Revision to the 

## New Hampshire State Implementation Plan

To Meet the Requirements of


## Clean Air Act Section 110(a)(2)(D)(i)

March 2008

Prepared by 

## The New Hampshire Department of Environmental ServicesTable of Contents

1.0 Summary ................................................................................................................. 1 2.0 Background ............................................................................................................. 1 3.0 Significant Contribution and Interf erence with Maintenance (Section 110(a)(2)(D)(i)(I)) ................................................................................................... 5 3.1 Ozone and PM 2.5 Attainment Status of Downwind Areas .................................. 6 3.2 Air Quality Dispersion Modeling ....................................................................... 6 3.2.1 Identification of Models and Domain Used .................................................... 6 3.2.2 Emissions Processing Methodology ............................................................... 9 3.2.3 Summary of USEPA’s CAIR Modeling Results .......................................... 12 3.2.4 Summary of OTC and NHDES Modeling Results ....................................... 14 3.2.5 CALGRID Zero Out of New Hampshire ...................................................... 17 3.2.6 Monitoring Data and Back Trajectories ........................................................ 20 4.0 Prevention of Significant Deterioration and Protection of Vi sibility (Section 110(a)(2)(D)(i)(II)) ............................................................................................... 27 5.0 Administrative Materials ...................................................................................... 29

List of Figures

Figure 2-1. Ozone Nonattainment Areas in New Hampshire ............................................. 3 Figure 3-1. Map of the CM AQ/CALGRID Modeling Domain.......................................... 7 Figure 3-2. Map of the RPO National Domain ................................................................... 8 Figure 3-3. QA/QC Plot of Surface Source CO Emissions .............................................. 10 Figure 3-4. QA/QC Plot of Surface Source VOC Emissions ........................................... 10 Figure 3-5. QA/QC Plot of Point Source NOx Emissions ................................................ 11 Figure 3-6. QA/QC Plot of Point Source SO 2 Emissions ................................................. 11 Figure 3-7. CMAQ SIP Quality Modeling Results for 2009 OTC OTB/OTW vs. 2002 Design Value Factors ............................................................................................ 15 Figure 3-8. Plot of the Maximum (Worst-cas e) Difference in Model Predicted 8-Hour Ozone Concentrations Between 2009 OTB/OTW and Zero Out of New Hampshire ............................................................................................................. 18 Figure 3-9. Historical 8-Hour Oz one Monitoring Data for Maine ................................... 21 Figure 3-10. HYSPLIT Back Trajectories for 8-Hour Ozone Exceedances Chicopee and Worcester, Massachusetts 2003-2005 .................................................................. 25 Figure 3-11. HYSPLIT Back Trajectories for 8-Hour Ozone Exceedances Newbury, Haverhill, and Chelmsford, Massachusetts 2003-2005 ........................................ 25 Figure 3-12. HYSPLIT Back Trajectories fo r 80Hour Ozone Exceedances Fairhaven and Truro, Massachusetts 2003 - 2005 ........................................................................ 26 Figure 3-13. HYSPLIT Back Trajectories for 8-Hour Ozone Exceedances Boston (Long Island) and Lynn, Ma ssachusetts 2003-2005 ........................................................ 26List of Tables

Table 3-1. Summary of CAIR Modeling Result s for Ozone for New Hampshire, Maine, and Massachusetts (in ppb) ................................................................................... 13 Table 3-2. Summary of CAIR Modeling Results for Annual PM 2.5 for New Hampshire, Maine, and Massachusetts (in micrograms per cubic meter) ................................ 14 Table 3-3. Modeling Summary of Monitors in New Hampshire and Downwind Areas (ppb) ...................................................................................................................... 16 Table 3-4. CMAQ/CALGRID Screening Results for Zero Out New Hampshire Scenario (ppb) ...................................................................................................................... 19 Table 3-5. Summary of Monitored 8-Hour Ozone Exceedances in Massachusetts for 2003-2005 ............................................................................................................. 22 Table 4-1. Major Source Emission Thresholds for Ozone Precursors .............................. 28

List of Appendices

Appendix A – Public Notice for SIP Revision Appendix B – Public Comments and NHDES Response Appendix C – Certification of Public Process Appendix D – Evidence of Legal AuthorityTransport SIP Revision Page 1 NHDES FINAL March 2008



### 1.0 

## Summary

The New Hampshire Department of Envir onmental Services (NHDES) submits this State Implementation Plan (SIP) revision to fu lfill the requirements of the United States Environmental Protection Agency’s (USEPA’s) Findings of Failure to submit a SIP meeting the requirements of Clean Air Act (CAA) Section 110(a)(2)(D)(i). 1 (70 FR 21147.) NHDES submits this SIP in accordance with CAA Sec tion 110(a)(2)(D)(i), the general SIP submittal requirements of 40 CFR Part 51 Appendi x V, and guidance provided by USEPA. 2

This SIP certifies that sources and emi ssion activities in New Hampshire do not contribute to nonattainment of the 8-hour oz one National Ambient Air Quality Standard (NAAQS) and the 1997 fine particulate matter (PM 2.5 ) NAAQS in other states and do not interfere with mainte nance of the 8-hour ozone NAAQS and the 1997 PM 2.5 NAAQS in other states. This SIP also confirms that New Ha mpshire’s SIP already contains provisions to prohibit major sources from interf ering with measures in other states to prevent significant deterioration through the Prev ention of Significant Deterior ation (PSD) and nonattainment New Source Review (NSR) provisions. In addition, NHDES confirms that the current SIP, in the PSD and NSR regulations, contains provisi ons to prevent sources from interfering with measures to protect visibility according to the 1980 visibility requirements. NHDES along with other states in Mid-Atlantic/Northeast Visibility Union (MANE-VU) and other Regional Planning Organizations (RPOs) are analyzing the 1999 regional haze requirements and will make a determination concerning these prov isions in the December 2007 regional haze SIP submittal.

On January 15, 2008, NHDES published in a statewide newspaper a public notice soliciting comment and announcing the opportunity for the public to request a public hearing for this SIP Revision. After the public co mment period and public h earing, if requested, NHDES will document and review any comments received and provide a response, if necessary. NHDES will amend this SIP Revisi on, as necessary, and resubmit it, with the additional documents required to certify the SIP submittal.



### 2.0 

## Background

On July 18, 1997, the USEPA adopted a new National Ambient Air Quality Standard (NAAQS) for ozone and fine particulate matter (PM 2.5 ). The new 8-hour ozone NAAQS is 0.08 parts per million (ppm) based on the three-year average of the annual fourth-highest daily maximum 8-hour average ozone concentrati on measured at each monitor. The original 1997 PM 2.5 NAAQS was 65 μ g/m 3 based on the three-year average of the 98 th percentile of

1 Finding of Failure to Submit Section 110 State Implementation Plans for Interstate Transport for the National Ambient Air Quality Standards for 8-Hour Ozone and PM 2.5

, 70 FR 21147 (April 25, 2005).
2 Memorandum from William Harnett, Director, Air Quality Policy Division, USEPA to Regional Air Quality Directors, USEPA, dated August 15, 2006.Transport SIP Revision Page 2 NHDES FINAL March 2008

24-hour concentrations and 15 μ g/m 3 based on the thr ee-year average of the weighted annual mean concentration. The 24-hour PM 2.5 standard was revised recently to 35 μ g/m 3 based on the three-year average of the 98 th percentile of 24-hour concen trations. This SIP submittal covers the new 8-hour ozone NAAQS and the 1997 PM 2.5 NAAQS.

Portions of Hillsborough, Merrimack, Ro ckingham, and Strafford Counties are designated as moderate 8-hour oz one nonattainment areas. The rest of the state is designated attainment except for the portions designated as maintenance areas for the 1-hour ozone NAAQS. These maintenance areas include Cheshire County for which there was incomplete data on the date of the designation for the 1-hour ozone NAAQS an d portions of the 4- counties (Hillsborough, Merrimack, Rockingham, and Strafford) that were designated nonattainment under the 1-hour ozone NAAQS and ar e currently designated as attainment under the 8-hour ozone NAAQS. The entire stat e is designated attainment for the 1997 PM 2.5 NAAQS. Figure 2-1 shows the current 8-hour ozone nonattainment areas (and previous 1- hour boundaries).

Section 110(a)(1) of the Clean Air Act (CAA) requires States to submit a State Implementation Plan (SIP) revision to provi de for the implementation, maintenance and enforcement of the new or revised NAAQS. S ection 110(a)(2) lists the elements that the SIP revision must include. Secti on 110(a)(2)(D) specifically relates to the transport of air pollution and the contribution or interfer ence with other states’ air quality.

Section 110(a)(1) says that states must s ubmit the SIP revisions three years after the promulgation of a new or revised NAAQS. Becau se of litigation over both the 8-hour ozone and 1997 PM 2.5 NAAQS and the need for additional monitoring of PM 2.5 , the SIP submittals have been delayed. On April 25, 2005, the US EPA published a finding that States had failed to submit the SIP revisions for the ozone and 1997 PM 2.5 NAAQS 3 . This finding was limited to the requirements of Section 110 (a)(2)(D)(i), the interstate transport provisions. With this finding, a 24-month sanction clock was started requiring the USEP A to issue a final Federal Implementation Plan (FIP) unless a State make s the required SIP submission and the USEPA approves the submission within the 24-month period by May 25, 2007.

The USEPA issued this finding of failure to submit SIPs as part of a Consent Decree between the USEPA and plaintiffs, who sued the USEPA for failure to take action on the SIP submission requirements for the new 8-hour ozone NAAQS and the 1997 PM 2.5 NAAQS. As part of this Consent Decree, the USEPA also committed to take action on the remaining SIP elements by March 17, 2008, for ozone and October 5, 2008, for PM 2.5.

3 Finding of Failure to Submit Section 110 State Implementation Plans for Interstate Transport for the National Ambient Air Quality Standards for 8-Hour Ozone and PM 2.5

, 70 FR 21147 (April 25, 2005).Transport SIP Revision Page 3 NHDES FINAL March 2008

Figure 2-1. Ozone Nonattainme nt Areas in New Hampshire



# STATE OF NEW HAMPSHIRE
Ozone Nonattainment Areas

8-Hour Southeast New Hampshire Moderate Area

Former 1-Hour Serious Nonattainment Areas
Former 1-Hour Marginal Nonattainment Areas

Attainment Areas

2/18/2008 1_8-hrBndys with Counties.gsm Pelham Hudson

Nashua Hollis Brookline Mason New Ipswich Rindge Windham

Salem Atkinson Newton South Hampton Seabrook Hampton North Hampton Rye Ports mouth New Castle

Hampstead Derry San down Dan Ville Kings

ton East Kings ton Kens

ington

Hamp ton Falls Exeter Strat ham Brent Wood Fremont

Epping Newmarket

Newfields Green land Newing ton Durham Madbury Dover

Rollingsford Sommersworth Rochester

Barrington

Milton

Farmington

Strafford

Nottingham Lee Northwood

Deerfield

Raymond Candia

Auburn
Chester

London Derry Manchester Hookset Concord

Allens town Bow Pembroke Hopkinton

Weare

Goffstown

Bedford

Amherst Merrimack

Litchfield New Boston

Lynde borough Mt. Vernon

Milford Wilton Temple Dunbarton

Fitzwilliam Richmound Winchester Hinsdale

Chesterfield

West moreland Keene

Swanzey
Troy Jaffrey Dublin Marl borough Roxbury Harrisville

Peter borough

Sharon

Greenland Frances town Hannock Benning ton Deering Antrim Stoddard

Nelson Sullivan Gilsum

Surry Walpole Acworth Lempster

Langdon Charles town

Alstead Marlow Washington Hillsborough Henniker Bradford Warner Newbury Goshen Unity Claremont

Cornish

Plantfield

Lebanon

Hanover

Enfield

Enfield

Grantham

Croydon

Newport Sunapee Springfield Grafton

Orange

Danbury Alexandria

Wilmot

New London

Sutton Salibury Andover Hill

Bristol Hebron Bridge water New Hampton Meredith

Sanbornton

Franklin

Northfield

Webster Canterbury

Loudon

Epsom Pittsfield Gilmanton Belmont Tilton Laconia
Gilford

Alton

Barnstead New Durham Brook field

Middle town Wakefield Wolfboro Moulton borough Tuftonboro Ossipee Lyme

Orford

Piermont

Haverhill Bath

Warren Benton

Wentworth

Dorchester Groton Rumney

Ellsworth

Woodstock Lincoln Easton Landaff Monroe Lyman
Lisbon Sugar Hill Franconia Bethlehem Littleton
Carroll

Livermore

Waterville Valley

Thornton

Campton

Plymouth Holderness

Ashland Sandwich

Hebron Albany

Tamworth Freedom

Effingham Conway

Madison Eaton Hebron

Jackson Chatham Beans Purchase Sargents Purchase Crawfords Purchase Low&Burbanks Grant

Beans Grant Martins Loc.

Greens Grant

Pinkhams Grant

Hales Location Dalton Whitefield Jefferson Lancaster North Umberland Kilkenny

Randolph Berlin

Gorham Shelburne Sucess Milan Stark Stratford

Columbia

Colebrook Stewartstown

Dixville

Millsfield

Odell

Dummer Cambridge Errol Wentworths Location

Second College Grant Dixs Grant Atkinson & Gilmanton

Academy Grant Clarksville Pittburg

Ervings Location



### COOS

GRAFTON

CARROLL

SULLIVAN

CHESHIRE MERRIMACK STRAFFORD

HILLSBOROUGH ROCKINGHAM BELKNAPTransport SIP Revision Page 4 NHDES FINAL March 2008

Section 110(a)(2)(D)(i)(I) requires that each state’s SIP must contain provisions prohibiting sources in a State from contributing significantly to the nonat tainment of another State or interfering with th e maintenance in another St ate. In addition, Section 110(a)(2)(D)(i)(II) requires that each state’s SIP must also contain provisions prohibiting emissions within the State from interfering w ith measures necessary to prevent significant deterioration of air quality or to protect visibility in another State.

In March 2005, the USEPA promulgated th e Clean Air Interstate Rule (CAIR). 4 Based upon the requirements of Section 110(a)(2 )(D)(i), the USEPA determined in CAIR that nitrogen oxide (NOx) emissions from 25 States 5 and the District of Columbia (DC) contribute significantly to nonattai nment and interfere with main tenance of the 8-hour ozone NAAQS in downwind states. In CAIR and a subsequent ruling 6 for Delaware and New Jersey, the USEPA determined that sulfur dioxide (SO 2 ) and nitrogen oxide (NOx) emissions from 23 States 7 and DC contribute significantly to the nonattainment a nd interfere with maintenance of the 1997 PM 2.5 NAAQS. New Hampshire was not included in CAIR as a state that contribu tes significantly to nonattainment nor interferes with maintenance of the 8- hour ozone NAAQS and the 1997 PM 2.5 NAAQS in downwind states.

The 8-hour ozone NAAQS Implementation Rule 8 and the 1997 PM NAAQS Implementation Rule 9 require States to develop and submit SIP revisions demonstrating attainment with the 8-hour ozone NAAQS and the 1997 PM 2.5 NAAQS. The 8-hour ozone NAAQS attainment plans were due June 15, 2007, and the 1997 PM 2.5 NAAQS attainment plans are due April 5, 2008.

To demonstrate attainment, States must c onduct air quality modeling. To fulfill this requirement, the member States 10 of the Ozone Transport Commission (OTC) have been conducting air quality modeling. As part of CAIR, the USEPA also conducted air quality modeling as the basis for determining what stat es contribute to the tr ansport of air pollution in downwind states and thus which stat es were to be included in CAIR.

The USEPA guidance for this Transport SIP submittal says that states should submit technical information such as air quality m odeling to support a nega tive declaration. NHDES

4 Rule to Reduce Interstate Transport of Fine Particulate Matter and Ozone (Clean Air Interstate Rule); Revisions to Acid Rain Program; Revisions to the NOx SIP Call; Final Rule , 70 FR 25162 (May 12, 2005).
5 Alabama, Arkansas, Connecticut, Florida, Delaware, I llinois, Indiana, Iowa, Kent ucky, Louisiana, Maryland, Massachusetts, Michigan, Mississippi, Missouri, New Yo rk, New Jersey, North Carolina, Ohio, Pennsylvania, South Carolina, Tennessee, Virginia, West Virginia, and Wisconsin.
6 Inclusion of Delaware and New Je rsey in Clean Air Interstate Rule , 71 FR 25288 (April 28, 2006).
7 Alabama, Florida, Delaware, Georgi a, Illinois, Indiana, Iowa, Kentucky, Louisiana, Maryland, Michigan, Minnesota, Mississippi, Missouri, New York, New Jersey, North Carolina, Ohio, Pennsylvania, South Carolina, Tennessee, Texas, Virginia, West Virginia, and Wisconsin.
8 Final Rule to Implement the 8-hour Ozone National Ambient Air Quality Standard , 70 FR 71612 (November 29, 2006).
9 Clean Air Fine Particle Implementation Rule ; Final Rule, 72 FR 20586 (April 25, 2007).
10 The Ozone Transport Region consists of Connecticut , Delaware, District of Co lumbia, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Northern Virginia, Pennsylvania, Rhode Island, and Vermont.Transport SIP Revision Page 5 NHDES FINAL March 2008
will rely on the air quality modeling conducted for the OTC states for the attainment demonstration, modeling conducted by NHDES, as well as the USEPA’s modeling for CAIR. The OTC and NHDES modeling confir ms the conclusions reached by the USEPA— that New Hampshire does not contribute to nonattainment or maintenance in downwind
states.

NHDES adopted Prevention of Significant De terioration (PSD) re quirements (Env-A 619) and New Source Review (NSR) regulati ons (Env-A 618) to help New Hampshire maintain and attain the NAAQS. These requirements also help prevent New Hampshire from contributing significantly to other states nonattainment and from interfering with the maintenance of air quality in other states.

In regards to visibility and regional haze, the USEPA issued regulations in 1980 to address visibility and in 1999 to address regional haze. The 1980 regulations address reasonably attributable visibi lity impairment—that is, visi bility impairment caused by emissions of air pollutants from one or a few sources. The 1999 regulat ions address regional haze—that is, visibility impairment caused by air emissions from numerous sources located over a wide geographic area. In accordance w ith the 1980 regulations, any new major source or major modification is required to assess visibility impacts as part of the permit application process. In the 1999 regional haze regulatio ns, the USEPA found thatall States contain sources that contribute to regiona l haze in at least one Class I ar ea. Thus, States are required to submit a SIP by December 17, 2007 that addr esses control measures for regional haze. States and Regional Planning Or ganizations (RPOs) are currently analyzing alternative strategies for addres sing regional haze.



### 3.0 

## Significant Contribution and Interference with Maintenance (Section 110(a)(2)(D)(i)(I))

Section 110(a)(2)(D)(i)(I) requir es states to include provisions in the SIP that prohibit any source or other type of emissions activit y from emitting air pollutants in amounts which contribute to nonattainment in anot her state or interfere with ma intenance in another state for newly promulgated NAAQS, that is, for ozone and PM 2.5
. New Hampshire makes a negative declaration to certify that sources in the state do not significantly contribute to nonattainment in another state or interfere with maintenance in another state with respect to ozone and PM 2.5 . The basis for New Hampshire’s certificati on is the attainment status of downwind areas and air quality modeling results conducted by the USEPA, the OTC, and NHDES. In addition, the NHDES’ New Source Review and PSD regulations help to prevent sources from interfering with maintenance in downw ind areas. Finally , NHDES has implemented reduction measures in the past, and will im plement additional reduction measures in the future as specified in ozone and regional haze SIPs, if necessary, to help prevent sources from contributing to nonattainment in other stat es and from interfering with maintenance in other states.Transport SIP Revision Page 6 NHDES FINAL March 2008

3.1 Ozone and PM 2.5 Attainment Status of Downwind Areas

The primary basis for NHDES’ certificati on that New Hampshire sources do not contribute to nonattainment of the ozone and 1997 PM 2.5 NAAQS in other areas is the fact that all of the areas downwind of New Hampsh ire are in attainment. Maine requested and was granted redesignatio n of the Portland, Maine ozone nonatt ainment area and the Midcoast Maine (Hancock, Knox, Lincoln, and Waldo Counties) ozone nonattainment areas to attainment in 2006. These areas have monito red attainment of the 8-hour ozone NAAQS based on the 3-year average of 2003 to 2005 and continuing th rough the summer of 2007. The rest of Maine was designate d attainment for the 8-hour oz one standard. One downwind area in Massachusetts is designated as an 8-hour ozone nonattainment area. All areas downwind of New Hampshire ar e already designated as PM 2.5 attainment areas.

3.2 Air Quality Modeling

For the purposes of its 8-hour ozone and the 24-hour and annual PM 2.5 and regional haze modeling, New Hampshire relied on the regional photochemical air quality modeling that was done by the New York State De partment of Environmental Conservation (NYSDEC), Northeast States for Coordinated Air Use Management (NESCAUM), and other modeling centers on the Community Multiscale Air Quality (CM AQ) and Regional Modeling System for Aerosols and Deposition (REMSAD) modeling platform. In addition, New Hampshire and other states used the CALG RID (California Photoc hemical Grid Model) screening-level modeling platform to evaluate additional emissions control scenarios and to perform sensitivity runs. The general methodologies that were used in running these modeling platforms are describe d in the sections below.

3.2.1 Identification of Models and Domain Used

As described above, the SIP-quality mode ling that was done in support of New Hampshire and other states’ 8-hour ozone, PM 2.5 , and regional haze SIPs was performed on the CMAQ modeling platform. Additiona l modeling was done on the REMSAD and CALGRID screening-level platforms. The CM AQ and CALGRID platforms were run on the same modeling domain using a common set of model inputs. Specifically, the OTC ozone modeling domain was set up on a Lambert C onic Conformal projection and covers the eastern United States and parts of Canada. Th e southwest corner of the domain was set at 264 km, -888 km and the northeast corner was set to 2328 km, 1176 km. A 12-km grid cell resolution was used with 172 grid cells in the east-west direct ion and 172 grid cells in the north-south direction. For the vertical grid definition, 22 layers were used in the CMAQ simulations. For CALGRID, processing prog rams were used to reformat the boundary conditions, meteorology, and emissions; these mapped the 22 layers used for CMAQ to a total of nine vertical layers for th e CALGRID modeling. The OTC CMAQ/CALGRID modeling domain is shown in Figure 3-1. The OTC 12-km modeling domain is a subset of the 36-km national domain which was used by th e RPOs for regional haze analysis. The 36- km national grid is shown in Figure 3-2.Transport SIP Revision Page 7 NHDES FINAL March 2008

Figure 3-1. Map of the CMA Q/CALGRID Modeling Domain



## 0 20 40 60 80 100 120 140 160 0 20 40 60 80 100 120 140 160Transport SIP Revision Page 8 NHDES FINAL March 2008

Figure 3-2. Map of the RPO National Domain

For the CMAQ modeling, boundary condition s were derived from GEOS-Chem (Goddard Earth Observing System) global atmospheric simulations by running CMAQ on the 36-km continental grid. For the CALGRI D platform, initial conditions, side boundary conditions, and top layer concentrations were derived from the CMAQ boundary conditions files by means of a processing program. This pr ogram mapped the 22 vertical layers used in the CMAQ simulations to the nine layers used with CALGRID. It produced the necessary side boundary file and top layer concentration file for each modeled episode day. It also produced an initial conditions file for each ep isode day processed; these files could be retained so that the CALGRID user could begi n a simulation on any desired episode day. It should be noted that the default option of using 2002 boundary conditions was employed for all of the base case and future year CMAQ and CALGRID simulations.

Further details regarding th e technical options used in the CMAQ simulations are available in NYSDEC’s tec hnical support document TSD-1d, 8hr Ozone Modeling using the SMOKE/CMAQ system, February 1, 2006. Additional information on the CALGRID modeling platform can be found in NHDES’ Modeling Protocol for the OTC CALGRID Screening-Level Modeling Platform fo r the Evaluation of Ozone, May 23, 2007.Transport SIP Revision Page 9 NHDES FINAL March 2008
3.2.2 Emissions Processing Methodology

The RPOs and their contractors prepared a se t of base year and future year emissions inventories for use in the regional photoche mical air quality modeli ng for the 8-hour ozone attainment demonstration as well as for the anal ysis of particulate matter and regional haze. These emissions inventories became the basi s of the modeling inventories that were processed for input into the CMAQ air quality model using the Sparse Matrix Operator Kernel Emissions (SMOKE) model. The SMOKE modeling was performed by New York State Department of Environmental Conser vation (NYSDEC) and other modeling centers, including the Virginia Department of Environmental Quality (VADEQ) and Northeast States for Coordinated Air Use Management (NESCAUM). Emissions processing was done for the 2002 Base Year, 2009 On The Books/On The Way (OTB/OTW), 2009 Beyond On The Way (BOTW), and 2012 BOTW modeling scenarios. Further details on the SMOKE processing that was done in support of the 8-hour ozone attainment demonstration are provided in NYSDEC’s technical support document TSD-1c, Emission Processing fo r the Revised 2002 OTC Regional and Urban 12 km Base Case Simulations , September 19, 2006

. For the CALGRID modeling effort, the pr e-merged SMOKE emissions files were obtained from the modeling centers and re-f ormatted for input into EMSPROC (Emissions Processor), the emissions pre-processor fo r the CALGRID modeling system. EMSPROC allows the CALGRID user to adjust emissions temporally, geographically, and by emissions category for control strategy analysis. The pre- merged SMOKE files that were obtained from the modeling centers were broken down into the bioge nic, point, area, no n-road, and on-road emissions categories. These files by comp onent were then converted for use with EMSPROC, thus giving CALGRID users the fl exibility to analyze a wide variety of emissions control strategies. QA/QC plots were generated during the re-formatting of the emissions data to ensure that an accurate modeling inventory was generated for the CALGRID platform. Example emissions QA/QC plots are shown in Figures 3-3 through 3- 6.Transport SIP Revision Page 10 NHDES FINAL March 2008

Figure 3-3. QA/QC Plot of Surface Source CO Emissions

Figure 3-4. QA/QC Plot of Surface Source VOC EmissionsTransport SIP Revision Page 11 NHDES FINAL March 2008

Figure 3-5. QA/QC Plot of Point Source NOx Emissions

Figure 3-6. QA/QC Plot of Point Source SO 2 EmissionsTransport SIP Revision Page 12 NHDES FINAL March 2008
3.2.3 Summary of USEPA’s CAIR Modeling Results

USEPA promulgated the Clean Air Inte rstate Rule (CAIR) on March 10, 2005. Under CAIR, 28 states across the eastern United States and the District of Columbia will make reductions in emissions of NOx and SO 2 . Similarly, USEPA issued the Clean Air Mercury Rule (CAMR) on March 15, 2005. CA MR will reduce mercury emissions from coal-fired power plants.

USEPA performed a technical analysis in support of CAIR and CAMR, including air quality modeling to evaluate ozone and PM 2.5 . The air quality modeling done in support of the final CAIR is described in USEPA’s Technical Support Document for the Final Clean Air Interstate Rule, Air Quality Modeling , March 2005. The air quality modeling for ozone was performed with the Comprehensive Air Qual ity Model with Extensions (CAMx) version 3.10 on a modeling domain covering much of the eastern United States. For PM 2.5 , visibility, and deposition, the air quality modeling wa s done with CMAQ version 4.3 on a domain encompassing the lower 48 states and parts of Canada and Mexico. For the ozone analysis, three summer 1995 meteorological episodes we re used in the CAMx modeling. For PM 2.5 , visibility, and deposition, the CMAQ model wa s run for the entire year 2001. The analysis years and emissions scenarios that we re assessed included the following:

y 2001 Base Year

y 2010 Base Case

y 2015 Base Case

y 2010 CAIR Controls

y 2015 CAIR Controls

y 2015 CAIR+BART

y 2015 BART-only The 2010 and 2015 Base Cases reflect expected economic growth and the anticipated benefits associated with exis ting emissions control programs. The CAMx and CMAQ model predictions for ozone and PM 2.5 were used in a relative manner. Weighted-average 1999-2003 design values were used as the basis of the observed 8-hour ozone and annual average PM 2.5 concentrations. Using this methodology, USEPA estimated maximum 8-hour ozone and annual PM 2.5 design values for each future-year scenario for each county in the modeling doma in with a monitor. Table 3-1 shows the maximum estimated future 8-hour ozone design values for New Hampshire, Maine, and Massachusetts. These results show that, even without the emissi ons benefits associated with CAIR, all New Hampshire counties were predicte d to be in attainment for 8-hour ozone for the 2010 and 2015 analysis years. Further, the table shows that areas downwind of New Hampshire (i.e., Maine and Massach usetts) were also pr edicted to be in attainment for 8-hour ozone for 2010 and 2015, even without the benefi ts of CAIR. Similarly, Table 3-2 shows the maximum estimated future annual design values for PM 2.5 . All of the maximum estimated future design values were predicte d in be in attainment for annual PM 2.5 for New HampshireTransport SIP Revision Page 13 NHDES FINAL March 2008
and its downwind areas. The technical support document for the final CAIR did not summarize estimated design values for 24-hour PM 2.5 , therefore they are not provided here.

Table 3-1. Summary of CAI R Modeling Results for Ozone for New Hampshire, Maine, and Massachusetts (in ppb) Estimated Maximum 8-hour Future Design Values State County 1999 – 2003 Average Design Value 2010 Base 2010 CAIR 2015 Base 2015 CAIR Belknap 78.0 68.5 68.2 65.8 65.0 Carroll 66.5 60.3 60.0 58.6 58.0 Cheshire 73.7 65.2 64.9 63.1 62.0 Hillsborough 85.0 76.7 76.6 74.1 73.9 Merrimack 73.0 64.8 64.6 62.3 61.8 Rockingham 82.7 75.2 75.1 73.3 72.9 New Hampshire

Strafford 77.3 69.2 69.1 66.8 66.5 Cumberland 84.7 75.9 75.8 73.4 73.0 Hancock 92.0 80.7 80.5 77.2 76.8 Kennebec 77.7 68.1 68.0 65.3 64.9 Knox 83.3 73.7 73.6 70.7 70.4 Oxford 61.0 54.9 54.7 53.2 52.7 Penobscot 83.0 72.8 72.6 70.0 69.5 Maine

York 89.0 80.3 80.2 78.0 77.6 Barnstable 94.7 83.7 83.6 80.8 80.2 Berkshire 87.0 76.3 76.1 73.6 73.2 Bristol 92.7 83.1 83.0 80.3 80.0 Essex 89.7 81.8 81.7 80.6 80.2 Hampden 90.3 80.4 80.2 77.3 76.7 Hampshire 87.3 78.2 78.0 75.4 74.9 Middlesex 88.7 79.3 79.1 76.1 75.8 Suffolk 88.0 78.3 78.1 75.2 74.9 Massachusetts

Worcester 85.3 76.1 76.0 73.3 72.9 Note: Data taken from Appendix E of USEPA’s Technical Support Document for the Final Clean Air Interstate Rule, Ai r Quality Modeling, March 2005.Transport SIP Revision Page 14 NHDES FINAL March 2008

Table 3-2. Summary of CAIR Modeling Results for Annual PM 2.5 for New Hampshire, Maine, and Massachusetts (in micrograms per cubic meter)

Estimated Maximum Annual Future Design Values State County 1999 – 2003 Average Design Value 2010 Base 2010 CAIR 2015 Base 2015 CAIR Cheshire 11.81 11.04 10.39 10.85 10.11 Coos 10.11 9.98 9.49 9.93 9.37 Merrimack 9.96 9.22 8.67 9.11 8.49 New Hampshire

Sullivan 9.95 9.40 8.75 9.26 8.53 Androscoggin 10.60 10.16 9.75 10.04 9.58 Aroostook 11.16 11.41 11.11 11.38 11.04 Cumberland 11.44 10.66 10.23 10.50 10.02 Hancock 6.20 5.98 5.65 5.95 5.58 Kennebec 10.55 10.21 9.81 10.12 9.67 Oxford 10.29 10.23 9.74 10.15 9.60 Penobscot 9.87 9.81 9.46 9.73 9.34 Maine

York 9.63 9.07 8.64 8.97 8.50 Berkshire 12.40 11.68 10.93 11.49 10.66 Hampden 13.80 12.81 12.10 12.59 11.79 Plymouth 11.34 10.65 10.02 10.50 9.78 Massachusetts

Suffolk 12.81 12.05 11.48 11.80 11.15 Note: Data taken from Appendix F of USEPA’s Technical Support Docu ment for the Final Clean Air Interstate Rule, Ai r Quality Modeling, March 2005.

3.2.4 Summary of OTC and NHDES Modeling Results

Regional air quality modeling was performed to examine various emission control strategies and determine the most acceptable SI P strategy. As described earlier, the model results were used in a relative sense—the eff ects on future design values were evaluated by applying relative reduction factors (RRF) base d on model output to base year monitored design values. This RRF design value approach recognizes that the regional models have innate uncertainties and that these uncertainties can be minimized if the model is used in a relative, rather than an absolute manner. To minimize the effects of seasonal fluctuations on design values, the base year design values that were used, in accordance with USEPA guidance, were calculated as the three-year average of monitored design values for the periods of 2000-2002, 2001-2003, and 2002-2004. Based upon USEPA guidance, the follo wing monitoring/modeling attainment demonstration strategies have been developed:

 The 2009 OTC On The Way/On the Books (2009 OTW/OTB) - SIP Strategy

 The 2009 OTC Beyond On The Way (2009 BOTW) - Contingency SIP StrategyTransport SIP Revision Page 15 NHDES FINAL March 2008
Estimated future year 8-hour ozone design values for each of the above strategies are shown to be below the NAAQS for all New Hampshire monitors and those monitors in downwind areas. Figure 3-7 shows the CMAQ predicted 2009 design values compared to actual 2002 design values. Table 3-3 summarizes the modeling results for monitors in New Hampshire and its downwind areas. The results in Table 3-3 indicate that all areas in New Hampshire and downwind are expected to be in attainment for 8-hour ozone.

Figure 3-7. CMAQ SIP Quality Mode ling Results for 2009 OTC OTB/OTW vs. 2002 Design Value Factors


## OTR Domain 2002 Design Values 2009 Design ValuesTransport SIP Revision Page 16 NHDES FINAL March 2008

Table 3-3. Modeling Summary of Monitors in New Hampshire and Downwind Areas (ppb)
Predicted Future Design Values (DVF)

AIRS ID Name Current Design Value (DVC) 2009 OTB/OTW (CMAQ) 2009 BOTW (CMAQ)
330012004 Laconia 76.5 nc nc 330031002 Conway 67 nc nc 330050007 Keene 74.3 64 64
330090008 Haverhill 70.3 nc nc 330110020 Manchest er 75.5 n/a n/a
330111010 Nashua 86 74 74
330115001 Peterborough 84 73 73
330130007 Concord 74.7 nc nc 330150012 Rye 83.5 72 72
330150013 Brentwood 80 68 68
330150015 Portsmouth 68 59 59
330173002 Rochester 78.5 67 67
330190003 Claremont 74.3 nc nc 230090102 ANP Cadillac Mt. 91.7 79 79
230312002 Kennebunkport 88.3 77 77
230313002 Kittery 85.3 74 74
230052003 Cape Elizabeth 84.3 73 73
230130004 Port Clyde 83.7 73 72
230090103 ANP McFarland 83.7 72 72
230112005 Gardiner 78 68 67
230090301 Castine 75 65 65
230310038 West Buxton 75 64 64
230173001 North Lovell 60.7 nc nc 230194008 Holden Rider 79 nc nc 250213003 Milton 91 83 82
250092006 Lynn 90 82 82
250010002 Truro 92 80 80
250051002 Fairhaven 91 80 79
250130008 Chicopee 92 80 80
250250041 Boston (Long I.) 88.7 80 80
250094004 Newbury 86 76 75
250154002 Ware 86.3 75 75
250171102 Stow 85.7 74 74
250034002 Adams 83.3 73 73
250130003 Agawam 83 72 72
250270015 Worcester 84 72 72
250250042 Boston (Harrison Ave.) 73 66 66
250150103 Amherst 74.7 69 65
250090005 Lawrence 70 61 61 Notes: 1) An “nc” indicates that a future design value was not calculated because of the limitation of the relative reduction factor (RRF) methodology. 2) The Manchester monitor was not included in the CMAQ results; this is indicated by “n/a” in the table.Transport SIP Revision Page 17 NHDES FINAL March 2008

3.2.5 CALGRID Zero Out of New Hampshire

NHDES performed a screening-level CALGRID model run to evaluate the impacts of New Hampshire’s emissions on downwind areas. For this model run, all anthropogenic emissions in New Hampshire were turned off. In this manner, an assessment of the change in estimated future 8-hour ozone design values could be made for the hypothetical case in which New Hampshire had no emissions. Figu re 3-8 shows the differences in maximum predicted 8-hour ozone concen trations between the 2009 OTB/ OTW scenario and the Zero Out New Hampshire run. With New Hampshire’ s emissions turned off, improvements in 8- hour ozone concentrations (which are expressed as positive diffe rences in the figure) can be seen in Maine and Massachusetts. Improveme nts of between 3 and 5 ppb occur along the Maine coast and in northeastern Massachusetts. Areas of le ss significant improvement (0.25 to 3 ppb) extend into inland areas of Maine and Massachusetts.

Table 3-4 shows the estimated future design values for monitors in New Hampshire, Maine, and Massachusetts for the 2009 OTB/OTW and Zero Out New Hampshire scenarios. For the most part, estimated future design values were less sensitive to the turning off of New Hampshire’s emissions than were the maximum predicted 8-hour ozone concentrations. In Maine, estimated future design values improved by 5 ppb at monitors in Gardiner and West Buxton. Estimated future design values at all other Maine monitors improved by 2 ppb or less. For monitors in Mass achusetts, estimated future de sign values improved by 1 ppb or less. Even in New Hampshire, estimated futu re design values at most monitors improved by 4 ppb or less. The exceptions to this were the monitors at Laconia, Manchester, and Concord; these monitors showed improveme nts of between 8 and 10 ppb. The CALGRID screening-level results for the Zero Out New Hampshire model run suggest that 8-hour ozone values in New Hampshire, Maine, and Massachusetts are strongly in fluenced by emissions from upwind areas.Transport SIP Revision Page 18 NHDES FINAL March 2008

Figure 3-8. Plot of the Maximum (Wors t-case) Difference in Model Predicted 8- Hour Ozone Concentrations Between 2009 OTB/OTW and Zero Out of New Hampshire

0 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150 160 170 0 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150 160 170

-30.00 -20.00 -10.00 -5.00 -1.00 0.25 1.00 3.00 5.00 10.00 15.00 20.00 25.00 30.00 40.00 Ozone Concentrations (PPB)

NHDES 7/31/07 CALGRID 2.45 Modeling DomainTransport SIP Revision Page 19 NHDES FINAL March 2008

Table 3-4. CMAQ/CALGRID Screening Results for Zero Out New Hampshire Scenario (ppb)
Predicted Future Design Values (DVF)

AIRS ID Name Current Design Value (DVC) 2009 OTB/OTW (CMAQ) CALGRID 2009 Predicted Difference
330012004 Laconia 76.5 nc 8
330031002 Conway 67 nc 3
330050007 Keene 74.3 64 1
330090008 Haverhill 70.3 nc 0
330110020 Manchester 75.5 n/a 9
330111010 Nashua 86 74 2
330115001 Peterborough 84 73 4
330130007 Concord 74.7 nc 10
330150012 Rye 83.5 72 1
330150013 Brentwood 80 68 3
330150015 Portsmouth 68 59 0
330173002 Rochester 78.5 67 2
330190003 Claremont 74.3 nc 0
230090102 ANP Cadillac Mt. 91.7 79 2
230312002 Kennebunkport 88.3 77 1
230313002 Kittery 85.3 74 0
230052003 Cape Elizabeth 84.3 73 0
230130004 Port Clyde 83.7 73 1
230090103 ANP McFarland 83.7 72 2
230112005 Gardiner 78 68 5
230090301 Castine 75 65 1
230310038 West Buxton 75 64 5
230173001 North Lovell 60.7 nc 2
230194008 Holden Rider 79 nc 0
250213003 Milton 91 83 1
250092006 Lynn 90 82 1
250010002 Truro 92 80 0
250051002 Fairhaven 91 80 0
250130008 Chicopee 92 80 0
250250041 Boston (Long I.) 88.7 80 0
250094004 Newbury 86 76 1
250154002 Ware 86.3 75 0
250171102 Stow 85.7 74 0
250034002 Adams 83.3 73 0
250130003 Agawam 83 72 0
250270015 Worcester 84 72 1
250250042 Boston (Harrison Ave.) 73 66 0
250150103 Amherst 74.7 69 0
250090005 Lawrence 70 61 0Transport SIP Revision Page 20 NHDES FINAL March 2008
3.2.6 Monitoring Data and Back Trajectories

To further support the CMAQ and CALG RID modeling, monitoring data and trajectory analyses reveal that New Hampshire does not significantly contribute to the attainment status of Maine and Massachusetts , the two states that lie downwind of New Hampshire during weather patterns typical of this region.

Maine

Monitoring data from Maine over the last te n years illustrate that the maximum ozone design value has been steadily declining, and for the last tw o years, the maximum design value has stayed below the current 8-hour ozone NAAQS of 0.08 ppm. For these reasons, Maine submitted and was granted a redesignation request to remove the nonattainment status of the Portland and MidCoast 8-hour ozone nonatta inment area. Historical monitoring data for Maine is illustrated in Figure 3-9.

Furthermore, none of Maine’s historical maximum PM 2.5 design values have exceeded the daily or annual standard. Thus, the entire state of Maine has been and currently remains in attainment of the PM 2.5 NAAQS.

Massachusetts

Table 3-5 presents a summary of the exceedances of the 8-hour ozone standard for monitors in Massachusetts for 2003 - 2005. A back trajectory analysis of these exceedances indicates that New Hampshire has not been a major contributor to ozone events in Massachusetts. Three-day back trajectories were run with the HYSPLIT (HYbrid SingleParticle Lagrangian Integrated Trajectory) mode l for selected sites in four regions of the state: central, northeastern, southeastern, a nd eastern (near Boston) Massachusetts. The ending times correspond to the hour of the 8-hour ozone exceedance at the site, and the ending locations are 100 meters above mean se a-level, approximately ground level. These back trajectories are shown below in Figures 3-10 to 3-13.

These trajectories rarely pass through New Hampshire. In stead, they indicate source regions in the Midwest and al ong the eastern corridor, incl uding major metropolitan areas such as New York City. Those trajectories that do pass through New Hampshire, such as several ending in the Boston ar ea, originate in the Midwes t and tend to pass through the southwestern corner of New Hampshire as oppo sed to the more densely population areas of south central and relatively low emission s outheastern New Hampshire. Thus, these trajectories are clearly dominated by large-scale transport from more distant regions. With the exception of the Newbury site on the far no rtheastern corner of the state, even those exceedances occurring at Haverhill and Chel msford, located just south of the New Hampshire border, involve air masses traveling up the coast.Transport SIP Revision Page 21 NHDES FINAL March 2008

Figure 3-9. Historical 8-Hour Ozone Monitoring Data for MaineTransport SIP Revision Page 22 NHDES FINAL March 2008

Table 3-5. Summary of Monitore d 8-Hour Ozone Exceedances in
Massachusetts for 2003-2005

Central MA
Date Site 8-Hr Conc (ppm) Hour (EST) 6/25/2003 Chicopee 0.099 10 6/27/2003 Chicopee 0.089 9 6/27/2003 Worcester 0.089 9 6/29/2003 Chicopee 0.093 11 7/22/2004 Chicopee 0.093 10 4/20/2005 Worcester 0.090 13 6/8/2005 Chicopee 0.088 12 6/9/2005 Chicopee 0.104 11 6/9/2005 Worcester 0.085 12 6/24/2005 Chicopee 0.085 12 6/24/2005 Worcester 0.087 13 6/25/2005 Chicopee 0.090 10 6/25/2005 Worcester 0.092 14 6/26/2005 Chicopee 0.095 9 7/26/2005 Chicopee 0.090 13 7/26/2005 Worcester 0.085 13 8/8/2005 Chicopee 0.085 11 8/12/2005 Chicopee 0.098 12

Northeastern MA
Date Site 8-Hr Conc (ppm) Hour (EST) 6/25/2003 Newbury 0.092 11 6/27/2003 Newbury 0.099 10 7/22/2004 Haverhill 0.091 10 7/30/2004 Newbury 0.085 11 6/25/2005 Chelmsford 0.085 16 6/27/2005 Chelmsford 0.095 10Transport SIP Revision Page 23 NHDES FINAL March 2008

Table 3-5 (Continued) - Summary of M onitored 8-Hour Ozone Exceedances in Massachusetts for 2003-2005

Southeastern MA
Date Site 8-Hr Conc (ppm) Hour (EST) 6/25/2003 Fairhaven 0.098 12 6/25/2003 Truro 0.094 10 6/26/2003 Fairhaven 0.100 13 6/27/2003 Fairhaven 0.117 5 6/27/2003 Truro 0.110 9 7/4/2003 Fairhaven 0.086 16 7/4/2003 Truro 0.087 19 7/5/2003 Fairhaven 0.094 11 7/5/2003 Truro 0.094 13 7/8/2003 Truro 0.088 11 7/26/2003 Fairhaven 0.087 13 7/26/2003 Truro 0.087 16 8/16/2003 Fairhaven 0.101 12 8/16/2003 Truro 0.089 12 8/21/2003 Fairhaven 0.085 12 8/21/2003 Truro 0.087 13 5/11/2004 Truro 0.085 14 6/8/2004 Truro 0.089 16 6/9/2004 Fairhaven 0.099 13 6/9/2004 Truro 0.107 13 4/19/2005 Truro 0.088 19 4/20/2005 Truro 0.088 13 6/9/2005 Truro 0.087 8 6/25/2005 Truro 0.088 12 6/26/2005 Truro 0.087 10 8/5/2005 Truro 0.094 10 8/11/2005 Fairhaven 0.086 9 8/11/2005 Truro 0.095 12Transport SIP Revision Page 24 NHDES FINAL March 2008
Table 3-5 (Continued) - Summary of M onitored 8-Hour Ozone Exceedances in Massachusetts for 2003-2005

Eastern MA (Boston Area)
Date Site 8-Hr Conc (ppm) Hour (EST) 6/25/2003 Lynn 0.088 9 6/27/2003 Boston - Long Island 0.102 7 6/27/2003 Lynn 0.100 9 8/22/2003 Lynn 0.092 9 6/8/2004 Boston - Long Island 0.094 16 6/8/2004 Lynn 0.092 17 7/30/2004 Lynn 0.088 10 4/20/2005 Lynn 0.086 10 6/24/2005 Boston - Long Island 0.086 14 6/24/2005 Lynn 0.094 16 6/25/2005 Boston - Long Island 0.095 16 6/25/2005 Lynn 0.099 15 6/26/2005 Boston - Long Island 0.091 9 6/26/2005 Lynn 0.096 9 7/22/2005 Lynn 0.085 11 7/26/2005 Lynn 0.088 12 7/27/2005 Boston - Long Island 0.085 9 8/11/2005 Boston - Long Island 0.089 11,12

The Newbury trajectories do not fit the general patt erns described above, but notwithstanding this site’s proximity to southeas tern New Hampshire, they also fail to imply significant contribution from New Hampshire emissi ons. Trajectory models have historically had problems accurately reproducing the complicat ed air flows, vertically and horizontally, along the New England sea coast. As a result, trajectory modeling analys es in this region can suffer and produce non-intuitive results. For inst ance, two of the thr ee Newbury trajectories come predominately off the ocean; these occur on June 25 th and 27 th , 2003, days during which several other sites also exceeded the ozon e standard despite very different trajectory paths. Most other sites in the st ate received westerly flow on the 25 th and slow southwesterly flow on the 26 th . These conditions point to a regional episode in which sea breezes may have drawn off-shore plumes derived from sources to the west and south into the coastal site at Newbury.

The third Newbury trajectory does cross di rectly through New Hampshire, but the original HYSPLIT plot reveals that this air mass descended sharply from a maximum elevation near 3000 meters over the vicinity of Montreal. One other Massachusetts site, Lynn, also exceeded the standard on the same da y (July 30, 2004), and its trajectory followed a similar profile, descending from a similarly hi gh elevation after stalling briefly in Canada; yet the Lynn trajectory is shifted more to the we st and barely hits the southwestern corner of New Hampshire. Comparison of these traj ectories reveals that the elevated ozoneTransport SIP Revision Page 25 NHDES FINAL March 2008
concentrations on this day came from air tran sported aloft from lo cations upwind of both Massachusetts and New Hampshire.
Figure 3-10. HYSPLIT Back Trajectori es for 8-Hour Ozone Exceedances Chicopee and Worcester, Massachusetts 2003-2005

Chicopee Worceste r HYSPLIT Model, EDAS Meteorology Three-Day Back Trajectories Ending Elevation 100m AMSL

Figure 3-11. HYSPLIT Back Trajectori es for 8-Hour Ozone Exceedances Newbury, Haverhill, and Chelmsford, Massachusetts 2003-2005

Newbury Haverhill Chelmsford HYSPLIT Model, EDAS Meteorology Three-Day Back Trajectories Ending Elevation 100m AMSLTransport SIP Revision Page 26 NHDES FINAL March 2008

Figure 3-12. HYSPLIT Back Trajectori es for 8-Hour Ozone Exceedances Fairhaven and Truro, Massachusetts 2003 - 2005

Fairhaven Truro HYSPLIT Model, EDAS Meteorology Three-Day Back Trajectories Ending Elevation 100m AMSL

Figure 3-13. HYSPLIT Back Trajectori es for 8-Hour Ozone Exceedances Boston (Long Island) and Lynn, Massachusetts 2003-2005

Boston - Long Island Lynn HYSPLIT Model, EDAS Meteorology Three-Day Back Trajectories Ending Elevation 100m AMSLTransport SIP Revision Page 27 NHDES FINAL March 2008



### 4.0 

## Prevention of Significant Deterioration and Protection of Visibility (Section 110(a)(2)(D)(i)(II))

Section 110(a)(2)(D)(i)(II) requires states to include provisions in the SIP that prohibit any source or other type of emissions activity from emitting air pollutants in amounts which will interfere with measures requi red to be included in the SIPs of another State to prevent significant dete rioration and to prot ect visibility. NHDES confirms that no major sources in the state in terfere with measures in th e SIP to prevent significant deterioration and to protect visibility accord ing to the 1980 visibility provisions. Because regional haze studies are only now underway, NHDES cannot make a determination at this time in regards to interf erence with measures to protect vi sibility in acco rdance with the 1999 regional haze provisions, but NHDE S plans to make such a determination in the Regional Haze SIP.

NHDES confirms that major sources and majo r modifications in the state are subject to Prevention of Significant Deteriorat ion (PSD) provisions in ozone and PM 2.5 attainment areas, including Best Available Control Technology (BACT) requirements and to Nonattainment New Source Review in ozon e nonattainment areas, including Lowest Achievable Emission Rate (LAER) and emission offset requirements. The PSD provisions are contained in Env-A 619, Prevention of Significant Deterior ation of Air Quality Permit Requirements.

In addition, New Hampshire is part of the Ozone Transpor t Region (OTR); therefore, NHDES also meets the additional NSR 11 and PSD provisions required in the OTR, particularly the major source and major modificat ion emission thresholds and offset ratios. The federal requirement for the emission threshold for major NOx sources in New Hampshire under the 8-hour ozone NAAQS is 100 tons per year (tpy) statewide because the minimum federal emission threshold in the OTR is 100 tpy and also is 100 tpy in a moderate 8-hour ozone nonattainment area. The federal emission threshold for major volatile organic compound (VOC) sources under the 8-hour ozon e NAAQS is 50 tpy statewide because the minimum federal emission threshold in the OT R is 50 tpy even though the federal emission threshold for moderate 8-hour ozone nonattainment areas is 100 tpy.

NHDES is currently more stringent than th e federal emission threshold requirements under the 8-hour ozone NAAQS because NHDES curre ntly uses the emissi on thresholds that NHDES adopted for the 1-hour ozone NAAQS, which were more stringent than required at that time as well because the emission thresholds are implemented countywide even if only a partial county is designated as nonattainment for the 8- hour ozone NAAQS. The emission threshold for major sources for VOCs is 50 tpy statewide. For NOx, the major source emission threshold is 50 tpy in the 4 c ounties (Hillsborough, Merrimack, Rockingham, and

11 NSR provisions are contained in Env-A 618, Additional Requirements in Non-Attainment Areas and the New Hampshire Portion of the Northeast Ozone Transport Region

.Transport SIP Revision Page 28 NHDES FINAL March 2008
Stafford), designated in part or whole as nonattainment for the previous 1-hour ozone standard (current 8-hour ozone NAAQS) and 100 tpy elsewhere in the state. Note that for anti-backsliding purposes, New Hampshire mu st maintain the major source emissions thresholds established under th e 1-hour ozone standard. See Table 4-1 for a comparison of current emission thresholds and curre nt federal requirements. For PM 2.5 (or PM 10 or TSP), the major source emission threshold is 250 tpy or 100 tpy statewide depending upon the source category.

Table 4-1. Major Source Emission Thresholds for Ozone Precursors

Current Emission

Threshold (tpy) 1-Hour Ozone Required Emission Threshold (tpy) 8-Hour Ozone Required Emission Threshold (tpy) OTR Required Emission Threshold (tpy)

VOC 50 50 100 50 NOx – 4 Counties 50 50 100 100

NOx – Statewide (Except 4 Counties) 100 100 100 100

For major modifications, the significant net emission increase leve l is 25 tpy for TSP and 15 tpy for PM 10 and PM 2.5 , since New Hampshire is using the PM 10 emission threshold and standard as a surrogate for PM 2.5 until PM 2.5 specific provisions are adopted. For VOCs, the significant net emission increase level for ma jor modifications is 25 tpy in the 4-counties (Hillsborough, Merrimack, Rockingham, and Stafford) and 40 tpy elsewhere in the state. For NOx, the significant net emission increase level for major modifications is 25 tpy in the 4- counties (Hillsborough, Merrimack, Rockingham, a nd Stafford) and 40 tpy elsewhere in the
state.

NHDES also has a special provision, Env-A 615, Interstate Air Quality Impacts

, which currently states the following:

The department shall apply special emissi on limits to a stationary source to ensure that its air quality impacts on adj acent states shall not interfere with the measures taken in those states to prevent significant deterioration of air quality and shall not prevent the attainment or main tenance of the NAAQS in those states.

For these provisions, air quality dispersion modeling is used to determine significant deterioration.

The PSD and NSR provisions for the 8-hour ozone and 1997 PM 2.5 NAAQS and the Interstate Air Quality Impact provisions are measures to prevent major sources from contributing to significant deterior ation of the 8-hour ozone and 1997 PM 2.5 NAAQS.Transport SIP Revision Page 29 NHDES FINAL March 2008

If deemed necessary, NHDES will update th e PSD/NSR provision s to meet the 8- hour ozone NAAQS and 1997 PM 2.5 NAAQS. In the meantime, NHDES uses the PSD and NSR regulations adopted to implement th e 1-hour ozone NAAQS. These PSD and NSR provisions are equivalent to or more stringent than what wo uld be required under the 8-hour ozone NAAQS. 12

In the future, if necessary, NHDES will revise its PSD regul ations accordi ngly. In the meantime, New Hampshire uses the PM 10 emission threshold and standard as a surrogate for PM 2.5 , per USEPA’s interim guidance. In addi tion, New Hampshire, in conjunction with other NESCAUM states, has developed PSD incr ement levels for air quality dispersion modeling purposes.

In terms of visibility, NHDES implements th e 1980 visibility provisi ons as part of the PSD/NSR permitting procedures; therefore, no major source or major modification can obtain a PSD/NSR permit unless it does not interf ere with the 1980 visibility requirements. At this time, NHDES along with other States in MANE-VU and other RPOs are analyzing emissions and emission reduction strategies and formulating an approach for addressing the 1999 regional haze provisions. In the re gional haze SIP submittal due December 17, 2007, NHDES plans to discuss potential measures to address the 1999 regional haze requirements, if necessary.



### 5.0 

## Administrative Materials

On January 15, 2008, NHDES published in a statewide newspaper a public notice soliciting comment and announcing the opportunity for the public to request a public hearing for this SIP Revision. Appendix A includes a copy of the public no tice of the comment period and request for a public hearing for this SIP revision. After the public comment period and public hearing, if requested, NHDES will document and review any comments received and provide a response, if necessary. NHDE S will amend this SIP Revision, as necessary, and resubmit it with the additional documentation required to certify the SIP submittal. Appendices B and C will cont ain the comments received on th is SIP revision and NHDES’ responses and the certification of the public hearing, if held. The Governor has designated the Director of the Air Resources Division as his designee per a copy of the letter included in Appendix D.

12 Note that in December 2005, NHDE S submitted a SIP revision with a preliminary draft of revisions to the PSD and NSR regulations. This revi sion was submitted in accordance with Parts C and D of Title I of the CAA.

### Appendix A Public Notice for SIP Revision

### Appendix B Public Comments and NHDES ResponseNH DES Responses to EPA’s Comments on New Hampshire’s Clean Air Act (CAA) Section 110(a)(2)(D)(i) State Implementation Plan (Transport SIP)

Response to Comment #1: NH DES has revised the Transpor t SIP narrative to reflect the revised action date of March 17, 2008, for the Infrastructure SIP.

Response to Comment #2: NH DES has revised Figure 2-1 to show Merrimack County as being designated marginal unde r the 1-hour ozone standard.

Response to Comment #3: NH DES has revised the referenced section of the te xt to read as follows: “In Maine, estimated future desi gn values improved by 5 ppb at monitors in Gardiner and West Buxton.”
Response to Comment #4: NH DES has revised the referenced se ction of the text to read as follows: “For these reasons, Maine submitted and was granted a redesignation request to remove the nonattainment status of the Port land and MidCoast 8-hour ozone nonattainment areas.”

### Appendix C Certification of Public Process

### Appendix D Evidence of Legal Authority