAQS based on the 2014 design value. Although the EPA TSD analysis points to a rea 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 PM 2.5 and precursor emissions by more than 56 percent.

DEP’s analysis supports the conclusion that the size of the 2012 a nnual PM 2.5 nonattainment area

should be reduced from EPA’s proposed designation to a single

- county nonattainment area

. It is strongly recommended that Northampton County a r ea be designated as a separate PM 2.5 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 PM 2.5 

## 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 PM 2.5 designations in December 2014 for the 2012 annual PM 2.5 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 des ign value. Therefore, the PA Department of Environmental Protection (DEP) intends to complete early certification of the

data for monitors within Pennsylvania . Once th e 2014 data is received, DEP will submit a letter

to EPA

, prior to the effective date o f the final designations

, requesting withdrawal of any area show ing attainment of the 2012 annual PM 2.5 NAAQS

. The D EP would also in that letter request that the designated nonattainment area(s) be reclassified as unclassifiable/attainment. Current air q uality 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 A rea, Johnstown area (Cambria County and partial Indiana County), Delaware County A rea, Lebanon County A rea and

Allentown A rea (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 PM 2.5 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

nonattainm ent areas. In 2013, all of these monitoring locations recorded an annual mean lower

than the 2012 annual PM 2.5 NAAQS of 12 .0 μg/m 3

.

Table 1 .1

. PM 2.5 Nonattain ing Monitors

- A nnual Mean (in μg/m 3 ) 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 monitor s had a difference in design value

from 2012 to 2013 of 0.7 μg/m 3

, 1.0 μg/m 3 and 1.4 μg/m 3 , respectively.- 2

-

Table 1 .2

. PM 2.5 Nonattain ing Monitors

- Annual Design Value (in μg/m 3 ) 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 nonattain ing monitors in the 2014 calendar year in order to meet or drop below the 2012 annual PM 2.5 NAAQS of 12 .0 μg/m 3

.

Table 1

. 3

. PM 2.5 Annual Mean Necessary in 2014 to Achieve Attainment (in μg/m 3 )

County Station AQS Code 201 4 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

. PM 2.5 Quarterly Values Thr ough Second Quarter 2014 (in μg/m 3 )

County Station AQS Code 1 st Quarter Average 2 nd Quarter

Average Average of

1 st & 2 nd

Quarters Allegheny Liberty 42

- 003

- 0064 14.73 12. 50 13.6 1

Cambria Johnstown 42

- 021

- 0011 16.07 10. 35 13.2 1

Delaware Chester 42

- 045

- 0002 15.07 10.9 5 1 3.01

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 Count ies ) will be in attainment of the 2012 annual PM 2.5 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 v alue

. The Liberty and Lebanon monitors will likely take another year or two to come into attainment of the standard.

If any of these monitoring location s achieve s a 2014 design value that is equal to or less than the

2012 annual PM 2.5 NAAQS of 12 .0 μg/m 3 , 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 request ing that the designated

nonattainment a rea(s) be reclassified as unclassifiable/ attainment.