Technical Support Document (TSD) For the Modeling Portions ofthe Document Entitled "North Reading NonattainmentArea, Berks County forthe 2008 Lead National AmbientAir Quality Standards", dated August 2015

TSD Prepared October 2015

Timothy A. Leon Guerrero Office ofAir Monitoring and Analysis, 3AP40 U.S. Environmental Protection Agency, Region 3 1650 Arch Street Philadelphia, Pennsylvania 19103

Reviewed by Alice Chow, Associate Director, Office ofAir Monitoring and Analysis (3AP40)

Date SignedTechnical SupportDocument for the Modeling Portion Ofthe Commonwealth ofPennsylvania's Lead StateImplementation Plan (SIP) entitledNorth ReadingNonattainmentArea, Berks County for the 2008 LeadNationalAmbientAir Quality Standards August 2015 

### Purpose oftheTechnical SupportDocument This Technical Support Document (TSD) describes the Environmental Protection Agency's (EPA's) evaluation ofthe air-dispersion modeling for the North Reading Nonattainment Area. The purpose ofthis TSD is to provide more detailed information than can be contained in the official notice published in the Federal Register. Readers who need more information than we provide in this TSD orwant to review the modeling in more detail are encouraged to review the final State Implementation Plan (SIP) submitted by the Commonwealth ofPennsylvania1• 

### Introduction and Regulatory Framework On October 15, 2008, the U.S. Environmental Protection Agency (EPA) promulgated a revised health-based primary and secondaryNational Ambient Air Quality Standards (NAAQS) for lead. The 2008 primary lead NAAQS, which is set at a level to protectpublic health from adverse effects, is 0.15 micrograms per cubic meter (!lg/m3). The secondary standard, which is set at a level requisite to protect the public welfare from adverse effects, is identical to the primary standard. InNovember of2010, the US EPA designated three (3) areas in Pennsylvania as lead nonattainment areas based on 2007-09 air quality monitoring data. Laureldale Borough, Muhlenberg Township and Alsace Township in Berks County, PA were designated as the North Reading Nonattainment Area. Figure 1 displays the North Reading, PANonattainment Area along with lead monitor sites and significant lead sources within the nonattainment area.

http:Uwww.portal.state.pa.us/portal/server.pt/communitv/regulations and clean air plans/21827/state imple mentation plan/1830622 Page 1 ofllTechnical SupportDocument for the Modeling Portion Ofthe Commonwealth ofPennsylvania's Lead State Implementation Plan (SIP) entitledNorth ReadingNonattainmentArea, Berks County for the 2008LeadNationalAmbientAir Quality Standards August 2015 North Reading, PA Lead Nonattainment Area Legend

Exide Yuasa £ Lead Monitors**Nor1hR..cllnj;~tlonatlilin101..,., NU** 

0 8 Kilomelers 

### Figure 

### 1. The municipal units and lead monitoring sites that are part ofthe North Reading, PA NonattainmentArea Lead SIP regulations found at 40 CFR 51.117 require states to employ atmospheric dispersion modeling for the demonstration ofattainment for areas in the vicinity ofpoint sources listed in 40 CFR 51.117(a)(1). Meteorological and other data are needed to complete the required airdispersion modeling. EPA notes 40 CFR 51.117(a) provides that states must include, as a part of their attainment modeling demonstration, an analysis showing that the SIP will attain and maintainthe standard in areas in the vicinity ofcertain point sources that are emitting significant emissions oflead and also in "any other area that has lead air concentrations in excess ofthe national ambient air quality standard concentration." In doing the analysis, required under 40 CFR 51.117(a )(2), EPA expects the state will take into consideration all sources oflead emissions within the nonattainment areathat may be required to be controlled.

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· .·Technical SupportDocumentfor the Modeling Portion Ofthe Commonwealth ofPennsylvania's Lead StateImplementation Plan (SIP) entitled North ReadingNonattainmentArea, Berks County for the 2008LeadNationalAmbientAir Quality Standards August 2015 

### Overview ofCommonwealth ofPennsylvania's General Modeling Approach PA DEP examined meteorological data measured by an Automated Surface Observing System (ASOS) at the Reading Regional Airport (KRDG) along with morning upper air data from the Washington Dulles International Airport (KIAD) to determine model dispersion conditions in the North Reading Nonattainment Area. The Reading Airport is located approximately 4 kilometers west ofExide Technologies (Exide) and Yuasa Battery, Inc. (Yuasa); KRDG can be seen on the extreme left side ofFigure 1. P A DEP was aware ofmeteorological data collected at a tower site near Exide. This data, however, could not be used due to the lack ofproper QA/QC documentation. To conductthe modeling attainment demonstration, PADEP hadto compile a lead emission inventory for significant sources near the noncompliant air monitoring sites. During promulgation ofthe 2008 lead standard, US EPA revised the requirements in 40 CFR 51.117(e) for lead nonattainment area SIP inventories from a 5 tons per year (tpy) threshold associated with the previous standard to a 0.5 tpy threshold. This was the threshold used to identify major lead sources in the North Reading Nonattainment Area. PA DEP identified one (1) facility, Exide Technologies, whose lead emissions exceeded 0.5 tpy in the North Reading Nonattainment Area. Exide operates a secondary lead smelter that recycles spent lead-acid batteries and other lead-containing materials. Additional lead emissions come from associated material handling and processing operations at the facility. PA DEP also included Yuasa in its modeling analysis. Yuasa operates a lead-acid battery assembly plant directly east across the street from the Exide facility. Lead emissions from nonpoint sources and mobile sources were also examined but found to be insignificant and while included in PA DEP's lead inventory they were not included in the lead modeling demonstration. Section 211(n) ofthe Clean Air Actprohibited the use ofany gasoline containing lead or lead additives for use as fuel in motor vehicles after December 31, 1995 ( 42 U.S.C.A. §7545) making mobile source lead emissions much smallerthan the point source contribution. Exide and Yuasa were the only lead sources included in the final model emission inventory. PA DEP noted that theExide facility is currently in an idled state with none ofits lead smelting processes in operation. Priorto restarting these operations, Exide will have to implement additional lead emission controls. Model emission inventories for the two (2) lead sources inthe North Reading were constructed for 2010 and 2015. The 2015 lead emissions were used inthe model attainment demonstration Page 3 ofllTechnical SupportDocumentfor theModelingPortion Ofthe Commonwealth ofPennsylvania's Lead State Implementation Plan (SIP) entitledNorth ReadingNonattainmentArea, Berks County for the 2008LeadNationalAmbientAir Quality Standards August 2015 to determine ifprojected (future) lead emission rates would comply with the lead NAAQS. Table 1 summarizes lead emissions compiled by PA DEP from both Exide and Yuasa. Lead emissions for other (non-point) sources in the North Reading Nonattainment Area were also compiled but totaled less than 0.2% ofthe 2010 Base Year (actual) lead emissions from Exide and Yuasa**(~0.0017** tpy). 

### Table 1. North ReadingLead Source Emissions Summary Lead Source 2010 Lead Emissions 2015 Projected Lead Emissions Exide 1.0417 0.8991 Yuasa 0.1520 0.0850 Projected 2015 lead emission reductions for Exide are based on the implementation ofthe control measures set forth in the.National Emissions Standards for Hazardous Air Pollutants; Secondary Lead Smelting, 77 FR 556 (January 5, 2012, NESHAP from Secondary Lead Smelting), as approved in Plan Approval No. 06-050661. Additional lead emission reductions and stack-specific emission limits are identified in the Exide Consent Order and Agreement (COA) to be incorporated into the SIP. PA DEP entered into a COA with Yuasa to establish lower emission limits needed for the North Reading Nonattainment Areato reach attainment. The COA is incorporated into the SIP ensuring the control measures will become permanent, federally enforceable, and creditable to demonstrate attainment ofthe 2008 Lead NAAQS. DispersionModelingfor theModel Attainment Demonstration PA DEP performed an air-dispersion modeling analysis for the North Reading Nonattainment Area. The air-dispersion modeling analysis was completed for base year and future year emission inventories representing two (2) facilities, Exide and Yuasa, with reported lead emissions in 2010 and projected (future) emissions for 2015. The modeling was conducted in accordance with 40 CFR Part 51, Appendix W - Guideline on Air Quality Models. The American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD) was utilized for the model attainment demonstration. There are two (2) input data preprocessors that need to be run to utilize the AERMOD modeling system; AERMET, which preprocesses representative meteorological data and AERMAP, which preprocesses terrain data from the United States Geological Survey (USGS) Digital Elevation Data. In orderto diagnose Page 4 ofllTechnical SupportDocument for theModeling Portion Ofthe Commonwealth ofPennsylvania's Lead State Implementation Plan (SIP) entitledNorth ReadingNonattainmentArea, Berks County for the 2008LeadNationalAmbientAir Quality Standards August 2015 

### building downwash effects, the Building Profile Input Program for Plume Rise Model Enhancements (BPIPPRM) was executed. Since the current regulatory version ofAERMOD is incapable ofcalculating the rolling three-month average concentrations necessary for demonstrating lead NAAQS compliance, the EPA post-processor LEADPOST was used. In its three-month average calculation, LEADPOST utilizes monthly average files created by AERMOD. A summary ofthe model versions used in PA DEP's model attainment demonstration is presented in Table 2. Generally, the most recent versions ofthe AERMOD and its related preprocessors at the time PA DEP prepared the lead SIP were used in the air-dispersion modeling analysis. Table 2. Summary ofAERMOD Used in PA DEP's ModelingAnalysis Model Version Description AERMOD 14134 Regulatory Air-Dispersion Model BPIPPRM 04274 Building Downwash Calculations for AERMOD AERMET 14134 AERMOD Meteorological Data Preprocessor AERMINUTE 14237 Processes sub-houriy met data for use in AERMET AERSURFACE 13016 Preprocessor for AERMETusing1992 Land Use/Land Cover AERMAP 11103 Terrain Processor, Preprocessor for AERMOD Lead Post 13262 Post Processor for AERMOD, Lead NAAQS Calculator Air-Dispersion Model Meteorological Data Development The North Reading modeling analysis utilized a five-year (2006-2010) meteorological dataset comprised ofsurface meteorological data from the Reading Airport (KRDG) and morning atmospheric soundings from Washington Dulles International Airport (KIAD). KRDG is located approximately four (4) kilometers west ofthe Exide and KIAD is located approximately 207 kilometers southwest Exide. The data sets were reviewed for completeness and representativeness ofthe North Reading Nonattainment Area. The meteorological data sets were found to meetthe completeness requirements outlined in Section 5.3.2 ofEPA'sMeteorological Monitoring Guidancefor RegulatoryModelingApplications 

### (EPA-454/R-99-005, February 2000) and are representative ofatmospheric conditions inthe vicinity ofExide and the North Reading Nonattainment Area. Page 5 ofllTechnical Support Document for the ModelingPortion Ofthe Commonwealth ofPennsylvania's Lead State Implementation Plan (SIP) entitledNorth ReadingNonattainmentArea, Berks County for the 2008LeadNationalAmbientAir Quality Standards August 2015 Meteorological files from KRDG and KIAD were processed using AERMET. AERMET is a meteorological preprocessor that organizes available meteorological data into a format suitable for use by the AERMOD air-quality dispersion model. One-minute ASOS wind data available from theNational Climatic Data Center (NCDC) in the TD-6405 format was further processed using AERMINUTE to generate hourly averaged wind speed and wind direction to supplement the standard hourly ASOS observations. The final processed meteorological data also includes ASOS temperatures, surface pressure and sky cover as well as morning vertical sounding information from KIAD. In addition to the meteorological data, AERMET needs surface characteristic information including surface roughness, albedo and Bowen Ratio. This information was constructed using AERSURFACE, which extracts this information from the USGS National Land Cover Database (NLCD, 1992). AERSURFACE was run at a seasonal resolution using a default 1-kilometer radius with twelve 30-degree sectors for surface roughness length. Surface moisture conditions were used in the Bowen Ratio calculation and were based on averaged precipitation data for Pennsylvania Climate Division 3. Specific seasonal surface moisture conditions were derived using precipitation data and comparing it to a 30-year climatological average to determine ifa particular season was considered dry, average or wet in accordance with Section 2.2 ofEPA's AERSURFACE User's Guide. Snow cover information was also examined to ensure there was no continuous snow cover occurring on a seasonal basis. Air-Dispersion Model Receptor Grid Development: 

### P

A DEP developed ground-level model receptors for areas defined as "ambient air" in accordance with 40 CFR §50.1(e). These model receptor points, once defined, are used by AERMOD to calculate air concentrations from lead emission sources. Facilities that have sufficient limitations onpublic access to their sites, a fence or other suitable physical barrier, do not have to establish model receptor points within their property boundary for their emissions. Sharedproperty boundaries between Exide and Yuasa and the close proximity ofthe facilities complicated the modeling analysis. Separate model receptor grids were established over Exide and Yuasa in orderto determine each facility's impact on the other's properties including flagpole receptors to determine model concentrations on buildings. A model receptor grid covering the remainder ofthe North Reading Nonattainment Area was also established. The model receptor grids were ofsufficient density to determine maximum modeled concentrations Page 6 ofllTechnical SupportDocumentfor the Modeling Portion Ofthe Commonwealth ofPennsylvania's Lead StateImplementation Plan (SIP) entitledNorth ReadingNonattainmentArea, Berks County for the 2008LeadNationalAmbientAir Quality Standards August 2015 and ensure modeled concentrations outside ofthe nonattainment area would not exceed the lead NAAQS. Once the model receptor grid was established, it was run through AERMAP to determine each receptor's elevation and terrain height scale, a parameter needed by AERMOD. These values were calculated from terrain data generally provided and maintained by the U.S. Geological Survey or USGS. PA DEP utilized the USGS National Elevation Dataset (NED) with a resolution ofone-third arc-second (approximately 1 0-meter resolution). Flagpole (rooftop) receptors were used for receptors within the Exide and Yuasa ambient air boundaries that were located over buildings. 

### Lead Emission Rates and BuildingDownwash Development Projected lead emissions from Exide and Yuasa were based on a combination ofNESHAP and COA limits. Modeled lead emissions from both facilities included stack emissions (point sources) and fugitive emissions (volume and area sources). A total ofseventy-seven (77) lead emission sources were modeled for Exide while twenty-seven (27) lead emission sources were modeled for Yuasa. Road-dust emissions accounted for most ofthe model sources at Exide since the facility's paved surfaces were broken into sixty-six (66) individual volume sources that represented a small segment ofeachroad surface. Road-dust emissions at Yuasa made up most ofthe emission sources but since the facility is much smaller its road segments consisted ofonly fifteen (15) sources. Projected building and stack configurations for Exide and Yuasa were run through EPA's BPIP program to determine building downwashparameters to be used in AERMOD. BPIP requires building locations and heights as well as stack height informationto determine building downwashparameters. Downwash output from BPIP is then used as input into AERMOD. 

### AERMOD Results Summary Two pieces ofinformation are needed to determine ifa nonattainment area will meet the lead NAAQS. These include a modeled lead concentration from an air-dispersion model like AERMOD and a representative background lead concentration. A dispersion model like AERMOD will estimate the ambient lead concentrations based onhourly lead emissions that are included as model inputs. The purpose ofa representative background lead concentration is to account for minor ancillary sources that may not be explicitly modeled. Page 7 ofllTechnical SupportDocumentfor theModeling Portion Ofthe Commonwealth ofPennsylvania's Lead State Implementation Plan (SIP) entitledNorth ReadingNonattainmentArea, Berks County for the 2008LeadNationalAmbientAir Quality Standards August 2015 PA DEP reviewed monitoring data from the two closest lead monitors to the Exide and Yuasa facilities. Lead emissions from both Exide and Yuasa have inevitably contributed to Laureldale North's and Laureldale South's monitored lead concentrations. Given that monitoring concentrations represent a composite 24-hr sample, it is difficult to isolate the_impacts ofExide and Yuasa on the monitor concentrations thus giving rise to the possibility of"double counting" their contributions when combining the modeled and monitored results. PA DEP decided to use a background lead concentration from a regional lead monitor to alleviate this possibility. The Ridley Park lead monitor was chosen as the background monitor after reviewing lead concentrations from three (3) surrounding lead monitors. The Ridley Park lead monitor is located in Delaware County, PA approximately 76 kilometers southeast ofExide. Background lead concentrations based on the 2012-14 design value at Ridley Parkwere 0.012 )lg/m3

. AERMOD does not directly calculate 3-month lead concentrations. LEADPOST must be run using specific output files generated by AERMOD to calculate a modeled 3-month lead concentration in the form ofthe NAAQS. LEADPOST takes AERMOD output files and calculates a rolling 3-month average lead concentration. This modeled concentration is then added to the background concentration and compared with the lead NAAQS to determine compliance. The highest projected 3-month modeled lead concentration from LEADPOST was 0.129107 )lglm 3

. Projected (future) modeled 3-month maximum lead concentrations over the North Reading Nonattainment Area are shown in Figure 2. Peak modeled concentrations occurjust south ofYuasa. Figure 3 shows modeled concentrations surrounding Exide and Yuasa. Model receptors were placed within both facility's ambient-air boundary since the emissions from each facility cannot be excluded on the other facility's property. Thus model concentrations on Exide's property represent impacts from Yuasa emissions and model concentrations on Yuasa's property represent impacts from Exide's emissions. Model concentrations onExide's property are lower since these model receptors are only impacted by emissions from Yuasa, which are much lower than emissions from Exide. The final modeled lead concentration is the maximum projected 3-month lead concentration from LEADPOST plus the background monitored concentration from the Ridley Park monitor. This yields a projected lead concentration of0.129107 )lg/m3 plus 0.012 )lg/m3, or 0.141107 )lg/m3, which is belowthe 2008 lead NAAQS of0.15 )lg/m3

. This indicates that projected lead concentrations based on projected operations at Exide and Yuasa (plus a representative background concentration) will meet the 2008 Lead NAAQS. Page 8 ofllTechnical SupportDocumentfor the Modeling Portion Ofthe Commonwealth ofPennsylvania's Lead StateImplementation Plan (SIP) entitledNorth ReadingNonattainmentArea, Berks County for the 2008 LeadNationalAmbientAir Quality Standards August 2015
North Reading, PA Lead Nonattainment Area Legend

< O.OtO uglm1 0.01 1
- 0.025 ugtml 0.01 5 . 0015 uglmJ 0.075 · 0. 100 IJ9Iml ,0.100**ugl~** Max Receptor (0.129107 ug.!nll



### Figure 2. Projected (future) maximum 3-month lead concentrations from PADEP's AERMOD analysis.

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.Lead State Implementation Plan (SIP) entitledNorth ReadingNonattainmentArea, Berks County for the 2008LeadNationalAmbientAir Quality Standards August 2015 North Reading, PA Lead Nonattainment Area Legend

< 0010 u9}ml 0010 - 0 025 l)Qiml 0025-0 .015 U9"n1l 0.075-0.110 ugtml
-" 0.100 uglm3 MaxRec.eptor(0.129107 u!)hn)

0 015 0.3 

### Figure 3. Close up ofprojected (future) maximum 3-month lead concentrations from PA DEP's AERMOD analysis.
Summa•y ofEPA's Technical Findings EPA has reviewed PA DEP's modeling analysis for the North Reading Nonattainment Area. PA DEP conducted air-dispersion modeling using EPA's AERMOD modeling system. In general, PA DEP followed procedures outlined in 40 CFR Part 51, Appendix W- Guideline on Air Quality Models. Meteorological data met data completeness requirements, was representative of atmospheric conditions in the North Reading Nonattainment Area and was properly processed using AERMOD'spreprocessors AERMET and AERSURFACE. The model receptor grid was designed to capture the maximum projected (future) modeled concentrations and properly processed using appropriate terrain information via AERMAP. Projected (future) lead emission inventories were developed for use in AERMOD along with source building and stack Page 10 ofllTechnical Support Document for the Modeling Portion Ofthe Commonwealth ofPennsylvania's Lead State Implementation Plan (SIP) entitled North ReadingNonattainmentArea, Berks County for the 2008LeadNationalAmbientAirQuality Standards August 2015 configurations to calculate building downwash conditions. An appropriate regionally representative background lead concentration was determined using monitoring data from the Ridley Park lead monitor. A regional lead monitor was chosen instead ofusing local monitors to remove any impacts ofExide's or Yuasa's lead emissions on the monitoring data. This removes the possibility of"double counting" source impacts in the modeling analysis and the background monitoring data. PA DEP's projected maximum 3-month modeled lead concentration was added to Ridley Park's 3-month background 2012-14 design value concentration. The final projected modeled lead concentration was 0.129107 j.Lg/m3

. This concentrations was added to the background lead concentration of0.0121J.g/m3 and yielded a total projected (future) 3-month lead concentration of 0.141107 j.Lg/m3

. This projected (future) lead concentration is belowthe 2008 Lead NAAQS (0.15 j.Lg/m3) and demonstrates thatNorth Reading NonattainmentAreawill reach attainment with the lead standards established by the US EPA. 

### Recommendation ofApproval ofPA DEP's Model Attainment Demonstration EPA has evaluatedthe information provided in PA DEP's lead SIP for the North Reading Nonattainment Area and concludes thatthe Commonwealth's model attainment demonstration shows current lead control and emission limits will provide for attainment ofthe 2008 Lead NAAQS.

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