Pennsylvania’s Proposed Designation Recommendations for the Lead National Ambient Air Quality Standards

1. Pennsylvania’s Proposed Designation Recommendations for the Lead National Ambient Air Quality Standards Air Quality Technical Advisory Committee November 18, 2009 Arleen Shulman, Chief Air Resource Management Division Bureau of Air Quality

2. General Information • State lead NAAQS designation recommendations were due to EPA on October 15, 2009; final recommendations were submitted to EPA this week. • Two public meetings held October 21: Beaver County (no attendees) and Berks County (full house) with public comment period.

3. Summary of Presentation • Lead pollution public health concerns • Revised lead National Ambient Air Quality Standard • Sources of lead in air • Lead concentrations in Pennsylvania • Designations and implications • Designation recommendation methods • Proposed Nonattainment Area recommendations (Beaver County and Berks County)

4. Lead Pollution Public Health Concerns • Lead in air can be inhaled or, after it settles out of the air can be ingested. Ingestion is the main route of exposure. • Children are most vulnerable: • Nervous system development • Red blood cell damage • Weakened immune system • Effects on adults include: • Increased blood pressure • Cardiovascular disease • Decreased kidney function

5. Lead National Ambient Air Quality Standards (NAAQS) • The U.S. Environmental Protection Agency (EPA) sets primary NAAQS to protect health with an adequate margin of safety. • The 2008 health-based lead standard, 0.15 μg/m3, measured as total suspended particles (TSP), is 10 times more protective than the previous 1978 standard. (73 Federal Register 66964, Nov. 12, 2008. • A maximum rolling three-month average evaluated over a three-year period will be used to determine attainment. • all 36 three-month averages must be below the 0.15 μg/m3.

6. Sources of Lead Emissions • Larger industrial sources: • Metals processing, particularly primary and secondary lead smelters. • Iron and steel foundries; primary and secondary copper smelting; industrial, commercial, and institutional boilers; waste incinerators; glass manufacturing; cement manufacturing. • Power plants. • Motor vehicles from leaded gasoline, but no longer in use in most applications. • Additive in general aviation gasoline used in piston-engine aircraft and a trace contaminant in other fuels. • Natural sources (e.g., windblown dust from weathering of deposits)

7. Lead Monitoring and Concentrations • Limited lead ambient monitoring networks currently exist because most areas across the country attained the previous standard for years due to the phase-out of lead in gasoline. • Remaining state monitoring associated with specific sources.

9. Expanded Lead Monitoring Network • EPA requires monitoring near sources that emit one ton or more of lead per year by January 1, 2010. • EPA requires monitoring in areas with a population over 500,000 by January 1, 2011. • A sampling frequency of 1 in 6 days (one 24-hour lead sample every six days). • Monitors must meet federal requirements in order to be considered in designations and redesignations.

10. Anticipated Lead Monitoring Locations • Associated with Lead Sources Emitting One Ton Per Year or More (begin operation Jan. 1, 2010) • Allegheny County (3) • Armstrong County • Beaver County (2) • Berks County (2) • Delaware County • Franklin County • Indiana County • Lawrence County • Luzerne County • Associated with Population Areas (current location or begin operation Jan. 1, 2011) • Pittsburgh area • Philadelphia area • Allentown-Bethlehem area • Harrisburg area • Scranton-WilkesBarre area • Lancaster area

11. Lead NAAQS Designations • EPA anticipates making designations for areas with sufficient monitoring data in October 2010, other areas as data becomes available, but no later than October 2011. • States must be notified if EPA proposes a decision different from state recommendations. • EPA also solicits public comment.

12. Lead NAAQS Implementation TimelineFor Areas With Existing Monitors and Sufficient Data • Designation Recommendations – due to EPA by October 15, 2009 • Monitoring Network – source oriented monitors installed/operational by January 2010 • Final Designations –no later than October 2010 (effective January 2011) • Infrastructure SIP revisions – due to EPA by October 2011 (3 years max after rule) • Attainment Demonstration SIP– due to EPA by July 1, 2012 (18 months max after designations) • Attainment date – no later than January 2016 (5 yrs max after designations)

13. Lead NAAQS Implementation TimelineFor Areas Without Existing Monitors and Sufficient Data • Designation Recommendations – due to EPA by October 15, 2009. • Monitoring Network – non-source oriented monitors installed/operational by January 1, 2011. • Final Designations –no later than October 2011 (effective January 1, 2012). • Infrastructure SIP revisions – due to EPA by October 2011 (3 years max after rule). • Attainment Demonstration SIP – due to EPA by July 1, 2013 (3 years max after rule). • Attainment date - no later than January 2017 (5 yrs max after designations).

14. Implication of Designations • State Implementation Plans (SIPs) must be developed with public consultation. • DEP intends to work closely and collaboratively with local and county governments, sources of lead emissions, public health groups and citizens in developing workable plans to meet NAAQS in nonattainment areas.

15. Implication of Lead NAAQS Designations • The federal Clean Air Act contains different regulatory requirements for new and modified stationary sources in areas designated as nonattainment and requires conformity for transportation plans and federal projects/actions.

16. Uncertainties • EPA has announced its decision to reconsider thresholds for source-based and population-based monitors. • More source-based monitors in Pennsylvania may be required. • DEP may change its recommendations to EPA based on additional and updated monitoring data. • If an area recommended for nonattainment is found to attain the standard based on properly sited and operated monitors, DEP could change its recommendations and/or EPA could decide not to designate as nonattainment.

17. Preparation of State Implementation Plan (SIP) for Nonattainment Areas: Challenges • If an established nonattainment area is found to have “clean data,” in order to be redesignated as attainment, the state must prepare a plan to maintain the standard for at least 10 years after the attainment date.

18. Preparation of State Implementation Plan (SIP) for Nonattainment Areas: Challenges • Designation is important in delineating an effective planning area that will identify sources of the violation at appropriately sited monitors and find ways to reduce emissions to protect health. • Attainment SIP must include: • an inventory of lead sources – point, area, mobile • Are there “legacy” sources contributing to violations, for example, fugitive dust emissions from point or area sources containing deposited lead? • Reasonably Available Control Measures that must already be adopted • Reasonable Further Progress including incremental reductions • Attainment Demonstration (modeling) • Contingency Measures

19. Nonattainment Areas • Section 107(d)(1) of the CAA defines an area as nonattainment if it does not meet the NAAQS or if it is contributing to ambient air quality in a nearby area that does not meet the NAAQS. • State recommendations are to determine boundaries around monitors that exceed the NAAQS, considering potential emission contributions.

20. EPA’s Regulations for Designations • County boundary of violating monitor is the default. • A nonattainment area must encompass the area that does not meet the NAAQS or contributes to air quality in a nearby area that does not meet the NAAQS. • Factors to consider if state is recommending other than full county designation are: • Emissions • Air quality • Population density and degree of urbanization and development • Expected growth • Geography/topography • Meteorology • Jurisdictional boundaries • Level of control of emission sources. • Dispersion modeling, interpolation and qualitative analysis may also be used.

21. EPA’s Regulations for Designations • Designation of less than the full county is allowed if there is evidence that violations are not occurring in the excluded portions of the county and that the excluded portions are not source areas that contribute to the violations.

22. PA Proposed Recommendations • Attainment in counties having air quality monitors with complete, certified, 2006-2008 data below the NAAQS – 4 counties. • Attainment/unclassifiable where monitoring is not now expected - 43 counties. • Unclassifiable where further monitoring is expected in county or metro area – 18 full counties and 2 partial counties. • Nonattainment where violations identified with existing monitoring – 2 areas in Berks County and 1 area in Beaver County. • Recommendations can be revised if EPA changes monitoring thresholds and/or sufficient data becomes available with new monitoring or additional years show attainment.

25. Recommended North Reading Nonattainment Area • Recommended area includes the violating monitor at Laureldale (0.38 ug/m3). • Recommended area includes the lead source emitting more than one ton, Exide’s lead smelter. • Meteorological analysis considering terrain on “high lead” days indicates lead concentrations are likely associated with the Exide area.

26. Recommended North Reading Nonattainment Area • Dispersion modeling was performed for purposes of locating monitors at/near maximum concentrations of 1 ton+ source and confirms lead emissions do not disperse long distances. • The recommended area includes adjacent municipalities could experience air quality at least ½ the NAAQS (0.075 ug/m3) based on this dispersion modeling. • Political boundaries were chosen because they are pre-established, clearly defined, and used in permitting and planning processes. • The nonattainment area provides a margin of safety for public health purposes.

29. Recommended Lyons Nonattainment Area • The recommended area includes the violating monitor at Lyons East (0.22 ug/m3). • The recommended area includes the lead source emitting more than one ton, East Penn’s lead smelter. • Lyons South monitor does not exceed the NAAQS (0.11). • Meteorological analysis considering terrain on “high lead” days indicates lead concentrations are likely associated with the East Penn area.

30. Recommended Lyons Nonattainment Area • Dispersion modeling was performed for purposes of locating monitors at/near maximum concentrations of 1 ton+ source and confirms lead emissions do not disperse long distances. • The recommended area includes adjacent municipalities which could experience air quality at least ½ the NAAQS (0.075 ug/m3) based on this dispersion modeling. • Political boundaries were chosen because they are pre-established, clearly defined, and used in permitting and planning processes. • The recommended area provides a margin of safety for public health purposes.

33. Recommended Lower Beaver Valley Nonattainment Area • Meteorological analysis considering river valley terrain on “high lead” days indicates the two sources with lead emissions are likely associated with nonattainment. • Area provides a margin of safety for public health purposes. • Political boundaries chosen because they are pre-established, clearly defined, and used in permitting and planning processes.

34. Recommended Lower Beaver Valley Nonattainment Area • The recommended area includes the violating monitor at Vanport (0.20 ug/m3) • The recommended area includes the two lead sources emitting more than one ton, Horsehead Corporation’s zinc smelter and FirstEnergy’s Bruce Mansfield power plant. • Both facilities operate according to current regulations as enforced by DEP.

35. Comments and DEP’s response for Beaver County • Commentators expressed support for less-than-county nonattainment area. • Based on comment and DEP’s modeling for monitor siting, final recommendation will exclude jurisdiction containing Bruce Mansfield power plant. Lead impacts with reported emissions are minimal; emissions may be less than reported. • DEP will monitor at this site and could change its recommendations based on monitoring. EPA would be able to take this monitoring data into account in designation decisions.

36. Comments and DEP’s response: Berks County • Commentators expressed support for less-than-county nonattainment areas. • Commentators expressed support for two separate less-than-county nonattainment areas. • Most commentators disagreed with political boundaries as criteria as it may overestimate nonattainment area in some jurisdictions, and had diverse ideas for other ways to define area. • Some commentators recommended expansion of nonattainment area in North Reading, others recommended contraction of area. • More modeling was recommended by many. • DEP decided to make initial recommendations as proposed, and will work with EPA on designations in the next year. DEP may do additional modeling as resources permit.

37. Availability • Proposed and final recommendations available on DEP’s website, www.depweb.state.pa.us • Choose Air, Pollutants, Area Designation Recommendations • DEP contacts: Arleen Shulman, recommendations; Jeff Miller, monitoring.