Proposed Lead “Infrastructure” State Implementation Plan Revision

COMMENT AND RESPONSE DOCUMENT 

Bureau of Air Quality

Department of Environmental Protection 

Commonwealth of Pennsylvania

September 2012
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COMMENTS AND RESPONSES

Proposed Lead “Infrastructure” State Implementation Plan Revision

The public comment period began June 9, 2012 and closed July 13, 2012. A public hearing was 

held on July 10, 2012 at DEP’s Southcentral Regional Office. No witnesses presented 

testimony. Public comment was received from one commentator, listed below:

Fred P. Osman, P.E. BCEE

President

Osman Environmental Solutions, LLC

4708 Rock Ledge Drive

Harrisburg, PA 17110

on behalf of Berks County

1. COMMENT: The commentator realizes that this State Implementation Plan (SIP)

revision is intended to show only that the “infrastructure” is in place in Pennsylvania to 

implement measures to adequately monitor lead nonattainment and to enforce needed 

controls to achieve attainment. However, the commentator believes one item is not 

properly addressed in the SIP revision: the requirements in §110(a)(2)(B)(i) regarding 

ambient monitoring.

RESPONSE: The Department agrees that the intent of this SIP revision, with regard to 

ambient monitoring, is to describe the authority and ability of the Commonwealth, under 

the Commonwealth’s already-approved SIP, to install an ambient monitoring network in 

compliance with Part 58, Appendix D. The purpose of this SIP revision is not to identify 

the placement of any specific lead monitor. Therefore, the Department disagrees that this 

item is not properly addressed in this SIP revision. 

The requirements in 40 CFR 58.10(a)(4) pertaining to lead monitoring have been met. 

As required, the Department submitted a plan to the U.S. Environmental Protection 

Agency (EPA) for establishing source-oriented lead monitoring sites for lead sources 

emitting 1.0 tpy or greater as part of the 2010 annual network plan submitted in 2009. 

Prior to submittal, the Department held a 30-day public comment period on this plan and 

prepared a comment and response document, which was provided to EPA as part of the 

plan. The monitoring in Berks County was described as part of this submittal. In July 

2011, the Department also submitted a plan, after public comment, to EPA for 

establishing source-oriented lead monitoring sites for lead sources emitting equal to or 

greater than 0.50 tpy but less than 1.0 tpy. EPA concurred with both plans. 

Due to ongoing concerns from the Berks County Commissioners, the Department is open 

to evaluating the possibility of future additional sampling in the vicinity of the largest 

lead emission source, Exide Technologies. 

Because the North Reading area in Berks County has been designated as nonattainment 

for lead, the Commonwealth must submit to EPA a SIP revision additional to this 
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“infrastructure” SIP revision, which will contain emission inventories, a demonstration 

that Reasonably Available Control Technology/Reasonably Available Control Measures 

will be used, a demonstration of reasonable further progress, a modeled attainment 

demonstration showing attainment by December 31, 2015, and contingency measures. 

The additional SIP revision will also contain items related to monitoring, such as air 

quality trends and a commitment for continued monitoring and will be subject to public 

comment and an opportunity for a public hearing. This additional SIP revision will 

describe the current monitoring operational in the North Reading area. Comments on the 

fulfillment of monitoring requirements for the North Reading area would be relevant to 

that SIP revision. 

2. COMMENT: The requirement to locate a monitor at the maximum lead concentration 

location impacted by the Exide-Reading lead smelter facility has not been met. A

monitor should be placed at an alternative site that may record significantly higher levels 

than DEP’s Laureldale North site. The commentator cites results from Exide’s own 

monitoring system, EPA’s modeled emission estimates for the Secondary Lead Smelter 

NESHAPs rule regarding fugitive emissions and guidance documents related to 40 CFR 

Part 58, Appendix D as evidence that the requirements have not been met. The 

commentator finds it “inconceivable” that DEP would propose and EPA approve the 

siting of the Laureldale North site.

RESPONSE: Since the intent of this SIP revision, with regard to ambient monitoring, is 

to describe the authority and ability of the Commonwealth to install an ambient 

monitoring network in compliance with 40 CFR Part 58, Appendix D, not to identify the 

placement of any specific lead monitor, no change has been made to the SIP revision as a 

result of this comment. The Department notes, however, that EPA approved the 

Laureldale North site as compliant with EPA requirements. 

3. COMMENT: DEP should not conclude that since fugitive dust emissions will be better 

controlled in the future, there is no need for the alternative monitoring location discussed 

in the comments. The commentator states that a plan approval (to put a total enclosure 

around the facility) is an authorization to construct, not a requirement to do so. The 

commentator also states that only the alternative monitoring location will validate that the 

proposed measures are working after they are implemented.

RESPONSE: Please see responses to comments 1 and 2.