# New Hampshire

Regional Haze SIP Revision

January 29, 2010



# Mid-Atlantic/Northeast Visibility Union (MANE-VU)

Prepared by



## Air Resources DivisionNew Hampshire Regional Haze SIP Revision Page i



### TABLE OF CONTENTS

1. THE REGIONAL HAZE ISSUE ........................

................................................... ................1 1.1 Regional Haze Planning after Remand of CAIR...

................................................... ......2

1.2 The Basics of Haze............................

................................................... ..........................5 1.3 Anatomy of Regional Haze ......................

................................................... ...................6 1.4 Regulatory Framework..........................

................................................... ......................7 1.4.1 The Regional Haze Rule......................

................................................... ...............8 1.4.2 State Implementation Plan...................

................................................... ...............9 1.5 New Hampshire’s Class I Areas.................

................................................... ................11

1.5.1 Great Gulf Wilderness.......................

................................................... ................12 1.5.2 Presidential Range - Dry River Wilderness, N ew Hampshire .............................13 1.5.3 Monitoring and Recent Visibility Trends.....

................................................... .....14

2. AREAS CONTRIBUTING TO REGIONAL HAZE............ ................................................16 2.1 Class I Areas Affected by New Hampshire’s Emis sion Sources ..................................17 2.2 States Contributing to Visibility Impairment i n New Hampshire’s Class I Areas........18

3. REGIONAL PLANNING AND CONSULTATION............. ...............................................19 3.1 Mid-Atlantic / Northeast Visibility Union (MAN E-VU).............................................. 19 3.2 Regional Consultation and the “Ask”...........

................................................... ..............20 3.2.1 New Hampshire-Specific Consultations........

................................................... ....24

3.2.2 The MANE-VU “Ask” ...........................

................................................... ...........26 3.2.2.1 Meeting the “Ask” – MANE-VU States ........ .............................................26 3.2.2.2 Meeting the “Ask” – New Hampshire......... ................................................27 3.2.2.3 Meeting the “Ask” – States outside MANE-VU .........................................27 3.2.3 Technical Ramifications of Differing Approac hes...............................................2 8

3.2.4 Consultation Issues.........................

................................................... ...................29 3.2.5 State/Tribe and Federal Land Manager Coordin ation ..........................................31

3.2.6 EPA Consultation and Review .................

................................................... .........33

4. ASSESSMENT OF BASELINE AND NATURAL VISIBILITY C ONDITIONS ..............34 4.1 Calculation Methodology .......................

................................................... ....................34 4.2 MANE-VU Baseline Visibility ...................

................................................... ...............35 4.3 New Hampshire Class I Areas – Baseline Visibil ity................................................ .....36 4.4 New Hampshire Class I Areas – Natural Backgrou nd ................................................. .37

5. AIR MONITORING STRATEGY........................

................................................... .............38 5.1 IMPROVE Program Objectives ....................

................................................... .............38 5.2 Monitoring Requirements.......................

................................................... ....................38 5.3 Monitoring Sites for MANE-VU Class I Areas ....

................................................... .....40
5.3.1 Acadia National Park, Maine .................

................................................... ...........40 5.3.2 Brigantine Wilderness, New Jersey...........

................................................... ........41 5.3.3 Great Gulf Wilderness, New Hampshire........

................................................... ...42 5.3.4 Presidential Range - Dry River Wilderness, N ew Hampshire .............................43New Hampshire Regional Haze SIP Revision Page ii

5.3.5 Lye Brook Wilderness, Vermont...............

................................................... ........43
5.3.6 Moosehorn Wilderness, Maine.................

................................................... .........44 5.3.7 Roosevelt Campobello International Park, New Brunswick, Canada..................46

6. EMISSIONS INVENTORY............................

................................................... ...................47

6.1 Baseline and Future-Year Emissions Inventories for Modeling ...................................47 6.1.1 Baseline Inventory (2002) ...................

................................................... ..............48

6.1.2 Future-Year Emissions Inventories ...........

................................................... ........49 6.2 Emission Processor Selection and Configuration

................................................... .......49 6.3 Inventories for Specific Source Categories ....

................................................... ............50 6.3.1 Stationary Point Sources....................

................................................... ................50 6.3.1.1 Electric Generating Units (EGUs)..........

................................................... ..50

6.3.1.2 Non-EGU Point Sources.....................

................................................... ......51 6.3.2 Stationary Area Sources .....................

................................................... ...............52

6.3.3 Non-Road Mobile Sources .....................

................................................... ...........52

6.3.4 On-Road Mobile Sources ......................

................................................... ............53 6.3.5 Biogenic Emission Sources ...................

................................................... ............53 6.4 Summary of Emissions Inventories..............

................................................... ..............53

7. AIR QUALITY MODELING ...........................

................................................... .................55 7.1 Meteorology ...................................

................................................... ............................55 7.2 Data Preparations.............................

................................................... ...........................57

7.3 Model Platforms ...............................

................................................... ..........................57
7.3.1 CMAQ ........................................

................................................... .......................59

7.3.2 REMSAD ......................................

................................................... ....................59

7.3.3 CALGRID .....................................

................................................... ....................59

7.3.4 CALPUFF.....................................

................................................... .....................60

8. UNDERSTANDING THE SOURCES OF HAZE-CAUSING POLLU TANTS .................61

8.1 Fine-Particle Pollutants ......................

................................................... ........................61 8.2 Contributing States and Regions ...............

................................................... .................62

8.3 Emission Sources and Characteristics ..........

................................................... ..............69
8.3.1 Sulfur Dioxide (SO 2 ) .................................................. ..........................................69 8.3.2 Volatile Organic Compounds (VOC)............

................................................... ....71 8.3.3 Oxides of Nitrogen (NO X ).................................................. ..................................73 8.3.4 Primary Particulate Matter (PM 10 and PM 2.5 ).................................................. .....74
8.3.5 Ammonia Emissions (NH 3 ).................................................. ................................79

9. BEST AVAILABLE RETROFIT TECHNOLOGY (BART)...... .........................................82 9.1 BART Applicability ............................

................................................... .......................82 9.2 BART-Eligible Sources in New Hampshire........

................................................... .......83 9.2.1 Cap-Outs and Shutdowns ................

................................................... ..................83 9.2.2 Small Source Exemptions.....................

................................................... .............83 9.2.3 Large Electrical Generating Units ...........

................................................... ..........83New Hampshire Regional Haze SIP Revision Page iii

9.3 Determination of BART Requirements for BART-El igible Sources and Analysis of Best Retrofit Technologies.........

................................................... ....84 9.3.1 BART Determinations and Required Control Lev els ..........................................84 9.3.2 Visibility Improvements Resulting from BART . .................................................87 9.3.3 Bart-Eligible EGUs and the Role of CAIR .....

................................................... ..88 9.4 Alternatives to BART for Any Source ...........

................................................... ............89 9.5 BART Enforceable Provisions and Implementation Schedule .....................................89

10. REASONABLE PROGRESS GOALS .....................

................................................... .......91 10.1 Calculation of Uniform Rate of Progress ......

................................................... ...........91
10.2 Identification of (Additional) Reasonable Con trol Measures .....................................9 2 10.2.1 Rationale for Determining Reasonable Contro ls................................................9 3 10.2.2 Best Available Retrofit Technology Controls

................................................... .95 10.2.3 Low-Sulfur Fuel Strategy...................

................................................... .............96 10.2.4 Targeted EGU Strategy for SO 2 Reductions......................................... ............100

10.2.5 Non-EGU SO 2 Emissions Reduction Strategy for Non-MANE-VU States .....106 10.3 Reasonable Progress Goals for Class I Areas i n the State........................................ .113 10.4 Visibility Effects of (Additional) Reasonable Control Measures..............................114

11. LONG-TERM STRATEGY............................

................................................... ...............116 11.1 Overview of Strategy Development Process.....

................................................... .....116 11.2 Technical Basis for Strategy Development .....

................................................... .......118 11.3 Existing Commitments / Expected Measures to R educe Emissions..........................119 11.3.1 Controls on EGUs Expected by 2018..........

................................................... ..120 11.3.2 Controls on Non-EGU Point Sources Expected by 2018.................................123 11.3.3 Controls on Area Sources Expected by 2018.. .................................................12 4 11.3.4 Controls on Mobile Sources Expected by 2018 ...............................................125 11.3.5 Controls on Non-Road Sources Expected by 20 18 ..........................................126

11.4 Additional Reasonable Measures ...............

................................................... ............127

11.4.1 BART .......................................

................................................... .....................128 11.4.2 Low-Sulfur Oil Strategy....................

................................................... ............128 11.4.3 Targeted EGU Strategy ......................

................................................... ...........129 11.5 Source Retirement and Replacement Schedules ..

................................................... ..132 11.6 Measures to Mitigate the Impacts of Construct ion Activities...................................13 2 11.7 Agricultural and Forestry Smoke Management ...

................................................... ..133 11.8 Estimated Effects of Long-Term Strategy on Vi sibility........................................... .133 11.9 New Hampshire’s Share of Emission Reductions.

................................................... .139 11.10 Emission Limitations and Compliance Schedule s .................................................. 140 11.11 Enforceability of Emission Limitations and C ontrol Measures ..............................141 11.12 Prevention of Significant Deterioratio n.................................................. .................143

12. ADMINISTRATIVE MATERIALS ......................

................................................... ........144New Hampshire Regional Haze SIP Revision Page iv



### LIST OF FIGURES

Figure 1.1 Map of CAIR States ......................

................................................... ......................2
Figure 1.2 Locations of Federally Protected Mandato ry Class I Areas................................... 8
Figure 1.3 Mt. Washington from the Southeast at Sun rise............................................... ......11
Figure 1.4 Location of New Hampshire’s Class I Area s .................................................. ......12
Figure 1.5 View of Great Gulf Wilderness from Mt. W ashington .........................................1 2
Figure 1.6 Views of Great Gulf Wilderness from Lowe r Elevation on Clear (6 deciview)

and Hazy (28 deciview) Days........................

................................................... .....13
Figure 1.7 Presidential Range - Dry River Wildernes s in Autumn ........................................ 13
Figure 1.8 Visibility Trends at Great Gulf and Pres idential Range – Dry River Wilderness

Areas..............................................

................................................... .....................14
Figure 2.1 Measured and Projected Mass Contribution in 2002 and 2018 at Great Gulf

and Presidential Range - Dry River Wilderness Areas on 20 Percent Worst Visibility Days....................................

................................................... ................17
Figure 3.1 EPA-Designated Regional Planning Organiz ations (RPOs) .................................19
Figure 5.1 Map of Acadia National Park Showing Loca tion of IMPROVE Monitor ............40
Figure 5.2 Acadia National Park on Clear and Hazy D ays................................................ .....40
Figure 5.3 Map of Edwin B. Forsythe National Wildli fe Refuge.......................................... .41
Figure 5.4 Brigantine Wilderness on Clear and Hazy Days ............................................... ....41
Figure 5.5 Map of Great Gulf and Presidential Range - Dry River Wilderness Area

Showing Location of IMPROVE Monitor ................ ............................................42
Figure 5.6 Great Gulf Wilderness on Clear and Hazy Days............................................... ....42
Figure 5.7 Upper Elevations of Presidential Range - Dry River Wilderness .........................43
Figure 5.8 Location of Lye Brook Wilderness IMPROVE Monitor ......................................43
Figure 5.9 Aerial View of Lye Brook Wilderness and IMPROVE Monitoring Site..............44
Figure 5.10 Lye Brook Wilderness on Clear and Hazy Days............................................... ....44
Figure 5.11 Map of the Baring and Edmunds Divisions of the Moosehorn National Wildlife

Refuge Showing Location of IMPROVE Monitor......... .......................................45
Figure 5.12 Moosehorn Wilderness on Clear and Hazy Days............................................... ...45
Figure 5.13 Map of Roosevelt Campobello Internation al Park ............................................ ....46
Figure 5.14 Roosevelt Campobello International Park on Clear and Hazy Days.....................46
Figure 7.1 Modeling Domains Used in MANE-VU Air Qua lity Modeling Studies

with CMAQ..........................................

................................................... ..............56
Figure 7.2 Examples of Processed Model-Ready Emissi ons................................................ ..58
Figure 8.1 Contributions to PM 2.5 Extinction at Seven Class I Areas ................. ...................61
Figure 8.2 Ranked Sulfate Contributions to Northeas t Class I Receptors Based on

Q/d Method (Mass Basis), by Location of Origin..... ............................................64
Figure 8.3 Ranked Sulfate Contributions to Mid-Atla ntic Class I Receptors Based on

Q/d Method (Mass Basis), by Location of Origin..... ............................................64
Figure 8.4 Modeled 2002 Contributions to Sulfate at Great Gulf, by State ...........................66
Figure 8.5 Modeled 2002 Contributions to Sulfate at Brigantine, by State............................66New Hampshire Regional Haze SIP Revision Page v

Figure 8.6 Modeled 2002 Contributions to Sulfate at Lye Brook, by State ...........................67
Figure 8.7 Modeled 2002 Contributions to Sulfate at Acadia, by State .................................6 7
Figure 8.8 Modeled 2002 Contributions to Sulfate at Moosehorn, by State ..........................68
Figure 8.9 Modeled 2002 Contributions to Sulfate at Shenandoah, by State .........................68
Figure 8.10 Modeled 2002 Contributions to Sulfate a t Dolly Sods, by State...........................69
Figure 8.11 Annual Sulfur Dioxide (SO 2 ) Emissions, by State.............................. ..................70
Figure 8.12 2002 Sulfur Dioxide (SO 2 ) Emissions, by State.............................. ......................71
Figure 8.13 2002 Volatile Organic Carbon (VOC) Emis sions, by State ..................................72
Figure 8.14 Annual Nitrogen Oxide (NO X ) Emissions, by State.............................. ................73
Figure 8.15 2002 Nitrogen Oxide (NO X ) Emissions, by State .............................. ...................74
Figure 8.16 Primary Course Particle (PM 10 ) Emissions, by State .............................. ..............75
Figure 8.17 Primary Fine Particle (PM 2.5 ) Emissions, by State.............................. ..................75
Figure 8.18 Wood Smoke Source Regional Aggregations

................................................... ....77
Figure 8.19 2002 Primary Coarse Particle (PM 10 ) Emissions, by State .............................. .....78
Figure 8.20 2002 Primary Fine Particle (PM 2.5 ) Emissions, by State.............................. .........78
Figure 8.21 Ammonia (NH 3 ) Emissions, by State.............................. ......................................80
Figure 8.22 2002 Ammonia (NH 3 ) Emissions, by State.............................. .............................80
Figure 10.1 Average Change in 24-hr PM 2.5 Due to Low-Sulfur Fuel Strategy (Phases

1 & 2 Combined) Relative to OTB/OTW (values in μ g/m 3 ) ...............................97
Figure 10.2..Location of 176 EGU Stacks Contributin g the Most to Visibility Impairment

at MANE-VU Class I Areas ...........................

................................................... .. 101
Figure 10.3 Preliminary Estimate of Average Change in 24hr PM 2.5 Resulting from a

90 Percent Reduction in SO 2 Emissions from the Top 167 EGU Stacks Affecting MANE-VU Class I Areas.................... ................................................ 102
Figure 10.4 Demonstration of Required and Reasonabl e Visibility Progress for

20 Percent Worst Visibility Days ...................

................................................... ..115
Figure 10.5 Demonstration of Required Maintenance o r Improvement of Visibility

for 20 Percent Best Visibility Days ................

................................................... ..115
Figure 11.1 Expected Visibility Improvement at Grea t Gulf Wilderness Based on

Most Recent Projections............................

................................................... .......136
Figure 11.2 Expected Improvements in Pollutant Conc entrations at Great Gulf Wilderness

on Best and Worst Days .............................

................................................... ......136
Figure 11.3 Expected Visibility Improvement at Acad ia National Park Based on Most

Recent Projections .................................

................................................... ...........137
Figure 11.4 Expected Visibility Improvement at Brig antine National Wildlife Refuge

Based on Most Recent Projections...................

................................................... 137
Figure 11.5 Expected Visibility Improvement at Lye Brook Wilderness Based on Most

Recent Projections .................................

................................................... ...........138
Figure 11.6 Expected Visibility Improvement at Moos ehorn National Wildlife Refuge

Based on Most Recent Projections...................

................................................... 138New Hampshire Regional Haze SIP Revision Page vi



### LIST OF TABLES

Table 1.1 Visibility Monitoring at Great Gulf and P residential Range - Dry River

Wilderness Area ....................................

................................................... .............14
Table 2.1 New Hampshire’s Contributions to Total An nual Average Sulfate Impact

(Percent, Mass Basis) at Eastern Class I Areas in 2 002........................................17

Table 2.2 Contributions of Individual MANE-VU State s and Other Regions to Total

Annual Average Sulfate Impact (Percent, Mass Basis) at New Hampshire’s
Class I Areas in 2002..............................

................................................... ............18

Table 3.1 MANE-VU Members ..........................

................................................... ...............20
Table 3.2 MANE-VU Consultation Principles for Regio nal Haze Planning ........................21
Table 3.3 Summary of MANE-VU’s Consultations on Reg ional Haze Planning.................23
Table 3.4 Class I Area States Requesting Consultati on with New Hampshire .....................24
Table 3.5 States (Listed by Regional Planning Organ ization) and Provinces Contributing

to Visibility Impairment at New Hampshire’s Class I Areas ................................25

Table 4.1 IMPROVE Monitors for MANE-VU Class I Area s..............................................34
Table 4.2 Summary of Baseline Visibility and Natura l Visibility Conditions for the

20 Percent Best and 20 Percent Worst Visibility Day s at MANE-VU
Class I Areas......................................

................................................... .................36
Table 4.3 Baseline Visibility for the 20 Percent Be st Days and 20 Percent Worst Days

during 2000-2004 in New Hampshire Class I Areas.... .........................................37
Table 6.1 2002 Emissions Inventory Summary for New Hampshire....................................54
Table 6.2 2018 OTB/OTW Emissions Inventory Summary for New Hampshire.................54
Table 6.3 2018 BOTW Emissions Inventory Summary for New Hampshire .......................54
Table 6.4 2018 Most Recent Emissions Inventory Summ ary for New Hampshire ..............54
Table 8.1 Percent Contributions (Mass Basis) of Ind ividual MANE-VU States and Other

Regions to Total Annual Sulfate Impacts at Northeas t Class I Areas (REMSAD) .63
Table 9.1 BART-Eligible Sources in New Hampshire...

................................................... ....83
Table 9.2 Emission Reductions Resulting from BART C ontrols at PSNH Merrimack

Station Unit MK2 ...................................

................................................... ............86
Table 9.3 Emission Reductions Resulting from BART C ontrols at PSNH Newington

Station Unit NT1 ...................................

................................................... .............86

Table 9.4 CALPUFF Modeling Results for Merrimack Station Unit MK2: Visibility

Improvements from BART Controls on the 20% Worst Vi sibility Days .........................88

Table 9.5 CALPUFF Modeling Results for Newington Station Unit NT1: Visibility

Improvements from BART Controls on the 20% Worst Vi sibility Days .........................88
Table 9.6 BART Enforceable Provisions and Complianc e Schedule for PSNH

Merrimack Station Unit MK2 .........................

................................................... ....90
Table 9.7 BART Enforceable Provisions and Complianc e Schedule for PSNH

Newington Station Unit NT1.........................

................................................... .....90
Table 10.1 Uniform Rate of Progress Calculation (al l values in deciviews) ..........................92
Table 10.2 Summary of Results from Four-Factor Anal ysis of Different Source Categories...94New Hampshire Regional Haze SIP Revision Page vii

Table 10.3 Estimated Emissions from BART-Eligible F acilities in MANE-VU States

(Facilities Likely to be Controlled as a Result of BART Alone) ..........................95
Table 10.4 Estimated Cost Ranges for SO 2 Control Options for Coal-Fired EGU Boilers

(2006 dollars per ton of SO 2 removed).......................................... ......................104

Table 10.5 Available SO 2 Control Options for ICI Boilers................... ................................108
Table 10.6 Estimated Costs of Dry Sorbent Injection (DSI) for ICI Boilers (2006 dollars) ...110

Table 10.7 Estimated Costs of Flue Gas Desulfurizat ion for ICI Boilers (2006 dollars) ..... 111
Table 10.8 Reasonable Progress Goals for Great Gulf Wilderness and Presidential Range - Dry River Wilderness (all values in decivie ws) ....................................113
Table 11.1 Projected SO 2 Emission Reductions from Targeted EGUs in New Hamp shire....129

Table 11.2 SO 2 Emissions from Point, Area, and Mobile Sources in New Hampshire ........140

Table 11.3 SO 2 Emissions from Point, Area, and Mobile Sources in all of MANE-VU......140



### LIST OF ATTACHMENTS

ATTACHMENT A EPA Regional Haze Checklist

ATTACHMENT B MANE-VU Contribution Assessment

ATTACHMENT C Inter-RPO State/Tribal and FLM Consult ation Framework

ATTACHMENT D Consultation Summaries and Other Docum entation

ATTACHMENT E The MANE-VU “Ask”
ATTACHMENT F Comments from VISTAS and West Virginia Department of
Environmental Protection
ATTACHMENT G MANE-VU Modeling for Reasonable Progre ss Goals

ATTACHMENT H Documentation of 2018 Emissions from E GUs in the Eastern United States
ATTACHMENT I Comments from Federal Land Managers and EPA (with Responses)

ATTACHMENT J Comments from Other Stakeholders
ATTACHMENT K MANE-VU Natural Background Visibility Conditions
ATTACHMENT L MANE-VU Baseline and Natural Backgroun d Visibility Conditions
ATTACHMENT M Technical Support Document for 2002 M ANE-VU SIP Modeling

Inventories, Version 3
ATTACHMENT N Development of Emission Projections fo r 2009, 2012, and 2018 for

NonEGU Point, Area, and Nonroad Sources in the MANE -VU Region
ATTACHMENT O Development of MANE-VU Mobile Source P rojection Inventories for

SMOKE/MOBILE6 Application
ATTACHMENT P NYSDEC Technical Support Document TSD- 1c
ATTACHMENT Q MANE-VU 2018 Visibility Projections
ATTACHMENT R NYSDEC Technical Support Document TSD- 1a
ATTACHMENT S NYSDEC Technical Support Document TSD- 1eNew Hampshire Regional Haze SIP Revision Page viii

ATTACHMENT T NYSDEC Technical Support Document TSD- 1d
ATTACHMENT U CALGRID Modeling Protocol
ATTACHMENT V Technical Support Document on Agricult ural and Forestry Smoke

Management in the MANE-VU Region
ATTACHMENT W MANE-VU Five-Factor Analysis of BART-E ligible Sources
ATTACHMENT X BART Analyses for Sources in New Hamps hire
ATTACHMENT Y Assessment of Reasonable Progress for Regional Haze in MANE-VU

Class I Areas
ATTACHMENT Z Assessment of Control Technology Optio ns for BART-Eligible

Sources
ATTACHMENT AA Low-Sulfur Heating Oil in the Northea st States
ATTACHMENT BB Comparison of CAIR and CAIR Plus Prop osal Using the Integrated

Planning Model (IPM®)
ATTACHMENT CC The Nature of Fine Particle and Regio nal Haze Air Quality Problems

in the MANE-VU Region
ATTACHMENT DD Technical Support Document on Measure s to Mitigate Visibility

Impacts of Construction Activities in the MANE-VU R egion
ATTACHMENT EE Temporary Permit for PSNH Merrimack S tation

ATTACHMENT FF Revisions to Env-A 1604, Sulfur Conte nt Limitations for Liquid Fuels (Draft)
ATTACHMENT GG Chapter Env-A 2300, Mitigation of Reg ional Haze (Draft)
ATTACHMENT HH Title V Operating Permit for PSNH Mer rimack Station (Draft)
ATTACHMENT II Title V Operating Permit for PSNH New ington Station

ATTACHMENT JJ Public Notice for SIP Revision

ATTACHMENT KK Certification of Public Process
ATTACHMENT LL Evidence of Legal Authority



### ACKNOWLEDGEMENTS

The New Hampshire Department of Environmental Servi ces would like to express appreciation to the dedicated staff s of the NESCAUM, MARAMA, and MANE-VU regional organizations and to t he
dedicated staffs of the MANE-VU member states for t heir invaluable assistance and timely contributions in the developm ent of New Hampshire’s Regional Haze SIP Revision.New Hampshire Regional Haze SIP Revision Page ix



### FOREWORD

This document revises New Hampshire’s State Impleme ntation Plan (SIP) to meet requirements of the Clean Air Act related t o protection of visibility. SIPs are dynamic documents describing the state’s statutory and regulatory (i.e., enforceable) emission control mea sures that will be implemented to ensure compliance with National Ambi ent Air Quality Standards and goals. SIPs must be reviewed and upd ated periodically to stay current with administrative requirements, chan ging air quality conditions, and new or amended federal programs. T he terms “SIP” and “SIP revision” are sometimes used interchangeably i n reference to new or revised portions of a state implementation plan. R egional Haze SIP, or Regional Haze Plan, refers specifically to that por tion of the State Implementation Plan which addresses visibility impr ovement.New Hampshire Regional Haze SIP Revision Page 1



### 1. THE REGIONAL HAZE ISSUE

In 1999, the Environmental Protection Agency (EPA) issued regulations to improve visibility in 156 national parks and wilderness areas across t he United States. The affected areas include many of our best known natural places, incl uding the Grand Canyon, Yosemite, Yellowstone, Mount Rainier, Shenandoah, the Great S mokies, Acadia, and the Everglades. In New Hampshire, the two affected areas are Great Gul f Wilderness and Presidential Range - Dry River Wilderness.

These regulations address visibility impairment in the form of regional haze. Haze is an atmospheric phenomenon that obscures the clarity, c olor, texture, and form of what we see. It is caused primarily by anthropogenic (manmade) poll utants but can also be caused by a number of natural phenomena, including forest fires , dust storms, and sea spray. Some hazecausing pollutants are emitted directly to the atmo sphere by anthropogenic emission sources such as electric power plants, factories, automobil es, construction activities, and agricultural burning. Others occur when gases emitted to the ai r (haze precursors) interact to form new particles that are carried downwind.

Emissions from these activities generally span broa d geographic areas and can be transported hundreds or thousands of miles. Consequently, regi onal haze occurs in every part of the nation. Because of the regional nature of haze, EP A’s regulations require the states to consult with one another toward the national goal of improv ing visibility – specifically, at the 156 parks and wilderness areas designated under the Cle an Air Act as mandatory Class I Federal

Areas.

The Regional Haze Rule calls for each state to esta blish reasonable progress goals for visibility improvement and to formulate a long-term strategy for meeting these goals. These requirements apply to any state having a Class I ar ea as well as any state that contributes to visibility impairment at any (downwind) Class I are a. The visibility goals must be designed both to improve visibility on the haziest days and to ensure that no degradation occurs on the clearest days.

A state’s long-term strategy must include enforceab le emission reduction measures designed to meet reasonable progress goals. The first long- term strategy covers the 10-15-year period ending in 2018, and subsequent revisions are to be issued every 10 years thereafter. In identifying the emission reduction measures to be i ncluded in the long-term strategy, states should address all types of manmade emissions contr ibuting to visibility degradation in Class I areas, including those from mobile sources; stati onary sources (such as factories); smaller, so-called “area” sources (such as residential wood stoves and small boilers); and prescribed
fires.

In developing their plans, states can take into acc ount emission reductions attributable to ongoing air pollution control programs at the state , regional, or national levels. For most states and regions of the country, however, additio nal emission control measures beyond those already on the books will be necessary if nat ional visibility goals are to be achieved. In addition, the Regional Haze Rule mandates that cont rol measures be implemented for certain existing sources placed into operation between 1962 and 1977. This portion of the rule is
known as BART

, for Best Available Retrofit Technology

.New Hampshire Regional Haze SIP Revision Page 2

Each state’s plan for addressing regional haze will take the form of a State Implementation Plan (SIP) or SIP revision. New Hampshire’s SIP re vision, presented here, was developed
after extensive consultations with other states and regional planning organizations. In particular, New Hampshire contributed to many analy ses and reports produced by the member
states of the Northeast States for Coordinated Air Use Management (NESCAUM) and the Mid-Atlantic/Northeast Visibility Union (MANE-VU) f or the purpose of coordinated regional haze planning. New Hampshire also consulted with s tates outside the Northeast and with the provinces of eastern Canada.

The regulatory, organizational, and technical basis for New Hampshire’s regional haze plan will be found in Sections 1 through 8 of this SIP d ocument. The prescriptive elements of New Hampshire’s plan – BART provisions, reasonable progress goals, and long-term strategy – are described in detail in Sections 9 through 11.



### 1.1 Regional Haze Planning after Remand of CAIR

On March 10, 2005, EPA issued the Clean Air Interst ate Rule (CAIR). This important federal rule was designed to achieve major permanent reduct ions in sulfur dioxide (SO 2 ) and nitrogen oxides (NO X ) emissions in the eastern United States through a cap-and-trade system using emission allowances. CAIR would permanently cap e missions originating in 28 eastern states and the District of Columbia (Figure 1.1). Althoug h New Hampshire was not designated as a participating CAIR state, this program would greatl y affect future air quality in the state.

Figure 1.1: Map of CAIR States

http://www.epa.gov/cair/New Hampshire Regional Haze SIP Revision Page 3

According to EPA’s CAIR website, SO 2 emissions in the affected states would be reduced by more than 70 percent from 2003 levels, and NO X emissions by more than 60 percent from 2003 levels, upon full implementation of CAIR (see http://www.epa.gov/cair/ ). Resulting improvements in air quality would yield $85 to $100 billion in health benefits and nearly $2 billion in visibility benefits per year by 2015, an d premature mortality would be substantially
reduced across the eastern U.S.

On July 11, 2008, the U.S. Court of Appeals for the District of Columbia Circuit found that CAIR violated basic provisions of the Clean Air Act . The Court vacated CAIR in its entirety and remanded to EPA to promulgate a new rule consis tent with the Court’s opinion. EPA appealed the decision amid widespread concern that, despite its flaws, some form of CAIR was preferable to the sudden regulatory void create d by the Court’s decision. Upon reconsideration, on December 23, 2008, the Court st ayed the vacatur of CAIR but maintained the remand to EPA to promulgate a new rule consiste nt with the Court’s July 11, 2008, opinion. The Court did not impose a definitive dea dline by which EPA must correct CAIR’s flaws, but the Court stated that it does “not inten d to grant an indefinite stay of the
effectiveness” of its decision.

Because CAIR formed the regulatory underpinnings fo r most of the emission reductions that were to produce visibility improvements in mandator y Class I areas, the vacatur of CAIR would have represented a major difficulty for the i ndividual states in attempting to comply with the Regional Haze Rule. While all eastern sta tes have depended in varying degree on CAIR in the preparation of their regional haze SIPs , some Southeast states have relied almost entirely on CAIR to demonstrate compliance with the rule. As a major ramification, the vacatur would have immediately invalidated EPA’s de termination that CAIR satisfied the requirements of BART.

The U.S. Congress and EPA are considering a number of possible short- and long-term regulatory or legislative fixes to improve CAIR. I t is too early to know when this process will
reach a conclusion and what the outcome will dictat e for regional haze planning. There may be some short-term slippage or loss in projected em ission reductions as a consequence of the Court’s July 11, 2008, decision. Over the longer t erm, New Hampshire anticipates that future emission control requirements meeting the provision s of a reauthorized Clean Air Act, or its successor, will be at least as stringent as CAIR or iginally would have obtained. As to the validity of the already-completed planning componen ts, a number of mitigating circumstances apply:

• Application of BART provisions where the old CAIR p reviously might have sufficed is likely to yield even greater emission reductions from BART-eligible facilities.

• New Hampshire and many other states have instituted their own emission reduction programs through multi-pollutant legislation and ot her means. New Hampshire applauds the efforts of other states and encourages them to follow through with the implementation of laws, consent decrees, and other measures that would complement
emission reductions from CAIR.

• Strict adherence to the spirit of the Clean Air Act in future national initiatives will probably result in emission reductions exceeding th ose previously projected for CAIR. A major limitation of the original CAIR was that it relied on interstate emissions trading and did not respond to the specific language of the Clean Air Act, Section 110(a)(2)(D), which prohibits any source or activity within a state from impairing t he ability of another state to meet national air quality standard s or visibility requirements. CAIRNew Hampshire Regional Haze SIP Revision Page 4

was only one tool, not an all-purpose remedy, for a ddressing the problem of interstate transport of pollutants.

For these reasons, NHDES believes that future emiss ions and air quality levels under newCAIR scenarios are not likely to be vastly differen t from values predicted by MANE-VU’s completed modeling, even though that modeling was b ased on implementation of CAIR as it was before the remand. Consequently, the reasonabl e progress goals and long-term strategy developed for New Hampshire’s regional haze SIP sti ll represent a defensible position from which to go forward with measures to improve visibi lity at MANE-VU’s Class I Areas.

New Hampshire and the other MANE-VU states have mai ntained all along that the regional haze SIPs should look beyond the provisions of CAIR to identify additional emission control measures that could be effectively employed to miti gate regional haze. In this respect, New Hampshire and the rest of MANE-VU stand apart from some other states in asserting that additional measures beyond CAIR are essential to me eting established visibility goals at
MANE-VU’s Class I Areas.

In describing New Hampshire’s present situation, it may be helpful to note that the remand of CAIR is a complicating factor but not an absolute i mpediment to making visibility progress in the near term. The salient points to consider are as follows:

• Because New Hampshire is a non-CAIR state, this fed eral program does not directly affect any of New Hampshire’s proposed in-state con trol strategies for visibility improvement. The control measures identified in th is regional haze SIP for in-state sources should be able to proceed without delay or obstruction.

• New Hampshire will meet its “fair share” of emissio ns in comparison with other MANE-VU states and the original CAIR states, as New Hampshire’s long-term strategy demonstrates (see Section 11).

• Sources in upwind states release most of the pollut ants contributing to visibility impairment at New Hampshire’s Class I areas. There fore, New Hampshire will continue to depend on mitigative actions by other s tates if visibility goals are to be
achieved for in-state Class I areas.

• By the time of the first regional haze SIP progress report (expected to be completed in
2013 1 ) the regulatory framework should be clearer; and i t is hoped that new modeling results will be available. If so, it will then be possible to fine-tune regional haze plans to meet the new-CAIR reality. New Hampshire is committed to reviewing and updating its regional haze SIP as new information b ecomes available.

It should be noted that New Hampshire’s Regional Ha ze SIP includes many references to the original CAIR program. These references serve two purposes: 1) They provide historical context, and 2) they help to maintain continuity wi th the large body of completed work –
much of it based on the old CAIR – that serves as t he foundation for regional haze planning in
the MANE-VU states to date.

1 40 CFR 51.308(g) states that the first progress report is due 5 years from the submittal of the initial imple mentation plan. The regional haze SIP was originally due on Decembe r 17, 2007. In New Hampshire’s case, it is expecte d that the first progress report will be completed and submitted in 2013, near the midpoint of the 10-year initial plan ning period from 2008
to 2018.New Hampshire Regional Haze SIP Revision Page 5



### 1.2 The Basics of Haze

Small particles and certain gaseous molecules in th e atmosphere cause poor visibility by scattering and absorbing light, thereby reducing th e amount of visual information about distant objects that reaches an observer. Some lig ht scattering by air molecules and naturally occurring aerosols occurs even under natural condit ions. 2

The distribution of particles in the atmosphere dep ends on meteorological conditions and leads to various forms of visibility impairment. When hi gh concentrations of pollutants are well mixed in the atmosphere, they form a uniform haze. When temperature inversions trap pollutants near the surface, the result can be a sh arply demarcated layer of haze. Plume blight – a distinct, frequently brownish plume of pollution from a particular emissions source – occurs under stable atmospheric conditions, where pollutan ts take a long time to disperse.

Visibility impairment can be quantified using three different, but mathematically related measures: light extinction per unit distance (e.g., inverse megameters, or Mm -1 ) 3 ; visual range (i.e., how far one can see); and deciviews (dv), a useful metric for measuring increments of visibility change that are just perceptible to the human eye. Each can be estimated from the ambient concentrations of individual particle const ituents, taking into account their unique light-scattering (or absorbing) properties and maki ng appropriate adjustments for relative humidity. Assuming natural conditions, visibility in the Northeast and Mid-Atlantic is
estimated to be about 23 Mm -1 , which corresponds to a visual range of about 106 miles or 8 dv (the lower the dv, the better the visibility). Und er current polluted conditions in the region, average visibility ranges from 103 Mm -1 in the south to 55 Mm -1 in the north; these values correspond to a visual range of 24 to 44 miles or 2 3 to 17 dv, respectively. On the worst 20 percent of days, visibility impairment in Northeast and Mid-Atlantic Class I areas ranges from
about 25 to 30 dv.

The small particles that commonly cause hazy condit ions in the East are primarily composed of sulfate, nitrate, organic carbon, elemental carb on (soot), and crustal material (e.g., soil dust, sea salt, etc.). Of these constituents, only eleme ntal carbon impairs visibility by absorbing visible light; the others scatter light. Sulfate, nitrate, and organic carbon 4 are secondary pollutants that form in the atmosphere from precurs or pollutants, primarily sulfur dioxide (SO 2 ), oxides of nitrogen (NO X ), and volatile organic compounds (VOCs), respectiv ely. By contrast, soot and crustal material and some organi c carbon particles are released directly to the atmosphere. Particle constituents also differ in their relative effectiveness at reducing visibility. Sulfates and nitrates, for example, co ntribute disproportionately to haze because of their chemical affinity for water. This property a llows them to grow rapidly, in the presence of moisture, to the optimal particle size for scatt ering light (i.e., 0.1 to 1 micrometer).

2 The fact that air molecules scatter more short-wa velength (blue) light accounts for the blue color o f the sky. The term “aerosol” is defined as a suspension of particles i n a gas. In this report, the term refers to partic les suspended in the atmosphere.

3 In units of inverse length. An inverse megameter (Mm -1 ) is equal to one over one thousand kilometers.

4 The term “organic carbon” encompasses a large num ber of hydrogen and carbon containing molecules. L ight scattering secondary organic aerosols result from the oxidatio n of hydrocarbons that are emitted from many differ ent sources, ranging from automobiles to solvents, to natural ve getation. Organic carbon can be emitted as a prima ry particle from sources such as wood burning, meat cooking, automob iles, and paved road dust.New Hampshire Regional Haze SIP Revision Page 6



### 1.3 Anatomy of Regional Haze

Monitoring data collected over the last decade show that fine particle 5 concentrations, and hence visibility impairment, are generally highest near industrial and highly populated areas
of the Northeast and Mid-Atlantic. Particle concen trations are lower, and visibility conditions are better, at the more northerly Class I sites (su ch as the Great Gulf and Presidential Range - Dry River Wildernesses in New Hampshire), where vis ibility on the 20 percent best days 6 is close to natural, unpolluted conditions. By contra st, visibility at the more southerly Brigantine site in New Jersey is substantially impa ired even on the 20 percent clearest days. On the 20 percent haziest days, visibility impairme nt is substantial throughout the region.

Sulfate is the dominant contributor to fine particl e pollution throughout the eastern U.S. On the haziest 20 percent of days, it accounts for one -half to two-thirds of total fine particle mass and is responsible for about three-quarters of tota l light extinction at Class I sites in the
Northeast and Mid-Atlantic. Even on the clearest 2 0 percent of days, sulfate typically constitutes 40 percent or more of total fine partic le mass in the region. Moreover, sulfate accounts for 60 to 80 percent of the difference in fine particle mass concentrations on hazy versus clear days.

Organic carbon consistently accounts for the next l argest fraction of total fine particle mass; its contribution typically ranges from 20 to 30 per cent on the haziest days. Notably, organic carbon accounts for as much as 40 to 50 percent of total mass on the clearest days, indicating that biogenic hydrocarbon sources (i.e., vegetation ) are important at Class I areas in the region.

The relative contributions of nitrate, elemental ca rbon, and fine soil are smaller than those of sulfate and organic carbon – typically less than 10 percent of total mass and varying with location. However, in some settings such as a moni toring site in Washington, DC, 7 nitrate plays a considerably larger role, pointing to the i mportance of local NO X sources to fineparticle pollution in urban environments.

About half of the worst visibility days in the New Hampshire Class I Areas occur in the summer when meteorological conditions are more cond ucive to the formation of sulfate from
SO 2 and to the oxidation of organic aerosols. The rem aining worst visibility days are divided nearly equally among spring, winter, and fall. In contrast to sulfate and organic carbon, the nitrate contribution is typically higher in the win ter months. 8 The crustal and elemental carbon fractions do not show a clear pattern of sea sonal variation. In addition, winter and summer transport patterns are different, possibly l eading to different contributions from upwind pollutant source regions.

The basis for EPA’s regional haze regulations is re cognition that visibility impairment is fundamentally a regional phenomenon. Emissions fro m numerous sources over a broad

5 “Fine particles” refers throughout this study to particles less than or equal to 2.5 micrometers in diameter, consistent with US EPA’s recently proposed fine particle National A mbient Air Quality Standard (NAAQS).

6 “20 percent best visibility conditions” are defin ed throughout this report as the simple average of the lower 20 th percentile of a cumulative frequency distribution of available data (expressed in deciviews). Similarly, “20 per cent worst visibility conditions” represent the upper 20 th percentile of the same distribution of available d ata.

7 The Washington, DC, site is part of the IMPROVE n ationwide monitoring network and is mentioned here for the purposes of comparison.

8 This is largely due to the fact that the ammonium nitrate bond is more stable at lower temperatures. The role of ammonia
in combination with both sulfate and nitrate is dis cussed further in later sections.New Hampshire Regional Haze SIP Revision Page 7

geographic area commonly create hazy conditions acr oss large portions of the eastern U.S. as a result of the long-range transport of airborne pa rticles and precursor pollutants in the atmosphere. The key sulfate precursor, SO 2 , for example, has an atmospheric lifetime of several days and is known to be subject to transpor t distances of hundreds of miles. NO X and some organic carbon species are also subject to lon g-range transport, as are small particles of
soot and crustal material.

The importance of transport dynamics is well illust rated by a particularly severe haze episode that occurred in mid-July of 1999. During this epi sode, unusually hot and humid conditions coincided with the development of a high-pressure s ystem over the Mid-Atlantic States that produced atmospheric stagnation over the heavily ur banized, southern portion of the northeastern Regional Planning Organization region (i.e., Philadelphia - DC - southern New Jersey). At the same time, wind patterns above the area of stagnation brought a steady flow of air from the Midwest into the New England states. This set of conditions resulted in several days of unusually high concentrations of fine-parti cle pollution throughout the region. On July 17, 1999, ambient sulfate concentrations at Ac adia National Park were 40 percent higher than any previous measurement at that site since th e late 1980s. On the same day, visibility at the Burlington, Vermont, airport was limited to jus t 3 miles. As is often the case, high concentrations of ground-level ozone accompanied th ese severe haze conditions. These coinciding conditions occurred because haze and gro und-level ozone – although they are fundamentally different phenomena – tend to form an d accumulate under similar meteorological conditions.



### 1.4 Regulatory Framework

In amendments to the Clean Air Act (CAA) in 1977, C ongress added Section 169A (42 U.S.C. 7491), setting forth the following national visibil ity goal:

“Congress hereby declares as a national goal the pr evention of any future, and the remedying of any existing, impairment of visibility in mandatory Class I Federal areas which impairment results from manmade air pollution.”

The "Class I" designation was given to each of 158 areas in existence as of August 1977 that met the following criteria:

• all national parks greater than 6000 acres

• all national wilderness areas and national memorial parks greater than 5000 acres

• one international park

In 1980, Bradwell Bay, Florida, and Rainbow Lake, W isconsin, were excluded for purposes of visibility protection as federal Class I areas. Today, 156 national park and wilderness areas remain as Class I visibility protection areas (Figu re 1.2).

Over the following years, modest steps were taken t o address the visibility problems in Class I areas. The control measures taken mainly addressed plume blight from specific pollution sources, a localized phenomenon, and did little to address regional haze issues in the Eastern
United States.

When the Clean Air Act was amended, again, in 1990, Congress added Section 169B (42 U.S.C. 7492), authorizing further research and regu lar assessments of progress made. In 1993, the National Academy of Sciences concluded th at “current scientific knowledge isNew Hampshire Regional Haze SIP Revision Page 8

adequate and control technologies are available for taking regulatory action to improve and protect visibility.”

In addition to authorizing creation of visibility t ransport commissions and setting forth their duties, Section 169B(f) of the CAA mandated creatio n of the Grand Canyon Visibility Transport Commission (GCVTC) to make recommendation s to EPA for the region affecting the visibility of the Grand Canyon National Park. GCVTC submitted its report to EPA in June 1996, following four years of research and pol icy development. This report, as well as the many research reports prepared by the GCVTC, co ntributed invaluable information to EPA in its development of regulations for visibilit y improvement.

Figure 1.2: Locations of Federally Protected Manda tory Class I Areas

1.4.1 The Regional Haze Rule

The federal requirements that states must meet to a chieve national visibility goals are contained in Title 40: Protection of Environment, P art 51 – Requirements for Preparation, Adoption, and Submittal of Implementation Plans, Su bpart P – Protection of Visibility (40 CFR 51.300-309). Known more simply as the Regional Haze Rule, these regulations were adopted on July 1, 1999, and went into effect on Au gust 30, 1999. The rule seeks to address the combined visibility effects of various pollutio n sources over a large geographic region. This wide-reaching pollution net means that many st ates – even those without Class I Areas – are required to participate in haze reduction effor ts. The specific requirements for States’New Hampshire Regional Haze SIP Revision Page 9

regional haze SIPs are set forth in 40 CFR 51.308, Regional Haze Program Requirements. In consultation with the states and tribes, EPA des ignated five Regional Planning Organizations (RPO) to assist with the coordination and cooperati on needed to address the regional haze issue. The Mid-Atlantic and Northeast states, join ed by the District of Columbia and tribes in the Northeast, formed the Mid-Atlantic / Northeast Visibility Union (MANE-VU). 9

EPA’s adoption of the Regional Haze Rule was not wi thout controversy and legal challenges. On May 24, 2002, the U.S. Court of Appeals for the District of Columbia Circuit ruled on the challenge brought by the American Corn Growers Asso ciation against the Regional Haze Rule. The Court remanded the BART provisions of th e rule to EPA and denied industry’s challenge to the haze rule goals of achieving natur al visibility levels and zero degradation. On June 15, 2005, EPA finalized a rule addressing t he court’s remand.

On February 18, 2005, the U.S. Court of Appeals for the D.C. Circuit issued another ruling vacating the Regional Haze Rule in part and sustain ing it in part. For more information see Center for Energy and Economic Development v. EPA , no. 03-1222, (D.C. Cir. Feb. 18, 2005) (“ CEED v. EPA”). In this case, the court granted a petiti on challenging provisions of the Regional Haze Rule governing the optional emissions trading program for certain Western States and Tribes (the WRAP Annex Rule).

In the aftermath of these decisions, EPA’s final ru lemaking incorporated the following changes to the Regional Haze Rule:

• Revised the regulatory text in 40 CFR 51.308(e)(2)( i) in response to the CEED court’s remand, to

− Remove the requirement that the determination of BA RT be based on cumulative visibility analyses, and

− Clarify the process for making such determinations, including the application of BART presumptions for electric generating units (EGUs) as contained in 40 CFR 51, Appendix Y;

• Added new regulatory text in 40 CFR 51.308(e)(2)(vi ) to provide minimum elements for cap-and-trade programs in lieu of BART; and

• Revised regulatory text in 40 CFR 51.309 to reconci le the optional framework for certain Western states and tribes to implement the recommendations of the GCVTC
with the CEED decision.

1.4.2 State Implementation Plan

New Hampshire submits this State Implementation Pla n revision to meet the requirements of EPA’s Regional Haze Rule. To facilitate states’ ef forts, EPA prepared a checklist summarizing the requirements of the final Regional Haze Rule. Attachment A is a copy of the checklist with cross-references to sections of New Hampshire’ s Regional Haze SIP showing how the requirements have been met.

9 MANE-VU includes the following member states: Con necticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhod e Island, Vermont, and the District of Columbia. A more complete description of MANE-VU appears in Section 3 of this SIP.New Hampshire Regional Haze SIP Revision Page 10

New Hampshire’s Regional Haze Plan addresses the co re requirements of 40 CFR 51.308(d) and the BART components of 40 CFR 50.308(e). In additi on, this SIP addresses requirements pertaining to regional planning, and state/tribe an d Federal Land Manager (FLM)
coordination and consultation.

40 CFR 51.308(f) requires the New Hampshire Departm ent of Environmental Services (NHDES) to submit periodic revisions to its Regiona l Haze SIP by July 31, 2018, and every ten years thereafter. NHDES acknowledges and will comply with this schedu le.

40 CFR 51.308(g) requires NHDES to submit a report to EPA every 5 years that evaluates progress toward the reasonable progress goal for ea ch mandatory Class I area located within the state and each mandatory Class I area located o utside the state that may be affected by
emissions from within the state. NHDES will submit the first progress report, in the form of a SIP revision, within 5 years from submittal of th e initial State Implementation Plan, but in no case later than December 31, 2013.

Pursuant to 40 CFR 51.308(d)(4)(v), NHDES will also make periodic updates to the New Hampshire’s emissions inventory (see Section 7, Emissions Inventory). NHDES propo ses to complete these updates to coincide with the prog ress reports.

Lastly, pursuant to 40 CFR 51.308(h), NHDES will submit a determination of adequacy of its regional haze SIP revision whenever a progress report is submitted. Depending on the findings of its five-year review, New Hampshire wil l take one or more of the following actions at that time, whichever actions are appropr iate or necessary:

• If New Hampshire determines that the existing State Implementation Plan requires no
further substantive revision in order to achieve es tablished goals for visibility improvement and emissions reductions, NHDES will pr ovide to the EPA Administrator a negative declaration that further revision of the e xisting plan is not needed.

• If New Hampshire determines that its implementation plan is or may be inadequate to ensure reasonable progress as a result of emissions from sources in one or more other state(s) which participated in the regional plannin g process, New Hampshire will provide notification to the EPA Administrator and t o those other state(s). New Hampshire will also collaborate with the other stat e(s) through the regional planning process, if viable regional organizations exist, fo r the purpose of developing additional strategies to address any such deficiencies in New Hampshire’s plan.

• If New Hampshire determines that its implementation plan is or may be inadequate to ensure reasonable progress as a result of emissions from sources in another country, New Hampshire will provide notification, along with available information, to the
EPA Administrator.

• If New Hampshire determines that its implementation plan is or may be inadequate to ensure reasonable progress as a result of emissions from sources within the state, New Hampshire will revise its implementation plan to ad dress the plan’s deficiencies within one year from this determination.New Hampshire Regional Haze SIP Revision Page 11



### 1.5 New Hampshire’s Class I Areas

In New Hampshire, the U.S. Forest Service manages t wo Class I wilderness areas: the Great Gulf Wilderness and the Presidential Range - Dry Ri ver Wilderness, both located in New Hampshire’s White Mountain National Forest.

These Class I areas flank the northern and southern slopes of the nationally renowned Mt. Washington, in the Presidential Range of the White Mountains (Figure 1.3). Mt. Washington is the highest mountain in the Northeast and attrac ts visitors (who can climb, drive, or ride to its summit) to enjoy expansive views from above tre e line. Any action taken to improve visibility in the adjacent Great Gulf and President ial Range

- Dry River Wilderness Areas will also improve the vistas from the summit of Mt. Washingto n. The White Mountain National Forest is the main tourist attraction in New Hampshire and ranks among the most popular National Forests in the country with over 7 million visitors annually ( source: U.S. Forest Service, http://www.fs.fed.us/r9/forests/white_mountain/abou t/history/index.php ).

Figure 1.3: Mt. Washington from the Southeast at S unrise

The Great Gulf Wilderness and the Presidential Rang e - Dry River Wilderness are two of 156 protected areas designated in 1977 as mandatory fed eral Class I areas for the purposes of the visibility protection program. Each of these areas covers thousands of acres containing high mountain terrain, scenic vistas, and interesting or unique geologic formations and vegetation communities. Many species of wildlife are present, including a number of alpine-zone residents. Among the alpine fauna are the northern bog lemming and two rare butterfly species. Cool, crystal-clear streams, cascades, an d high-elevation ponds are common throughout the two areas, and the region is full of natural woodland. Hardwoods are most abundant on the lower slopes; mixed birches, maples , and spruce-fir dominate the mid-slopes; and spruce-fir are most common on the upper mountai nsides. The unusual low-elevation tree line in the White Mountains of New Hampshire is cau sed by the high winds and harsh conditions this area experiences through the year. The result is a fragile, near-Arctic-tundra vegetation at the higher elevations.

The delicate ecosystems in both wilderness areas ha ve been under stress resulting from years of highly acidic precipitation, which has leached p lant nutrients from the soils and acidified mountain streams and ponds. The damage done by air pollution to Great Gulf and Presidential Range - Dry River Wilderness Areas wil l take decades to repair.New Hampshire Regional Haze SIP Revision Page 12

1.5.1 Great Gulf Wilderness

The Great Gulf Wilderness is located in Greens Gran t in the White Mountain National Forest of northern New Hampshire (Figure 1.4). Occupying the northeastern slopes of the Presidential Range, Great Gulf covers an area of 5, 552 acres and ranges in elevation from 1,680 to 5,807 feet.

Figure 1.4: Location of New Hampshire’s Class I Ar eas

The Great Gulf Wilderness is formed by a high mount ain valley located north-northeast of the Mt. Washington summit (Figures 1.5 and 1.6). The v alley has steep walls rising from 1,100 feet to 1,600 feet above the valley floor. The are a includes many rivulets that drain eastward to the West Fork of the Peabody River. For visitor s, the Great Gulf has 21.3 miles of marked trails, which offer some of the best views of the r idges and summits of the Presidential Range. Great Gulf receives about 20,000 visitors annually.

Figure 1.5: View of Great Gulf Wilderness from Mt. Washington

http://www.penemco.com/matthew/New Hampshire Regional Haze SIP Revision Page 13

Figure 1.6: Views of Great Gulf Wilderness from Lo wer Elevation on Clear (6 deciview) and Hazy (28 deciview) Days

1.5.2 Presidential Range - Dry River Wilderness, Ne w Hampshire

The Presidential Range - Dry River Wilderness is al so located in Greens Grant in the White Mountain National Forest of northern New Hampshire (Figure 1.4); however, at 27,380 acres, it is about five times larger than the Great Gulf W ilderness. Ranging in elevation from 880 to 5,413 feet, the Presidential Range - Dry River Wild erness constitutes a rugged expanse of mountains and valleys lying to the south of Mt. Was hington’s summit. On its western side, the area flanks other peaks in the Presidential Ran ge, including Mt. Eisenhower and Mt. Monroe. The wilderness area extends across and bey ond the central valley of the Dry River to the Saco River, encompassing numerous brooks and smaller, heavily forested mountains (Figure 1.7).

Figure 1.7: Presidential Range - Dry River Wildern ess in Autumn.

http://www.wilderness.net

As the name suggests, the Dry River is almost witho ut water by late summer but swells quickly during heavy rains. There are ten trails i n the wilderness area totaling 46.1 miles in length. Because of its remote location, this area receives fewer visitors than Great Gulf (about 7,000 annually). Its southern portion has almost n o trails, is very steep and rugged, and offers a rare degree of solitude. http://www.wilderness.netNew Hampshire Regional Haze SIP Revision Page 14

1.5.3 Monitoring and Recent Visibility Trends

Visibility monitoring at Great Gulf Wilderness and Presidential Range - Dry River Wilderness is accomplished with instruments located at a singl e site at Camp Dodge. This monitoring station, which represents both wilderness areas, me asures and records light scattering, aerosols, and relative humidity (Table 1.1). The c ollected data are compiled and sorted to ascertain visibility levels on the 20 percent most and least visibility-impaired days, and this
information is tracked over time to look for trends in visibility.

Table 1.1: Visibility Monitoring at Great Gulf and Presidential Range - Dry River
Wilderness Areas

Parameter Instrument
Scattering coefficient Nephelometer

Aerosol IMPROVE module A

Aerosol IMPROVE module B

Aerosol IMPROVE module C

Aerosol IMPROVE module D Meteorology Relative humidity

Figure 1.8 depicts recent visibility trends (in ann ual average deciviews) at Great Gulf Wilderness and Presidential Range - Dry River Wilde rness for the 20 percent most and least visibility-impaired days for each year from 1995 to 2004. The graph also shows the reconstructed natural background level. The differ ence between the 20 percent haziest days and the natural background level shows the magnitud e of the gap that needs to be closed in order to attain the national visibility goal establ ished in the Clean Air Act.

Figure 1.8: Visibility Trends at Great Gulf and Pr esidential Range - Dry River
Wilderness AreasNew Hampshire Regional Haze SIP Revision Page 15

The plotted trend lines serve only as semi-quantita tive indicators of baseline conditions for a
number of reasons:

• As of 1999, there were no complete years of samplin g data for the Great Gulf site; so the trend lines represent only the subset of summer months from May or June through September.

• Since the haziest days typically occur in the warme st months, average deciview values for the 20 percent most visibility-impaired summert ime days would almost certainly be higher than the corresponding value for the year as a whole.

• The short time span of the trend plots (10 years’ w orth of data) makes it impossible to draw definitive conclusions about recent visibility trends in New Hampshire.

Despite these caveats, the trend plots do suggest t he following:

• The 20 percent most visibility-impaired days have v isibility readings in the order of 10 deciviews above the worst natural background level; and

• The 20 percent least visibility-impaired days have visibility readings in the order of 4 deciviews above the best natural background level

.New Hampshire Regional Haze SIP Revision Page 16



### 2. AREAS CONTRIBUTING TO REGIONAL HAZE

40 CFR 51.308I(3) of the Regional Haze Rule require s states to determine their contributions to visibility impairment at mandatory Class I areas . Through source apportionment modeling (more fully described in Section 8, Understanding t he Sources of Visibility-Impairing Pollutants), MANE-VU has identified and evaluated t he major contributors to regional haze at
MANE-VU Class I Areas as well as Class I areas in n earby Regional Planning Organizations (RPOs). The complete findings are contained in a r eport produced by the Northeast States for Coordinated Air Quality Management (NESCAUM) entitl ed, “Contributions to Regional
Haze in the Northeast and Mid-Atlantic United State s,” August 2006, otherwise known as the Contribution Assessment (Attachment B).

The regional modeling performed by MANE-VU included a pollutant tagging scheme to produce a comprehensive assessment of the individua l contributions from 28 nearby states to visibility impairment at the New Hampshire Class I areas and six other nearby Class I areas. The modeling also provided a partial accounting of the contributions from several states along the western and southern edges of the modeling doma in (i.e., boundary conditions) where only a portion of the states’ emissions were tracke d. Modeling was conducted for the base year 2002 and then projected to year 2018, when cur rently anticipated emission control programs would be in place.

Modeling results indicate that the relative contrib utions of states within the modeling domain will decrease significantly by 2018 as a result of anticipated SO 2 emission reductions from implementation of existing state programs, applicab le portions of the federal Clean Air Interstate Rule (CAIR), and additional state and fe deral control measures described in following sections of this document. At the same t ime, there will be large increases in the
relative contributions from Canada and the boundary areas. These predicted increases are not absolute increases in mass but are due simply to th e fact that contributions from outside the modeling domain will represent a larger share of th e total after the various emission control programs within the U.S. portion of the modeling do main have reduced contributions from
within the domain.

It is noteworthy that projected SO 2 reductions from emission sources in New Hampshire are on pace with states enrolled in the CAIR program ev en though New Hampshire is not included in this program. As do many other states, New Hampshire has its own program for reducing SO 2 emissions.

According to the completed MANE-VU modeling, sulfat e concentrations at the Great Gulf and Presidential Range - Dry River Wilderness Areas on the 20 percent worst visibility days will decline from 7.3 μg/m 3 in 2002 (representing the baseline period of 2000- 2004) to 4.6 μg/m 3 in 2018. Included in these values is New Hampshire’s own sulfate contribution, which is projected to drop from 0.4 μg/m 3 in 2002 to 0.3 μg/m 3 in 2018. Mirroring the results for sulfate, fine particulate matter (PM 2.5 ) concentrations from all sources are projected to fall by a similar percentage, from 12.5 μg/m 3 in 2002 to 9.2 μg/m 3 in 2018. The modeling that produced these results is described in Section 7, Air Quality Mode ling, and in “2018 Visibility Projections,” May 13, 2008 (Attachment Q). The emission control programs responsible for the projected visibility improvements are described in Section 11 , Long-Term Strategy.

Figure 2.1 shows the magnitude of the 2002 (measure d) and 2018 (projected) sulfate
concentrations at the Great Gulf and Presidential R ange - Dry River Wilderness Areas, as well as the relative mass contributions of each state, o n the 20 percent worst visibility days. Similar findings apply to the other Class I areas ( graphical figures for these other sites are available in the Contribution Assessment but, for b revity, are not repeated here).New Hampshire Regional Haze SIP Revision Page 17

Figure 2.1: Measured and Projected Mass Contributi ons in 2002 and 2018 at Great Gulf and Presidential Range

- Dry River Wilderness Areas on 20 Percent Worst Visi bility Days



### 2.1 Class I Areas Affected by New Hampshire’s Emiss ion Sources

Emission sources within New Hampshire have had meas urable impacts on visibility at Class I
areas both within the state and at downwind locatio ns. The magnitude of these impacts is
described in detail in MANE-VU’s Contribution Asses sment (Attachment B). Table 2.1 briefly lists the affected Class I areas and New Ha mpshire’s percent contribution to total annual sulfate at each area in the 2002 baseline ye ar, as determined from the modeling.

Table 2.1: New Hampshire’s Contributions to Total Annual Average Sulfate Impact

(Percent, Mass Basis) at Eastern Class I Areas in 2 002

Mandatory Class I Area(s) Percent Contribution

Great Gulf Wilderness* & Presidential Range - Dry R iver Wilderness* 3.95

Acadia National Park* 2.25 Moosehorn Wilderness* & Roosevelt Campobello Intern ational Park* 1.74 Lye Brook Wilderness* 1.68 Brigantine Wilderness* 0.60

Shenandoah National Park 0.08 Dolly Sods Wilderness 0.04

*MANE-VU Class I AreaNew Hampshire Regional Haze SIP Revision Page 18

Interestingly, New Hampshire’s own SO 2 emissions account for only about 4 percent of visibility-impairing sulfate in New Hampshire’s Cla ss I Areas and approximately 2 percent of visibility-impairing sulfate in the downwind Class I areas of Acadia National Park, Moosehorn Wilderness, Roosevelt Campobello Internat ional Park, and Lye Brook Wilderness. Also, New Hampshire’s emissions accoun t for less than 1 percent of visibilityimpairing sulfate in the more southerly Class I are as of Brigantine Wilderness, Shenandoah National Park, and Dolly Sods Wilderness.



### 2.2 States Contributing to Visibility Impairment in New Hampshire’s Class I Areas

Through participation in the MANE-VU regional haze planning process, New Hampshire has identified the states and Canadian provinces contri buting to visibility impairment at New Hampshire’s two Class I areas: the Great Gulf Wilde rness and the Presidential Range - Dry
River Wilderness. Table 2.2 lists the states and r egions responsible for visibility degradation at these Class I areas, and the corresponding perce ntage contributions to total sulfate impact. Taken from MANE-VU’s Contribution Assessment, the d ata provide clear evidence that the large majority of sulfate pollution at New Hampshir e’s Class I areas originates from sources outside the state and, more significantly, from sou rces outside the MANE-VU region. Note that “other” sources contribute nearly a quarter of the total sulfate impact. These sources represent all emissions from outside the modeling d omain (i.e., boundary conditions, including emissions coming primarily from regions l ying west of the Mississippi River).

Table 2.2: Contributions of Individual MANE-VU Sta tes and Other Regions to Total Annual Average Sulfate Impact (Percent, Mass Basis) at New Hampshire’s Class I
Areas in 2002

State or Region Percent

Contribution

Pennsylvania 8.30

New York 5.68 New Hampshire 3.95

Massachusetts 3.11

Maine 2.33 Maryland 1.92 New Jersey 0.89

Delaware 0.63

Connecticut 0.48

Vermont 0.41

Rhode Island 0.11

District of Columbia 0.01

MANE-VU 27.83

MRPO 20.10

VISTAS 12.04

CenRAP 1.65

Canada 14.84

Other 23.54 Note: Indicated percent contributions from, VISTAS, CenRAP, and Canada apply only to those portions lying within the modeling domain (see Figure 7.1). Actual contributions, especially from CenRAP, would be higher than stated.New Hampshire Regional Haze SIP Revision Page 19



### 3. REGIONAL PLANNING AND CONSULTATION

In 1999, EPA and affected states/tribes agreed to c reate five Regional Planning Organizations (RPOs) to facilitate interstate coordination on Sta te Implementation Plans (SIPs) addressing regional haze. The RPOs, and states/tribes within each RPO, are required to consult on emission management strategies toward visibility im provement in affected Class I areas. As shown in the accompanying map (Figure 3.1), the fiv e RPOs are MANE-VU (MidAtlantic/Northeast Visibility Union), VISTAS (Visib ility Improvement State and Tribal Association of the Southeast), MRPO (Midwest Region al Planning Organization), CenRAP (Central Regional Air Planning Association), and WR AP (Western Regional Air Partnership). New Hampshire is a member of MANE-VU.

Figure 3.1: EPA-Designated Regional Planning Organ izations (RPOs).



### 3.1 Mid-Atlantic / Northeast Visibility Union (MANE -VU)

MANE-VU’s work is managed by the Ozone Transport Co mmission (OTC) and carried out by OTC, the Mid-Atlantic Regional Air Management As sociation (MARAMA), and the Northeast States for Coordinated Air Use Management (NESCAUM). The states, tribes, and federal agencies comprising MANE-VU are listed in T able 3.1. Individuals from the member states, tribes, and agencies, along with profession al staff from OTC, MARAMA, and NESCAUM, make up the various committees and workgro ups. MANE-VU also established a Policy Advisory Group (PAG) to provide advice to de cision-makers on policy questions. EPA, Federal Land Managers, states, and tribes are represented on the PAG, which meets on
an as-needed basis.New Hampshire Regional Haze SIP Revision Page 20

Table 3.1: MANE-VU Members

Connecticut Rhode Island

Delaware Vermont

Maine District of Columbia Maryland Penobscot Nation Massachusetts St. Regis Mohawk Tribe New Hampshire U.S. Environmental Protection Agency * New Jersey U.S. Fish and Wildlife Service*

New York U.S. Forest Service* Pennsylvania U.S. National Park Service*

*Non-voting member

Since its inception on July 24, 2001, MANE-VU has c reated an active committee structure to
address both technical and non-technical issues rel ated to regional haze. The primary committees are the Technical Support Committee (TSC ) and the Communications Committee,
While the work of these committees are instrumental to policies and programs, all policy decisions reside with and are made by the MANE-VU B oard.

The TSC is charged with assessing the nature and ma gnitude of the regional haze problem within MANE-VU, interpreting the results of technic al work, and reporting on such work to
the MANE-VU Board. This committee has evolved to f unction as a valuable resource on all technical projects and issues for MANE-VU. The TSC has established a process to ensure that important regional-haze-related projects are c ompleted in a timely fashion, and members are kept informed of all MANE-VU tasks and duties. In addition to the formal working committees, there are three standing workgroups of the TSC assigned by topic area: the Emissions Inventory Workgroup, the Modeling Workgroup, and th e Monitoring/Data Analysis Workgroup.

The Communications Committee is charged with develo ping approaches to inform the public about the regional haze problem and making recommen dations to the MANE-VU Board to facilitate that goal. This committee oversees the production of MANE-VU’s newsletter and outreach tools, both for stakeholders and the publi c, regarding regional issues affecting
MANE-VU’s members.



### 3.2 Regional Consultation and the “Ask”

On May 10, 2006, MANE-VU adopted the Inter-RPO Stat e/Tribal and FLM Consultation Framework (Attachment C). That document set forth the principles presented in Table 3.2. The MANE-VU states and tribes applied these princip les to the regional haze consultation and SIP development process. Issues addressed included regional haze baseline assessments, natural background levels, and development of reaso nable progress goals – described at length in later sections of this SIP.New Hampshire Regional Haze SIP Revision Page 21

Table 3.2: MANE-VU Consultation Principles for Reg ional Haze Planning

1. All State, Tribal, RPO, and Federal participants ar e committed to continuing dialogue and information sharing in order to create understandin g of the respective concerns and needs of the parties.

2. Continuous documentation of all communications is n ecessary to develop a record for inclusion
in the SIP submittal to EPA.

3. States alone have the authority to undertake specif ic measures under their SIP. This inter-RPO framework is designed solely to facilitate needed c ommunication, coordination and cooperation among jurisdictions but does not establish binding obligation on the part of participating agencies.

4. There are two areas which require State-to-State an d/or State-to-Tribal consultations (“formal” consultations): (i) development of the reasonable p rogress goal for a Class I area, and (ii) development of long-term strategies. While it is a nticipated that the formal consultation will cover the technical components that make up each of these policy decision areas, there may be a need for the RPOs, in coordination with their Sta te and Tribal members, to have informal
consultations on these technical considerations.

5. During both the formal and informal inter-RPO consu ltations, it is anticipated that the States and Tribes will work collectively to facilitate the consultation process through their respective RPOs, when feasible.

6. Technical analyses will be transparent, when possib le, and will reflect the most up-to-date
information and best scientific methods for the dec ision needed within the resources available.

7. The State with the Class I area retains the respons ibility to establish reasonable progress goals.
The RPOs will make reasonable efforts to facilitate the development of a consensus among the
State with a Class I area and other States affectin g that area. In instances where the State with the Class I area can not agree with such other Stat es that the goal provides for reasonable progress, actions taken to resolve the disagreement must be included in the State’s regional haze implementation plan (or plan revisions) submit ted to the EPA Administrator as required under 40 CFR §51.308(d)(1)(iv).

8. All States whose emissions are reasonably anticipat ed to contribute to visibility impairment in a Class I area, must provide the Federal Land Manager (“FLM”) agency for that Class I area with an opportunity for consultation, in person, on thei r regional haze implementation plans. The States/Tribes will pursue the development of a memo randum of understanding to expedite the
submission and consideration of the FLMs’ comments on the reasonable progress goals and related implementation plans. As required under 40 CFR §51.308(i)(3), the plan or plan revision must include a description of how the Stat e addressed any FLM comments.

9. States/Tribes will consult with the affected FLMs t o protect the air resources of the State/Tribe
and Class I areas in accordance with the FLM coordi nation requirements specified in 40 CFR §51.308(i) and other consultation procedures develo ped by consensus.

10. The consultation process is designed to share infor mation, define and document issues, develop a range of options, solicit feedback on options, de velop consensus advice if possible, and facilitate informed decisions by the Class I States

.
11. The collaborators, including States, Tribes and aff ected FLMs, will promptly respond to other RPOs’/States’/Tribes’ requests for comments.New Hampshire Regional Haze SIP Revision Page 22

The following points offer a snapshot of several im portant ways in which MANE-VU member states and tribes have cooperatively address ed regional haze:

• Prioritization : MANE-VU developed a process to coordinate MARAMA, OTC, and NESCAUM staff in developing budget priorities, proj ect rankings, and the eventual federal grant requests.

• Issue Coordination : MANE-VU established a conference call and meetin g schedule for each of its committees and workgroups. In addi tion, its MANE-VU directors regularly discussed pertinent issues.

• SIP Policy and Planning : MANE-VU states/tribes collaborated on the develo pment of a regional haze SIP template and the technical aspe cts of the SIP development process.

• Capacity Building : To educate its staff and members, MANE-VU includ ed technical presentations on conference calls and organized wor kshops with nationally recognized experts. Presentations on data analysis, Best Avai lable Retrofit Technology (BART) applicability, inventory topics, modeling, and cont rol measures were effective education
and coordination tools.

• Routine Operations : MANE-VU staff at OTC, MARAMA, and NESCAUM establ ished a coordinated approach to budget tracking, project deliverables and due dates, workgroup meetings, inter-RPO consultations, etc.

Both formal and informal consultations within MANE- VU have been ongoing since the organization’s establishment in 2001; but the bulk of formal consultation took place in 2007,
as outlined in Table 3.3. Further documentation of consultation meetings and calls is included
in Attachment D.New Hampshire Regional Haze SIP Revision Page 23

Table 3.3: Summary of MANE-VU’s Consultations on R egional Haze Planning

1.1.7 New Hampshire’s Consultations

40 CFR Section 51.308(d)(3)(i) requires the State o f New Hampshire to consult with other states/tribes to develop coordinated emission manag ement strategies. This requirement applies both when emissions from a state/tribe are reasonably anticipated to contribute to visibility impairment in Class I areas outside the state/tribe and when emissions from other states/tribes are reasonably anticipated to contrib ute to visibility impairment at mandatory
Class I areas within a state/tribe.

New Hampshire consulted with other states/tribes by participating in the MANE-VU and inter-RPO processes leading to the creation of coor dinated strategies on regional haze. This coordinated effort considered the individual and ag gregated impacts of states’/tribes’
emissions on Class I areas within and outside the s tates/tribes.

As described in Section 2.0, Areas Contributing to Regional Haze, emissions originating in New Hampshire have had, and will continue to have, impacts on other Class I areas in the region. Accordingly, New Hampshire has entered int o consultations with the states and provinces in which the affected Class I areas are l ocated (Table 2.1).

Table 2.1: Class I Areas States Requesting Consult ation with New Hampshire

Class I Federal Area State / Province Great Gulf Wilderness New Hampshire Presidential Range Dry River Wilderness New Hamps hire

Acadia National Park Maine

Moosehorn Wilderness Maine Roosevelt Campobello International Park Maine / N ew Brunswick Lye Brook Wilderness Vermont Brigantine Wilderness New Jersey

The listed states represent only a fraction of thos e with whom New Hampshire has entered into consultations on regional haze. Through the M ANE-VU process, more than twenty states and Canadian provinces have been identified as cont ributing to visibility degradation in New Hampshire’s two Class I areas: the Great Gulf Wilde rness and the Presidential Range - Dry River Wilderness. On April 2, 2007, NHDES sent let ters formally requesting consultation under the Regional Haze Rule to states and Canadian provinces – specifically, those shown via modeling to contribute at least 2 percent of vi sibility-impairing sulfates at Class I Areas in New Hampshire (refer to the Contribution Assessment , Attachment B), and all other states
located within MANE-VU MANE-VU Intra-Regional Consultation Meeting, March 1, 2007:

MANE-VU members reviewed the requirements for regio nal haze plans, preliminary modeling results, the work being done to prepare the MANE-VU report o n reasonable progress factors, and control strategy options under review.

MANE-VU Intra-State Consultation Meeting, June 7, 2 007:

The MANE-VU Class I states adopted a statement of p rinciples, and all MANE-VU members discussed draft statements concerning reasonable controls wit hin and outside of MANE-VU. Federal Land Managers also attended the meeting, which was open to stakeholders.

MANE-VU Conference Call, June 20, 2007:

The MANE-VU states concluded discussions of stateme nts concerning reasonable controls within and outside MANE-VU and agreed on the statements called the MANE-VU “Ask” (see Part 3.2.2 of this SIP), including a statement concerning controls wit hin MANE-VU, a statement concerning controls outside MANE-VU, and a statement requesting a cours e of action by the U.S. EPA. Federal Land Managers also participated in the call. Upon appro val, all statements as well as the statement of principles adopted on June 7 were posted and public ly available on the MANE-VU website. The MANE-VU Ask was determined to represent New Hampshi re’s needs for meeting Regional Haze rule requirements and was thus adopted as the New Hampsh ire Ask.

MANE-VU Class I States’ Consultation Open Technical Call, July 19, 2007:

The MANE-VU/New Hampshire Ask was presented to stat es in other RPOs, RPO staff, and Federal Land Managers; and an opportunity was provided to r equest further information. This call was intended to provide information to facilitate informed discu ssion at follow-up meetings.

MANE-VU Consultation Meeting with MRPO, August 6, 2 007:

This meeting, held at LADCO offices in Chicago, was attended by representatives of MANE-VU and MRPO states as well as staff. The meeting provided an opportunity to formally present the MANE-VU/ New Hampshire Ask to MRPO states and to consult wit h them on the reasonableness of the requested controls. Federal Land Manager agencies also atten ded the meeting.

MANE-VU Consultation Meeting with VISTAS, August 20 , 2007:

This meeting, held at State of Georgia offices in A tlanta, was attended by representatives of MANE-VU and VISTAS states. The meeting provided an opportu nity to formally present the MANE-VU/New Hampshire Ask to VISTAS states and to consult with them on the reasonableness of the requested controls. Federal Land Manager agencies also atten ded the meeting.

MANE-VU / MRPO Consultation Conference Call, Septem ber 13, 2007:

As a follow-up to the meeting held on August 6 in C hicago, this call provided an opportunity for MANE-VU to clarify further what was being asked of the MRPO states. The flexibility in the Ask was explained. MRPO and MANE-VU staff agreed to work t ogether to facilitate discussion of further
controls on ICI boilers and EGUs.

MANE-VU Air Directors’ Consultation Conference Call , September 26, 2007:

MANE-VU members clarified their understanding of th e Ask and provided direction to modeling staff regarding interpretation of the Ask for purposes of estimating visibility impacts of the requested con trols.New Hampshire Regional Haze SIP Revision Page 24

3.2.1 New Hampshire-Specific Consultations

40 CFR 51.308(d)(3)(i) of the Regional Haze Rule r equires the State of New Hampshire to consult with other states/tribes to develop coordin ated emission management strategies. This requirement applies both when emissions from a stat e/tribe are reasonably anticipated to contribute to visibility impairment in Class I area s outside the state/tribe and when emissions from other states/tribes are reasonably anticipated to contribute to visibility impairment at mandatory Class I areas within a state/tribe.

New Hampshire consulted with other states/tribes by participating in the MANE-VU and inter-RPO processes leading to the creation of coor dinated strategies on regional haze. This coordinated effort considered the individual and ag gregated impacts of states’/tribes’
emissions on Class I areas within and outside the s tates/tribes.

As described in Section 2, Areas Contributing to Re gional Haze, emissions originating in New Hampshire have had, and will continue to have, impacts on other Class I areas in the region. Accordingly, New Hampshire has entered int o consultations with the states and provinces in which the affected Class I areas are l ocated (Table 3.4).

Table 3.4: Class I Area States Requesting Consulta tion with New Hampshire

Class I Federal Area State / Province
Great Gulf Wilderness New Hampshire
Presidential Range - Dry River Wilderness New Ham pshire

Acadia National Park Maine

Moosehorn Wilderness Maine Roosevelt Campobello International Park Maine / N ew Brunswick Lye Brook Wilderness Vermont Brigantine Wilderness New Jersey

The listed states represent only a fraction of thos e with whom New Hampshire has entered into consultations on regional haze. Through the M ANE-VU process, more than twenty states and Canadian provinces have been identified as cont ributing to visibility degradation in New Hampshire’s two Class I areas: the Great Gulf Wilde rness and the Presidential Range - Dry River Wilderness. On April 2, 2007, NHDES sent let ters formally requesting consultation under the Regional Haze Rule to states and Canadian provinces – specifically, those shown via modeling to contribute at least 2 percent of vi sibility-impairing sulfates at Class I Areas in New Hampshire (refer to Contribution Assessment, At tachment B), and all other states located
within MANE-VU.

To maintain consistency within MANE-VU, every MANE- VU member was requested to consult with New Hampshire. Several states outside MANE-VU were also requested to join this consultation in response to the findings of MA NE-VU’s evaluations. In addition, the Canadian Provinces of Ontario and Quebec were invit ed to join in informal consultation with New Hampshire, although they are under no legal obl igation to meet U.S. requirements. Table 3.5 provides a complete listing of states, pr ovinces, and regional planning organizations invited to participate in consultations with New Ha mpshire on measures to mitigate regional
haze. Note that all MANE-VU states with Class I ar eas have similarly requested consultation with New Hampshire on the regional haze issue.New Hampshire Regional Haze SIP Revision Page 25

Table 3.5: States (Listed by Regional Planning Org anization) and Provinces Contributing to Visibility Impairment at New Hampsh ire’s Class I Areas

MANE-VU VISTAS MRPO International
Connecticut Georgia Illinois Ontario, Canada Delaware Kentucky Indiana Quebec, Canada District of Columbia North Carolina Michigan

Maine South Carolina Ohio Maryland Tennessee Massachusetts Virginia New Jersey West Virginia

New York Pennsylvania

Rhode Island

Vermont

As a result of the invitation to consult, Ontario, Canada, invited representatives of NHDES, Vermont Department of Environmental Conservation (V TDEC), Maine Department of Environmental Protection (MEDEP), New York Departme nt of Environmental Conservation (NYDEC), and NESCAUM to join the Shared Air Summit in Toronto on June 12, 2007, followed by an informal consultation meeting with r epresentatives from Ontario on June 13, 2007. At these meetings, Ontario announced its pla n to shut down all coal electrical generation and challenged participating states to pursue simil ar goals. Considerable discussion took place regarding trans-border air pollution transpor t and its affect on human health.

Formal inter-regional consultation meetings took pl ace on August 6, 2007, in Rosemont, Illinois, (for Midwestern states) and on August 20, 2007, in Atlanta, Georgia, (for Southern states). Consultation continues with the Midwester n states, seeking common approaches for reducing power plant emissions beyond the levels de fined under the original CAIR rule, controls on industrial boilers, and cleaner-burning fuels for mobile sources. Ongoing consultation with MRPO focuses mainly on the health benefits of reducing ozone and small particulate emissions; however, the control measure s being considered would also result in visibility improvements.

Throughout the consultation process, New Hampshire was guided by the principals contained in a resolution adopted by the MANE-VU Class I stat es on June 7, 2007. In the resolution, the Class I states agreed to set reasonable progres s goals for 2018 that would provide visibility improvement at least as great as that which would b e achieved under a uniform rate of progress to reach natural visibility conditions by 2064. The goals would be set by the Class I states at levels reflecting implementation of measu res determined to be reasonable after consultation with the contributing states. At the same time, the Class I states recognized that each state should be given the flexibility to choos e other measures that achieve the same or greater benefits.

The final results of New Hampshire’s consultation e fforts will ultimately rest with the individual states as they develop and implement the ir own regional haze SIPs. The other MANE-VU states have agreed to incorporate certain c ontrol measures into their SIPs, but most of these plans are still under development. F or the non-MANE-VU states, New Hampshire has the expectation that the same or equi valent control measures will be included in those states plans. However, some states – part icularly those within the VISTAS region –New Hampshire Regional Haze SIP Revision Page 26

have already submitted draft SIPs that do not go as far in controlling emissions as MANE-VU would like. See Subpart 3.2.2.3 and Part 3.2.4, be low, for further discussion related to the

non-MANE-VU states.

3.2.2 The MANE-VU “Ask”

In addition to having a set of guiding principles f or consultation (as described in Table 3.2, above), MANE-VU needed a consistent technical basis for emission control strategies to combat regional haze. After much research and anal ysis, on June 20, 2007, MANE-VU adopted the following pair of documents (available in Attachment E), which provide the technical basis for consultation among the interest ed parties and define the basic strategies for controlling pollutants that cause visibility impair ment at Class I areas in the eastern U.S.:

• “Statement of the Mid-Atlantic / Northeast Visibili ty Union (MANE-VU) Concerning a Course of Action within MANE-VU toward Assuring Rea sonable Progress,” and

• “Statement of the Mid-Atlantic / Northeast Visibili ty Union (MANE-VU) Concerning a Request for a Course of Action by States outside of MANE-VU toward Assuring Reasonable Progress. ”

Together, these documents are known as the MANE-VU “ Ask .” Because New Hampshire agrees in total to the language and substance of th ese documents, the MANE-VU’s Ask is also the New Hampshire Ask . The particular emission management strategies th at comprise the Ask are described in Subparts 3.2.2.1 through 3 .2.2.3, below.

3.2.2.1 Meeting the “Ask” – MANE-VU States

The member states of MANE-VU have stated their inte ntion to meet the terms of the Ask in their individual State Implementation Plans. The A sk for member states promises that each state will pursue the adoption and implementation o f the following emission management strategies, as appropriate and necessary:

• Timely implementation of BART requirements , in accordance with 40 CFR 51.308(e).

• A low-sulfur fuel oil strategy in the inner zone st ates (New Jersey, New York, Delaware and Pennsylvania, or portions thereof) to reduce the sulfur content of: distillate oil to 0.05% sulfur by weight (500 ppm) by no later than 2012, of #4 residual oil to 0.25% sulfur by weight by no later than 2012 , of #6 residual oil to 0.3-0.5% sulfur by weight by no later than 2012, and to redu ce the sulfur content of distillate oil further to 15 ppm by 2016;

• A low-sulfur fuel oil strategy in the outer zone st ates (the remainder of the MANEVU region) to reduce the sulfur content of distilla te oil to 0.05% sulfur by weight (500 ppm) by no later than 2014, of #4 residual oil to 0 .25-0.5% sulfur by weight by no later than 2018, and of #6 residual oil to no great er than 0.5 % sulfur by weight by no later than 2018, and to reduce the sulfur content o f distillate oil further to 15 ppm by 2018, depending on supply availability;

• A targeted EGU strategy for the top 100 electric generating unit (EGU) emis sion points, or stacks, identified by MANE-VU as contrib uting to visibility impairment at each mandatory Class I area in the MANE-VU region. (The combined list for allNew Hampshire Regional Haze SIP Revision Page 27

seven MANE-VU Class I Areas contains 167 distinct e mission points. Consequently, this strategy is sometimes referred to as the 167-s tack strategy.) The targeted EGU strategy calls for a 90-percent or greater reductio n in sulfur dioxide (SO 2 ) emissions
from all identified units. If it is infeasible to achieve that level of reduction from these specific units, equivalent alternative measures wil l be investigated in such state; and

• Continued evaluation of other control measures , including improvements in energy efficiency, use of alternative (clean) fuels, furth er control measures to reduce SO 2 and nitrogen oxide (NO X ) emissions from all coal-burning facilities by 201 8, and new source performance standards for wood combustion. These and other measures will be evaluated during the consultation process to det ermine whether they are reasonable strategies to pursue.

 NHDES supports the SIPs of each of its fellow MANE- VU states, provided that these commitments are incorporated into approvable State Implementation Plans.

3.2.2.2 Meeting the “Ask” – New Hampshire

New Hampshire, being a MANE-VU member state, adopte d the Ask at the MANE-VU Board meeting on June 7, 2007. New Hampshire intends to meet the terms of this agreement by controlling its two in-state BART-eligible sources with timely control strategies as well as pursuing the low-sulfur fuel oil strategy. Both BA RT-eligible sources also fall on the list of the top 167 contributing EGU emission points.

The larger of these facilities (Merrimack Station U nit MK2) will be controlled with scrubber technology by 2013 to comply with New Hampshire law . The other facility, a smaller, oilfired unit (Newington Station Unit NT1), will contr ol fuel sulfur levels under BART requirements to reduce SO 2 emissions. NHDES has determined that controlling the latter facility to the 90-percent level of the Ask is not reasonable at this time and will seek alternative measures to achieve the equivalent overall reductio n in SO 2 emissions. The facility has low utilization (about 5 percent in 2007), making it co st-ineffective to retrofit with scrubber technology. NHDES anticipates that controls instal led at Merrimack Station, the largest SO 2 source within the state, will result in reductions greater than the 90 percent specified under the Ask, thereby offsetting, at least partially, the ex pected lesser control level at the oil-fired unit.
Additional reductions in SO 2 emissions are planned through the use of lower-sul fur fuels across a variety of source categories, including in dustrial, commercial, and institutional (ICI) boilers and home heating units. For more details, refer to Section 11, Long-Term Strategy.

3.2.2.3 Meeting the “Ask” – States outside MANE-VU

New Hampshire agrees with the MANE-VU Ask for consu lting states outside the MANE-VU region. This Ask requests the affected states to p ursue adoption and implementation of the following control strategies, as appropriate and ne cessary:

• Timely implementation of BART requirements , as described for the MANE-VU

states;

• A targeted EGU strategy , as described for the MANE-VU states, for the top 167 EGU stacks contributing the most to visibility impairme nt at mandatory Class I areas in the MANE-VU region, or an equivalent SO 2 emission reduction within each state;New Hampshire Regional Haze SIP Revision Page 28

• Installation of reasonable control measures on non- EGU sources by 2018 to achieve an additional 28 percent reduction in non-EGU SO 2 emissions beyond current on-thebooks/on-the-way (OTB/OTW) measures, resulting in a n emission reduction that is equivalent to that from MANE-VU’s low-sulfur fuel o il strategy (see Section 11, Long-Term Strategy);

• Continued evaluation of other control measures , including additional reductions in

SO 2 and NO X emissions from all coal-burning facilities by 2018 and promulgation of new source performance standards for wood combustio n. These and other measures will be evaluated during the consultation process t o determine whether they are reasonable strategies to pursue.

 NHDES looks for each consulting state to address sp ecifically, in its Regional Haze SIP, each element of the MANE-VU Ask.

NHDES is concerned that non-MANE-VU states may be i nclined not to adopt MANE-VU’s Ask because of the associated costs, potential conf licts, and relative lack of perceived benefits within their jurisdictions. On the basis of consul tations held, MANE-VU members believe that some non-MANE-VU states will choose not to pur sue reductions beyond CAIR controls and other measures pertaining to BART requirements. New Hampshire understands that, among non-MANE-VU states that have already submitte d their regional haze SIPs to EPA, a
number of the affected states have decided not to a ddress major elements of the MANE-VU Ask in their plans.

There are some positive developments, however. Man y states of the MRPO are working with MANE-VU states to investigate the potential for wid espread use of low-sulfur fuel oil and
installation of emission controls on ICI boilers wi thin their region. The Midwest states would be more likely than Southeast states to adopt a low -sulfur oil strategy because the VISTAS states do not have the same extent of fuel oil usag e and lack the inventory infrastructure found in more northerly states. Both MRPO and VISTAS cla im that a substantial portion of the top 167 contributing EGU stacks will be controlled. Ho wever, instead of taking concrete actions on uncontrolled or under-controlled facilities, many o f these states appear to be satisfied with meeting CAIR-equivalent requirements and not lookin g beyond this level of emission controls for
additional emission reductions. Further discussion of these issues is provided in Part 3.2.4, below.

3.2.3 Technical Ramifications of Differing Approach es

MANE-VU states intended to develop a modeling platf orm that was common in terms of meteorology and emissions with each of the other ne arby RPOs. The RPOs worked hard to form a common set of emissions with similar develop mental assumptions. Even with the best of intentions, it became difficult to keep up with each RPO’s updates and corrections. Each rendition of emissions inventory improved its quali ty, but even a single update to one RPO’s emissions required each of the other RPOs to adopt the updates. With each rendition, the
revised emissions had to be re-blended with the ful l set of emission files for all associated RPOs in the modeling domain. Because each renditio n put previous modeling efforts out of date, and a single modeling run could take more tha n a month to complete, inventory updates have contributed to SIP delays. The emission inven tory conflicts have been excessively timeconsuming and caused most states to miss the offici al filing date of December 17, 2007.New Hampshire Regional Haze SIP Revision Page 29

The RPOs also took differing perspectives on which version of the EGU dispatching model to use. At the beginning of the process, Internationa l’s Integrated Planning Model (IPM®) version 2.1.9 was available, and EPA agreed to its use for emissions preparation. Subsequently, IPM version 3.0 became available and was preferred by s ome users because of its updated fuel costs. MRPO adopted IPM v3.0 for its use, but VIST AS stayed with IPM v2.1.9. Rather than develop non-comparative datasets for its previous I PM analyses, MANE-VU opted also to remain with IPM v2.1.9. Therefore, for the three e astern RPOs, differing emissions assumptions eventually worked their way into the fi nal set of modeling assumptions.

MANE-VU’s most recent visibility projections take i nto account on-the-books/on-the-way (OTB/OTW) emissions control programs for 2018, and go further by including additional reasonable controls in the region, as developed thr ough the MANE-VU Ask. It should be noted that other RPOs may not have included such me asures in their final modeling and, as a result, may have been able to complete their analys es ahead of New Hampshire’s. Where that is the case, those states’ modeling results will be inconsistent with meeting the terms of the Ask – a situation that may not be adequately addres sed in their individual SIPs.

3.2.4 Consultation Issues

40 CFR 51.308(d)(1)(iv) of the Regional Haze Rule d escribes another consultation requirement for Class I states. If a contributing state does not agree with a Class I state on its reasonable progress goal, the Class I state must de scribe in its SIP submittal the actions taken to resolve the disagreement.

While states without Class I areas are required to consult at the request of states with Class I areas, the Regional Haze Rule does not actually req uire the states to agree on a common course of action. Instead, if agreement cannot be reached, the disagreement needs to be described in each state’s SIP along with a descript ion of what actions were taken to resolve the disagreement. Most states willingly consulted with NHDES and took New Hampshire’s regional haze Ask under serious consideration. In fact, all of the MANE-VU states worked together to strategize on how to develop a common a pproach to meeting the Ask. All states involved in these discussions found that working to gether helped them to develop plans that would produce region-wide visibility and health ben efits. In particular, reductions in SO 2 emissions, because they would yield lower ambient c oncentrations of fine particle (PM 2.5 ) pollution, would help all MANE-VU states in meeting the NAAQS and would have direct benefits to public health and welfare.

A few non-MANE-VU states did not respond to New Ham pshire’s consultation requests or responded by downplaying the magnitude of their sta tes’ contributions to visibility impairment at New Hampshire’s Class I areas. Some states claimed that CAIR alone set the standard for reasonableness. By this rationale, an y measure more expensive than CAIR on a cost-per-ton basis would not be reasonable. A unif orm rate of progress was all that some states felt was required; and if that set of condit ions could be met with CAIR, then no other
measures needed to be considered. Also a concern f or New Hampshire is the possibility that some states may have performed modeling for establi shment of reasonable progress goals without including the effects of a rigorous BART de termination for the non-EGU sector. It is apparent that the various regions of the country ha ve differing interpretations of how the Regional Haze Rule should be applied.New Hampshire Regional Haze SIP Revision Page 30

In a letter to MANE-VU dated April 25, 2008 (Attach ment F), VISTAS indicated that for its member states, most actions exceeding CAIR requirem ents would not be reasonable. MANEVU has taken a more rigorous position with respect to additional control measures – including
the belief that controls on ICI boilers and use of low-sulfur fuels are reasonable measures and
that it is not reasonable to assume reductions from EGUs for planning purposes unless they are explicitly incorporated into a State Implementa tion Plan. More specifically, MANE-VU believes that a sector-wide average of 50-percent c ontrol on coal-fired boilers and 75-percent control on oil-fired boilers are reasonable targets that can be achieved cost-effectively. Also, MANE-VU believes that low sulfur fuels – even thoug h they are less widely available in the Southeast U.S. than in the Northeast – still repres ent a reasonable control measure in light of the widespread requirement for use of such fuels th roughout the MANE-VU region. The
reasonableness of these additional controls is exam ined more fully in Section 10, Reasonable Progress Goals.

During the consultation process, disagreements such as these were worked through to the maximum extent possible, and the results of these c onsultations are summarized below:

• Situation : BART analyses and projected controls were not fu lly incorporated into the VISTAS emissions inventory provided to MANE-VU. VI STAS stated that they would further review BART-applicable controls.

→ Outcome : In MANE-VU’s modeling to determine reasonable pr ogress goals, MANE-VU made no adjustments to controls in the VIST AS region to reflect application of BART beyond the information that VIS TAS provided.

• Situation : The low-sulfur fuel oil strategy adopted by MANE -VU elicited concerns from MRPO and VISTAS as not being reasonable becaus e of the limited availability of low-sulfur fuel oil and the historically lower u sage of this fuel within their regions.

→ Outcome : MANE-VU agreed to modify the Ask to reflect grea ter flexibility in providing for alternative measures that would produ ce a comparable rate of emission reductions. Accordingly, the Ask for non- MANE-VU states was modified to provide for an overall 28 percent reduc tion in SO 2 emissions wherever they were found to be reasonable. In MANE-VU’s mod eling to determine reasonable progress goals, SO 2 emissions from non-EGU sources in non-MANEVU contributing states were reduced by this same am ount.

• Situation : MANE-VU received no response from other RPOs con cerning non-EGU control measures that they did consider reasonable.

→ O utcome : As a default position, MANE-VU’s modeling includ ed emission adjustments for those regions based on MANE-VU’s ow n analyses of what
constituted reasonable control measures from non-EG U sources (see Section 10 , Reasonable Progress Goals).

• Situation : The targeted EGU strategy was thought by some no n-MANE-VU states to
be too restrictive and too difficult to achieve. M ANE-VU recognized that a 100-percent compliance with this portion of the Ask was unlikel y to occur because the CAIR trading market would probably dominate. However, M ANE-VU had hoped that nonMANE-VU states would make a more concerted effort t oward meeting this request. MANE-VU did receive a partial list of facilities th at were expected to comply.New Hampshire Regional Haze SIP Revision Page 31

→ Outcome : For the top contributing EGU stacks located with in the MANE-VU, MRPO, and VISTAS regions, expected emission reducti ons resulting from the Ask were distributed among facilities on the basis of r ecommendations received during inter- and intra-regional consultations. To mainta in the CAIR emissions budget as predicted by the modeling, excess emission reductio ns (also predicted by the modeling) were uniformly added back to EGUs in all three regions.

While the original CAIR rule would have been the pr imary determinant of which EGUs among the top 167 stacks are to be fitted with emission c ontrols, at the same time, MANE-VU recognized that these units are the primary sources affecting visibility in the MANE-VU states. For the initial planning, MANE-VU has allo wed flexibility as to how other RPOs meet the Ask. However, MANE-VU expects that, over time, these actual facilities will need to be controlled if significant improvements in visibilit y at affected Class I areas are to be realized.

MANE-VU believes that the goals of the Ask will be attained only by means of binding obligations to EGU emission reductions beyond the l evels of control that CAIR originally would have provided. MANE-VU therefore maintains t hat additional federal action is needed to achieve the visibility benefits shown to be feas ible through sensitivity modeling (see Attachment G, “MANE-VU Modeling for Reasonable Prog ress Goals: Model Performance Evaluation, Pollution Apportionment, and Control Me asure Benefits,” February 7, 2008) and demonstrated to be available at reasonable cost (se e Attachment H, Alpine Geophysics, LLC,
“Documentation of 2018 Emissions from Electric Gene rating Units in the Eastern United States for MANE-VU’s Regional Haze Modeling,” Final Report, August 16, 2009).

MANE-VU’s position on this issue is formally expres sed in its “Statement of the MidAtlantic / Northeast Visibility Union (MANE-VU) Con cerning a Request for a Course of Action by the U.S. Environmental Protection Agency (EPA) toward Assuring Reasonable Progress,” adopted June 20, 2007. This statement, more commonly known as MANE-VU’s National Ask, is included in Attachment E.

Although other RPOs did not adopt all of the same p hilosophies or processes for their regional haze SIPs, the consultation process maintains a cen tral role in regional haze planning. New Hampshire is pleased with the significant opportuni ties identified for ongoing consultation with other states concerning long-term strategies n ot only for regional haze mitigation but also for improved air quality in general.

3.2.5 State/Tribe and Federal Land Manager Coordina tion

New Hampshire will continue to coordinate and consu lt with the Federal Land Managers during the development of future progress reports a nd plan revisions, as well as during the implementation of programs having the potential to contribute to visibility impairment in the mandatory Class I areas.

40 CFR 51.308(i) of the Regional Haze Rule requires coordination between states/tribes and the Federal Land Managers (FLMs). Opportunities ha ve been provided by MANE-VU for
FLMs to review and comment on each of the technical documents developed by MANE-VU and included in this SIP. New Hampshire has identi fied agency contacts to the FLMs as required under 40 CFR 51.308(i)(1). New Hampshire has consulted with the FLMs in the development of this plan and, in accordance with 40 CFR 51.308(i)(2), has provided theNew Hampshire Regional Haze SIP Revision Page 32

FLMs an opportunity for consultation, in person, at least 60 days prior to holding any public hearing on the SIP. The draft SIP was submitted to the FLMs on August 1, 2008, for review
and comment.

Pursuant to 40 CFR 51.308(i)(3), New Hampshire has requested and received comments on the regional haze SIP from the Federal Land Managers. NHDES received preliminary comments from the U.S. Department of the Interior (DOI), Nat ional Park Service (NPS) and U.S. Fish and Wildlife Service (FWS) on August 27, 2008, and from the U.S. Department of Agriculture, U.S. Forest Service (USFS) on August 28, 2008. For mal comments from DOI – NPS and FWS on the SIP were received in a letter dated Sept ember 26, 2008. Conference calls to discuss the agencies’ comments took place on August 28 and September 18, 2008, with representatives from NPS, USFS, USFWS, EPA, and NHDES in attendance . Following these consultations, NHDES revised the draft implementation plan to addr ess the agencies’ comments. A public hearing on the draft final SIP was held at NHDES he adquarters on Wednesday, June 24, 2009. The U.S. Department of the Interior, Nationa l Park Service provided final written comments during the public comment period, which en ded on June 26, 2009.

A compilation of comments received, responses by NH DES, and summaries of conference calls is presented in Attachment I of this plan. A ll of these documents were made available for public review during the public comment period. (Note: The MANE-VU states also received comments from other stakeholders during th e planning process; their comments can be found in Attachment J.)

The comments submitted by the FLMs were both genera l and specific. The reviewing agencies found New Hampshire’s Regional Haze SIP to be well written and comprehensive. The uncertainty surrounding CAIR and discrepancies in modeling (especially inclusion of the MANE-VU Ask) between MANE-VU and other RPOs were id entified as broad topics for further discussion through the consultation process . Comments of a specific nature were relatively minor for the most part. The agencies r equested that NHDES provide additional information in support of New Hampshire’s BART anal yses. NHDES’s responses to the agencies’ comments are addressed point-by-point in the response document contained in
Attachment I.

40 CFR 51.308(i)(4) requires procedures for continu ing consultation between the states/tribes and FLMs on the implementation of the visibility pr otection program. In particular, New Hampshire will consult with the designated visibili ty protection program coordinators for the National Park Service, U. S. Fish and Wildlife Serv ice, and U.S. Forest Service, periodically and as circumstances require, on the following impl ementation items:

1. Status of emissions strategies identified in the SI P as contributing to improvements in the worst-day visibility;

2. Summary of major new source permits issued;

3. Status of New Hampshire’s actions toward completing any future assessments or rulemakings on sources identified as probable contr ibutors to visibility impairment, but not directly addressed in the most recent SIP r evision;

4. Any changes to the monitoring strategy or status of monitoring stations that might affect tracking of reasonable progress;New Hampshire Regional Haze SIP Revision Page 33

5. Work underway for preparing the 5-year SIP review a nd/or 10-year SIP revision, including any items where the FLMs’ consideration o r support is requested; and

6. Summary of topics discussed in ongoing communicatio ns (e.g., meetings, emails, etc.) between New Hampshire and the FLMs regarding implem entation of the visibility improvement program.

3.2.6 EPA Consultation and Review

New Hampshire has consulted with EPA on many occasi ons in the course of regional haze modeling and plan development, and EPA has provided specific input regarding completion of the SIP. On July 10, 2008, NHDES received writt en comments from EPA on an early SIP draft that was submitted to the agency for prelimin ary review. On October 24, 2008, NHDES
received additional written comments from EPA on a modified version that was identical to the draft SIP reviewed by the FLMs. Following the public hearing, in a letter dated June 26, 2009, EPA provided formal comments on the draft fin al SIP.

New Hampshire has addressed EPA’s comments by makin g appropriate amendments to the SIP, all of which are incorporated into the present document. EPA’s specific comments and NHDES’s responses are included in Attachment I.New Hampshire Regional Haze SIP Revision Page 34



### 4. ASSESSMENT OF BASELINE AND NATURAL VISIBILITY CO NDITIONS

Pursuant to 40 CFR 51.308(d)(2) of the Regional Haz e Rule, states must determine baseline and natural visibility conditions for each Class I area within their jurisdictions. This information
allows states to assess current levels of visibilit y degradation and provides a basis for setting reasonable progress goals toward restoration of nat ural visibility conditions in Class I areas.

The effectiveness of any plan to reduce regional ha ze in Class I areas is dependent on the availability of reliable data. The Interagency Mon itoring of Protected Visual Environments (IMPROVE) program was established in 1985 to provid e the data necessary to support the creation of Federal and State implementation plans for the protection of visibility in Class I areas. IMPROVE has made it possible to assess curr ent visibility conditions, track changes in visibility, and identify the chemical species and e mission sources responsible for visibility impairment. In particular, IMPROVE data were used to calculate baseline and natural
conditions for MANE-VU Class I Areas.

The IMPROVE monitors listed in Table 4.1 provide da ta representative of Class I Areas in the MANE-VU region.

Table 4.1: IMPROVE Monitors for MANE-VU Class I Ar eas

IMPROVE Site / Location Class I Area(s) Served Latitude, Longitude State

ACAD1
Acadia National Park Acadia National Park 44.38, -68.26 Maine

MOOS1
Moosehorn Wilderness Moosehorn Wilderness;

Roosevelt Campobello
International Park 45.13, -67.27 Maine

GRGU1 Great Gulf Wilderness Great Gulf Wilderness;

Presidential Range - Dry
River Wilderness 44.31, -71.22 New Hampshire

LYBR1 Lye Brook Wilderness Lye Brook Wilderness 43.15, -73.13 Vermont

BRIG1 Brigantine National Wildlife Refuge Brigantine National Wildlife Refuge 39.47, -74.45 New Jersey

http://www.vista.circa.colostate.edu/views/; http: //vista.cira.colostate.edu/improve/



### 4.1 Calculation Methodology

In September 2003, EPA issued guidance for the calc ulation of natural background and baseline visibility conditions. The guidance provi ded a default method and described certain refinements that states might consider in order to tailor their estimates to any Class I areas not adequately represented by the default method. At t hat time, MANE-VU calculated natural visibility for each of the MANE-VU Class I Areas us ing the default method for the 20 percent best and 20 percent worst visibility days. MANE-VU also evaluated ways to refine the estimates. Potential refinements included 1) incre asing the multiplier used to calculate impairment attributed to carbon, 2) adjusting the f ormula used to calculate the 20 percent bestNew Hampshire Regional Haze SIP Revision Page 35

and worst visibility days, and 3) accounting for vi sibility impairment caused by sea salt at coastal sites. However, MANE-VU found that these r efinements did not significantly improve the accuracy of the estimates, and MANE-VU states desired a consistent approach to visibility assessment. Therefore, default estimate s were used with the understanding that this methodology would be reconsidered upon demonstrated improvements in the science.

Once the technical analysis of visibility condition s was complete, MANE-VU provided an opportunity to comment to federal agencies and stak eholders. The proposed approach to visibility assessment was posted on the MANE-VU web site on March 17, 2004, and a stakeholder briefing was held on the same day. Com ments were received from the Electric Power Research Institute (EPRI), the Midwest Ozone Group (MOG), the Appalachian Mountain Club, the National Parks Conservation Asso ciation, the National Park Service, and
the US Forest Service.

Several comments supported the proposed approach in general; other comments were divided among four main topics: 1) the equation used to cal culate visibility, 2) the statistical technique used to estimate the 20 percent best and worst visi bility days, 3) the inclusion of transboundary effects and fires, and 4) the timing as to when new information should be
included. All comments were reviewed and summarize d by MANE-VU; and air directors were briefed on comments, proposed response options , and implications. Attachment J provides a compilation of comments received and a s ummary of stakeholders’ comments.

MANE-VU’s position on natural background conditions was presented in a report issued in June 2004 (see Attachment K, “Natural Background Vi sibility Conditions: Considerations and Proposed Approach to the Calculation of Natural Bac kground Visibility Conditions at MANE-VU Class I Areas,” June 10, 2004). The report stated, “Refinements to other aspects of the default method (e.g., refinements to the ass umed distribution or treatment of Rayleigh extinction, inclusion of sea salt, and improved ass umptions about the chemical composition of the organic fraction) may be warranted prior to sub mission of SIPs depending on the degree to which scientific consensus is formed around a speci fic approach...”

In 2006, the IMPROVE Steering Committee adopted an alternative reconstructed extinction equation to revise certain aspects of the default m ethod. The scientific basis for these revisions was well understood, and the Committee de termined that the revisions improved the performance of the equation at reproducing observed visibility at Class I sites.

In 2006, MANE-VU conducted an assessment of the def ault and alternative approaches for calculation of baseline and natural background cond itions at MANE-VU Class I Areas. Based on that assessment, in December 2006, MANE-VU recommended adoption of the alternative reconstructed extinction equation for u se in the regional haze SIPs. (See Attachment L, “Baseline and Natural Background Visi bility Conditions: Considerations and Proposed Approach to the Calculation of Baseline an d Natural Background Visibility Conditions at MANE-VU Class I Areas,” December 2006 .) MANE-VU will continue to participate in further research efforts on this top ic and will reconsider the calculation methodology as scientific understanding evolves.



### 4.2 MANE-VU Baseline Visibility

The IMPROVE program has calculated the 20 percent b est and 20 percent worst baseline (2000-2004) and natural visibility conditions using the EPA-approved alternative method
described above for each MANE-VU Class I Area. The data are posted on the VisibilityNew Hampshire Regional Haze SIP Revision Page 36

Information Exchange Web System (VIEWS) operated by the regional planning organizations. The information can be accessed at http://vista.cir a.colostate.edu/views/ ) and is summarized in Table 4.2 below. Displayed are the five-year av erage baseline visibility values for the period 2000-2004, natural visibility levels, and t he difference between baseline and natural visibility values for each of the MANE-VU Class I A reas. The difference columns (best and worst) are of particular interest because they desc ribe the magnitude of visibility impairment attributable to manmade emissions, which are the fo cus of the Regional Haze Rule.

The five-year averages for 20 percent best and wors t visibility were calculated in accordance with 40 CFR 51.308(d)(2), as detailed in NESCAUM’s Baseline and Natural Background
document found in Attachment L.

Table 4.2: Summary of Baseline Visibility and Natu ral Visibility Conditions for the 20 Percent Best and 20 Percent Worst Visibility Day s at MANE-VU Class I Areas

2000-2004 Baseline (deciviews) Natural Conditions

(deciviews) Difference

(deciviews) Class I Area(s) Best
20% Worst

20% Best

20% Worst

20% Best

20% Worst

20%

Acadia National Park 8.8 22.9 4.7 12.4 4.1 10.5

Moosehorn Wilderness and Roosevelt Campobello International Park 9.2 21.7 5.0 12.0 4.1 9.7

Great Gulf Wilderness and Presidential Range - Dry River Wilderness 10 7.7 22.8 3.7 12.0 3.9 10.8

Lye Brook Wilderness 6.4 24.5 2.8 11.7 3.6 12.7

Brigantine Wilderness 14.3 29.0 5.5 12.2 8.8 16.8

Source: VIEWS (http://vista.circa.colo state.edu/views/ ), prepared on 6/22/2007



### 4.3 New Hampshire Class I Areas – Baseline Visibili ty

As indicated in the table above, the 2001-2004 base line visibility for the Great Gulf and Presidential Range - Dry River Wilderness Class I a reas was 7.7 deciviews for the 20 percent best visibility days and 22.8 deciviews for the 20 percent worst visibility days. These are average values based on data collected at the Great Gulf (GRGU1) IMPROVE monitoring site. As described in Section 5, Monitoring Strat egy of this SIP, New Hampshire accepts designation of this monitoring site as representati ve of the Great Gulf and Presidential Range - Dry River Wilderness Areas in accordance with 40 CF R 51.308(d)(2)(i). (The two wilderness areas are close enough together that a single monit or suffices.)

Tables 4.3 and 4.4 list the baseline visibility for the 20 percent best and 20 percent worst visibility days for each year of the period 2000-20 04, from which the valid four-year average values in Table 4.2 were calculated. The averages were determined in accordance with 40 CFR 51.308(d)(2), as detailed in the NESCAUM Baseli ne and Natural Background document
found in Attachment L of this SIP. The deciview vi sibility values for best and worst days
were obtained from data included in Attachment L.

10 Deciview values based on 4-year average for 2001- 2004 (data collection in 2000 was for summer only).New Hampshire Regional Haze SIP Revision Page 37

Table 4.3: Baseline Visibility for the 20 Percent Best Days and 20 Percent Worst Days

During 2000-2004 in New Hampshire Class I Areas

Baseline Visibility (deciviews) Class I Area(s) Year 20% Best 20% Worst Footnote

2000 7.4 20.0 11

2001 8.3 23.3

2002 7.8 24.8

2003 6.9 21.6

2004 7.7 21.6 Great Gulf Wilderness and Presidential Range - Dry River Wilderness

Average 7.7 22.8 12

Source: VIEWS (http://vista.circa.colostate.edu/vie ws )



### 4.4 New Hampshire Class I Areas – Natural Backgroun d

Natural background refers to the visibility conditi ons that existed before human activities affected air quality in the region. Consistent wit h the stated visibility goals of the Clean Air Act, natural background is identified as the visibi lity target to be reached by 2064 in each Class

I area.

The Great Gulf and Presidential Range - Dry River W ilderness Class I areas have an estimated natural background visibility of 3.7 deciviews on t he 20 percent best days and 12.0 deciviews on the 20 percent worst days. These best and worst 20 percent visibility values were calculated using the above-referenced EPA guideline s and approved alternative method described in NESCAUM’s Baseline and Natural Backgro und document (Attachment L).

11 Approximate values, based on summer-only observatio ns.

12 Based on 4 valid years, 2001-2004New Hampshire Regional Haze SIP Revision Page 38



### 5. AIR MONITORING STRATEGY

In the mid-1980’s, the Interagency Monitoring of Pr otected Visual Environments (IMPROVE) program was established to measure visibi lity impairment in mandatory Class I areas throughout the United States. The monitoring sites are operated and maintained through a formal cooperative relationship between the U.S. EPA, National Park Service, U.S. Fish and Wildlife Service, Bureau of Land Management, and U. S. Forest Service. In 1991, several additional organizations joined the effort: State a nd Territorial Air Pollution Program
Administrators and the Association of Local Air Pol lution Control Officials (which have since merged under the name National Association of Clean Air Agencies), Western States Air Resources Council, Mid-Atlantic Regional Air Manage ment Association, and Northeast States for Coordinated Air Use Management.



### 5.1 IMPROVE Program Objectives

The IMPROVE program provides scientific documentati on of the visual air quality of America’s wilderness areas and national parks. Man y individuals and organizations – land managers; industry planners; scientists, including university researchers; public interest groups; and air quality regulators – use the data c ollected at IMPROVE sites to understand and protect the visual air quality resource in Clas s I areas. Major objectives of the IMPROVE program include the following:

• Establish current visibility and aerosol conditions in mandatory Class I areas;

• Identify chemical species and emission sources resp onsible for existing anthropogenic visibility impairment;

• Document long-term trends for assessing progress to wards the national visibility goals;

• Provide regional haze monitoring for all visibility -protected federal Class I areas where practical, as required by EPA’s Regional Haze Rule.



### 5.2 Monitoring Requirements

EPA’s Regional Haze Rule establishes air monitoring requirements that affected states must meet to assess visibility impairment caused by regi onal haze in Class I areas. The following describes how New Hampshire is complying with speci fic sections of the rule:

• 40 CFR 51.308(d)(4) requires a monitoring strategy for measuring, characterizing, and reporting regional haze / visibility impairment that is representative of all mandatory Class I areas. (Note that this monitoring strategy must be coordinated with the additional requirements of 40 CFR 51.305, which is not applica ble to New Hampshire.) New Hampshire’s monitoring strategy relies on participa tion in the IMPROVE network and Visibility Information Exchange Web System (VIEWS). NHDES will evaluate the monitoring network periodically and make appropriat e adjustments to it as necessary, consistent with the IMPROVE program objectives stat ed above. However, New Hampshire’s commitment to following this strategy a nd providing continuing assessments of progress toward national visibility goals at mandatory Class I Areas will remain contingent on sufficient federal funding in support of monitoring program requirements and associated databases. In the even t that existing funding sources are eliminated or curtailed, New Hampshire will consult with the FLMs on the most practicable course of action.New Hampshire Regional Haze SIP Revision Page 39

• 40 CFR 51.308(d)(4)(i) requires states to establish additional monitoring sites or equipment as needed to assess whether reasonable pr ogress goals are being achieved toward visibility improvement at mandatory Class I areas. At this time, the current
monitors are sufficient to make this assessment. N ew Hampshire’s commitment to maintain the current level of monitoring, and to ex pand monitoring or analysis should such action become necessary, will remain contingen t on federal funding assistance.

• 40 CFR 51.308(d)(4)(ii) requires each affected stat e to include procedures by which monitoring data and other information are used to d etermine the state’s contribution of emissions to visibility impairment at mandatory Cla ss I areas both within and outside the state. New Hampshire’s estimated contributions are summarized in Subsection 2.1
of this SIP and are documented in a detailed techni cal analysis prepared by NESCAUM entitled, “Contributions to Regional Haze i n the Northeast and MidAtlantic United States,” August 2006 (Attachment B) . The NESCAUM study used various tools and techniques to assess the contribu tions of individual states and regions to visibility degradation in Class I areas within and outside MANE-VU.

• 40 CFR 51.308(d)(4)(iv) requires a state to submit visibility monitoring data annually for each Class I area and, if possible, to provide the data in electronic format. The Federal Land Manager submits the data, and the data are pos ted on the VIEWS website.

• 40 CFR 51.308(d)(4)(v) requires a statewide invento ry of emissions of pollutants that are reasonably anticipated to cause or contribute t o visibility impairment in mandatory Class I areas within New Hampshire. Section 6, Emi ssions Inventory, addresses this requirement.

• 40 CFR 51.308(d)(4)(vi) requires that SIPs provide other elements, including reporting, recordkeeping, and other measures necess ary to assess and report on visibility. While NHDES believes the current IMPRO VE network is sufficient to adequately measure and report progress toward the r egional haze goals set for New Hampshire’s and other Class I areas, NHDES in the p ast has found additional monitoring information to be useful in assessing pa tterns of regional visibility and fine particle pollution. Examples of these data sources include:

− The MANE-VU RAIN network, which provides continuous , speciated
information on rural aerosol characteristics and vi sibility parameters;

− The EPA CASTNET program, which has provided complem entary rural fine particle speciation data at non-Class I sites;

− The EPA Speciation Trends Network (STN), which prov ides speciated, urban fine particle data to help develop a comprehensive picture of local and regional sources;

− State-operated rural and urban speciation sites usi ng IMPROVE or Speciation Trends Network (STN) methods (the latter program co mprising 54 monitoring stations located mainly in or near larger metropoli tan areas); and

− The Supersites program, which has undertaken specia l studies to expand knowledge of the processes that control fine particle formati on and transport in the region.

Assuming that these resources will continue to be a vailable and that fiscal realities will allow, New Hampshire will continue using these and other data sources for the purposes of understanding visibility impairment and documenting progress toward national visibility goals for Class I areas under t he Regional Haze Rule.New Hampshire Regional Haze SIP Revision Page 40

Acadia National Park IMPROVE Site

Created by Tom Downs, MEDEP 4/17/07 IMPROVE MONITOR LOCATION

ACADIA NATIONAL PARK LEGEND

http://www.maine.gov/dep/air/meteorology/images/Aca dia.jpg Figure 5.1: Map of Acadia National Park Showing
Location of IMPROVE Monitor 

### 5.3 Monitoring Sites for MANE-VU Class I Areas

IMPROVE monitoring sites have been established for each of the Class I areas in the region. The Great Gulf Wilderness and Presidential Range - Dry River Wilderness share a single monitoring site. Each of the other MANE-VU Class I Areas has its own monitoring site.

5.3.1 Acadia National Park, Maine

The IMPROVE monitor for Acadia National Park (ACAD1 ) is located at park headquarters, near Bar Harbor, Maine, at elevation 157 meters, la titude 44.38 ̊, and longitude -68.26 ̊. This monitor is operated and maintained by the National Park Service. New Hampshire considers the ACAD1 site as adequate for assessing reasonable pro gress toward visibility goals at Acadia National Park, and no additional monitoring sites o r equipment are necessary at this time.

Figure 5.2: Acadia National Park on Clear and Hazy Days

http://www.hazecam.net/class1/acadia.htmlNew Hampshire Regional Haze SIP Revision Page 41

5.3.2 Brigantine Wilderness, New Jersey

The IMPROVE monitor for the Brigantine Wilderness ( BRIG1) is located at the Edwin B. Forsythe National Wildlife Refuge Headquarters in O ceanville, New Jersey, at elevation 5 meters, latitude 39.47 ̊, and longitude -74.45 ̊. Th is monitor is operated and maintained by the U.S. Fish & Wildlife Service. New Hampshire consid ers the BRIG1 site as adequate for assessing reasonable progress toward visibility goa ls at the Brigantine Wilderness, and no additional monitoring sites or equipment are necess ary at this time.

Figure 5.3: Map of Edwin B. Forsythe National Wild life Refuge

http://www.fws.gov/northeast/forsythe/MAP.htm

Figure 5.4: Brigantine Wilderness on Clear and Haz y Days

http://www.hazecam.net/class1/brigantine.h tmlNew Hampshire Regional Haze SIP Revision Page 42

IMPROVE MONITOR SITE 5.3.3 Great Gulf Wilderness, New Hampshire

The IMPROVE monitor for the Great Gulf Wilderness ( GRGU1) is located at Camp Dodge,
in the mid-northern area of Greens Grant in the Whi te Mountain National Forest. The monitor site lies just east and south of where Rout e 16 crosses the Greens Grant / Martins Location boundary, south of Gorham, New Hampshire, at elevation 454 meters, latitude 44.31 ̊, and longitude of -71.22 ̊. This monitor, wh ich also represents the Presidential Range - Dry River Wilderness (see 5.3.4 below), is operated and maintained by the U.S. Forest Service. New Hampshire considers the GRGU1 site as adequate for assessing reasonable progress toward visibility goals at the Great Gulf Wilderness, and no additional monitoring sites or equipment are necessary at this time.

Figure 5.5: Map of Great Gulf and Presidential Ran ge - Dry River Wilderness Areas

Showing Location of IMPROVE Monitor

http://www.maine.gov/dep/air/meteorology/images/NHc lass1.jpg

Figure 5.6: Great Gulf Wilderness on Clear and Haz y Days

http://www.wilderness.netNew Hampshire Regional Haze SIP Revision Page 43

5.3.4 Presidential Range - Dry River Wilderness, Ne w Hampshire

The IMPROVE monitor for the Presidential Range - Dry River Wilderness is also the monitor for Great Gulf Wilderness (GRGU1), as described abo ve. New Hampshire considers the GRGU1 site as adequate for assessing reasonable pro gress toward visibility goals at the Presidential Range - Dry River Wilderness, and no a dditional monitoring sites or equipment are necessary at this time.

Figure 5.7: Upper Elevations of Presidential Range - Dry River Wilderness

http://www.fs.fed.us/r9/forests/white_mountain/recr eation/wilderness/

5.3.5 Lye Brook Wilderness, Vermont

The IMPROVE monitor for the Lye Brook Wilderness (L YBR1) is located on Mount Equinox at the windmills in Manchester, Vermont, at elevation 1015 meters, latitude 43.15 ̊, and longitude of -73.13 ̊. The monitor does not lie within the wilderness area but is situated on a mountain peak across the valley to the west of the wilderness area. The IMPROVE site and the Lye Brook Wilderness are at similar elevati ons. The monitor is operated and maintained by the U.S. Forest Service. New Hampshi re considers the LYBR1 site as adequate for assessing reasonable progress toward visibility goals at the Lye Brook Wilderness, and no additional monitoring sites or equipment are necess ary at this time.

Figure 5.8: Location of Lye Brook Wilderness IMPRO VE Monitor

http://www.wilderness.net/index.cfm?fuse=NWPS&sec=s tateView&state=NH&map=menhvt IMPROVE MONITOR SITENew Hampshire Regional Haze SIP Revision Page 44

Figure 5.9: Aerial View of Lye Brook Wilderness IM PROVE Monitoring Site

sources: GoogleEarth; and Paul Wishinski, Vermont D EC, Air Pollution Control Division

Figure 5.10: Lye Brook Wilderness on Clear and Haz y Days

http://www.hazecam.net/class1/lye.html

5.3.6 Moosehorn Wilderness, Maine

The IMPROVE monitor for the Moosehorn Wilderness (M OOS1) is located near McConvey Road, about one mile northeast of the National Wild life Refuge Baring (ME) Unit Headquarters, at elevation 78 meters, latitude 45.1 3 ̊, and longitude -67.27 ̊. This monitor also represents the Roosevelt Campobello Internatio nal Park in New Brunswick, Canada. The monitor is operated and maintained by the U.S. Fish & Wildlife Service. New Hampshire considers the MOOS1 site as adequate for assessing reasonable progress toward visibility goals at the Moosehorn Wilderness, and no additiona l monitoring sites or equipment are necessary at this time.

IMPROVE MONITOR SITE APPROX

. WILDERNESS BOUNDARYNew Hampshire Regional Haze SIP Revision Page 45

Figure 5.11: Map of the Baring and Edmunds Divisio ns of the Moosehorn National

Wildlife Refuge Showing Location of IMPROVE Monitor

Figure 5.12: Moosehorn Wilderness on Clear and Haz y Days

http://www.hazecam.net/moosehor n.htmlNew Hampshire Regional Haze SIP Revision Page 46

5.3.7 Roosevelt Campobello International Park, New Brunswick, Canada

The IMPROVE monitor for Roosevelt Campobello Intern ational Park is also the monitor for the Moosehorn Wilderness (MOOS1), as described abov e. New Hampshire considers the MOOS1 site as adequate for assessing reasonable pro gress toward visibility goals at Roosevelt Campobello International Park, and no additional mo nitoring sites or equipment are necessary
at this time.

Figure 5.13: Map of Roosevelt Campobello Internati onal Park

http://www.maine.gov/dep/air/meteorology/ima ges/rcip.jpg

Figure 5.14: Roosevelt Campobello International Pa rk on Clear and Hazy Days

source: Chessie JohnsonNew Hampshire Regional Haze SIP Revision Page 47



### 6. EMISSIONS INVENTORY

40 CFR 51.308(d)(4)(v) of EPA’s Regional Haze Rule requires a statewide emissions inventory of pollutants that are reasonably anticip ated to cause or contribute to visibility impairment in any mandatory Class I area. The inve ntory must include emissions for a baseline year, future (projected) year, and the mos t recent year for which high-quality data are available. New Hampshire’s baseline year, 2002, is also the most recent year for which data are available. The pollutants inventoried by New H ampshire include nitrogen oxides (NO X ), sulfur dioxides (SO 2 ), volatile organic compounds (VOCs), fine particle s (particulate matter less than 2.5 micrometers in diameter, or PM 2.5 ), coarse particles (particulate matter less than 10 micrometers in diameter, or PM 10 ), and ammonia (NH 3 ). The following source categories were included in New Hampshire’s emissions inventor y: stationary point sources, stationary area sources, on-road mobile sources, non-road mobi le sources, and biogenic sources. These emissions categories are discussed further in Subse ction 7.3, Model Platforms.



### 6.1 Baseline and Future-Year Emissions Inventories for Modeling

40 CFR 51.308(d) (3) (iii) of EPA’s Regional Haze R ule requires the State of New Hampshire to identify the baseline emissions inventory on whi ch emission control strategies are founded. The baseline inventory is intended to be used for a ssessing progress in making emission reductions. In accordance with EPA’s guidance memo randum “2002 Base Year Emission Inventory SIP Planning: 8-hour Ozone, PM 2.5 , and Regional Haze Programs,” November 18, 2002, all of the MANE-VU states are using 2002 as t he baseline year for regional haze.

Previously, on July 5, 2006, New Hampshire submitte d its 2002 baseline inventory to EPA to meet its implementation planning obligations under the 8-hour ozone program. It should be noted, however, that emissions inventories are not static documents, but are constantly revised and updated to reflect the input of better emission s estimates as they become available. With contractor assistance, MARAMA developed a 2002 base line modeling inventory using the inventories that New Hampshire and other states sub mitted to EPA to meet their SIP obligations and the requirements of the Consolidate d Emissions Reporting Rule (CERR). To create the 2002 baseline inventory for modeling, MA RAMA and its contractor qualityassured and augmented states’ inventories and gener ated the necessary input files for the emissions processing model. As described in Part 6 .1.1 below, work on this effort underwent several versions. Therefore, the 2002 baseline emi ssions summarized in this document may differ slightly from New Hampshire’s original 2002 baseline inventory submittal.

Future-year inventories for 2009, 2012, and 2018 we re projected from the 2002 base year. These future-year emissions inventories include emi ssions growth due to projected increases in economic activity as well as emissions reductions e xpected from the implementation of control measures. While the 2009 and 2012 emissions projec tions were originally developed in support of New Hampshire’s and other states’ ozone attainme nt demonstrations, the inventory for 2018 (the year targeted by the Regional Haze Rule) was d eveloped for the specific purposes of regional haze SIP planning. Therefore, although the 2009 an d 2012 projected inventories are mentioned in subsequent sections, only the 2002 baseline invento ry and 2018 projected inventory are described below in Subsection 6.4, Summary of Emissions Inven tories.New Hampshire Regional Haze SIP Revision Page 48

Accurate baseline and future-year emissions invento ries are crucial to the analyses required for the regional haze SIP process. These emissions inventories were used to drive the air quality modeling simulations undertaken to assess t he visibility improvements that would result from possible control measures. Air quality modeling was also used to perform a pollution apportionment, which evaluates the contri bution to visibility impairment by geographic region and emission source sector.

To be compatible with the air quality modeling simu lations, the baseline and future-year emissions inventories were processed with the Spars e Matrix Operator Kernel Emissions (SMOKE) emissions pre-processor for subsequent inpu t into the CMAQ and REMSAD air quality models described in Subsection 7.3. Furthe r description of the base and future-year emissions inventories is provided below.

6.1.1 Baseline Inventory (2002)

The starting point for the 2002 baseline emissions inventory was the 2002 inventory submittals that were made to EPA by state and local agencies as part of the Consolidated Emissions Reporting Rule (CERR). With contractor a ssistance (E.H. Pechan & Associates, Inc.,), MANE-VU then coordinated and quality-assure d the 2002 inventory data, and prepared it for input into the SMOKE emissions model. The 2 002 emissions from non-MANE-VU areas within the modeling domain were obtained from other Regional Planning Organizations for their corresponding areas. These Regional Planning Organizations included the Visibility Improvement State and Tribal Association of the Sou theast (VISTAS), the Midwest Regional Planning Organization (MRPO), and the Central Regio nal Air Planning Association (CenRAP).

The 2002 baseline inventory went through several it erations. Work on Version 1 of the 2002 MANE-VU inventory began in April 2004, and the fina l inventory and SMOKE input files were completed during January 2005. Work on Versio n 2 (covering the period of April through September 2005) involved incorporating revi sions requested by some MANE-VU state/local agencies on the point, area, and on-roa d categories. Work on Version 3 (covering the period from December 2005 through April 2006) i ncluded additional revisions to the point, area, and on-road categories as requested by some states. Thus, the Version 3 inventory for point, area, and on-road sources was built upon Versions 1 and 2. This work also included development of the biogenic inventory. In Version 3, the non-road inventory was completely redone because of changes that EPA made to the NONR OAD2005 non-road mobile
emissions model.

Version 3 of the MANE-VU 2002 baseline emissions in ventory was used in the regional air quality modeling simulations. Further description of the data sources, methods, and results for this version of the 2002 baseline inventory is presented in E.H. Pechan & Associates, Inc., “Technical Support Document for 2002 MANE-VU SIP Mo deling Inventories, Version 3, November 20, 2006, also known as the Baseline Emiss ions Report (Attachment M). Emissions inventory data files are available on the MARAMA website at: http://www.marama.org/visibility/EI_Projects/index. html

.New Hampshire Regional Haze SIP Revision Page 49

6.1.2 Future-Year Emissions Inventories

Future-year emissions inventories are provided in M ACTEC’s technical support document, “Development of Emissions Projections for 2009, 201 2, and 2018 for NonEGU Point, Area, and Nonroad Sources in the MANE-VU Region,” Final R eport, February 28, 2007, also known as the Emission Projections Report (Attachmen t N). This document describes the data sources, methods, and modeling results for three fu ture years, five emission source sectors, two emission control scenarios, seven pollutants, a nd eleven states plus the District of Columbia. The following summarizes the basic frame work of the future-year inventories that were developed:

• Projection years : 2009, 2012, and 2018;

• Emission source sectors : point-source electric generating units (EGUs), po int-source non-electric generating units (non-EGUs), area sour ces, non-road mobile sources, and
on-road mobile sources.

• Emission control scenarios :

- A combined on-the-books/on-the-way (OTB/OTW) contro l strategy accounting for emission control regulations already in place a s of June 15, 2005, as well as some emission control regulations that are not yet finalized but are expected to achieve additional emission reductions by 2009; and

- A beyond-on-the-way (BOTW) scenario to account for Phase 1 implementation of a low-sulfur fuel strategy for non-EGU sources a nd controls from potential new regulations that may be necessary to meet attai nment and other regional air quality goals, mainly for ozone.

- An updated scenario (sometimes referred to as “best -and-final”) to account for additional potentially reasonable control measures. For the MANE-VU region,
these include: SO 2 reductions at a set of 167 EGUs which were identif ied as contributing to visibility impairment at northeast Class I areas; Phase 2 implementation of a low-sulfur fuel strategy for no n-EGU sources; and implementation of a Best Available Retrofit Technol ogy (BART) strategy for BART-eligible sources not controlled under other pr ograms.
(Note: Refer to Section 11, Long-Term Strategy, fo r detailed descriptions of specific control strategies.)

• Pollutants : ammonia, carbon monoxide (CO), oxides of nitrogen (NO X ), sulfur dioxide (SO 2 ), volatile organic compounds (VOCs), fine particul ate matter (PM 2.5 , sum of filterable and condensable components), and coarse particulate matter (PM 10 , sum of filterable and condensable components).

• States : Connecticut, Delaware, Maine, Maryland, Massachus etts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, a nd Vermont, plus the District of Columbia (all members of the MANE-VU region).



### 6.2 Emission Processor Selection and Configuration

The Sparse Matrix Operator Kernel Emissions (SMOKE) model was used to format the emissions inventories for use with the air quality models that are discussed in Subsection 7.3. SMOKE is primarily an emissions processing system, as opposed to a true emissions inventory preparation system, in which emissions es timates are simulated from “first principles.” This means that, with the exception o f mobile and biogenic sources, SMOKE’sNew Hampshire Regional Haze SIP Revision Page 50

purpose is to provide an efficient, modern tool for converting emissions inventory data into the formatted emissions files required for a photoc hemical air quality model. The SMOKE emissions processing that was performed in support of the air quality modeling for regional
haze is described further in Subsection 7.2.



### 6.3 Inventories for Specific Source Categories

There are five emission source classifications in t he emissions inventory, as follows:

• Stationary point,

• Stationary area,

• Non-road mobile,

• On-road mobile, and

• Biogenic.

Stationary point sources are large sources that emit greater than a specifi ed tonnage per year,
as described below. Stationary area sources are those sources whose individual emissions are relatively small (i.e., dry cleaners, service s tations, agricultural areas, fires, etc.), but because of the large number of these sources, their collective emissions are significant. Nonroad mobile sources are equipment that can move but do not use the road ways (i.e., lawn mowers, construction equipment, railroad locomotive s, marine vessels, aircraft, etc.). Onroad mobile sources include automobiles, trucks, buses, and motorcycle s that use the roadway system. Biogenic sources include the off-gassing of natural sources such as trees, crops, grasses, and natural decay of plants.

The subsections below give an overview of each of t he source categories and the methods that were used to develop their corresponding baseline a nd future-year emissions estimates. All emissions data were prepared for modeling in accord ance with EPA guidance.

6.3.1 Stationary Point Sources

Point source emissions are emissions from large ind ividual sources. Generally, point sources have permits to operate, and their emissions are in dividually calculated based on sourcespecific parameters. Emissions estimates for point sources are usually made on a regular basis, and the largest point sources are inventorie d annually. Sources with emissions greater than or equal to 100 tons per year (tpy) of a crite ria pollutant, 10 tpy of a single hazardous air pollutant (HAP), or 25 tpy for total HAPs are consi dered to be major sources. Emissions from smaller point sources are also calculated indi vidually but less frequently. Point sources
are further subdivided into EGUs and non-EGUs.

6.3.1.1 Electric Generating Units (EGUs)

The base-year inventory for EGU sources were based on 2002 continuous emissions monitoring (CEM) data reported to EPA in compliance with the Acid Rain Program or 2002 state emissions inventory data. The CEM data provi ded actual hourly emission values used in the modeling of SO 2 and NO X emissions from these large sources. See Chapter I I, Section A.2.a.i of the “Technical Support Document for 2002 MANE-VU SIP Modeling Inventories,” Version 3 (Attachment M) for a discussion of the qu ality assurance steps performed on the
CEM data that were included in the 2002 baseline mo deling inventory. Emissions of other pollutants (e.g., VOCs, CO, NH 3 , and PM 2.5 ) were provided by the states in most instances.New Hampshire Regional Haze SIP Revision Page 51

Future-year inventories of EGU emissions for 2009, 2012 and 2018 were developed using ICF International’s Integrated Planning Model (IPM® ) to forecast growth in electric demand and replacement of older, less efficient and more p olluting power plants with newer, more
efficient and cleaner units. This effort was under taken by an inter-RPO workgroup. While the output of the IPM model predicts that a certain number of older plants will be replaced by newer units to meet future electric growth and stat e-specific NO X and SO 2 caps, New Hampshire did not directly rely on the closure of a ny particular plant in establishing the 2018 inventory upon which the reasonable progress goals were set.

The IPM model results do not provide a reliable bas is upon which to predict EGU closures. Specific plant closures in the New Hampshire are ad dressed in Section 10, Reasonable Progress Goals. Preliminary modeling was performed with unchanged IPM 2.1.9 model results. However, prior to the most recent modelin g, future-year EGU inventories were adjusted as follows:

• First, IPM predictions were reviewed by permitting and enforcement staff of the MANE-VU states. In many cases, staff believed that the IPM shutdown predictions were unlikely to occur. In particular, many oil-fi red EGUs in urban areas were predicted to be shut down by IPM. Similar source i nformation was solicited from
states in both VISTAS and MRPO. As a result of thi s model validation, the IPM modeling output was adjusted before the most recent modeling to reflect staff knowledge of specific plant status in MANE-VU, VIST AS, and MRPO states. Where expected EGU operating status was contrary to what was predicted by IPM modeling, the future-year emissions inventory was adjusted to reflect the expected operation of those plants.

• Second, as a result of inter- and intra-RPO consult ations, MANE-VU agreed to pursue certain emission control measures (see Section 3, R egional Planning). For EGUs, the agreed-upon approach was to pursue emission reducti ons from each of the top 167 stacks located in MANE-VU, MRPO, and VISTAS that co ntributed the most to visibility impairment at any Class I area in the MA NE-VU region. This approach, known as the targeted EGU strategy, is further desc ribed in Section 11 of this SIP.

6.3.1.2 Non-EGU Point Sources

The primary basis for the 2002 baseline non-EGU emi ssions inventory was data reported by state and local agencies for the CERR. As describe d in Part 6.1.1, MANE-VU’s contractor, E.H. Pechan & Associates (Pechan), coordinated the quality assurance of the inventory and prepared the necessary files for input into the SMO KE emissions model. Further information on the preparation of the MANE-VU 2002 baseline poi nt source modeling emissions inventory can be found in Chapter II of the Baseline Emission s Report (Attachment M).

Projected non-EGU point source emissions were devel oped for the MANE-VU region by MACTEC Federal Programs, Inc. under contract to Mid -Atlantic Regional Air Management Association (MARAMA). The specific methodologies t hat were employed are described in Section 2 of the Emission Projections Report (Attac hment N). MACTEC used state-supplied growth factor data, where available, to project fut ure-year emissions. Where state-supplied data were not available, MACTEC used EPA’s Economic Growth and Analysis System, Version 5.0 (EGAS 5.0) to develop applicable growth factors for the non-EGU component. MACTEC also incorporated the applicable federal and state emissions control programs to account for the expected emissions reductions that will take place under the OTB/OTW and
BOTW scenarios.New Hampshire Regional Haze SIP Revision Page 52

6.3.2 Stationary Area Sources

Stationary area sources include sources whose indiv idual emissions are relatively small but, because the number of sources is large, their colle ctive emissions are significant. Some examples include dry cleaners, service stations, an d residential heating. For each area source, emissions are estimated by multiplying an appropria te emission factor by some known indicator of collective activity, such as fuel usage, number of households, or population.

The area source emissions inventory submittals made for the CERR became the basis for the area source portion of the 2002 baseline inventory. MANE-VU’s consultant, Pechan, prepared the area source modeling inventory using t he CERR submittals as a starting point. Pechan quality-assured the inventory and augmented it with additional data, including MANE-VU-sponsored inventories for categories such a s residential wood combustion and open burning. Details on the preparation of MANE-V U’s 2002 baseline area source emissions inventory can be found in Chapter III of the Baseli ne Emissions Report (Attachment M).

In similar fashion, MACTEC prepared future-year are a source emission projections for the MANE-VU region. The specific methodologies employe d are described in Section 3 of the Emission Projections Report (Attachment N). MACTEC applied growth factors to the 2002 baseline area source inventory using state-supplied data, where available, or using the EGAS 5.0 growth factor model. MACTEC also accounted for the appropriate control strategies in the future year projections.

6.3.3 Non-Road Mobile Sources

Non-road mobile sources are equipment that can move but do not typically use the roadways, such as construction equipment, aircraft, railroad locomotives, and lawn & garden equipment. For the majority of non-road mobile sources, emissi ons are estimated using the EPA’s NONROAD model. Aircraft, railroad locomotives, and commercial marine vessels are not included in the NONROAD model; and their emissions are estimated using applicable references and methodologies. Again, Pechan prepar ed the 2002 baseline modeling inventory using the state and local CERR submittals as a star ting point. Details on the preparation of the 2002 baseline non-road inventory are described in Chapter IV of the Baseline Emissions Report (Attachment M).

Future-year non-road mobile source emissions were p rojected for the MANE-VU region by MACTEC. The methodologies employed are discussed i n Section 4 of the Emission Projections Report (Attachment N). MACTEC used EPA ’s NONROAD2005 non-road
vehicle emissions model as contained in EPA’s Natio nal Mobile Inventory Model (NMIM). Since the calendar year is an explicit input into t he NONROAD model, future-year emissions for non-road vehicles could be calculated directly for the applicable projection years. For the non-road vehicle types that are not included in the NONROAD model (i.e. aircraft, locomotives, and commercial marine vessels), MACTEC used the 2002 baseline inventory and the projected inventories that EPA developed fo r these categories for the Clean Air Interstate Rule (CAIR) to develop emission ratios a nd subsequent combined growth and control factors. Since the future years for the CA IR projections did not precisely match those required for the purposes of ozone, particulate mat ter, and regional haze analyses (i.e. 2009, 2012, and 2018), MACTEC used linear interpolation t o develop factors for the required future

years.New Hampshire Regional Haze SIP Revision Page 53

6.3.4 On-Road Mobile Sources

The on-road emissions source category consists of v ehicles that are meant to travel on public roadways, including cars, trucks, buses, and motorc ycles. The basic methodology used for on-road mobile source calculations is to multiply v ehicle-miles-traveled (VMT) by emission factors developed using the EPA’s MOBILE6 motor veh icle emission factors model. The onroad mobile category requires that SMOKE model inpu ts be prepared instead of the SMOKE/IDA emissions data format that is required by the other emission source categories. Therefore, for the 2002 baseline inventory, Pechan prepared the necessary VMT and MOBILE6 inputs in SMOKE format.

Projected on-road mobile source inventories were de veloped by NESCAUM for the MANEVU region for ozone, particulate matter, and region al haze SIP purposes. As with the other emissions source categories, projected on-road mobi le inventories were developed for calendar years 2009, 2012, and 2018. As part of th is effort, MANE-VU member states were asked to provide VMT data and MOBILE6 model inputs for the applicable calendar years. Using the inputs supplied by the MANE-VU member sta tes, NESCAUM compiled and generated the required SMOKE/MOBILE6 emissions mode l inputs. Further details regarding the on-road mobile source projections can be found in NESCAUM’s “Technical Memorandum, Development of MANE-VU Mobile Source Pr ojection Inventories for SMOKE/MOBILE6 Application,” June 2006 (Attachment O ).

6.3.5 Biogenic Emission Sources

For the purposes of the 2002 baseline modeling emis sions inventory, biogenic emissions were calculated for the modeling domain by the New York State Department of Environmental Conservation (NYSDEC). NYSDEC used the Biogenic Em issions Inventory System (BEIS)
Version 3.12 as contained within the SMOKE emission s processing model. Biogenic emissions estimates were made for CO, nitrous oxide (NO) and VOCs. Further details about the biogenic emissions processing can be found in N YSDEC’s technical support document TSD-1c, “Emission Processing for the Revised 2002 O TC Regional and Urban 12 km Base Case Simulations,” September 19, 2006 (Appendix P), and in Chapter VI of Pechan’s “Technical Support Document for 2002 MANE-VU SIP Mo deling Inventories,” Version 3, November 20, 2006 (Appendix M). Biogenic emissions were assumed to remain constant for the future-years analysis – a reasonable approximat ion reflecting the expectation that most of the region will remain heavily forested for the dur ation of the planning period.



### 6.4 Summary of Emissions Inventories

New Hampshire’s baseline and future-year emissions inventories are summarized in Tables 6.1 through 6.4, below. All values are reported in tons per year (tpy). The three different emissions inventories for 2018 represent the emissi on control scenarios described under the
third bullet in Part 6.1.2 of this section.New Hampshire Regional Haze SIP Revision Page 54

Table 6.1: 2002 Emissions Inventory Summary for Ne w Hampshire (tpy)

Emission Sector VOC NO X PM 2.5 PM 10 NH 3 SO 2 Point 1,599 9,759 2,938 3,332 74 46,560
Area 65,370 10,960 17,532 43,328 2,158 7,072
Mobile 16,762 33,283 562 814 1,447 777
Non-Road Mobile 22,376 9,912 965 1,058 9 891 Biogenic 141,894 482

-- -- -- -- TOTAL 248,001 64,396 21,997 48,532 3,688 55,300

Table 6.2: 2018 OTB/OTW Emissions Inventory Summar y for New Hampshire (tpy)

Emission Sector VOC NO X PM 2.5 PM 10 NH 3 SO 2 Point 1,367 4,524 3,208 3,397 184 10,583
Area 64,368 12,430 18,316 49,801 2,789 7,421
Mobile 6,564 7,671 263 282 1,916 537
Non-Road Mobile 15,003 6,344 634 697 11 246 Biogenic 141,894 482
-- -- -- -- TOTAL 229,196 31,451 22,421 54,177 4,900 18,787

Table 6.3: 2018 BOTW Emissions Inventory Summary f or New Hampshire (tpy)

Emission Sector VOC NO X PM 2.5 PM 10 NH 3 SO 2 Point 1,292 4,258 3,208 3,397 184 10,568
Area 62,650 12,180 18,087 49,544 2,789 3,118
Mobile 6,564 7,671 263 282 1,916 537
Non-Road Mobile 15,003 6,344 634 698 12 246 Biogenic 141,894 482

-- -- -- -- TOTAL 227,403 30,935 22,192 53,921 4,901 14,469

Table 6.4: 2018 Most Recent Emissions Inventory Su mmary for New Hampshire (tpy)

Emission Sector VOC NO X PM 2.5 PM 10 NH 3 SO 2 Point 1,291 4,258 3,208 3,397 184 11,849
Area 62,649 12,180 14,993 21,775 2,789 972
Mobile 6,564 7,671 263 282 1,916 537
Non-Road Mobile 15,003 6,344 634 697 11 246 Biogenic 141,894 482

-- -- -- -- TOTAL 227,401 30,935 19,098 26,151 13 4,900 13,604

13 An adjustment factor was applied during the proces sing of emissions data to restate fugitive particul ate matter emissions. Grid models have been found to overestimate fugitiv e dust impacts when compared with ambient samples; therefore, an adjustment is typically applied to account for the removal of particles by vegetation and other terrai n features. The summary emissions for PM 10 in Table 6.4 reflect this adjustment. Comparable adjustments were not made to PM 10 values listed in Tables 6.1 through 6.3.New Hampshire Regional Haze SIP Revision Page 55



### 7. AIR QUALITY MODELING

Air quality modeling to assess regional haze has be en performed cooperatively between New Hampshire and its regional planning organization, M ANE-VU, with major modeling being conducted by NESCAUM and screening modeling being c onducted by NHDES. These modeling efforts include emissions processing, mete orological input analysis, and chemical transport modeling to perform regional air quality simulations for calendar year 2002 and several future periods, including the primary targe t date, 2018, for this SIP. Modeling was conducted in order to assess contributions from upw ind areas as well as New Hampshire’s
contribution to Class I areas in downwind states. Further, the modeling evaluated visibility benefits of specific control measures being conside red to achieve reasonable progress goals and establish a long-term emissions management stra tegy for MANE-VU Class I Areas.

Several modeling tools were utilized for these anal yses:

• The Fifth-Generation Pennsylvania State University/ National Center for Atmospheric Research (NCAR) Mesoscale Model (MM5) was used to d erive the required meteorological inputs for the air quality simulatio ns.

• The Sparse Matrix Operator Kernel Emissions (SMOKE) emissions modeling system was used to process and format the emissions invent ories for input into the air quality
models.

• The Community Mesoscale Air Quality model (CMAQ) wa s used for the primary SIP modeling.

• The Regional Model for Aerosols and Deposition (REM SAD) was used during contribution apportionment.

• The California Puff Model (CALPUFF) was used to ass ess the contribution of
individual states’ emissions to sulfate levels at s elected Class I receptor sites.

• The CALGRID photochemical grid model was used to pe rform screening-level analyses of emission control strategies.

Each of these tools has been evaluated and found to perform adequately. The SIP-pertinent modeling underwent full performance testing, and th e results were found to meet the specifications of EPA modeling guidance.

For more details on the regional haze modeling, ref er to the NESCAUM report, “MANE-VU Modeling for Reasonable Progress Goals: Model Perfo rmance Evaluation, Pollution Apportionment, and Control Measure Benefits,” Febru ary 7, 2008 (Attachment G). The detailed modeling approach for the most recent 2018 projections can be found in NESCAUM’s “2018 Visibility Projections,” May 13, 20 08 (Attachment Q).



### 7.1 Meteorology

The meteorological inputs for the air quality simul ations were developed by the University of Maryland (UMD) using the MM5 meteorological modelin g system. Meteorological inputs were generated for 2002 to correspond with the base line emissions inventory and analysis year. The MM5 simulations were performed on a nest ed grid (Figure 7.1). The modeling domain is composed of a 36-km, 145 x 102 continenta l grid and a nested 12-km, 172 x 172New Hampshire Regional Haze SIP Revision Page 56

grid encompassing the eastern United States and par ts of Canada. In cooperation with the New York State Department of Conservation (NYSDEC), an assessment was made for the period of May-September 2002 to compare the MM5 pre dictions with observations from a variety of data sources, including:

• Surface observations from the National Weather Serv ice and the Clean Air Status and Trends Network (CASTNET),

• Wind-profiler measurements from the Cooperative Age ncy Profilers (CAP) network,

• Satellite cloud image data from the UMD Department of Atmospheric and Oceanic Science, and

• Precipitation data from the Earth Observing Laborat ory at NCAR.

Further details regarding the MM5 meteorological pr ocessing and the modeling domain can be found in NYSDEC’s technical support document TSD -1a, “Meteorological Modeling Using Penn State/NCAR 5 th Generation Mesoscale Model (MM5),” February 1, 200 6 (Attachment R), and in the NESCAUM report, “MANE-VU Modeling for Reasonable Progress Goals, Model Performance Evaluation, Pollu tion Apportionment, and Control Measure Benefits,” November 27, 2007 (Attachment G)

.

Figure 7.1: Modeling Domains Used in MANE-VU Air Q uality

Modeling Studies with CMAQ

Note: Outer (blue) domain is 36-km grid. Inner (r ed) domain is 12-km grid. Gridlines are shown at 1 80-km intervals (5×5 36-km cells and 15×5 12-km cells).New Hampshire Regional Haze SIP Revision Page 57



### 7.2 Data Preparations

Emissions data were prepared for input into the CMA Q and REMSAD air quality models using the SMOKE emissions modeling system. SMOKE s upports point, area, mobile (both on-road and non-road), and biogenic emissions. The SMOKE emissions modeling system uses flexible processing to apply chemical speciati on as well as temporal and spatial allocation to the emissions inventories. SMOKE incorporates t he Biogenic Emission Inventory System (BEIS) and EPA’s MOBILE6 motor vehicle emission fac tor model to process biogenic and on-road mobile emissions, respectively. Vector-mat rix multiplication is used during the final processing step to merge the various emissions comp onents into a single model-ready emissions file. Examples of processed emissions ou tputs are shown in Figure 7.2.

Further details on the SMOKE processing conducted i n support of the air quality simulations is provided in NYSDEC’s technical support document TSD-1c, “Emission Processing for the Revised 2002 OTC Regional and Urban 12 km Base Case Simulations,” September 19, 2006 (Attachment P), and in NESCAUM’s report, “MANE-VU M odeling for Reasonable Progress Goals, Model Performance Evaluation, Pollution Appo rtionment, and Control Measure Benefits,” February 7, 2008 (Attachment G). Additi onal details on the emissions inventory preparation can be found in Section 6 of this repor t.



### 7.3 Model Platforms

Two regional-scale air quality models, CMAQ and REM SAD, were used for the air quality simulations that directly supported the regional ha ze SIP effort. CMAQ was developed by EPA and was used to perform the primary SIP-related modeling. The CMAQ modeling simulations were also an important tool for the 8-h our ozone SIP process. REMSAD was developed by ICF Consulting/Systems Applications In ternational with support from EPA. REMSAD was used by NESCAUM to perform a source appo rtionment (contribution assessment) analysis. All of the air quality simul ations that were used in the SIP efforts were performed on the 12-km eastern modeling domain show n in Figure 7.1, above.

NYSDEC performed an extensive model performance ana lysis to evaluate CMAQ model predictions against observations of ozone, PM 2.5 , and other pollutant species. This model performance evaluation is described in detail in NY SDEC’s technical support document TSD1e, “CMAQ Model Performance and Assessment, 8-Hr OT C Ozone Modeling,” February 23, 2006 (Attachment S). A model performance evaluatio n for PM 2.5 species, aerosol extinction coefficient, and the haze index is provided in NESC AUM’s report, “MANE-VU Modeling for Reasonable Progress Goals, Model Performance Evalua tion, Pollution Apportionment, and Control Measure Benefits,” February 7, 2008 (Attach ment G).New Hampshire Regional Haze SIP Revision Page 58

Figure 7.2: Examples of Processed Model-Ready Emis sions: (a) SO 2 from Point,

(b) NO 2 from Area, (c) NO 2 from On-Road, (d) NO 2 from Non-Road, (e) Isoprene from Biogenic, and (f) SO 2 from all Source CategoriesNew Hampshire Regional Haze SIP Revision Page 59

7.3.1 CMAQ

The CMAQ air quality simulations were performed coo peratively among five modeling centers: NYSDEC, the New Jersey Department of Envir onmental Protection (NJDEP) in association with Rutgers University, the Virginia D epartment of Environmental Quality (VADEQ), UMD, and NESCAUM. NYSDEC also performed a n annual 2002 CMAQ simulation on the 36-km domain shown in Figure 7.1; this simulation was used to derive the boundary conditions for the inner 12-km eastern mod eling domain. Boundary conditions for
the 36-km simulations were obtained from a run of t he GEOS-Chem (Goddard Earth Observing System) global chemistry transport model that was performed by researchers at Harvard University. The technical options that wer e used in performing the CMAQ
simulations are described in detail in NYSDEC’s tec hnical support document TSD-1d, “8hr Ozone Modeling Using the SMOKE/CMAQ System,” Februa ry 1, 2006 (Attachment T). Further technical details regarding the CMAQ model and its execution are also provided in NESCAUM’s report, “MANE-VU Modeling for Reasonable Progress Goals, Model Performance Evaluation, Pollution Apportionment, an d Control Measure Benefits,” February 7, 2008 (Attachment G).

7.3.2 REMSAD

The REMSAD modeling simulations were used to produc e the contribution assessment required by the Regional Haze Rule. REMSAD’s speci es tagging capability makes it an important tool for this purpose. The REMSAD model simulations were performed on the same 12-km eastern modeling domain as shown in Figu re 7.1. NESCAUM’s report, “MANE-VU Modeling for Reasonable Progress Goals, Mo del Performance Evaluation, Pollution Apportionment, and Control Measure Benefi ts,” February 7, 2008 (Attachment G), further describes the REMSAD model and its applicat ion to the regional haze SIP efforts.

7.3.3 CALGRID

In addition to the SIP-quality modeling platforms d escribed above, another modeling platform was developed for use as a screening tool to evalua te additional control strategies or to perform sensitivity analyses. The CALGRID model wa s selected as the basis for this platform. CALGRID is a grid-based photochemical ai r quality model that is designed to be
run in a Windows environment. In order to make the CALGRID model the best possible tool to supplement the SIP-quality CMAQ and REMSAD model ing, the current version of the CALGRID platform was set up to be run with the same set of inputs as the SIP-quality models. The CALGRID air quality simulations were r un on the same 12-km eastern modeling domain that was used for CMAQ and REMSAD. This model’s performance was comparable to the performance of the already evalua ted CMAQ and REMSAD models and was thus determined to perform adequately.

Conversion utilities were developed to reformat the meteorological inputs, the boundary conditions, and the emissions data for use with the CALGRID modeling platform. Premerged SMOKE emissions files were obtained from the modeling centers and reformatted for input into Emission Processor version 6 (EMSPROC6), the emissions pre-processor for the CALGRID modeling system. EMSPROC6 allows the CALGR ID user to adjust emissions temporally, geographically, and by emissions catego ry for control strategy analysis. The premerged SMOKE files that were obtained from the mode ling centers were broken down into the biogenic, point, area, non-road, and on-road em issions categories. These files byNew Hampshire Regional Haze SIP Revision Page 60

component were then converted for use with EMSPROC6 , thus giving CALGRID users the flexibility to analyze a wide variety of emissions control strategies. Additional information on the CALGRID modeling platform can be found in NH DES’ “Modeling Protocol for the OTC CALGRID Screening-Level Modeling Platform for t he Evaluation of Ozone,” May 23, 2007 (Attachment U).

7.3.4 CALPUFF

CALPUFF is a non-steady-state Lagrangian puff model that simulates the dispersion, transport, and chemical transformation of atmospher ic pollutants. Two parallel CALPUFF modeling platforms were developed by the Vermont De partment of Environmental Conservation (VTDEC) and the Maryland Department of the Environment (MDE). The VTDEC CALPUFF modeling platform utilized meteorolog ical observation data from the National Weather Service (NWS) to drive the CALMET meteorological model. The MDE platform utilized the same MM5 meteorological input s that were used in the modeling done in support of the ozone and regional haze SIPs. These two platforms were run in parallel to
evaluate individual states’ contributions to sulfat e levels at Northeast and Mid-Atlantic Class I areas. The CALPUFF modeling effort is described in detail in NESCAUM’s report, “Contributions to Regional Haze in the Northeast an d Mid-Atlantic United States,” August 2006 (Attachment B).

References

Center for Environmental Modeling for Policy Develo pment, University of North Carolina at Chapel Hill. Sparse Matrix Operator Kernel Emissions (SMOKE) Mod el

. http://www.smoke-model.org/index.cfm

.

Community Modeling and Analysis System (CMAS) Cente r, University of North Carolina at Chapel Hill. Community Multiscale Air Quality (CMAQ) Modeling Sy stem. http://www.cmaq-model.org

.

ICF International/Systems Applications Internationa l. Regional Modeling System for Aerosols and Deposition (REMSAD) . http://remsad.saintl.com

.

Pennsylvania State University/National Center for A tmospheric Research. Mesoscale Model (MM5) . http://www.mmm.ucar.edu/mm5/mm5-home.html

.

Scire, J.S., Strimaitis, D.G., and Yamartino, R.J. A User’s Guide for the CALPUFF Dispersion Model (Version 5) . January 2000.New Hampshire Regional Haze SIP Revision Page 61

# # # #

# #

# 

## Contributions to PM 2.5 

## Extinction at 7 Sites

20% Worst Visibility Days (2000-2004)

Soil

Sea Salt

OC

EC

Nitrate

Sulfate

0 20 40 60 80 100 120 140 160 180

100 120 140 160 180Extinction (Mm-1)

Dolly Sods

Shenandoah Brigantine Lye Brook Great Gulf Acadia

Moosehorn 

### 8. UNDERSTANDING THE SOURCES OF HAZE-CAUSING POLLUTANTS

This section explores the origins, quantities, and roles of visibility-impairing pollutants
emitted in the eastern United States and Canada tha t contribute significantly to regional haze at MANE-VU’s mandatory Class I areas.



### 8.1 Fine-Particle Pollutants

The pollutants primarily responsible for fine parti cle formation, and thus contributing to regional haze, include SO 2 , NO X , VOCs, NH 3 , PM 10 , and PM 2.5 . The MANE-VU Contribution Assessment (Attachment B), finalized in August 2006 , reflects a conceptual model in which sulfate emerges as the most important single consti tuent of haze-forming fine particle pollution and the principle cause of visibility imp airment across the Northeast region. Sulfate alone accounts for anywhere from 1⁄2 to 2⁄3 of total fine particle mass on the 20 percent hazi est days at MANE-VU Class I Areas. This translates to about 2⁄3 to 3⁄4 of visibility extinction on those days.

Visibility extinction is a measure of the ability o f particles to scatter and absorb light. Extinction is expressed in units of inverse mega-me ters (Mm -1 ). Figure 8.1 shows the dominance of sulfate in visibility extinction calcu lated from 2000-2004 baseline data for
seven Northeast Class I Areas.

Figure 8.1: Contributions to PM 2.5 Extinction at Seven Class I AreasNew Hampshire Regional Haze SIP Revision Page 62

Given the dominant role of sulfate in the formation of regional haze in the Northeast and MidAtlantic Regions, MANE-VU concluded that an effecti ve emissions management approach would rely heavily on broad-based regional SO 2 control measures in the eastern United States.
The focus on SO 2 as MANE-VU’s first priority makes sense not only b ecause of its dominant role in regional haze but also because its emission sources are well understood. Moreover, the
control measures needed for SO 2 emission reductions are readily available, cost-ef fective, and could be implemented quickly. On the basis of the scientific evidence, it is apparent that the bulk of haze-causing pollution can be eliminated by pursuing SO 2 emission controls.

Organic carbon was found to be the next largest con tributor to haze after sulfate. In comparison with sulfate, the emission sources of or ganic carbon, are diverse, variable, more diffuse, and less well understood; and the problem of controlling organic carbon emissions is exceedingly complex. For these reasons, MANE-VU co nsidered organic carbon to be the subject of possible future control measures but not a specific target pollutant in the initial strategy to mitigate regional haze.



### 8.2 Contributing States and Regions

The MANE-VU Contribution Assessment used various mo deling techniques, air quality data analysis, and emissions inventory analysis to ident ify source categories and states that contribute to visibility impairment in MANE-VU and nearby Class I areas. Based on estimates obtained by several evaluation methods, e missions that originated within MANEVU states contributed approximately one-fourth of t he total sulfate aerosol recorded at New Hampshire’s Class I areas in 2002. More specifical ly, four different estimation methods yielded the following contribution ranges: MANE-VU, 21-28 percent; MRPO, 20-27 percent; VISTAS, 12-18 percent; CenRAP, 2-5 percent; Canada, 7-19 percent; and all other regions, 23-24 percent (see Tables 8.1, 8.2, 8.3, and 8.5 of the Contribution Assessment for details).

It should be pointed out that the listed values for VISTAS, CenRAP, and Canada understate the actually percentage contributions from those re gions because they count only emissions originating within the modeling domain (see Figure 7.1). Actual contributions, especially in the case of CenRAP, would be considerably higher th an stated. Differences between actual and stated values are lumped into “Other.”

These findings highlight the importance of emission s from outside MANE-VU to visibility impairment inside the region. Note that, although there is some variation in the contribution estimates among the different assessment methods em ployed, there is a general consistency of
results from one method to another.

Table 8.1 displays the results of just one of the m ethods used (the REMSAD model) to assess state-by-state and regional contributions to annual sulfate impacts in nine Class I areas.New Hampshire Regional Haze SIP Revision Page 63

Table 8.1: Percent Contributions (Mass Basis) of I ndividual MANE-VU States and Other Regions to Total Annual Sulfate Impacts at Northeas t Class I Areas (REMSAD)

Mandatory Class I Area

Contributing State or Region Acadia

ME Brigantine

NJ Dolly Sods

WV Great Gulf &

Presidential Range - Dry River, NH Lye Brook

VT Moosehorn

& Roosevelt Campobello

ME Shenandoah

VA

Connecticut 0.76 0.53 0.04 0.48 0.55 0.56 0.08

Delaware 0.96 3.20 0.30 0.63 0.93 0.71 0.61

District of Columbia 0.01 0.04 0.01 0.01 0.02 0.01 0.04

Maine 6.54 0.16 0.01 2.33 0.31 8.01 0.02 Maryland 2.20 4.98 2.39 1.92 2.66 1.60 4.84

Massachusetts 10.11 2.73 0.18 3.11 2.45 6.78 0.35 New Hampshire 2.25 0.60 0.04 3.95 1.68 1.74 0.08
New Jersey 1.40 4.04 0.27 0.89 1.44 1.03 0.48

New York 4.74 5.57 1.32 5.68 9.00 3.83 2.03 Pennsylvania 6.81 12.84 10.23 8.30 11.72 5.53 12.05

Rhode Island 0.28 0.10 0.01 0.11 0.06 0.19 0.01

Vermont 0.13 0.06 0.00 0.41 0.95 0.09 0.01

MANE-VU 36.17 34.83 14.81 27.83 31.78 30.08 20.59

MRPO 11.98 18.16 30.26 20.10 21.48 10.40 26.84

VISTAS 8.49 21.99 36.75 12.04 13.65 6.69 33.86

CenRAP 0.88 1.12 1.58 1.65 1.67 0.82 1.48

Canada 8.69 7.11 3.90 14.84 12.43 7.85 4.75

Other 33.79 16.78 12.70 23.54 18.99 44.17 12.48

Note: Indicated percent contributions from, VISTAS , CenRAP, and Canada apply only to those portions l ying within the modeling domain (see Figure 7.1). Actual contributions, esp ecially from CenRAP, would be higher than stated.

Source: Table 8-1 of the MANE-VU Co ntribution Assessment

Figures 8.2 and 8.3, also borrowed from the Contrib ution Assessment, illustrate another method for identifying and ranking states’ contribu tions to sulfate at Class I areas using the 2002 data. This simple technique for deducing the relative impact of emissions from specific point sources on specific receptor sites involves c alculating the ratio of annual emissions (Q) to source-receptor distance (d). The ratio (Q/d) i s then multiplied by a factor to account for the frequency effect of prevailing winds. The use of this technique is explained in the Contribution Assessment (see pages 4-12 to 4-17 of Attachment B).New Hampshire Regional Haze SIP Revision Page 64

Figure 8.2: Ranked Sulfate Contributions to Northe ast Class I Receptors Based on

Q/d Method (Mass Basis), by Location of Origin

0.00 0.10 0.20 0.30 0.40 0.50 0.60 0.70CanadaPAOHINNYMIWVILGAMAKYNCVAMDALTNTXMOFLWINJMESCNHDEKSMNIACTOKMSLANEVTARRIDCAnnual Average Contribution (μg/m3 SO4)

Acadia

Great Gulf
Lye Brook

Moosehorn

Figure 8.3: Ranked Sulfate Contributions to Mid-At lantic Class I Receptors Based on

Q/d Method (Mass Basis), by Location of Origin

0.00 0.10 0.20 0.30 0.40 0.50 0.60 0.70OHPAWVNCCanadaMDINVAKYGANYILTNMIALNJTXFLDESCMOWIMAMSKSMNOKIALACTNHARNEMEDCRIVTAnnual Average Contribution (μg/m3 SO4)

Brigantine Dolly Sods

Shenandoah

The first of the Q/d plots covers the four northern Class I areas with IMPROVE monitoring in
MANE-VU. The second covers one Class I area in the southern part of MANE-VU and two neighboring Class I areas in the VISTAS region. Ob serve, again, the comparative importance
of emissions from Canada and from states outside th e MANE-VU region.New Hampshire Regional Haze SIP Revision Page 65

The ranking of emission contributions to visibility impairment in the MANE-VU Class I Areas by methods such as these has direct relevance to the consultation process described previously in Section 3, Regional Planning and Cons ultation. Using results from the REMSAD model, MANE-VU applied the following three c riteria to identify states and regions for the purposes of consultation on regiona l haze:

1. Any state/region that contributed 0.1 μ g/m 3 sulfate or greater on the 20 percent worst visibility days in the base year (2002),

2. Any state/region that contributed at least 2 percen t of total sulfate observed on the 20 percent worst visibility days in 2002, and

3. Any state/region among the top ten contributors on the 20 percent worst visibility days
in 2002.

For the purposes of deciding how broadly to consult , the MANE-VU States settled on the second of the three criteria: any state/region that contributed at least 2 percent of total sulfate observed on the 20 percent worst visi bility days in 2002.

In Figures 8.4 through 8.10, below, states and regi ons meeting the three listed criteria are identified graphically for seven Class I areas: She nandoah and Dolly Sods are Class I areas in the VISTAS region that are impacted by emissions fr om MANE-VU states; the other five
Class I areas are in MANE-VU. Note that the IMPROV E monitor at Great Gulf also represents the Presidential Range - Dry River Wilde rness, and the IMPROVE monitor at Moosehorn also represents Roosevelt Campobello Inte rnational Park.

Each figure has the following components:

• On the left is a single bar graph of the IMPROVE-mo nitored PM 2.5 mass concentration ( μ g/m 3 ) by constituent species for the baseline years 200 0-2004. The yellow, bottom portion of the bar represents the measured sulfate concentration.

• The middle component of each figure provides a bar graph of the 2002 total sulfate contribution of each state or region as estimated b y REMSAD.

• Finally, the right segment contains three maps show ing which states meet the criteria
described above.

Connecticut, Rhode Island, Vermont, and the Distric t of Columbia were not identified as being among the political or regional units contrib uting at least 2 percent of sulfate at any of the seven Class I areas. However, as participants in MANE-VU, those entities have agreed to pursue adoption of regional control measures aimed at visibility improvement on the haziest days and prevention of visibility degradation on th e clearest days.New Hampshire Regional Haze SIP Revision Page 66

Figure 8.4: Modeled 2002 Contributions to Sulfate at Great Gulf, by State



# Great Gulf

20% Worst Days

0 2 4 6 8 10 12

Great Gulf

Sulfate Nitrate EC OC Sea Salt Soil

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Great Gulf CA NA DA

CENRA P

SE_BC

W_BC

N_BC

DC

MS

V T

RI

ME

CT

DE

A L

NJ

WI

SC

TN

V A

IL

MD

GA

NH

KY

NC

MI

WV

IN

MA

NY

PA

OH IMPROVE mass 00-04 Threshold options REMSAD 2002 Contribution to Sulfate 0.1 μg/m 3 Sulfate

2 % of Sulfate

Top 10 Statesμg/m3

# # #

Figure 8.5: Modeled 2002 Contributions to Sulfate at Brigantine, by State



# Brigantine

20% Worst Days

0 5 10 15 20 25

Brigantine

Sulfate Nitrate EC OC Sea Salt Soil

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Brigantine CA NA DA

CENRA P

SE_BC

W_BC

N_BC

V T

RI

ME

DC

MS

CT

NH

MA

WI

NY

A L

IL

SC

MI

KY

TN

IN

NJ

DE

GA

WV

MD

V A

NC

OH

PA 0.1 μg/m 3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 Threshold options REMSAD 2002 Contribution to Sulfateμg/m3

# # #New Hampshire Regional Haze SIP Revision Page 67

Figure 8.6: Modeled 2002 Contributions to Sulfate at Lye Brook, by State



# Lye Brook

20% Worst Days

0 2 4 6 8 10 12 14 16

Lye Brook

Sulfate Nitrate EC OC Sea Salt Soil

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Lye Brook CANA DA

CENRAP

SE_BC

W_BC

N_BC

DC

RI

MS

ME

CT

V T

NH

WI

DE

SC

A L

NJ

IL

MA

TN

GA

MI

KY

V A

IN

NC

MD

WV

NY

OH

PA 0.1 μg/m 3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 Threshold options REMSAD 2002 Contribution to Sulfateμg/m3

# # #

Figure 8.7: Modeled 2002 Contributions to Sulfate at Acadia, by State



# Acadia

20% Worst Days

0 2 4 6 8 10 12

Acadia

Sulfate Nitrate EC OC Sea Salt Soil

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

A cadia CA NA DA

CENRA P

SE_BC

W_BC

N_BC

DC

MS

VT

RI

AL

DE

WI

CT

TN

GA

SC

NJ

VA

IL

KY

MD

MI

NC

NH

IN

WV

ME

NY

PA

OH

MA 0.1 μg/m 3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 Threshold options REMSAD 2002 Contribution to Sulfateμg/m3

# # #New Hampshire Regional Haze SIP Revision Page 68

Figure 8.8: Modeled 2002 Contributions to Sulfate at Moosehorn, by State



# Moosehorn

20% Worst Days

0 2 4 6 8 10 12

Moosehorn

Sulfate Nitrate EC OC Sea Salt Soil

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Moosehorn CA NA DA

CENRAP

SE_BC

W_BC

N_BC

MS

DC

VT

RI

AL

CT

WI

DE

SC

TN

GA

NJ

VA

MI

IL

KY

NH

MD

NC

IN

WV

ME

NY

OH

PA

MA 0.1 μg/m 3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 Threshold options REMSAD 2002 Contribution to Sulfateμg/m3

# # #

Figure 8.9: Modeled 2002 Contributions to Sulfate at Shenandoah, by State



# Shenandoah

20% Worst Days

0 2 4 6 8 10 12 14 16 18 20

Shenandoah

Sulfate Nitrate EC OC Sea Salt Soil

IMPROVE mass 00-04 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Shenandoah CANADA

CENRAP

SE_BC

W_BC

N_BC

VT

RI

ME

DC

MS

NH

CT

MA

NJ

DE

SC

WI

AL

TN

IL

GA

NY

NC

MI

MD

VA

KY

IN

WV

PA

OH Threshold options

0.1 μg/m 3 Sulfate

2 % of Sulfate

Top 10 States

REMSAD 2002 Contribution to Sulfate # # #μg/m3New Hampshire Regional Haze SIP Revision Page 69

Figure 8.10: Modeled 2002 Contributions to Sulfate at Dolly Sods, by State



# Dolly Sods

20% Worst Days

0 2 4 6 8 10 12 14 16 18 20

Dolly Sods

Sulfate Nitrate EC OC Sea Salt Soil

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Dolly Sods CA NA DA

CENRA P

SE_BC

W_BC

N_BC

RI

V T

ME

DC

CT

NH

MA

MS

DE

NJ

WI

NY

MD

SC

MI

IL

V A

A L

TN

NC

GA

IN

KY

PA

WV

OH 0.1 μg/m 3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 Threshold options REMSAD 2002 Contribution to Sulfate # # #μg/m3



### 8.3 Emission Sources and Characteristics

As previously mentioned, the major pollutants respo nsible for regional haze are SO 2 , NO X , VOCs, NH 3 , PM 10 , and PM 2.5 . The following is a description of the sources (e .g., point, area, and mobile) and characteristics of pollutant emissi ons contributing to haze in the eastern United States. Emissions data and graphics present ed for the purposes of this section are
taken from the MANE-VU 2002 Baseline Emissions Inve ntory, Version 2.0 (note that the
more recent MANE-VU 2002 Baseline Emissions Invento ry, Version 3.0, released in April 2006, has superseded Version 2.0 for modeling purpo ses). Although the emissions inventory database also includes carbon monoxide (CO), this p rimary pollutant is not considered here because it does not contribute to regional haze.

8.3.1 Sulfur Dioxide (SO 2 )

SO 2 is the primary precursor pollutant for sulfate par ticles. Sulfate particles commonly account for more than 50 percent of particle-relate d light extinction at northeastern Class I areas on the clearest days and for as much as 80 pe rcent or more on the haziest days. Hence,
SO 2 emissions are an obvious target of opportunity for reducing regional haze in the eastern United States. Combustion of coal and, to a lesser extent, of certain petroleum products accounts for most anthropogenic SO 2 emissions. In fact, in 1998, a single source cate gory – coal-burning power plants – was responsible for two -thirds of total SO 2 emissions nationwide (NESCAUM, 2001a).

Figure 8.11 shows SO 2 emissions in the MANE-VU states as extracted from the 2002 MANE-VU inventory (MARAMA, 2005). Most states in t he region showed declines in
annual SO 2 emissions through 2002 compared with those from pr evious inventories.New Hampshire Regional Haze SIP Revision Page 70

This decline can be attributed in part to implement ation of Phase 2 of the Acid Rain Program,
which in 2000 further reduced allowable emissions b elow Phase 1 levels and extended emission limits to a greater number of power plants.

Figure 8.11: Annual Sulfur Dioxide (SO 2 ) Emissions, by State

0.0 0.2 0.4 0.6 0.8 1.0 1.2

C on n ec t icu t Delaware

D is tr ict o f Colu m b ia M a in e

M a r yla n d

M assachu s ett s

N e w H a m p sh ir e

N ew Je r se y New York

P e n ns y lv an ia

R ho d e Is la n d
Ve r mo n tmillion t/y MV 2002 v.3

The bar graph in Figure 8.12 displays the percentag e contributions from different emission source categories to annual SO 2 emissions in the MANE-VU states in 2002. The char t shows that point sources – consisting mainly of stationar y combustion sources for generating electricity, industrial power, and heat – dominate SO 2 emissions in the region. Smaller stationary combustion sources, referred to collecti vely as area sources, are another important source category in the MANE-VU states. These inclu de smaller industrial, commercial, and
institutional boilers as well as residential heatin g sources. By contrast, on-road and non-road mobile sources make a relatively minor contribution to overall SO 2 emissions in the region (NESCAUM, 2001a).New Hampshire Regional Haze SIP Revision Page 71

Figure 8.12: 2002 Sulfur Dioxide (SO 2 ) Emissions, by State Bar Graph = Percentage Fractions of Four Source Cat egories Line Graph = Total Annual Emissions (10 6 tpy)

0% 25% 50% 75% 100%

Con n e c ticut Dela wa r e

Di s trict o f Co l umb i a Ma in e

M a ryland Mass a chusetts

N ew Ha mp s h i re

Ne w J e rs e y Ne w Yo rk

Pe n nsylvania

Rh o d e I sla n d Vermon t 0.0 0.2 0.4 0.6 0.8 1.0 1.2million t/y

AREA NONROAD ONROAD POINT Emission

8.3.2 Volatile Organic Compounds (VOC)

Existing emissions inventories generally refer to v olatile organic compounds (VOCs) as hydrocarbons whose volatility and reactivity in the atmosphere make them particularly important to ozone formation. From a regional haze perspecti ve, there is less concern with the volatile organic gases emitted directly to the atmosphere th an with the secondary organic aerosols (SOAs) that VOCs form after undergoing condensation and oxidation. Thus the VOC inventory category is of interest primarily because of the organic carbon component of PM 2.5

.

After sulfate, organic carbon generally accounts fo r the next largest share of fine particle mass and particle-related light extinction at northeaste rn Class I sites. The term organic carbon encompasses a large number and variety of chemical compounds that may be emitted directly from emission sources as components of primary PM o r that may form in the atmosphere as secondary pollutants. The organic carbon present a t Class I areas includes a mix of species, including pollutants originating from anthropogenic (i.e., manmade) sources as well as biogenic hydrocarbons emitted by vegetation. Recen t efforts to cut back on manmade organic carbon emissions have been undertaken mainly for th e purpose of reducing summertime
ozone formation in urban centers. Future efforts t o make further reductions in organic carbon emissions may be driven by programs that address fi ne particles and visibility.

Understanding the source regions and transport dyna mics for organic carbon in MANE-VU and nearby Class I areas is likely to be more compl ex than for sulfate. This complexity derives from the large number and diversity of orga nic carbon species, the wide variation in their transport characteristics, and the fact that a given species may undergo numerous complex chemical reactions in the atmosphere. Thus , the organic carbon contribution toNew Hampshire Regional Haze SIP Revision Page 72

visibility impairment at most Class I areas in the region is likely to include manmade pollution from nearby sources, manmade pollution tr ansported from a distance, and biogenic emissions – especially terpenes from coniferous for ests.

As shown in Figure 8.13, the VOC inventory is domin ated by mobile (on- and off-road)
sources and area sources. Mobile sources of VOCs i nclude evaporative emissions from transportation fuels and exhaust emissions from gas oline passenger vehicles and dieselpowered, heavy-duty vehicles. VOC emissions may al so originate from a variety of area sources (including those that use organic solvents, architectural coatings, and dry cleaning fluids) as well as from some point sources (e.g., i ndustrial facilities and petroleum refineries).

Biogenic VOCs (not included in Figure 8.13) may pla y an important role within the rural settings typical of Class I areas. The oxidation o f hydrocarbon molecules containing seven or more carbon atoms is generally the most significant pathway for the formation of lightscattering organic aerosol particles (Odum et al., 1997). Smaller reactive hydrocarbons that may contribute significantly to urban smog (ozone) are less likely to play a role in organic aerosol formation, although it is noted that high o zone levels can have an indirect effect on visibility by promoting the oxidation of other avai lable hydrocarbons, including biogenic emissions (NESCAUM, 2001a). In short, further work is needed to characterize the organic carbon contribution to regional haze in the MANE-VU states and to develop emissions inventories that will be of greater value for visib ility planning purposes. As pointed out in Subsection 8.1, above, organic carbon could be the subject of future control measures to mitigate regional haze but is not the focus of init ial planning.

Figure 8.13: 2002 Volatile Organic Carbon (VOC) Em issions, by State

Bar Graph = Percentage Fractions of Four Source Cat egories Line Graph = Total Annual Emissions (10 6 tpy)

0% 25% 50% 75% 100%

Connecticut Del a war e

Distr i ct of Columbia M

ai ne Maryland

M ass achus et t s New Ham ps hire New Je rsey New Y or k Pennsyl v ania

R hode Is l and

V er mont 0.0

0.2 0.4 0.6 0.8 1.0 1.2million t/y

AREA NONROAD ONROAD POINT EmissionNew Hampshire Regional Haze SIP Revision Page 73

8.3.3 Oxides of Nitrogen (NO X )

NO X emissions contribute to visibility impairment in t he eastern U.S. by forming lightscattering nitrate particles. Nitrate generally ac counts for a substantially smaller fraction of fine particle mass and related light extinction tha n sulfate and organic carbon at northeastern Class I areas. Notably, nitrate may play a more im portant role in urban settings and in the wintertime. In addition, NO X may have an indirect effect on summertime visibili ty by virtue of its role in the formation of ozone, which in tur n promotes the formation of secondary organic aerosols (NESCAUM, 2001a).

Since 1980, nationwide emissions of NO X from all sources have shown little change. Emissions increased by 2 percent between 1989 and 1 998 (EPA, 2000a). To a large extent, increases from the industrial and transportation se ctors have been offset by emission reductions from power plant combustion sources impl emented during the same time period. Figure 8.14 shows NO X emissions in 2002 for each state in the MANE-VU re gion. In the several years just prior to 2002, most MANE-VU stat es experienced declining NO X emissions.

Mobile sources and power plants generally dominate state and national NO X emissions inventories. Nationally, power plants account for more than one-quarter of all NO X emissions, amounting to over six million tons annua lly. The electric sector plays an even larger role in parts of the industrial Midwest, whe re power plants contribute significantly to

NO X emissions. By contrast, mobile sources dominate t he NO X inventories for more urbanized MANE-VU states, as shown in Figure 8.15. In these states, on-road mobile sources (i.e., highway vehicles) represent the largest NO X source category. Emissions from non-road (i.e., off-highway) mobile sources, primarily diese l-powered engines, also make up a substantial fraction of the inventory.

Figure 8.14: Annual Nitrogen Oxide (NO X ) Emissions, by State

0.0 0.2 0.4 0.6 0.8 1.0

Co n ne c ti c ut Del a ware

Di s tr i c t o f Co l u mb i a Ma i ne

M a ryl a nd Massachusetts

Ne w Ha mp s hir e New Jersey

N ew Yo r k Pennsylv a nia

Rh od e Isla nd Vermontmillion t/y MV 2002 v.3New Hampshire Regional Haze SIP Revision Page 74

Figure 8.15: 2002 Nitrogen Oxide (NO X ) Emissions, by State Bar Graph = Percentage Fractions of Four Source Cat egories Line Graph = Total Annual Emissions (10 6 tpy)

0% 25% 50% 75% 100%

C o nnecticut Delaware

D i strict of Col u mbia Maine

Maryl and

M ass achusetts

N ew H ampshi r e

N e w Jer sey New York Penns yl vani a Rhode Island

Vermont 0.0

0.3 0.6 0.9million t/y

AREA NONROAD ONROAD POINT Emission

8.3.4 Primary Particulate Matter (PM 10 and PM 2.5 )

Directly emitted, or “primary,” particles (as disti nct from secondary particles that form in the atmosphere through chemical reactions involving pre cursor pollutants such as SO 2 and NO X ) can also contribute to regional haze. For regulato ry purposes, a distinction is made between particulate matter (PM) with an aerodynamic diamete r less than or equal to 10 micrometers (PM 10 ) and smaller particles with an aerodynamic diamete r less than or equal to 2.5 micrometers (PM 2.5 ).

Figures 8.16 and 8.17 show PM 10 and PM 2.5 emissions, respectively, for the MANE-VU states as reported for the 2002 base year. Most states sh owed a steady decline in annual PM 10 emissions in the years leading up to the 2002 inven tory. By contrast, emission trends for primary PM 2.5 were more variable.

Crustal sources are significant contributors of pri mary PM emissions. This category includes fugitive dust emissions from construction activitie s, paved and unpaved roads, and agricultural tilling. Typically, monitors estimate PM 10 emissions from these types of sources by measuring the horizontal flux of particulate mass a t a fixed downwind sampling location within perhaps 10 meters of a road or field. Compa risons between estimated emission rates for fine particles using these types of measurement techniques and observed concentrations of crustal matter in the ambient air at downwind recep tor sites suggest that physical or chemical processes remove a significant fraction of crustal material relatively quickly. As a result, it rarely entrains into layers of the atmosphere where it can be transported to downwind receptor locations. Because of this discrepancy between est imated emissions and observed ambient concentrations, modelers typically reduce estimates of total PM 2.5 emissions from all crustalNew Hampshire Regional Haze SIP Revision Page 75

sources by applying a factor of 0.15 to 0.25 to the total PM 2.5 emissions before including them in modeling analyses.

Figure 8.16: Primary Coarse Particle (PM 10 ) Emissions, by State

0.0 0.1 0.2 0.3 0.4 0.5

C o n n e c t i c u t

D e l a w a r e

D i s t r i c t o f C o l u m b i a M a i n e

M a r y l a n d

M a s s a c h u s e t t s

N e w H a m p s h i r e

N e w J e r s e y

N e w Y o r k

P e n n s y l v a n i a

R h o d e I s l a n d

V e r m o n tmillion t/y MV 2002 v.3

Figure 8.17: Primary Fine Particle (PM 2.5 ) Emissions, by State

0.00 0.02 0.04 0.06 0.08 0.10 0.12

C o n n e c t i c u t

D e l a w a r e

D i s t r i c t o f C o l u m b i a M a i n e

M a r y l a n d

M a s s a c h u s e t t s

N e w H a m p s h i r e

N e w J e r s e y

N e w Y o r k

P e n n s y l v a n i a

R h o d e I s l a n d

V e r m o n tmillion t/y MV 2002 v.3New Hampshire Regional Haze SIP Revision Page 76

From a regional haze perspective, crustal material generally does not play a major role. On the 20 percent best visibility days during the base line period (2000-2004), crustal PM accounted for six to eleven percent of particle-rel ated light extinction at MANE-VU Class I sites. On the 20 percent worst visibility days, ho wever, crustal material generally plays a much smaller role, ranging from two to three percen t visibility extinction, than other hazeforming pollutants. Moreover, the crustal fraction includes materials of natural origin, such as soil or sea salt, that is not targeted under the Re gional Haze Rule. Of course, the crustal fraction can be influenced by construction, agricul tural practices, and road maintenance (including wintertime salting). Thus, to the exten t that these types of activities are found to affect visibility at Northeastern Class I areas, co ntrol measures to reduce coarse and fine particulate matter deriving from crustal material m ay prove beneficial and are within the purview of EPA or state agencies.

Experience from the western United States, where th e crustal component has played a more significant role in overall particulate levels, may be applicable to the extent that it is relevant
to the situation in the eastern states. In additio n, a few areas in the Northeast, such as New Haven, Connecticut, and Presque Isle, Maine, have h ad some experience with the control of dust and road-salt stemming from regulatory obligat ions related to their past non-attainment status with respect to the NAAQS for PM 10

.

Current emissions inventories for the entire MANE-V U area indicate that residential wood combustion represents 25 percent of primary fine pa rticle emissions in the region. This finding implies that rural sources can play an impo rtant role as well as contributions from the region’s many populous urban areas. An important c onsideration in this regard is that residential wood combustion occurs mainly in the wi nter months, while managed or prescribed burning activities occur largely in othe r seasons. The latter category includes agricultural field-burning, prescribed burning of f orested areas, and miscellaneous burning activities such as construction waste burning. Par ticulate emissions from many of these sources can be managed by limiting allowed burning activities to times when favorable meteorological conditions can efficiently disperse the emissions.

Although data are currently lacking, New Hampshire and other MANE-VU states are concerned about the growing use of residential wood stoves by homeowners seeking alternatives to petroleum-based fuels for home heating. Recent, lo calized problems with smoke emissions from outdoor wood boilers (wood-fired hydronic heat ers) prompted the New Hampshire legislature, in August 2008, to pass a law that tig htens requirements on the sale, installation, and use of these devices. NHDES will keep close wa tch on smoke emissions from the
residential sector to determine whether additional control measures on this source category may be necessary in the next few years.

Figure 8.18, taken from Appendix B of the MANE-VU C ontribution Assessment, represents the results of source apportionment and trajectory analyses on wood smoke in the area extending from the Gulf States to the Northeast. T he green-highlighted portion of the map depicts the wood smoke source region in the Northea st states. The stars on the map represent air monitor sites (including those at several Class I areas) whose data sets were determined to be useful to the modeling analysis. Although New H ampshire’s Great Gulf Wilderness was not specifically analyzed, it is believed that the green portion of the map adequately characterizes the wood smoke source region in the v icinity of this Class I area.New Hampshire Regional Haze SIP Revision Page 77

Figure 8.18: Wood Smoke Source Regional Aggregatio ns

Northeast: ACAD, PMRC, LYBR Mid-Atlantic: WASH, SHEN, JARI Southeast: GRSM, MACA

MANE-VU’s “Technical Support Document on Agricultur al and Forestry Smoke Management in the MANE-VU Region,” September 1, 200 6 (Attachment V), concluded that fire from land management activities was not a majo r contributor to regional haze in MANEVU Class I Areas, and that the majority of emission s from fires were from residential wood
combustion.

Figures 8.19 and 8.20 show that area sources domina te primary PM emissions. (EPA’s National Emissions Inventory categorizes residentia l wood combustion and some other combustion sources as area sources.) The relative contribution of point sources is larger in the primary PM 2.5 inventory than in the primary PM 10 inventory because the crustal component of particulate emissions (consisting mainly of larger, or coarse, particles) contributes more to
overall PM 10 levels than to PM 2.5 levels. At the same time, pollution control equip ment commonly installed at large point sources is usuall y more efficient at capturing coarse particle
emissions.New Hampshire Regional Haze SIP Revision Page 78

Figure 8.19: 2002 Primary Coarse Particle (PM 10 ) Emissions, by State

Bar Graph = Percentage Fractions of Four Source Cat egories Line Graph = Total Annual Emissions (10 6 tpy)

0% 25% 50% 75% 100%

Conn e cticut Dela w a r e

D istri c t of Col u mbia M aine Mar y la n d

M a s sa c h u s e tt s New H a mps h ir e

N ew Jer s ey New Y o r k Penns y lvan i a Rhode Is l an d

V e r m o n t 0.0 0.2 0.4 0.6million t/y

AREA NONROAD ONROAD POINT Emission

Figure 8.20: 2002 Primary Fine Particle (PM 2.5 ) Emissions, by State

Bar Graph = Percentage Fractions of Four Source Cat egories Line Graph = Total Annual Emissions (10 6 tpy)

0% 25% 50% 75% 100%

Connecticut

D e la w are

D ist r ict of Colum b i a Maine

M aryl a nd Mass ach uset ts

New Hampshir e New Jersey New York

Pe nnsylvan i a Rhod e I s l an d Vermont 0.00

0.02 0.04 0.06 0.08 0.10 0.12million t/y

AREA NONROAD ONROAD POINT EmissionNew Hampshire Regional Haze SIP Revision Page 79

8.3.5 Ammonia Emissions (NH 3 )

Because ammonium sulfate ((NH 3 ) 2 SO 4 ) and ammonium nitrate (NH 3 NO 3 ) are significant contributors to atmospheric light scattering and fi ne particle mass, knowledge of ammonia emission sources is important to the development of effective regional haze reduction strategies. According to 1998 estimates, livestock agriculture and fertilizer use accounted for approximately 86 percent of all ammonia emissions t o the atmosphere (EPA, 2000b). However, improved ammonia inventory data are needed as inputs to the photochemical models used to simulate fine particle formation and transport in the eastern United States. States were not required to include ammonia in thei r emissions data collection efforts until fairly recently (see the Consolidated Emissions Rep orting Rule, 67 CFR 39602, June 10, 2002). Therefore, emissions data for ammonia do no t exist at the same level of detail or reliability as exists for other pollutants.

Ammonium ion (formed from ammonia emissions to the atmosphere) is an important constituent of airborne particulate matter, typical ly accounting for 10–20 percent of total fine particle mass. Reductions in ammonium ion concentr ations can be instrumental to controlling regional haze because such reductions yield proport ionately greater reductions in fine particle mass. Ansari and Pandis (1998) showed that a 1 μ g/m 3 reduction in ammonium ion could result in up to a 4 μ g/m 3 reduction in fine particulate matter. Decision mak ers, however, must weigh the benefits of ammonia reduction against the signi ficant role it plays in neutralizing acidic
aerosol. 14

To address the need for improved ammonia inventorie s, MARAMA, NESCAUM, and EPA funded researchers at Carnegie Mellon University (C MU) in Pittsburgh to develop a regional ammonia inventory (Davidson et al., 1999). This st udy focused on three issues with respect to current emission estimates: 1) a wide range of a mmonia emission factors, 2) inadequate temporal and spatial resolution of ammonia emission s estimates, and 3) a lack of standardized ammonia source categories.

The CMU project established an inventory framework with source categories, emission factors, and activity data that are readily accessi ble to the user. With this framework, users can obtain data in a variety of formats 15 and can make updates easily, allowing additional
ammonia sources to be added or emission factors to be replaced as better information becomes available (Strader et al., 2000; NESCAUM, 2 001b).

Figures 8.21 and 8.22 show estimated ammonia emissi ons for the MANE-VU states in 2002.
Area and on-road mobile sources dominate the ammoni a inventory data. Specifically, emissions from agricultural sources and livestock p roduction account for the largest share of estimated ammonia emissions in the MANE-VU region, except in the District of Columbia. The two other sources contributing significant emis sions are wastewater treatment systems and gasoline exhaust from highway vehicles.

14 SO 2 reacts in the atmosphere to form sulfuric acid (H 2 SO 4 ). Ammonia can partially or fully neutralize this strong acid to form ammonium bisulfate or ammonium sulfate. If pl anners focus future control strategies on ammonia a nd do not achieve corresponding SO 2 reductions, fine particles formed in the atmospher e will be substantially more acidic than those presently observed.

15 For example, the user will have the flexibility to choose the temporal resolution of the output emissi ons data or to spatially
attribute emissions based on land-use data.New Hampshire Regional Haze SIP Revision Page 80

Figure 8.21: Ammonia (NH 3 ) Emissions, by State

0.00 0.02 0.04 0.06 0.08 0.10 0.12

C o n n e ct i cu t

D e la w a r e

D is tr ic t o f C o lu mbi a M a in e

M a r y la n d

M a s s achu s e t ts

New Hampshire New Jersey New York Pennsylvan i a

Rh o de Island

V e rmontmillion t/y MV 2002 v.3

Figure 8.22: 2002 Ammonia (NH 3 ) Emissions, by State Bar Graph = Percentage Fractions of Four Source Cat egories Line Graph = Total Annual Emissions (10 6 tpy)

0% 25% 50% 75% 100%

Co n n e cticu t
De l a w are

Distri c t of Col u mbia Maine

Ma r y l a n d Massac h usetts New Hampshire

N e w Je r s e y

N ew Y ork

Pe n ns y lva n ia Rhode I s lan d

V e r m on t 0.00 0.01 0.02 0.03 0.04 0.05 0.06 0.07 0.08 0.09 0.10million t/y

AREA NONROAD ONROAD POINT EmissionNew Hampshire Regional Haze SIP Revision Page 81

References

Ansari, A. S., and Pandis, S.N., “Response of inorg anic PM to precursor concentrations,”
Environ. Sci. Technol

. , 32, 2706-2714, 1998.

Davidson, C., Strader, R., Pandis, S., and Robinson , A., Preliminary Proposal to MARAMA and NESCAUM: Development of an Ammonia Emissions Inven tory for the Mid-Atlantic States and New England . Carnegie Mellon University, Pittsburgh, PA, Janu ary 7, 1999.

Duyzer, J., “Dry Deposition of Ammonia and Ammonium Aerosols over Heathland,” J. Geophys. Res., 99(D9):18,757 – 18,763, 1994.

EPA, National Air Quality and Emission Trends Report, 19 98 , EPA 454/R-00-003 (available online), 2000a. http://www.epa.gov/oar/aqtrnd98/

.

EPA, National Air Pollutant Trends, 1900 – 1998 , EPA 454/R-00-002 (available online), 2000b. http://www.epa.gov/ttn/chief/trends/trends9 8/trends98.pdf

.

EPA, Emissions Inventories, 2005. http://www.epa.g ov/ttn/chief/eiinformation.html

.

MARAMA, MANE-VU 2002 Emissions Inventory, 2007. http://www.marama.org/visibility/Inventory%20Summar y/2002EmissionsInventory.htm

.

NESCAUM, “Regional Haze and Visibility in the North east and Mid-Atlantic States,” January 2001a.

NESCAUM, “Development of an Improved Ammonia Emissi ons Inventory for the United States,” December 2001b.

Odum, J.R., Jungkamp, T.P.W., Griffin, R.J., Flagan , R.C., and Seinfeld, J.H., “The Atmospheric Aerosol-forming Potential of Whole Gasoline Vapor,” Science , 276, 96-99, 1997.

Strader, R., Anderson, N., and Davidson, C., Development of an Ammonia Inventory for the Mid-Atlantic States and New England, Progress Repor t, October 18, 2000

. http://marama.org/rt_center/MARAMAprogress10-18-00. pdf

.New Hampshire Regional Haze SIP Revision Page 82



### 9. BEST AVAILABLE RETROFIT TECHNOLOGY (BART)

In the Regional Haze Rule, EPA included provisions for reducing emissions of visibilityimpairing pollutants from large sources that, becau se of their age, were exempted from new source performance standards (NSPS) established und er the Clean Air Act. These provisions, known as Best Available Retrofit Technology, or BAR T, are published in 40 CFR 51.308(e).

Under this part of the rule, New Hampshire is requi red to submit an implementation plan containing emission limitations representing Best A vailable Retrofit Technology and schedules for compliance with BART for each BART-el igible source that may reasonably be anticipated to cause or contribute to any impairmen t of visibility in any mandatory Class I area. This requirement applies unless New Hampshir e demonstrates that an emissions trading program or other alternative will achieve greater r easonable progress toward natural visibility conditions. New Hampshire, with the help of the MA NE-VU Regional Planning Organization, has developed a strategy meeting the requirements o f BART. This section of the SIP specifically addresses how New Hampshire’s plan sat isfies BART requirements. A more general description of BART implementation within M ANE-VU is presented later in Part 10.2.2 of Section 10, Reasonable Progress Goals.

The BART provisions of the Regional Haze Rule requi re states to develop an inventory of sources within each state that would be eligible fo r BART controls. The rule also:

• Outlines methods to determine whether a source is “ reasonably anticipated to cause or contribute to haze,”

• Defines the methodology for conducting BART control analysis,

• Provides presumptive performance levels for electri city generating units (EGUs) at fossil-fuel-fired power plants larger than 750 mega watts (all BART-eligible EGUs in New Hampshire are below this size); and

• Provides a justification for the use of the Clean A ir Interstate Rule (CAIR) as meeting BART requirements for CAIR-affected electrical gene rating units (EGUs). (Note: With the pending redesign of CAIR, EPA’s previous determ ination of regulatory equivalency is invalid. New Hampshire has always h eld that, because the old CAIR requirements were not source-specific, they should not, in the general case, be considered equivalent to BART requirements, which are source-specific. The location of a source remains an important factor in assessin g and controlling visibility impacts.)

Beyond the specific elements listed above, EPA has allowed the states a great deal of flexibility in implementing the BART program. Beca use of the collective importance of BART sources to the management of regional haze, th e MANE-VU Board decided, in June 2004, that a BART determination would be made by th e member states for each BARTeligible source, without exception. Consequently, New Hampshire has completed a BART analysis on all BART-eligible sources in the state. This process includes consideration of the available technology, potential improvements in visibility, and other factors described
later in this section.



### 9.1 BART Applicability

The BART requirements pertain to large facilities i n each of 26 source categories that meet certain criteria, including industrial boilers, pul p and paper mills, cement kilns, and other largeNew Hampshire Regional Haze SIP Revision Page 83

stationary sources. The BART program applies to un its installed and operated between 1962 and 1977 with the potential to emit more than 250 t ons per year of a visibility-impairing pollutant. Each BART-eligible unit must undergo a case-by-case analysis to determine whether new emission restrictions are appropriate to limit the unit’s impact on visibility at Class I areas.



### 9.2 BART-Eligible Sources in New Hampshire

A list of New Hampshire’s BART-eligible sources is presented in Table 9.1. These sources were identified using the methodology contained in 40 CFR Part 51, Appendix Y – Guidelines for BART Determinations under the Regional Haze Rul e, adopted July 6, 2005.

Table 9.1: BART-Eligible Sources in New Hampshire

MANE-VU
BART ID Source and Unit BART

Pollutants Location

NH1 Public Service of New Hampshire

Merrimack Station Unit MK2
320-MW EGU SO 2 NO X PM Bow, NH

NH2 Public Service of New Hampshire

Newington Station Unit NT1

400-MW EGU SO 2 NO X PM Newington, NH

Note: Both BART-eligible sources are located at po wer plants smaller than the 750-MW minimum
size for which EPA has provided presumptive performance levels.

9.2.1 Cap-Outs and Shutdowns

Many facilities in the MANE-VU region are relativel y small emission sources with potential emissions exceeding the BART applicability threshol d of 250 tons per year of haze-causing pollutants but whose actual emissions are well belo w 250 tons in any year. Some of these facilities may have accepted an enforceable permit limitation restricting their emissions to less than 250 tons per year. Any otherwise BART-eligibl e facility may be allowed to “cap-out” of BART by accepting enforceable permit limits. In ad dition, some BART-eligible facilities within the region may have permanently shut down. In New Hampshire, no BART-eligible facilities capped out or permanently shut down to a void BART.

9.2.2 Small Source Exemptions

As provided in 40 CFR 51.308(e)(1)(ii)I of the Regi onal Haze Rule, a state is not required to
make a BART determination for either SO 2 or NO X if a BART-eligible source has the potential to emit less than 40 tons per year of the se pollutants, or for PM 10 if a BART-eligible source emits less than 15 tons per year of this pol lutant. No BART-eligible sources in New Hampshire have been exempted from the BART determin ation process.

9.2.3 Large Electrical Generating Units

Under 40 CFR 51.308(e)(1)(ii)(B), the determination of BART for large EGUs at fossil-fuelfired power plants having a total generating capaci ty greater than 750 megawatts must follow the guidelines presented in 40 CFR Part 51, Appendi x Y. This part of the rule defines the process for making BART determinations on a case-by -case basis. (States are not required toNew Hampshire Regional Haze SIP Revision Page 84

use this process when making BART determinations fo r other types of sources.) Because all BART-eligible EGUs in New Hampshire are installed a t power plants smaller than 750 MW, they are not subject to the guidelines of 40 CF R Part 51, Appendix Y. However, as discussed in Subsection 9.4 below, NHDES has conduc ted a source-specific BART analysis using the Appendix Y guidelines for each of these E GUs.



### 9.3 Determination of BART Requirements for BART-Eli gible Sources and Analysis of Best Retrofit Technologies

40 CFR 51.308(e)(1)(ii)(A) requires that, for each BART-eligible source within the state, any BART determination must be based on an analysis of the best system of continuous emission control technology available and the associated emi ssion reductions achievable. In addition to considering available technologies, this analysis m ust evaluate five specific factors for each

source:

1. The costs of compliance,

2. The energy and non-air quality environmental impact s of compliance,

3. Any existing pollution control technology in use at the source,

4. The remaining useful life of the source, and
5. The degree of visibility improvement which may reas onably be anticipated from
the use of BART.

NESCAUM examined, from a regional perspective, the various options available to MANEVU states for meeting these requirements. The find ings are contained in the NESCAUM report “Five-Factor Analysis of BART Eligible Sourc es: Survey of Options for Conducting BART Determinations,” June 1, 2007 (Attachment W).

9.3.1 BART Determinations and Required Control Leve ls

NHDES has performed BART determinations for all BAR T-eligible sources in New Hampshire.
The BART level of control for each source was taken to be that level of continuous emission reductions that would be achieved by installation o f the best retrofit system, after considering the technology available, the costs of compliance, the energy and non-air quality environmental impacts of compliance, any pollution control equipm ent in use or in existence at the source, the remaining useful life of the source, and the de gree of improvement in visibility which may reasonably be anticipated to result from the use of such technology.

For its BART determinations on each BART-eligible s ource, NHDES used the method in 40 CFR Part 51, Appendix Y, Guidelines for BART Determ inations under the Regional Haze Rule. Because all BART-eligible EGUs located in Ne w Hampshire are less than 750 MW in capacity, NHDES performed case-by-case BART analyse s on these units. Detailed BART analyses for New Hampshire’s two BART sources, PSNH Merrimack Station Unit MK2 and PSNH Newington Station Unit NT1, are presented in A ttachment X. The application of BART to these two sources yields estimated emission reductions from the 2002 baseline year in the following amounts:

• Approximately 21,000 tons per year of sulfur dioxid e,

• No additional reduction in nitrogen oxides (existin g controls = BART), and

• No additional reduction in particulate matter (exis ting controls = BART).New Hampshire Regional Haze SIP Revision Page 85

Tables 9.2 and 9.3 summarize the BART determination s for the two BART-eligible sources in New Hampshire for the visibility-impairing pollutan ts SO 2 , NO X , and PM. Included in these tables are the baseline (2002 actual) and BART cont rol levels, BART emission limits, and annual emissions before and after BART implementati on.

In Table 9.2, the BART control level for sulfur dio xide, for PSNH Merrimack station Unit MK2, is stated as 90 percent. This control level i s based on implementation of New Hampshire’s Multiple Pollutant Reduction Program, R SA-125-O, which requires the installation and operation of a flue gas desulfuriz ation, or scrubber, system on both units at this facility. Because the scrubber will be optimi zed for mercury emission reductions, Unit MK2 may not experience the typical SO 2 removal efficiency of 95 percent associated with new FGD technology. Consequently, a more conservat ive SO 2 control level of 90 percent was established as an operating condition in the fa cility’s air permit. (The Multiple Pollutant Reduction Program requires the scrubber to operate at a sustained control level of 80 percent or greater for mercury emission reductions.) The r equired SO 2 control level effectively means
that actual SO 2 emission reductions must exceed 90 percent on average. To the extent that these higher SO 2 removal rates can be realized, they will be applie d against the less than 90- percent SO 2 reduction expected at Newington Station in order t o fulfill the state’s commitment to the MANE-VU targeted EGU strategy.

For PSNH Newington Station Unit NT1, the BART contr ol level for sulfur dioxide is based on a proposed emission limitation of 0.50 lb/MMBtu, applicable to all fuels and fuel mixtures. (The boiler can be fired with either natural gas or liquid fuel (i.e., residual fuel oil or biofuel), or it can be co-fired with both types of fuel at th e same time.) Note that SO 2 emissions from this unit may be further reduced with the planned i ntroduction of 0.5-percent-sulfur residual fuel oil by 2018 upon implementation of MANE-VU’s l ow-sulfur oil strategy (contingent on fuel availability and cost). See Parts 10.2.3 and 11.4.2 of this SIP for a detailed description of
this control measure.New Hampshire Regional Haze SIP Revision Page 86

Table 9.2: Emission Reductions Resulting from BART Controls

at PSNH Merrimack Station Unit MK2

Pollutant BART Controls Baseline Capacity
Factor (%) 2002 Baseline
Emissions (tpy) Baseline

Control
Level (%) BART

Control
Level (%) BART

Emission Limit Est. 2002

Emissions
after BART (tpy) Est. 2002

Emission
Reductions (tpy)

SO 2 Flue gas
desulfurization (FGD) (in progress) 72 20,902 40 16 90 17 (as initially modeled) 10% of uncontrolled

SO 2 emissions, calendar monthly avg. 2,090 18,812

NO X S elective c atalytic reduction (SCR) (existing) 72 2,871 85 85 (same as baseline) 0.37 lb/MMBtu,

calendar monthly avg. ( ≈ RACT limit) 2,871 0

PM Two electrostatic precipitators (ESPs) in series (existing) 72 210 99 99 (same as baseline) 0.08 lb/MMBtu

total suspended particulate (TSP) 18 210 0

Table 9.3: Emission Reductions Resulting from BART Controls

at PSNH Newington Station Unit NT1

Pollutant BART Controls Baseline Capacity
Factor (%) 2002 Baseline
Emissions (tpy) Baseline

Control
Level (%) BART

Control
Level (%) BART

Emission Limit Est. 2002

Emissions
after BART (tpy) Est. 2002

Emission
Reductions (tpy)

SO 2 SO 2 emission
limitation (proposed) 19 19 5,226 0 67 20 0.50 lb/MMBtu, calendar monthly avg. 1,742 3,484 21

NO X Overfire air and water injection (existing) 19 943 33 22 33 (same as baseline) 0.35 lb/MMBtu ( oil )

and 0.25 lb/MMBtu (oil/gas), daily avg. (= RACT limit) 943 0

PM ESP (existing) 19 196 42 / 93 23 42 / 93 (same as baseline) 0.22 lb/MMBtu

total suspended particulate (TSP) 196 0

16 The 40% baseline level of control for Unit MK2 is based on a switch to a lower-sulfur coal that occur red in 1994.

17 For modeling purposes, a control level of 90% from baseline 2002 SO 2 emissions has been applied as a conservative estimate of expected performance. The actual rate of reduction from baseline 2002 emissions will vary , depending on the sulfur content of coal used in future years. Unit MK2 will continue to be subject to Title V operatin g permit conditions that limit coal sulfur content to 2.0 lb/MMBtu gros s heat content and that require SO 2 emissions to be controlled to no more than 10 percent of the uncontrolled SO 2 emission rate (i.e., 90% SO 2 removal).

18 This revised emission limit will simultaneously app ly to Units MK1 and MK2. (Unit MK1 is not a BART-e ligible source).

19 The current Title V operating permit for PSNH Newi ngton Station limits the annual capacity factor for Unit NT1 to 66.2%. This capacity factor limit is expressed as a restri ction on the maximum annual heat input rating for t he unit.

20 Minimum expected reduction based on 100% use of re sidual fuel oil at 0.4% actual sulfur content, or a 50:50 ratio (Btu basis) of natural gas to residual fuel oil at 0.8% actual sulfur content.

21 Additional emission reductions beyond the stated va lue may occur with a switch to 0.5% low-sulfur oil upon implementation of MANE-VU’s low-sulfur oil strategy by no later than 2018.

22 The baseline level of NO X control was calculated by comparing emission test results from October 1992 (0.371 lb/MMBtu) to test results from 2001 (0.249 lb/MMBtu) after a num ber of NO X reduction projects were completed on Unit NT1.

23 The lower value is based on a 2001 stack test value of 0.058 lb/MMBtu and an AP42 uncontrolled emissio n factor of 0.103 lb/MMBtu. The higher value is the stated efficienc y under normal operating conditions from a 1971 Bue ll Envirotech Corp. performance specification for this unit; maximum ef ficiency under design conditions is stated as 98 pe rcent.New Hampshire Regional Haze SIP Revision Page 87

9.3.2 Visibility Improvements Resulting from BART

NHDES used the CALGRID photochemical model to perfo rm a screening-level analysis of the anticipated effects of BART controls at New Ham pshire’s two BART-eligible sources (see Part 7.3.3 for a description of the CALGRID mo deling platform). Separate CALGRID modeling runs were conducted to examine the effects of selected emission control measures
on each of these sources. One run assessed the eff ects of installing scrubber technology on
Unit MK-2 at PSNH Merrimack Station. The second ru n assessed the effects of switching to
lower-sulfur residual fuel oil for Unit NT-1 at PSN H Newington Station. Both simulations were performed for the full summer modeling episode (May 15 to September 15, 2002) and used the 2018 BOTW emissions inventory scenario as a baseline (see Part 6.1.2 for a description of all future-year emissions inventorie s). The CALGRID model outputs took the
form of ambient concentration reductions for SO 2 , PM 2.5 , and other haze-related pollutant within the region. NHDES post-processed the modele d concentration reductions to estimate the corresponding visibility improvements at Class I areas.

Based on the CALGRID modeling results, the installa tion of scrubber technology on Merrimack Station Unit MK-2 is expected to reduce m aximum predicted 24-hour average

SO 2 concentration impacts by up to 21 μ g/m 3 (8 ppb by volume) and maximum predicted 24- hour average PM 2.5 concentration impacts by up to 1 μ g/m 3 . The largest modeled pollutant
concentration reductions occur within a 50-kilomete r radius of the facility, an area which does not contain any federal Class I areas. For the aff ected Class I areas (located 100 to 500 kilometers away), reductions in the maximum predict ed concentrations of SO 2 , PM 2.5 , and other haze-related pollutants, combined, are expect ed to yield a nominal improvement in visibility (about 0.1 deciview) on direct-impact ha zy days.

For Newington Station Unit NT1, switching to lower- sulfur residual fuel oil is expected to reduce maximum predicted 24-hour average SO 2 concentration impacts by 2 μ g/m 3 and maximum predicted 24-hour average PM 2.5 concentration impacts by 0.1 μ g/m 3 . At the affected Class I areas, reductions in the maximum p redicted concentrations of SO 2 , PM 2.5 , and other haze-related pollutants, combined, would yiel d negligible visibility improvement.

In recognition of EPA’s preferred methodology for a ssessing visibility impacts, NHDES also conducted a limited set of CALPUFF modeling runs fo r the New Hampshire BART-eligible
sources under controlled and uncontrolled condition s. Results were tabulated for the average of the 20% worst visibility (about 22.8 dv) modeled days at each nearby Class 1 area. The BART guidelines suggest that models be used in a “r elative” way to estimate the expected visibility benefits of BART controls. NHDES normal ized the CALPUFF modeling results and then applied predicted concentrations to a loga rithmic best-fit equation to the actual
observed PM 2.5 -to-deciview relationship measured at Acadia NP, Gr eat Gulf NW, and Lye Brook NW. Thus, CALPUFF was applied in a relative way using real data as the basis. The CALPUFF-predicted visibility benefits from BART con trols on the 20% worst visibility days are shown in Tables 9-4 and 9-5 for New Hampshire’s two BART facilities:New Hampshire Regional Haze SIP Revision Page 88

Table 9-4. CALPUFF Modeling Results for Merrimack Station Unit MK2: Visibility Improvements from BART Controls on the 2 0% Worst Visibility Days

Pollutant Control Level Acadia NP Great Gulf NW Lye Brook

SO 2 90% with FGD 0.17 dv 0.15 dv 0.08 dv

NOx Additional 25%

with SCR upgrade 0.02 dv 0.01 dv < 0.01 dv

PM 99% with upgraded controls < 0.01 dv* < 0.01 dv* < 0.01 dv*

Table 9-5. CALPUFF Modeling Results for Newington Station Unit NT1: Visibility Improvements from BART Controls on the 2 0% Worst Visibility Days

Pollutant Control Level Acadia NP Great Gulf NW Lye Brook

1.0%-S Residual Fuel Oil (50% sulfur reduction**) 0.05 dv 0.04 dv 0.02 dv

0.5%-S Residual Fuel Oil (75% sulfur reduction**) 0.07 dv 0.06 dv 0.03 dv SO 2

0.3%-S Residual Fuel Oil

(85% sulfur reduction**) 0.08 dv 0.07 dv 0.04 dv

NOx 50% with SCR 0.01 dv < 0.01 dv* < 0.01 dv*

PM 99% with upgraded controls *** *** ***

* below sensitivity limit of model
** from maximum permitted level
*** Modeling for PM was not performed because exist ing controls may already be achieving greater than 90% reduction, and any visibility benefit would be below the model ’s sensitivity limit.

Further description of the assessment of visibility impacts from these two BART sources may be found in the detailed BART analyses presented in Attachment X.

9.3.3 BART-Eligible EGUs and the Role of CAIR

The BART-eligible EGUs in MANE-VU represent the lar gest opportunity for potential emission reductions among the various BART-eligible source categories. Under the Clean Air Interstate Rule (CAIR), the population of BART- eligible EGUs within the MANE-VU domain fall into three geographical groups.

• CAIR states (year-round) : EGUs in states eligible to participate in the (C AIR) program on a year-round basis (Delaware, District o f Columbia, Maryland, New Jersey, New York, and Pennsylvania, for SO 2 and NO X );

• CAIR states (seasonal) : EGUs in states eligible to participate in the se asonal CAIR program only (Connecticut and Massachusetts, for su mmertime NO X ); and

• Non-CAIR states : EGUs in states not eligible to participate in th e CAIR program (Maine, New Hampshire, Rhode Island, and Vermont).

In 40 CFR 51.308(e)(4), EPA established that a stat e’s participation in the CAIR program would satisfy BART requirements for BART-eligible E GUs that were also subject to CAIR.New Hampshire Regional Haze SIP Revision Page 89

This provision affected all BART-eligible EGUs in P ennsylvania, Delaware, Maryland, New Jersey, New York, the District of Columbia, and tho se EGUs located in Connecticut and Massachusetts that were also included in the CAIR p rogram, but only with respect to their
emissions of ozone-season NO X . Following the federal court’s remand of CAIR, th e BARTequivalency provision may be revised or rescinded.

The original purpose of BART was to require source- specific controls on BART-eligible units. NHDES has always maintained that emissions from BAR T-eligible EGUs and their impacts on visibility in Class I areas should be addressed as the BART rule intended. MANE-VU assessments have determined that allowing EGUs with the largest impacts on Class I areas to purchase allowances under the CAIR emissions tradin g program would produce less visibility benefit than intended by the BART rule. Accordingl y, MANE-VU developed a targeted EGU strategy in order to recapture some of the lost ben efit. (The targeted EGU strategy is discussed at length in Sections 10 and 11).



### 9.4 Alternatives to BART for Any Source

40 CFR 51.308(e)(1)(v)(2) of the Regional Haze Rule provides that a state may opt to implement an emissions trading program or other alt ernative measure rather than require sources subject to BART to install, operate, and ma intain BART. In such case, the state must demonstrate that the emissions trading program or o ther alternative measure will achieve greater reasonable progress than would be achieved through the installation and operation of BART. To make this demonstration, the state must s ubmit an implementation plan containing the elements listed in the above-referenced part of the rule.

New Hampshire does not support the provisions of th e BART rule that allow emissions trading programs or other alternative measures because they are not likely to yield visibility improvements equivalent to those that would accrue from source-specific BART controls. Consequently, NHDES does not propose to use alterna tive measures for BART-eligible sources in New Hampshire.



### 9.5 BART Enforceable Provisions and Implementation Schedule

The enforceable provisions and compliance schedule for BART are summarized in Tables 9-6 and 9-7 for New Hampshire’s two BART-eligible sourc es. The BART control measures will be enforceable through a combination of existing pe rmit conditions, existing administrative rules, and a proposed administrative rule to be ado pted as Chapter Env-A 2300 Mitigation of Regional Haze (see draft rule, Attachment GG).

40 CFR 51.308(e)(1)(iv) requires that BART must be in operation for each applicable source no later than five years after SIP approval. NHDES is requiring all BART-eligible sources to install and operate BART controls as expeditiously as practicable but in no case later than July 1, 2013.

40 CFR 51.308(e)(1)(v) requires that each source su bject to BART maintain the required control equipment and establish procedures to ensur e such equipment is properly operated and maintained. New Hampshire will meet this requireme nt by including in the Title V operating permit for each BART-eligible source provisions to ensure proper operation and maintenance of the control equipment. Note that, because New H ampshire does not have a merged construction permitting and Title V permitting prog ram, requirements related to BART willNew Hampshire Regional Haze SIP Revision Page 90

first need to be placed into a state temporary perm it (i.e., construction permit) before they can be incorporated subsequently into a federal Title V operating permit.

Table 9-6: BART Enforceable Provisions and Complia nce Schedule

for PSNH Merrimack Station Unit MK2

Pollutant BART Controls /

Emission Limitations Regulatory Citations* Compliance
Date

NO X SCR (existing);

NOx emission limit of 0.37 lb/MMBtu, calendar monthly average (proposed) Draft Title V operating permit (TV-0055);

Administrative Rule Env-A 2300 Mitigation of Regional Haze (proposed); Rule: July 1, 2013

PM Two ESPs in series (existing)

TSP emission limit of 0.08 lb/MMBtu (proposed) Draft Title V operating permit (TV-0055);

Administrative Rule Env-A 2300 Mitigation of Regional Haze (proposed) Rule: July 1, 2013

SO 2 Fuel sulfur limits (existing);

Flue gas desulfurization (FGD), with required SO 2 percent reduction set at maximum sustainable rate, but not less than 90% as a calendar monthly average (proposed) Administrative Rule Env-A 1606.01
Maximum Sulfur Content Allowable in Coal (existing);

Temporary permit for FGD system (TP-0008);

Draft Title V operating permit (TV-0055) FGD: July 1, 2013

Table 9-7: BART Enforceable Provisions and Complia nce Schedule

for PSNH Newington Station Unit NT1

Pollutant BART Controls /

Emission Limitations Regulatory Citations* Compliance
Date

NO X Overfire air and water injection (existing);

NOx emission limits of 0.35 lb/MMBtu with oil and 0.25 lb/MMBtu with oil/gas, 24-hour calendar day average (existing) Title V operating permit (TV-OP-054) N.A (Existing
controls are BART)

PM Electrostatic precipitator (existing);

TSP emission limit of 0.22 lb/MMBtu (existing) Title V operating permit (TV-OP-054) N.A (Existing controls are BART)

SO 2 SO 2 emission limit of 0.50 lb/MMBtu, calendar monthly average, applicable to any fuel type or mix (proposed) Administrative Rule Env-A 2300 Mitigation of Regional Haze (proposed) Rule: July 1, 2013

*Applicable permits and draft rules are available i n Attachments FF through II.

The tentative schedule for development and adoption of Env-A 2300 Mitigation of Regional
Haze is as follows:

Circulate rough draft of rule................................ January 2012 Confer with affected stakeholders.........................February - June 2012 Issue draft rule; initiate formal public process......... .. September 2012 Adopt final rule.............................................. May 2013 Final rule becomes effective by............ ................ July 1, 2013New Hampshire Regional Haze SIP Revision Page 91



### 10. REASONABLE PROGRESS GOALS

40 CFR 51.308 (d)(1) of the Regional Haze Rule requ ires New Hampshire to establish, for each Class I area within the state, reasonable prog ress goals (RPG) toward achieving natural visibility conditions. On June 1, 2007, the U.S. E nvironmental Protection Agency (EPA) released final guidance to be used by states in set ting reasonable progress goals. The goals must provide for visibility improvement on the days of greatest visibility impairment and ensure no visibility degradation on the days of lea st visibility impairment for the duration of the State Implementation Plan (SIP) period.

As provided in 40 CFR 51.308 (d)(1)(iv), the state must consult with other states in the setting of reasonable progress goals. The rule states:

“In developing each reasonable progress goal, the S tate must consult with those States which may reasonably be anticipated to cause or contribute to visibility impairment in the mandatory Class I Federal area. In any situation in which the State cannot agree with another such State or group of States that a goal provides for reasonable progress , the State must describe in its submittal the actions taken to resolve the disagreement. In revi ewing the State’s implementation plan submittal,
the Administrator will take this information into a ccount in determining whether the State’s goal for visibility improvement provides for reasonable prog ress towards natural visibility condition.”

New Hampshire consulted with states found to contri bute to visibility impairment at New Hampshire’s Class I areas and with states that requ ested consultation with New Hampshire regarding visibility conditions at their Class I ar eas. In particular, New Hampshire worked closely with the other MANE-VU states to ensure con sistency of approach in setting reasonable progress goals. Accordingly, New Hampshire agrees with the reason able progress goals established by Maine, Vermont, and N ew Jersey. A description of the consultation process is found under Section 3, Regi onal Planning and Consultation.

The Regional Haze Rule also requires each Class I s tate to consider four factors in setting reasonable progress goals: cost, time needed for co mpliance, energy and non-air quality environmental impacts, and remaining useful life. In addition, the state must show that it considered the uniform rate of improvement and the emission reduction measures needed to achieve it for the period covered by the implementa tion plan. If the state proposes a rate of progress slower than the uniform rate of progress, the state must assess the number of years it
would take to attain natural conditions if visibili ty improvement continues at the rate proposed.



### 10.1 Calculation of Uniform Rate of Progress

As a benchmark to aid in developing reasonable prog ress goals, MANE-VU compared baseline visibility conditions to natural visibilit y conditions at each MANE-VU Class I area.
The difference between baseline and natural visibil ity conditions for the 20 percent worst days was used to determine the uniform rate of progress that would be needed during each implementation period in order to attain natural vi sibility conditions by 2064. Table 10.1 presents baseline visibility, natural visibility, a nd required uniform rate of progress for each MANE-VU Class I area. Visibility values are expres sed in deciviews (dv), where each single-unit deciview decrease would represent a bar ely perceptible improvement in visibility.New Hampshire Regional Haze SIP Revision Page 92

Table 10.1: Uniform Rate of Progress Calculation ( all values in deciviews)

Class I Area 2000-2004
Baseline Visibility (20% Worst Days) Natural

Visibility (20% Worst Days) Total

Improvement Needed by
2018 Total

Improvement Needed by
2064 Uniform

Annual Rate of Improvement

Acadia National Park 22.9 12.4 2.4 10.5 0.174

Moosehorn Wilderness and Roosevelt Campobello
International Park 21.7 12.0 2.3 9.7 0.162

Great Gulf Wilderness and Presidential Range - Dry River
Wilderness 22.8 12.0 2.5 10.8 0.180

Lye Brook Wilderness 24.5 11.7 3.0 12.8 0.212

Brigantine Wilderness 29.0 12.2 3.9 16.8 0.280

Note: Both natural conditions and baseline visibil ity for the 5-year period from 2000 through 2004 we re calculated in conformance with an alternative method recommended by the IMPROVE St eering Committee. 24

The reasonable progress goals established for MANE- VU’s Class I Areas, described later in Subsection 10.3, are expected to provide visibility improvements in excess of the uniform rates of progress shown above.



### 10.2 Identification of (Additional) Reasonable Cont rol Measures

New Hampshire and the other MANE-VU states have ide ntified specific emission control measures – beyond those which individual states or RPOs had already made commitments to implement – that would be reasonable to undertake a s part of a concerted strategy to mitigate regional haze. The proposed additional control mea sures were incorporated into the regional strategy adopted by MANE-VU on June 20, 2007, to me et the reasonable progress goals
established in this SIP. The basic elements of thi s strategy are described in the New Hampshire/MANE-VU “Ask” (see Part 3.2.2 under Secti on 3, Regional Planning and Consultation). States targeted for coordinated act ions toward achieving these goals include all of the MANE-VU states plus Georgia, Illinois, India na, Kentucky, Michigan, North Carolina, Ohio, South Carolina, Tennessee, Virginia, and West Virginia. 25

In addition to including proposed emission controls in the eastern United States, MANE-VU
determined that it was reasonable to include antici pated emission reductions in Canada in the modeling used to set reasonable progress goals. Th is determination was based on evaluations conducted before and during the consultation proces s (see description of relevant consultations in Part 3.2.1). Specifically, the modeling account s for six coal-burning electric generating units (EGUs) in Canada having a combined output of 6,500 MW that are scheduled to be shut

24 “Baseline and Natural Visibility Conditions, Consi derations and Proposed Approach to the Calculation of Baseline and Natural Visibility Conditions at MANE-VU Class I Ar eas,” NESCAUM, December 2006.

25 In addition, Vermont identified at least one sourc e in Wisconsin as a significant contributor to visi bility impairment at the Lye Brook Wilderness Class I Area.New Hampshire Regional Haze SIP Revision Page 93

down and replaced by nine natural gas turbine units equipped with selective catalytic reduction (SCR) by 2018.

The process of identifying reasonable measures and setting reasonable progress goals is
described in the subsections which follow. Further elaboration on the reasonable measures which make up the New Hampshire/MANE-VU long-term s trategy is provided in Section 11 of this SIP. Under this plan, the affected states will have a maximum of 10 years to implement reasonable and cost-effective control mea sures to reduce primarily SO 2 and NO X emissions. For a description of how proposed emiss ion control measures were modeled to estimate resulting visibility improvements, see Sub section 10.4, Visibility Affects of (Additional) Reasonable Control Measures.

10.2.1 Rationale for Determining Reasonable Control s

40 CFR 51.308(d)(1)(i)(A) of EPA’s Regional Haze Ru le requires that, in establishing reasonable progress goals for each Class I area, th e state must consider the costs of compliance, the time necessary for compliance, the energy and non-air quality environmental impacts of compliance, and the remaining useful lif e of any potentially affected sources. The SIP must include a demonstration showing how these factors were taken into consideration in setting the RPGs. These factors are sometimes term ed the “four statutory factors,” since their consideration is required by the Clean Air Act.

Early Focus on SO 2 : MANE-VU conducted a Contribution Assessment (Att achment B) and developed a conceptual model that showed the domina nt contributor to visibility impairment at all MANE-VU Class I areas during all seasons in the base year was particulate sulfate
formed from emissions of SO 2 . While other pollutants, including organic carbon , will need to
be addressed in order to achieve the national visib ility goals, MANE-VU’s contribution assessment suggested that an early emphasis on SO 2 would yield the greatest near-term benefit. Therefore, it is reasonable to conclude t hat the additional measures considered in setting reasonable progress goals require reduction s in SO 2 emissions.

Contributing Source s : The MANE-VU Contribution Assessment indicates th at emissions from within MANE-VU in 2002 were responsible for ap proximately 25 percent of the sulfate
at MANE-VU Class I Areas. Sources in the Midwest a nd Southeast regions were responsible for about 15 to 25 percent each. Point sources dom inated the inventory of SO 2 emissions. Therefore, MANE-VU’s long-term strategy includes ad ditional measures to control sources of
SO 2 both within the MANE-VU region and in other states that were determined to contribute to regional haze at MANE-VU Class I Areas.

The Contribution Assessment documented the source c ategories most responsible for visibility degradation at MANE-VU Class I Areas. A s described in Section 11, Long-Term Strategy, there was a collaborative effort between the Ozone Transport Commission and MANE-VU to evaluate a large number of potential con trol measures. Several measures that
would reduce SO 2 emissions were identified for further study.

Four-Factor Analysis : These efforts led to production of the MANE-VU report by MACTEC Federal Programs, Inc., “Assessment of Reaso nable Progress for Regional Haze in MANE-VU Class I Areas,” Final, July 9, 2007, otherw ise known as the Reasonable Progress Report (Attachment Y). This report provides an ana lysis of the four statutory factors for five major source categories: electrical generating unit s (EGUs); industrial, commercial, andNew Hampshire Regional Haze SIP Revision Page 94

institutional (ICI) boilers; cement and lime kilns; heating oil combustion; and residential
wood combustion. Table 10.2 summarizes the results of MANE-VU’s four-factor analysis for the source categories considered.

Table 10.2: Summary of Results from Four-Factor An alysis of Different Source Categories

Source Category Primary

Regional
Haze
Pollutant Control Measure(s) Average Cost in
2006 dollars (per ton of pollutant reduction) Compliance

Timeframe Energy and NonAir Quality
Environmental Impacts Remaining

Useful Life

Electric Generating
Units SO 2

Switch to a low-sulfur coal (generally <1% sulfur); switch to natural gas (virtually 0% sulfur); coal cleaning; flue gas desulfurization (FGD), including wet, spray-dry, or dry. $775-$1,690
based on IPM®
v.2.1.9 *

$170-$5,700 based
on available
literature 2-3 years following

SIP submittal Fuel supply issues,

possible permitting issues, reduced electricity production capacity, wastewater
issues 50 years or

more

Industrial, Commercial,
Institutional
Boilers SO 2

Switch to a low-sulfur coal (generally <1% sulfur); switch to natural gas (virtually 0% sulfur); switch to a lower-sulfur oil; coal cleaning; combustion controls; flue gas desulfurization (FGD), including wet, spray-dry, or dry. $130-$11,000
based on available literature; dependent on size. 2-3 years following

SIP submittal Fuel supply issues,

potential permitting issues, control device energy requirements,
wastewater issues 10-30 years

Cement and
Lime Kilns SO 2

Fuel switching; flue gas desulfurization (FGD), including wet, spray-dry, or dry; advanced flue gas desulfurization (FGD). $1,900-$73,000
based on available literature; dependent on size. 2-3 years following

SIP submittal Control device

energy requirements,
wastewater issues 10-30 years

Heating Oil SO 2

Switch to lower-sulfur fuel (varies by state) $550-$750 based on available literature; high degree of uncertainty with this
cost estimate Currently feasible;

capacity issues may
influence timeframe for implementation
of new fuel standards Increased

furnace/boiler efficiency, reduced
furnace/boiler
maintenance requirements 18-25 years

Residential
Wood
Combustion PM State implementation of NSPS, ban on resale of uncertified devices, installer training certification or inspection program, pellet stoves, EPA Phase II certified RWC devices, retrofit requirement, accelerated changeover requirement or
inducement $0-$10,000 based on
available literature Several years,

depending on
mechanism for
emission reductions Increased efficiency

of combustion device, reduced greenhouse gas
emissions 10-15 years

* Integrated Planning Model® CAIR versus CAIR plus analysis conducted for MARAMA/MANE-VU by ICF Consul ting, L.L.C.

The MANE-VU states reviewed the four-factor analyse s presented in the Reasonable Progress Report, consulted with one another about possible c ontrol measures, and concluded by adopting the statements known as the MANE-VU Ask. These statements identify the control measures that would be pursued toward improving vis ibility in the region. The following discussions focus on the four basic control strateg ies chosen by MANE-VU and included in the modeling to establish the reasonable progress g oals:

1. Best Available Retrofit Technology (BART),

2. Low-sulfur fuel oil requirements,

3. Emission reductions from specific EGUs, and

4. Additional measures determined to be reasonable.New Hampshire Regional Haze SIP Revision Page 95

10.2.2 Best Available Retrofit Technology Controls

The MANE-VU states have identified approximately 10 0 BART-eligible sources in the region. Most of these facilities are already contr olling emissions in response to other federal or state air programs or are likely to install emis sion controls under new programs. (Previously, EPA determined that CAIR fulfilled the BART requirement for all EGUs in participating CAIR states. New Hampshire anticipat es that those same units will be covered under BART, by CAIR successor legislation, or by ne w rulemaking following the redesign of CAIR.) A complete compilation of BART-eligible sou rces in the MANE-VU region is available in Appendix A of MANE-VU’s “Assessment of Control Technology Options for BART-Eligible Sources,” March 2005, also known as t he BART Report (Attachment Z).

To assess the benefits of implementing BART in the MANE-VU region, NESCAUM estimated emission reductions for twelve BART-eligi ble sources in MANE-VU states that would probably be controlled as a result of BART re quirements alone. These sources include
one EGU and eleven non-EGUs. The affected sources were identified by a survey of states’ staff members, who furnished data on the potential control technologies and expected control levels for these sources under BART implementation. The twelve sources are listed in Table 10.3 along with their 2002 baseline and 2018 estima ted emissions. Information on these sources was incorporated into the 2018 emissions in ventory projections that were used in the modeling to set reasonable progress goals.

Table 10.3: Estimated Emissions from BART-Eligible Facilities in MANE-VU States

(Facilities Likely to be Controlled as a Result of BART Alone)

State Facility Name Unit
Name SCC Code Plant ID (MANE-VU Inventory) Point ID

(MANE-VU Inventory) Facility

Type 2002

SO 2 Emissions (tons) 2018

SO 2 Emissions (tons)

MD EastAlco Aluminum 28 30300101 021-0005 28 Metal Production 1,506 1,356

MD Eastalco Aluminum 29 30300101 021-0005 29 Metal Production 1,506 1,356

MD Lehigh Portland
Cement 39 30500606 013-0012 39 Portland
Cement 9 8

MD Lehigh Portland
Cement 16 30500915 021-0003 16 Portland
Cement 1,321 1,189

MD Lehigh Portland
Cement 17 30500915 021-0003 17 Portland
Cement 9,76 8,78

MD Westvaco Fine Papers 2 10200212 001-0011 2 Paper and Pulp 8,923 1,338

ME Wyman Station Boiler 3 10100401 2300500135 004 E GU 616 308

ME SAPPI Somerset Power Boiler 1 10200799 2302500027 001 Paper and Pulp 2,884 1,442

ME Verso Androscoggin
LLC Power

Boiler 1 10200401 2300700021 001 Paper and Pulp 2,964* 1,482

ME Verso Androscoggin
LLC Power

Boiler 2 10200401 2300700021 002 Paper and Pulp 3,086* 1,543

NY Kodak Park Division U00015 10200203 8261400205 U 00015 Chemical Manufacturer 2,3798 1,4216

NY Lafarge Building Materials, Inc 41000 30500706 4012400001 041000 Portland Cement 14,800 4,440

Note: Many additional sources in MANE-VU are BART- eligible but are expected to be controlled as a res ult of other emission reduction programs (e.g., state-specific m ulti-pollutant programs, a redesigned CAIR, etc.).
*Data for 1999 baseline year.New Hampshire Regional Haze SIP Revision Page 96

Best Available Retrofit Technology is Reasonable : BART controls are part of the strategy for improving visibility at MANE-VU Class I Areas. MANE-VU prepared reports to provide
states with information about available control tec hnologies (e.g., MANE-VU’s BART Report referenced above), estimated cost ranges, and other factors associated with those controls. The reasonable progress goals established in this r egional haze SIP assume that states whose emissions affect Class I areas in New Hampshire and elsewhere in MANE-VU will make determinations demonstrating the reasonableness of BART controls for sources in their states.

10.2.3 Low-Sulfur Fuel Strategy

The MANE-VU region, especially the Northeast, is he avily reliant on distillate oil for home space heating, with more than 4 million gallons use d, according to 2006 estimates from the Energy Information Administration 26 . Likewise, the heavier residual oils are widely u sed by non-EGU sources and, to a lesser extent, the EGU se ctor. The sulfur content of distillate fuels currently averages above 2,000 ppm (0.2 percent). Although the sulfur content of residual oils varies by source and region, it can exceed 2.0 percent. Combustion of distillate and
residual fuel in the MANE-VU states resulted in SO 2 emissions totaling approximately 380,000 tons in 2002.

As the second component of MANE-VU’s long-term stra tegy, the member states agreed to pursue measures that would require the sale and use of fuel oils having reduced sulfur content. This strategy would be implemented in two phases:

• Phase 1 would require reducing the sulfur content i n distillate (#1 and # 2) fuel oils from current levels of 2,000 to 2,300 ppm (0.20 to 0.23 percent) to a maximum of 500 ppm (0.05 percent) by weight. It would also restri ct the sale of heavier blends of residual (# 4, #5, and # 6) fuel oils that have sul fur content greater than 2,500 ppm (0.25 percent) and 5,000 ppm (0.5 percent) by weigh t, respectively.

• Phase 2 would require further reducing the sulfur c ontent of the distillate fraction from 500 ppm (0.05 percent) to 15 ppm (0.015 percent) wh ile keeping the sulfur limits on residual oils at first-phase levels.

The two phases are to be introduced in sequence wit h slightly different timing for an inner zone
of MANE-VU states 27 and the remainder of MANE-VU states. While all MAN E-VU states have agreed to pursue implementation of both phases to full effect by the end of 2018, it is possible that not every state can make a firm commi tment to these measures today. States are expected to review the situation by the time of the first regional haze SIP progress report in 2013 and to seek alternate, equivalent reductions i f necessary.

Reductions in sulfur dioxide emissions will occur a s a direct consequence of the low-sulfur fuel strategy. For both phases combined, it is est imated that SO 2 emissions in the MANE-VU region will decline from 2002 levels by 168,222 ton s per year for combustion of light distillates and by 42,875 tons per year for combust ion of the heavier fuels. Together, these reductions represent a 35 percent decrease in the p rojected 2018 SO 2 emissions inventory for non-EGU sources in the region.

26 U.S. Department of Energy, EIA, Table F3a, at http ://www.eia.doe.gov/emeu/states/sep_fuel/html/fuel_u se_df.html

.

27 The inner zone includes New Jersey, Delaware, New York City, and possibly portions of eastern Pennsyl vania.New Hampshire Regional Haze SIP Revision Page 97

NESCAUM analyzed the two program phases separately for MANE-VU, but it is the combined benefit of implementing both phases that i s relevant to the question of visibility improvement by 2018. To estimate the effects of th e low-sulfur fuel strategy, MANE-VU applied the expected sulfur dioxide emission reduct ions to all non-EGU sources burning #1, #2, #4, #5, or #6 fuel oil. These emission reducti ons would result directly from the lowering of fuel sulfur content from original levels to 0.01 5 percent for #1 and #2 oil, to 0.25 percent for #4 oil, and to 0.5 percent for #5 and #6 oil.

The reduction in SO 2 emissions by 2018 will yield corresponding reducti ons in sulfate aerosol, the main culprit in fine-particle pollutio n and regional haze. The full benefit of MANE-VU-s low-sulfur fuel strategy is represented i n Figure 10.1, which displays the estimated average reductions in 24-hr PM 2.5 concentration as calculated by the CMAQ model for the combined first and second phases of the pro gram.

Figure 10.1: Average Change in 24-hr PM 2.5 Due to Low-Sulfur Fuel Strategy (Phases 1 and 2 Combined) Relative to OTB/OTW (val ues in μ g/m 3 )

Low-Sulfur Fuel Oil Requirements are Reasonable : The MANE-VU Contribution Assessment documented source apportionment analyses that linke d visibility impairment in MANE-VU
Class I Areas with SO 2 emissions from sources burning fuel oil. The reas onable assumption underlying the low-sulfur fuel oil strategy is that refiners can, by 2018, produce home heating and fuel oils that contain 50 percent less sulfur f or the heavier grades (#4 and #6 residual oil), and 75 to 99.25 percent less sulfur in #2 fuel oil (also known as home heating oil, distillate, or diesel fuel) at an acceptably small increase in pri ce to the consumer.New Hampshire Regional Haze SIP Revision Page 98

Four-Factor Analysis – Low-Sulfur Fuel Oil Strategy : The MANE-VU Reasonable Progress Report discussed the four factors as they apply to low-sulfur fuel use for ICI boilers and residential heating systems. MANE-VU’s Reasonable Progress Report identified switching to
a lower-sulfur fuel oil as an available SO 2 control option that would achieve 50 to 90 percent
reductions in SO 2 emissions from ICI Boilers. The report also noted that home heating oil use generates an estimated 100,000 tons of SO 2 emissions in the Northeast each year and that SO 2 emissions would decline in proportion to reductions in fuel sulfur content. The following discussion summarizes information concerning the fo ur factors for the low-sulfur fuel
strategy.

1) Low-Sulfur Fuel Oil Strategy – Costs of Complian ce : The MANE-VU Reasonable Progress report noted that because of requirements for motor vehicle fuels, refineries have already performed the capital investments required for the production of low-sulfur diesel (LSD) and ultra-low sulfur diesel (ULSD). The repo rt estimated a cost per ton of SO 2 removed by switching to lower-sulfur fuel would ran ge from $554 to $734 per ton (converted from 2001 to 2006 dollars using a conversion factor of 1.1383). In some seasons and some locations, low-sulfur diesel is actually cheaper th an regular diesel fuel. (See Chapter 8 of the Reasonable Progress Report.)

The sulfur content of #4 and #6 fuels can also be c ost-effectively reduced. Residual oil is essentially a byproduct of the refining process and is produced in several grades that can be blended to meet a specified fuel sulfur content lim it. New York Harbor residual fuel prices for the week ending March 21, 2008, ranged from a l ow of $71.38 a barrel for 2.0 and 2.2 percent sulfur fuel to a high of $91.38 per barrel for 0.3 percent sulfur fuel 28

.

While the costs of achieving the projected emission s reductions with the low-sulfur fuel strategy are somewhat uncertain, they are believed to be reasonable in comparison with the costs of controlling other sectors. Some MANE-VU s tates are proceeding with low-sulfur oil requirements much sooner than 2018; however, all ofthe MANE-VU states concur that a lowsulfur oil strategy is both reasonable and achievab le within the MANE-VU region by no later
than 2018. MANE-VU has concluded that the cost of requiring the use of lower-sulfur fuels
is reasonable.

2) Low-Sulfur Fuel Oil Strategy – Time Necessary fo r Compliance : MANE-VU’s Reasonable Progress Report indicated that furnaces and boilers would not have to be retrofit and would not require expensive control technologies to burn ULSD distillate fuel oil. Therefore, the time necessary for compliance would be determined b y the availability of the fuel.

The MANE-VU Reasonable Progress Report notes that, on a national scale, more ULSD is produced than both LSD and high-sulfur fuel, and co ncludes that the United States has the infrastructure to produce adequate stocks of these fuels. NESCAUM’s report, “Low Sulfur Heating Oil in the Northeast States: An Overview of Benefits, Costs, and Implementation Issues,” December 2005 (Attachment AA) observes tha t the federal rules for heavy duty highway diesel fuel are flexible, so that if there is a shortage of 15 ppm fuel, the 15 to 500 ppm fuel could be used to relieve the shortage. Wi th this flexibility, the report concludes that

28 During this same period, low-pour (low-temperature, reduced viscosity) residual fuel oil with a 0.5 pe rcent sulfur content sold for $80.83 per barrel. Residual oil with a fu el sulfur content limit of 0.7 percent and 1.0 perc ent traded at $75.13 and $72.63, respectively.New Hampshire Regional Haze SIP Revision Page 99

the likelihood of a fuel shortage in the short term due to use of ULSD for heating oil is diminished. The volatile nature of heating supply and demand presents unique challenges to the fuel oil industry. The success of a low-sulfur fuel oil program is predicated on meeting these challenges. The Northeast states are consult ing with fuel suppliers and assessing a variety of business strategies and regulatory appro aches that could be used to minimize any potential adverse supply and price impacts that cou ld result from a regional 500 ppm sulfur standard for heating oil. Suppliers can increase p re-season reserves of low-sulfur product. Blending domestically produced biodiesel into heati ng oil offers opportunity to reduce imports, stabilize supplies and minimize supply-rel ated price spikes.

Potential supply disruptions and price spikes for r esidual fuels are a particular concern for several northern MANE-VU states. Maine, New Hampsh ire, and Massachusetts receive a significant percentage of their residual fuel suppl ies from offshore sources during the winter months, when barge traffic from New York Harbor is interrupted because of severe weather. At these times, residual oil is often imported dire ctly from foreign sources (e.g., Venezuela and Russia), and stakeholders have expressed concer ns that the supply of low-sulfur residual fuels may be insufficient to satisfy demand during these periods. While the potential for disruptions in the supply of residual fuels is grea ter than that for distillate oil, these disruptions would affect only a limited number of s tates during extreme weather events.

MANE-VU has identified several mechanisms that coul d be implemented to address disruptions, including seasonal averaging and emerg ency waivers. A seasonal averaging approach would reduce potential supply constraints by allowing the use of higher-sulfur fuel during periods of peak demand (and limited supply), and then requiring the increased sulfur content of these fuels to be offset through the use of a lower-sulfur fuel at other times. This approach would provide regulatory certainty and gre ater flexibility during the winter months when fuel supplies may be subject to weather-relate d disruptions, but at a cost of increased recordkeeping and compliance monitoring. Since man y states already have statutory authority to waive fuel sulfur limits in an emergen cy, states could also utilize their discretionary powers to address short-term supply d isruptions.

Although New Hampshire does not intend to use seaso nal averaging, the state would reserve the option of pursuing an emergency waiver in a fuel su pply disruption and would follow EPA’s established procedures for fuel waivers. As descri bed on the agency’s’s fuel waivers website at http://www.epa.gov/compliance/resources/faqs/civil/ fuelwaiver.html , EPA, with the concurrence of the Department of Energy, may temporarily waive a fuel or fuel additive requirement if doing so will alleviate the fuel supply emergency. Clean Air Act Section 211(c)(4)(C), which authorizes fuels waivers, specifies the criteria fo r granting a fuel waiver and the conditions
that must be included in a fuel waiver. In the cas e of an emergency disruption of low-sulfur fuel supplies, NHDES would seek a short-term emerge ncy waiver on fuel sulfur content. To the extent feasible, it would be the intent of any such waiver to moderate the degree of visibility degradation resulting from temporary use of higher-sulfur fuels in a supply disruption. The details would be worked out in res ponse to the particulars of the emergency situation at the time of any waiver request.

To implement the low-sulfur fuel oil strategy, New Hampshire and the other MANE-VU states propose a phase-in of the required use of lo wer-sulfur fuels by 2018, allowing adequate time to achieve the strategy’s full effect.New Hampshire Regional Haze SIP Revision Page 100

3) Low-Sulfur Fuel Oil Strategy – Energy and Non-Ai r Quality Environmental Impacts of Compliance : According to MANE-VU’s Reasonable Progress Repor t, reducing the sulfur content of fuel oil would have a variety of benefic ial consequences for boilers and furnaces using this fuel. Low-sulfur distillate fuel is cle aner burning and emits less particulate matter, thereby reducing the rate of fouling of heating uni ts and allowing longer time intervals between cleanings. The MANE-VU report cites a stud y by the New York State Energy Research and Development Authority (NYSERDA) that s howed that boiler deposits are reduced by a factor of two by lowering the fuel sul fur content from 1,400 ppm to 500 ppm.
The use of low-sulfur oil could extend the useful l ife of a source by reducing the maintenance required because low-sulfur oil is less damaging to the combustion equipment.

The report also notes that decreasing sulfur levels in fuel would enable manufacturers to develop more efficient furnaces and boilers by usin g more advanced condensing equipment that recovers energy normally lost to the heating o f water vapor in the exhaust gases. In addition, SO 2 controls would have beneficial environmental impac ts by reducing acid deposition and helping to decrease ambient concentr ations of PM 2.5 . Reductions in PM 2.5 resulting from use of low-sulfur fuels could help n onattainment areas meet health-based National Ambient Air Quality Standards.

4) Low-Sulfur Fuel Oil Strategy – Remaining Useful Life of Any Potentially Affected Sources : Residential furnaces and boilers have finite life s pans, but they do not need to be replaced to burn low- or ultra-low-sulfur fuel oil. The Energy Research Center estimates that the average life expectancy of a residential heating oil boileris 20-25 years. As noted above, use of lowsulfur fuel is less damaging to equipment and could therefore extend the useful life of an oilfired residential furnace or boiler.

Available information on the remaining useful life of ICI boilers indicates a wide range of life expectancies, depending on unit size, capacity fact or, and level of maintenance performed. (Capacity factor is defined as the actual amount of energy a boiler generates in one year divided by the total amount it could generate if it ran full time at full capacity.) The typical life expectancy of an ICI boiler ranges from 10 yea rs to more than 30 years. As in the case of residential units, use of lower-sulfur fuels could extend the life span of an ICI boiler.

10.2.4 Targeted EGU Strategy for SO 2 Reduction

Electrical generating units (EGUs) are the single l argest sector contributing to visibility impairment at MANE-VU’s Class I Areas. SO 2 emissions from power plants continue to dominate the emissions inventory. Sulfate formed t hrough atmospheric processes from SO 2 emissions are responsible for over half the mass an d approximately 70-80 percent of visibility extinction on the days of worst visibility (see NES CAUM’s Contribution Assessment, Attachment B).

To ensure that EGU control measures are targeted at those units having the greatest impact on visibility at MANE-VU Class I Areas, a CALPUFF mode ling analysis was conducted to identify the individual sources responsible for the highest contributions to visibility degradation. Accordingly, MANE-VU developed lists of the 100 EGU emission points (stacks) having the largest impacts at each MANE-VU Class I Area during 2002. The combined list for all seven
MANE-VU Class I Areas identified a total of 167 dis tinct emission points. These 167 stacks are spread across the Northeast, Southeast, and Mid west (Figure 10.2).New Hampshire Regional Haze SIP Revision Page 101

Figure 10.2: Location of 167 EGU Stacks Contributi ng the Most to Visibility Impairment at MANE-VU Class I Areas

Note: Some facilities have more than one stack.

After consultations with its member states and with other RPOs, MANE-VU requested a 90- percent reduction in SO 2 emissions from the top 167 stacks by no later than 2018 (see the MANE-VU “Ask”). NESCAUM’s preliminary modeling for MANE-VU showed that SO 2 emission reductions of this magnitude from the targ eted facilities would produce substantial improvements in ambient 24-hour PM 2.5 concentrations. Assuming a control level equal to 10 percent of the 2002 baseline emissions (i.e., 90-pe rcent emission reduction), NESCAUM used CMAQ to model sulfate concentrations in 2018 after implementation of controls. The modeled
sulfate values were then converted to estimates of PM 2.5 concentration. Figure 10.3 displays the predicted average change in 24-hr PM 2.5

.

The map illustrates the reductions in fine-particle pollution in the Eastern U.S. that would result from implementation of the targeted EGU strategy fo r SO 2 . Improvements in PM 2.5 levels would occur throughout the MANE-VU region and porti ons of the VISTAS and MRPO regions, especially along the Ohio River Valley.New Hampshire Regional Haze SIP Revision Page 102

Figure 10.3: Preliminary Estimate of Average Chang e in 24-hr PM 2.5 Resulting from a
90-Percent Reduction in SO 2 Emissions from the Top 167 EGU Stacks

Affecting MANE-VU Class I Areas

Although the reductions would be both advantageous and potentially large, MANE-VU determined, after further consultation with affecte d states, that it was unreasonable to expect that the full 90-percent reduction in SO 2 emissions would be achieved by 2018. Therefore, additional modeling was conducted to assess the mor e realistic scenario in which emissions would be controlled by the individual facilities an d/or states to levels already projected to take place by that date. At some facilities, the actual emission reductions are anticipated to be greater or less than the 90 percent benchmark. For details, see Alpine Geophysics’ report for MARAMA entitled, “Documentation of 2018 Emissions f rom Electric Generating Units in the Eastern United States for MANE-VU’s Regional Ha ze Modeling,” Final Report, August 16, 2009 (Attachment H).

Targeted EGU SO 2 Reduction Strategy Controls are Reasonable : MANE-VU identified specific EGU stacks that were significant contribut ors to visibility degradation at MANE-VU Class I Areas in 2002. The CALPUFF modeling analys es identifying potentially significant contributing sources are documented in the Contribu tion Assessment. MANE-VU obtained information about existing and planned controls on emissions from those stacks. These analyses and information on proposed EGU controls a re presented in MANE-VU’s Reasonable Progress Report and the Contribution Ass essment as well as in Section 6, Emissions Inventory, and Section 11, Long-Term Stra tegy section of this SIP.New Hampshire Regional Haze SIP Revision Page 103

Based on information gathered from the states and r egional planning organizations, MANEVU anticipated that emissions from many of the targ eted EGU stacks would be subject to EPA’s Clean Air Interstate Rule (CAIR). However, b ecause CAIR was a cap-and-trade program, it was not possible to predict with certai nty which of the 167 stacks would actually be
controlled under CAIR in 2018.

Four-Factor Analysis – Targeted EGU SO 2 Reduction Strategy : The following discussion addresses each of the four factors with respect to the strategy of controlling specific EGUs. Information is taken primarily from the MANE-VU Rea sonable Progress Report (Attachment Y) and MANE-VU BART Report (Attachment Z).

1) Targeted EGU SO 2 Reduction Strategy – Costs of Compliance : Technologies to control the precursors of regional haze are commercially availa ble today. Because EGUs are the most significant stationary source of SO 2 , NO X , and PM, they have been subject to extensive federal and state regulations to control all three pollutants. The technical feasibility of control technologies has been successfully proven for a sub stantial number of small (e.g., 100 MW) to very large (over 1,000 MW) boilers burning diffe rent types of coal. Over the last few years, the cost data clearly indicate that many tec hnologies provide substantial and costeffective emission reductions.

Both wet and dry scrubbers are in wide commercial u se in the U.S. for controlling SO 2 emissions from coal-fired power plants. The capita l costs for new or retrofit wet or dry scrubbers are higher than the capital costs for NO X and PM controls. The MANE-VU BART report found that the capital costs of scrubbers ra nged from $180/kW for large units (greater than 600 MW) to as high as $350/kW for small units (200 to 300 MW). Typical costs were in the range of 200 to 500 dollars per ton of SO 2 removed, but rose steeply for small units burning lower-sulfur coal and operating at low capa city factors. (See pages 2-22 through 2-25 of the BART Report, Attachment Z).

The MANE-VU Reasonable Progress Report (Attachment Y) reviewed options for controlling coal-fired EGU boilers, including switching to lowe r-sulfur coal, switching to natural gas, coal cleaning, and flue gas desulfurization (FGD). The most effective control option (but not necessarily appropriate for all installations) is F GD, which can achieve up to 95 percent
reduction in SO 2 emissions. The costs of different technologies va ry considerably among units and were estimated to range from as low as $1 70/ton to as high as $5,700/ton.

Table 10.4 summarizes the estimated costs of contro lling SO 2 emissions, expressed in dollars per ton of SO 2 removed.New Hampshire Regional Haze SIP Revision Page 104

Table 10.4: Estimated Cost Ranges for SO 2 Control Options for Coal-Fired EGU Boilers (2006 dollars per ton of SO 2 removed)

To predict future emissions and further evaluate th e costs of emission controls for electric generating units, MANE-VU and other RPOs have follo wed the example of the US Environmental Protection Agency (EPA) in using the Integrated Planning Model (IPM®), an integrated economic and emissions model for EGUs. This model projects electricity supplies based on various assumptions while at the same time developing least-cost solutions to electrical generating needs within specified emissi ons targets. IPM also provides estimates of the costs of complying with various policy requirem ents.

EPA developed IPM version 2.1.9 and used this model to evaluate the impacts of CAIR and the Clean Air Mercury Rule (CAMR). (Note that CAMR was vacated by the federal courts and is no longer in effect.) Recently, EPA updated their input data and developed IPM v.3.0. However, because of time constraints, all MANE-VU r uns were based on EPA IPM v.2.1.9 with changes made to the input assumptions.

The RPOs collaborated with one another to update the inputs to IPM v.2.1. 9 using more current data on the EGUs and more realistic fuel pr ices. The resulting IPM run is called VISTAS PC_1f. This IPM run serves as the basis for regional air quality modeling for ozone
and haze SIPs in MANE-VU and the OTC.New Hampshire Regional Haze SIP Revision Page 105

MANE-VU, through MARAMA, contracted with the consul ting firm ICF Resources, L.L.C. to prepare two new IPM runs, as documented in “Comp arison of CAIR and CAIR Plus Proposal using the Integrated Planning Model (IPM®) ,” Final Draft Report, May 30, 2007 (Attachment BB). The first run, known as the MARAM A CAIR Base Case run (also known as MARAMA_5c), was based on the VISTAS PC_1f run an d underlying EPA IPM v.2.1.9 with some updated information on fuel prices, contr ol constraints, etc. The second run, called the MARAMA CAIR Plus run (also known as MARAMA_4c), was similarly based on VISTAS PC_1f run and the underlying EPA IPM v.2.1.9 . The MARAMA CAIR Plus run included updated information used in the VISTAS run but assumed lower NO X emission caps and higher SO 2 retirement ratios.

Based on the modeling results, MANE-VU estimates th at the marginal cost of SO 2 emission reductions (the cost of reducing one additional ton of emissions) ranges from $640/ton in 2008 to $1,392/ton in 2018 (see Table 6, “Allowance Prices (Marginal Costs) of Emissions Reductions...,” in Attachment BB).

Costs will vary for individual plants to reduce emi ssions by 90 percent, as recommended in the New Hampshire/MANE-VU Ask. However, this strat egy provides states with flexibility to pursue controls on specific sources as appropria te and to control emissions from alternative sources, if necessary, to meet the 90 percent targe t established in the Ask.

Given the importance of SO 2 emissions from specific EGUs to visibility impairm ent in MANE-VU Class I Areas, the MANE-VU Commissioners, a fter weighing all factors – the availability of technology to reduce emissions, the estimated costs of controls, the costs of alternative measures, the flexibility to achieve al ternative reductions if necessary, etc. – concluded that the costs of the targeted EGU strate gy are reasonable. New Hampshire agrees
with this conclusion.

2) Targeted EGU SO 2 Reduction Strategy – Time Necessary for Compliance : MANE-VU’s Reasonable Progress Report indicates that, generall y, sources are given a 2- to 4-year phase-in period to comply with new rules. Under Phase I of the NO X SIP call, EPA provided a compliance date of about 31⁄2 years from the SIP subm ittal date. Most MACT standards allow a 3-year compliance period. Under Phase II of the NO X SIP Call, EPA provided for 2-year compliance period from the SIP submittal date. New Hampshire concludes that there is more
than sufficient time between 2008 and 2018 for affe cted states to adopt requirements and for affected sources to install necessary controls.

3) Targeted EGU SO 2 Reduction Strategy – Energy and Non-Air Quality En vironmental Impacts of Compliance : The MANE-VU Reasonable Progress Report identifie d several energy and non-air quality impacts from additional EGU controls. Large-scale fuel switching could potentially impact fuel supplies. Flue gas d esulfurization systems may generate wastewater and sludge (which is sometimes recycled as a useful byproduct). On the other hand, SO 2 , NO X , and ammonia controls would have beneficial enviro nmental impacts by reducing acid deposition and nitrogen deposition to water bodies and natural land areas. Emission reductions for these pollutants would also produce decreases in ambient levels of

PM 2.5 and result in corresponding health benefits. Simi larly, mercury emissions may be reduced by the addition of controls for other pollu tants. New Hampshire concludes that the energy and non-air quality impacts of additional EG U controls are reasonable.New Hampshire Regional Haze SIP Revision Page 106

4) Targeted EGU SO 2 Reduction Strategy – Remaining Useful Life of Any Potentially Affected

Sources : As noted in the MANE-VU Reasonable Progress Repo rt, remaining useful life estimates of EGU boilers indicate a wide range of o perating lifetimes, depending on unit size, capacity factor, and level of maintenance performed . Typical life expectancies range to 50 years or more. Additionally, implementation of air pollution regulations over the years has
necessitated emission control retrofits that have i ncreased the expected life spans of many EGUs. The lifetime of an EGU may be extended throu gh repair, re-powering, or other strategies if the unit is more economical to run th an to replace with power from other sources. Extending facility lifetime may be particularly lik ely for a unit serving an area with limited transmission capacity to bring in other power.

10.2.5 Non-EGU SO 2 Emissions Reduction Strategy for Non-MANE-VU State s

In addition to the measures described above (i.e., BART, low-sulfur fuel, and targeted EGU controls), New Hampshire asked states in neighborin g regional planning organizations to consider further non-EGU emission reductions compar able to those achieved by MANE-VU states through application of MANE-VU’s low-sulfur fuel strategy. Previous modeling indicated that the MANE-VU low-sulfur fuel strategy would achieve a greater than 28- percent reduction in non-EGU SO 2 emissions by 2018. After consultation with other states and consideration of comments received, MANE-VU dec ided to include, in the latest modeling for the VISTAS and MRPO regions, implement ation of control measures capable of achieving SO 2 emission reductions equivalent to MANE-VU’s 28-per cent reduction in nonEGU SO 2 emissions in 2018.

To model the effects of this strategy on visibility at MANE-VU Class I Areas, MANE-VU had to make reasonable assumptions about where the requested emission reductions would occur in the VISTAS and MRPO states without knowing precisely how those reductions would be realized. As a way to represent approxima tely a 28-percent reduction in non-EGU

SO 2 emissions, the following reductions were modeled:

• For control measures in VISTAS and MRPO states:

− Coal-fired ICI boilers: SO 2 emissions were reduced by 60 percent.

− Oil-fired ICI boilers: SO 2 emissions were reduced by 75 percent.

− ICI boilers lacking fuel specification: SO 2 emissions were reduced by 50 percent.

• For additional controls only in the VISTAS states: SO 2 emissions from other oil-fired area sources were reduced by 75 percent (based on t he same SCCs identified in MANE-VU’s oil strategies list).

This modeling scenario represents just one example of realistic strategies that states outside of MANE-VU could employ to meet the non-EGU SO 2 emissions reductions requested by

MANE-VU.

New Hampshire acknowledges that a number of non-MAN E-VU states have not included, or may not include, the requested 28-percent reduction in non-EGU SO 2 emissions in their State Implementation Plans at the present time. New Hamp shire expects these states to revisit the MANE-VU Ask in the course of future regional haze S IP revisions and to make commitments to this request where feasible. NHDES will continu e to monitor other states’ actions with respect to regional haze planning. In time, actual reductions could turn out to be greater or less than the MANE-VU Ask. If necessary, New Hamps hire will adjust its reasonableNew Hampshire Regional Haze SIP Revision Page 107

progress goals and long-term strategy at a later da te to be consistent with programs implemented by the non-MANE-VU states. Any such ad justments would be incorporated into New Hampshire’s first regional haze SIP revisi on in 2013.

Non-EGU SO 2 Emission Reduction Measures Outside MANE-VU are Re asonable : After EGUs, ICI boilers are the next largest class of SO 2 emitters. ICI boilers are thus a logical choice among non-EGU sources for consideration of a dditional SO 2 control measures.

ICI Boiler Control Options : Air pollution reduction and control technologies for ICI boilers have advanced substantially over the past 25 years. However, according to a 1998 survey of industrial boilers by EPA (2004), only 2 percent of gas-fired boilers and 3 percent of oil-fired boilers had installed any kind of air pollution con trol device. A larger percentage of coalfired boilers had installed air pollution controls: specifically, 47 percent had installed some type of control device, mainly to control particula te matter (PM). Post-combustion SO 2 controls were used by less than one percent of indu strial boilers in 1998, with the exception of boilers firing petroleum coke (2 percent of boilers using this fuel had acid scrubbers). A small percentage of industrial boilers had combustion con trols in place in 1998, although additional
low-NO X firing systems may have been installed since that date.

Almost all SO 2 emission control technologies fall into the categor y of reducing SO 2 after its formation as opposed to minimizing its formation du ring combustion. The method of SO 2 control appropriate for any individual ICI boiler i s dependent upon the type of boiler, type of fuel, capacity utilization, and the types and stagi ng of other air pollution control devices. However, cost-effective emission reduction technolo gies for SO 2 are available and are effective in reducing emissions from the exhaust ga s stream of ICI boilers. Post-combustion
SO 2 control is accomplished by reacting the SO 2 in the gas with a reagent (usually calcium- or sodium-based) and removing the resulting product (a sulfate/sulfite) for disposal or commercial use, depending on the particular technol ogy. SO 2 reduction technologies are commonly referred to as flue gas desulfurization (F GD) and are usually described in terms of the process conditions (wet versus dry), byproduct utilization (throwaway versus saleable) and reagent utilization (once-through versus regene rable).

The exceptions to the nearly universal use of post- combustion controls are found in fuel switching, coal cleaning, and fluidized bed boilers , in which limestone is added to the fuel in the combustion chamber. Both pre- and post-combust ion SO 2 emission control alternatives
for ICI boilers are outlined in Table 10.5. Furthe r description of these technology options is available in Chapter 4 of the MANE-VU Reasonable Pr ogress Report (Attachment Y).

The SO 2 removal efficiency of these controls varies from 2 0 to 99+ percent depending on the fuel type and control technology. For coal-fired b oilers, options include switching to lowsulfur coal, coal cleaning, wet FGD, dry FGD, and s pray dryers. The overall SO 2 reductions vary from a low of 20 to 25 percent for fuel switch ing to a high of 60 to 95 percent for wet FGD and spray dry FGD. The majority of control str ategies, however, are capable of achieving a 60 percent or greater reduction. Thus, assuming that coal-fired ICI boilers adopt varying levels of controls, with most choosing a 50 - to 70- percent reduction strategy and fewer choosing either the 20-percent or the 90-perc ent reduction strategy, the region-wide average would be likely to fall in the vicinity of a 60- percent reduction in SO 2 emissions. This assumption is validated by data showing that w et FGD systems represent 85 percent of the FGD systems in use in the United States and tha t these systems have an average SO 2 removal efficiency of 78 percent. MANE-VU’s modeli ng of a 60-percent reduction in SO 2 emission from coal-fired ICI boilers is therefore r easonable.New Hampshire Regional Haze SIP Revision Page 108

Table 10.5: Available SO 2 Control Options for ICI Boilers

For oil-fired boilers, options include switching to a lower-sulfur fuel (e.g., oil or natural gas), dry FGD, and spray dryers. The overall SO 2 reductions vary from a low of 40 to 60 percent for dry FGD to a high of 60 to 95 percent for spray dry FGD. For comparison, the MANEVU low-sulfur fuel strategy assumes a 50- to 90- pe rcent reduction in SO 2 emissions from oilfired ICI boilers. Assuming a normal distribution of control strategies chosen by the sources, MANE-VU’s modeling of an average 75-percent reducti on in SO 2 emission from oil-fired ICI
boilers is reasonable.

For ICI boilers in which a fuel was not specified, a 50-percent reduction in SO 2 emissions was assumed. ICI boilers in this category include thos e outside the MANE-VU region for which the current inventory did not specify the type of f uel burned. Because a response from the MRPO was not received, this assumption also encompa sses some of the uncertainty regarding the implementation of MANE-VU’s non-EGU Ask. Given the paucity of data, a lower
reduction in SO 2 emissions (50 percent) was assumed for this catego ry than for coal- or oilfired ICI boilers. Implementation of one or more o f the suggested SO 2 control options to achieve, on average, a 50-percent reduction in SO 2 emissions at these sources is a reasonable assumption.

For emissions from other area oil-combustion source s in the VISTAS region, an SO 2 reduction of 75 percent was assumed. This reductio n is equal to the reduction that would

Technology Description Applicability Performance

Flue Gas Desulfurization (FGD) - Dry Powdered lime or other suitable sorbent is injected directly into flue gas Applicable primarily for boilers currently firing low
to medium sulfur fuels 40-60% reduction in SO 2 emissions Flue Gas Desulfurization (FGD) - Spray Dry A fine mist containing lime or
other suitable sorbent is injected directly into flue gas Applicable primarily for boilers currently firing low
to medium sulfur fuels 60-95%+ reduction in SO 2 emissions Flue Gas Desulfurization (FGD) - W et SO 2 is removed from flue gas by dissolving it in a lime or limestone slurry. (Other
alkaline chemical are sometimes used) Applicable to all coal-fired
ICI boilers 30-95%+ reduction in SO 2 emissions Combustion Control A reactive material, such as limestone or bi-carbonate, is
introduced into the combustion chamber along
with the fuel Applicable to pulverized
coal-fired boilers and circulating fluidized bed
boilers 40%-85% reductions in SO 2 emissions Coal Cleaning Coal is washed to remove
some of the sulfur and ash prior to combustion Potential control measure
for all coal-fired ICI boilers 20-25% reduction in SO 2 emissions Switch to a Lower Sulfur Oil Replace higher-sulfur
residual oil with lower-sulfur distillate oil. Alternatively, replace medium sulfur
distillate oil with ultra-low
sulfur distillate oil Potential control measure
for all oil-fired ICIs currently using higher
sulfur content residual or
distillate oils 50-80% reduction in SO 2 emissions by switching to a
lower-sulfur oil Switch to Natural Gas (virtually 0% sulfur) Replace coal combustion with natural gas Potential control measure
for all coal-fired ICIs Virtually eliminate SO 2 emissions by switching to natural gas Switch to a Low Sulfur Coal (generally <1% sulfur) Replace high-sulfur
bituminous coal combustion
with lower-sulfur coal Potential control measure
for all coal-fired ICIs currently using coal with high sulfur content 50-80% reduction in SO 2 emissions by switching to a
lower-sulfur coalNew Hampshire Regional Haze SIP Revision Page 109

result from implementing the MANE-VU low-sulfur fue l strategy for this sector. The fourfactor analysis for the low-sulfur fuel strategy wa s described in Part 10.2.3 of this section.

Four-Factor Analysis – Non-EGU SO 2 Emission Reduction Measures Outside MANE-VU : Based on the survey of available technologies outli ned above and the four-factor analyses summarized below, MANE-VU concludes that each of th e strategies assumed for modeling purposes to meet the New Hampshire/MANE-VU Ask of a 28-percent reduction in non-EGU

SO 2 emissions is reasonable. States should have no di fficulty in meeting this benchmark in light of the control efficiencies that are attainab le at reasonable costs with retrofit technologies that are available for ICI boilers today.

1) Non-EGU SO 2 Emission Reduction Measures outside MANE-VU – Cost s of Compliance : Industrial boilers have a wider range of sizes than EGUs and often operate over a wider range of capacities. Thus, cost estimates for the same t echnologies will generally span a relatively larger range, and costs for an individual boiler wi ll depend on the capacity of the boiler and typical operating conditions. In general, cost-eff ectiveness increases as boiler size and capacity factor (a measure of boiler utilization) i ncreases.

MANE-VU’s Reasonable Progress Report (Attachment Y) provides emission control cost estimates for ICI boilers in the range of $130 to $ 11,000 per ton of SO 2 removed, a very wide spread due to the variability of sources and contro l options in this category. All costs presented below for emission controls on ICI boiler s are borrowed from this report. Dollar amounts originated from EPA publications cited in t he report and are restated in 2006 dollars using appropriate adjustment factors found at www.i nflationdata.com

.

◊ Cost of Fuel Switching : Although fuel switching can be a very effective means of controlling SO 2 emissions (reductions of 50 to 99.9 percent are pos sible), burning low-sulfur fuel may not be technically feasible or economicall y practical as an SO 2 control option for every coal-fired boiler. Factors impacting applica bility include the characteristics of the plant and the particular type of fuel change being consid ered. Additionally, switching to a lowersulfur coal can affect fuel handling systems, boile r performance, PM control effectiveness, and ash handling systems. Oil-fired boilers switch ing to a lower-sulfur fuel of the same grade (e.g., switching from #6 fuel oil at 2.0% S to #6 f uel oil at 0.5% S) do not typically encounter these issues. (See Part 10.2.3 for a discussion of the costs and issues associated with switching to low-sulfur fuel oil.)

The costs of coal fuel switching, including substit ution or blending with a low-sulfur coal, can
be attributed to two main factors: the cost of low -sulfur coal compared to higher-sulfur coal (including consideration of the coal’s heating valu e), and the cost of necessary boiler or coalhandling equipment modifications. Many plants will be able to switch from high-sulfur to
low-sulfur bituminous coal without serious difficul ty, but switching from bituminous to subbituminous coal may require potentially signific ant investments and modifications to an existing plant. Even if a lower-sulfur fuel is ava ilable, it may not be cost competitive if it must be supplied in small quantities or transported long distances from the supplier. It also may be more cost-effective to burn a higher-sulfur fuel supplied by nearby suppliers and to use a post-combustion control device.

Switching from coal combustion to natural gas combu stion virtually eliminates SO 2 emissions. It is technically feasible to switch fr om coal to natural gas; but it is currently uneconomical to consider this option for large ICI boilers because of the required equipmentNew Hampshire Regional Haze SIP Revision Page 110

modifications, the fuel quantities necessary, and t he generally higher price of natural gas compared to coal.

◊ Cost of Coal Cleaning : The World Bank, an organization which assists wi th economic and technological needs in developing countries, report s that the cost of physically cleaning coal varies from $1 to $10 per ton of coal cleaned, depe nding on the coal quality, the cleaning process used, and the degree of cleaning desired. In most cases, the costs were found to be between $1 and $5 per ton of coal cleaned. Coal cl eaning typically results in a 20- to 25- percent reduction in SO 2 emissions and increases the heating value of the fu el by a small

amount.

◊ Cost of Combustion Controls : Dry sorbent injection (DSI) systems have lower c apital and operation costs than post-combustion FGD systems be cause of the simplicity of the DSI design, lower water use needs, and smaller land are a requirements. Table 10.6 presents the estimated costs of adding DSI-based SO 2 emission controls to ICI boilers for different boi ler sizes, fuel types, and capacity factors.

Table 10.6: Estimated Costs of Dry Sorbent Injecti on (DSI) for ICI Boilers (2006 dollars)

Cost-Effectiveness ($/ton of SO 2 removed)

Fuel SO 2

Reduction (%) Capacity

Factor (%) 100

MMBtu/hr 250

MMBTU/hr 1,000

MMBTU/hr
14 4,686 3,793 2,979
50 1,312 1,062 834 2%-Sulfur Coal 40

83 772 624 490
14 2,732 2,212 1,737

50 765 619 486 3.43%-Sulfur Coal 40

83 450 364 286
14 2,205 1,786 1,402

50 617 500 392 2%-Sulfur Coal 85

83 363 294 231
14 1,286 1,040 818

50 360 291 229 3.43%-Sulfur Coal 85

83 212 171 134

Note: Data as compiled and presented in Table 4.3 of MACTEC Federal Programs, Inc., “Assessment of Reasonable Progress for Regional Haze in MANE-VU Class I Areas,” Final, July 9, 2007.

◊ Cost of FGD : Installation of post-combustion SO 2 controls in the form of FGD has several impacts on facility operations, maintenance, and wa ste handling procedures. FGD systems generally require substantial land area for constru ction of the absorber towers, sorbent tanks, and waste handling equipment. The facility costs t herefore depend on the cost and availability of space for construction of the FGD s ystem. In addition, significant quantities of waste material may be generated that require dispos al. The costs may be mitigated, however, by utilization of a forced oxidation FGD process th at produces commercial-grade gypsum, which may be sold as a raw material for other comme rcial processes.

Table 10.7 presents the total estimated cost-per-to n of adding FGD-based SO 2 emission controls to ICI boilers for different boiler sizes, fuel types, and capacity factors. There is noNew Hampshire Regional Haze SIP Revision Page 111

indication that these cost data include possible re venues from gypsum sales, which would partially offset the costs of FGD controls.

Carbon dioxide is also emitted as a byproduct of FG D; therefore, the impacts of increased carbon emissions associated with this technology wo uld need to be considered. CO 2 emissions will become more of an issue in the future if they are limited under climate change mitigation strategies. Given the uncertainty of such future s trategies, costs related to increased carbon emissions from FGD cannot yet be assessed.

MANE-VU’s request for a 28-percent reduction in non -EGU SO 2 emissions allows states flexibility in determining which sources to control , so that the most cost-effective control measures can be adopted and implemented over the ne xt 10 years. Given the wide range of control options and costs available for this purpos e, MANE-VU has concluded that the request for a 28-percent reduction in non-EGU SO 2 emissions is reasonable. New Hampshire
concurs with this conclusion.

Table 10.7: Estimated Costs of Flue Gas Desulfuriz ation for ICI Boilers (2006 dollars)

Cost-Effectiveness ($/ton of SO 2 removed)

Fuel Technology SO 2 Reduction (%) Capacity

Factor (%) 100

MMBtu/hr 250

MMBTU/hr 1,000

MMBTU/hr
14 3,781 2,637 1,817
50 1,379 1,059 828 High-Sulfur
Coal a FGD (dry) 40
83 1,006 814 676
14 4,571 3,150 2,119
50 1,605 1,207 928 Lower-Sulfur
Coal b FGD (dry) 40
83 1,147 906 744
14 4,183 2,786 1,601
50 1,290 899 567 Coal FGD

(spray dry) 90

83 843 607 407
14 3,642 2,890 1,909
50 1,116 875 601 High-Sulfur
Coal FGD

(spray dry) 90

83 709 563 398
14 4,797 3,693 2,426
50 1,415 1,106 751 Lower-Sulfur
Coal FGD (wet) 90

83 892 705 492
14 10,843 8,325 5,424
50 2,269 1,765 1,184 Oil c FGD (wet) 90
83 1,371 1,079 740

Note: Data as compiled and presented in Table 4.4 of MACTEC Federal Programs, Inc., “Assessment of Reasonable Progress for Regional Haze in MANE-VU Cl ass I Areas,” Final, July 9, 2007.

a Assumes sulfur content = 3.43% and ash content = 1 2.71%.

b Assumes sulfur content = 2.0% and ash content = 13 .2%.

c Sulfur content of oil is not specified.New Hampshire Regional Haze SIP Revision Page 112

2) Non-EGU SO 2 Emission Reduction Measures outside MANE-VU – Time Necessary for Compliance : For pre- and post-combustion SO 2 emission controls, engineering and construction lead times will vary between 2 and 5 y ears, depending on the size of the facility and specific control technology selected. Generall y, sources are given a 2- to 4- year phase-in period to comply with new rules, as previously desc ribed, and states generally have a 2-year period for compliance with RACT rules.

For the purposes of this review, it is assumed that a 2-year period after SIP submittal is adequate for pre-combustion controls (fuel switchin g or cleaning), and a 3-year period is adequate for the installation of post-combustion co ntrols. MANE-VU has therefore
concluded that there is sufficient time between 200 8 and 2018 for affected states to adopt emission control requirements and for affected sour ces to install the necessary controls to meet MANE-VU’s requested SO 2 emission reductions from non-EGU sources. New Hampshire concurs with this conclusion.

3) Non-EGU SO 2 Emission Reduction Measures Outside MANE-VU – Ener gy and Non-Air Quality Environmental Impacts of Compliance : The primary energy impact of pre- or postcombustion control alternatives is a potential incr ease in electricity usage. Fuel switching and cleaning do not significantly affect the efficiency of the boiler itself, but require additional energy to clean or blend coal. FGD systems typical ly operate with high-pressure drops across the control equipment and therefore consume signifi cant amounts of electricity to operate blowers and circulation pumps. In addition, some c ombinations of FGD technology and plant configuration may require flue gas reheating to pre vent physical damage to equipment, resulting in higher fuel usage.

The primary non-air environmental impacts of fuel s witching derive from transportation of the fuel. Secondary environmental impacts derive f rom waste disposal and material handling operations (e.g. fugitive dust). For FGD systems, the generation of wastewater and sludge
from the SO 2 removal process is a consideration. Wastewater fr om the FGD systems will increase sulfate, metals, and solids loading at the receiving wastewater treatment facility, resulting in potential impacts to operating cost, e nergy requirements, and effluent water quality. Processing of the wastewater sludge can r equire energy for stabilization and/or dewatering, and transporting the dewatered sludge t o a landfill has additional environmental implications.

Fuel switching to a low-sulfur distillate fuel oil has a variety of beneficial consequences for
ICI boilers. Low-sulfur distillate fuel is cleaner burning and emits less particulate matter, which reduces the rate of fouling of heating units substantially and permits longer time intervals between cleanings. According to a study conducted by NYSERDA (reference 10 in Attachment AA), boiler deposits are reduced by a fa ctor of two by lowering the fuel sulfur content from 1,400 ppm to 500 ppm. These reduction s in buildup of deposits result in longer service intervals between cleanings.

Reducing SO 2 emissions from ICI boilers would have positive envi ronmental and health impacts. SO 2 controls would reduce acid deposition, helping to preserve aquatic life, forests, and crops as well as buildings and sculptures made of acid-sensitive materials. These emission reductions would also help to decrease amb ient levels of PM 2.5 , a significant contributor to premature morbidity and illness in i ndividuals with heart or lung conditions.New Hampshire Regional Haze SIP Revision Page 113

MANE-VU has concluded that the energy and non-air e nvironmental impacts of controlling

SO 2 emissions from ICI boilers are justified in light o f the beneficial impacts on regional haze, fine particulate air pollution, acid rain, and equi pment operation, as described above. New Hampshire concurs with this conclusion.

4) Non-EGU SO 2 Emission Reduction Measures Outside MANE-VU – Rema ining Useful Life of Any Potentially Affected Sources : Available information for remaining useful life estimates of ICI boilers indicates a wide range of life expec tancies, depending on unit size, capacity factor, and level of maintenance performed. Typica l life spans range from about 10 years to over 30 years. However, the remaining useful life of a specific source is highly variable; and older units are not likely to be retrofitted with e xpensive emission controls. Given the typical range of life expectancies of ICI boilers, the tech nical options available, and the flexibility that non-MANE-VU states would have to meet the Ask, MANE-VU has concluded that a 28- percent reduction in non-EGU SO 2 emissions is reasonable. New Hampshire concurs wit h
this conclusion.



### 10.3 Reasonable Progress Goals for Class I Areas in the State

As required under 40 CFR 51.308(d)(1), this regiona l haze SIP establishes reasonable progress goals for Class I areas in New Hampshire f or the 10-year period of the implementation plan ending in 2018. These RPGs are determined from modeling based on implementation of the proposed reasonable measures included in MANE-VU’s long-term strategy. Table 10.8 provides a summary of the rea sonable progress goals, in deciviews, for New Hampshire’s two Class I areas: Great Gulf Wilde rness and Presidential Range - Dry
River Wilderness.

Table 10.8: Reasonable Progress Goals for Great Gu lf Wilderness and Presidential Range - Dry River Wilderness (all val ues in deciviews)

Visibility Condition Natural Visibility 2000-2004

Baseline Visibility RPG

(Visibility Expected by 2018) Visibility

Improvement Expected by
2018

20 Percent Worst Days (Average) 12.0 22.8 19.1 3.7

20 Percent Best Days (Average) 3.7 7.7 7.2 0.5

Both natural conditions and baseline visibility for the 5-year period from 2000 through 2004
were calculated in conformance with an alternative method recommended by the IMPROVE Steering Committee. (See Attachment L, “Baseline a nd Natural Visibility Conditions: Considerations and Proposed Approach to the Calcula tion of Baseline and Natural Visibility Conditions at MANE-VU Class I Areas,” December 2006 .) Future progress toward the 2018 visibility target will be calculated in a nationall y consistent manner based on 5-year averages in accordance with EPA’s “Guidance for Tracking Pro gress Under the Regional Haze Rule” (EPA-454/B-03-004, September 2003) with adjustments for the alternative method as recommended by the IMPROVE Steering Committee.New Hampshire Regional Haze SIP Revision Page 114

40 CFR 51.308(d)(1)(vi) requires that reasonable pr ogress goals represent at least the visibility improvement expected from implementation of other Clean Air Act programs during the applicable planning period. The modeling that formed the basis for reasonable progress goals for MANE-VU Class I Areas included estimation of the effects of all other programs required by the Clean Air Act. MANE-VU’s modeling also included the specific control measure assumptions described previously in Subsect ion 10.2. Additional information may be found in Section 6, Emissions Inventory, and Sec tion 11, Long-Term Strategy, as well as in the documentation for the MANE-VU modeling.

In setting the reasonable progress goals to improve visibility at MANE-VU Class I Areas, New Hampshire recognizes that contributing states w ill have flexibility to submit SIP revisions and implement various control measures to meet these goals between now and 2018. The overall approach to reducing and preventing emi ssions that contribute to regional haze allows each state up to 10 years to implement reaso nable SO 2 and NO X control measures as appropriate and necessary.



### 10.4 Visibility Effects of (Additional) Reasonable Control Measures

MANE-VU’s evaluations included modeling to estimate the effects on visibility of the New Hampshire/MANE-VU Ask. The results of this work ar e summarized below.

NESCAUM performed preliminary modeling as described in the report entitled “MANE-VU Modeling for Reasonable Progress Goals, Model Perfo rmance Evaluation, Pollution Apportionment, and Control Measure Benefits,” Febru ary 7, 2008 (Attachment G). NESCAUM also conducted more recent, revised modelin g to assess the effects of all haze reduction strategies combined. The latter modeling is described in NESCAUM’s “2018 Visibility Projections,” May 13, 2008 (Attachment Q ).

The NESCAUM modeling demonstrates that significant visibility benefits will accrue from implementation of the additional reasonable control measures described in Subsection 10.2, above. Figures 10.4 and 10.5 describe the results of this modeling. In the first of the two figures, the light yellow bars represent expected v isibility at MANE-VU Class I Areas in 2018. Comparison of these values with the 2018 “gl ide slope” values (the plum-colored bars) shows that all areas are expected to experience vis ibility improvements that meet or exceed the uniform rate of progress calculated for each ar ea. The second figure shows that, for the 20 percent of days having best visibility, expected vi sibility in 2018 will be better than it is today
at all locations.

In conclusion, the reasonable control measures prop osed by New Hampshire and the other
MANE-VU states are found to be consistent with the stated national goals of preventing further visibility degradation while making measura ble progress toward achieving natural visibility conditions in wilderness areas by 2064.New Hampshire Regional Haze SIP Revision Page 115

Figure 10.4: Demonstration of Required and Reasona ble Visibility Progress

for 20 Percent Worst Visibility Days

Visibility Progress for 20% Worst Days

0 5 10 15 20 25 30 35

Acadia Brigantine Great Gulf Lye Brook MoosehornVisibility (deciviews)

2002 Baseline 2018 Glideslope 2018 Projected Progress Natural

(Visibility Improvements Must be Made at Reasonable Rate)

Figure 10.5: Demonstration of Required Maintenance or Improvement of Visibility for 20 Percent Best Visibility Days

Visibility Progress For 20% Best Days

0 2 4 6 8 10 12 14 16

Acadia Brigantine Great Gulf Lye Brook MoosehornVisibility (deciviews)

2002 Baseline 2018 Projected Progress

(Baseline Visibility Must be Maintained or Improved )

References

U.S. Environmental Protection Agency, National Emission Standards for Hazardous Air Pollutants for Industrial/ Commercial/Institutional Boilers and Process Heaters

, http://cascade.epa.gov/RightSite/dk_public_collecti on_detail.htm?ObjectType=dk_docket_collection

&cid=OAR-2002-0058&ShowList=items&Action=view (accessed Feb. 25, 2004).New Hampshire Regional Haze SIP Revision Page 116



### 11. LONG-TERM STRATEGY

40 CFR 51.308(d)(3) of the Regional Haze Rule requi res the State of New Hampshire to submit a long-term strategy that addresses regional haze visibility impairment for all mandatory Class I federal areas within and outside the state that may be affected by emissions
from within the state. Affected areas include the seven designated Class 1 areas within the MANE-VU region: Great Gulf Wilderness, Presidential Range - Dry River Wilderness, Acadia National Park, Moosehorn Wilderness, Roosevelt Camp obello International Park, Lye Brook Wilderness, and Brigantine Wilderness. As presente d in Section 3, Regional Planning and Consultation, New Hampshire consulted with other st ates to develop the coordinated emission management strategies contained in this SIP. The f ollowing describes how New Hampshire meets the long-term strategy requirements of the Re gional Haze Rule.

New Hampshire’s long-term strategy includes enforce able emission limitations, compliance schedules, and other measures necessary to achieve the reasonable progress goals described in Section 10. Additional measures may be reasonable to adopt at a later date after further consideration and review. In developing this long- term strategy, New Hampshire also considered the requirements of the Clean Air Act, S ection 110 (a)(2)(D)(i)(II), pertaining to interstate and international transport of pollutant s. NHDES has previously addressed this issue in New Hampshire’s “Transport SIP Revision,” submitted to EPA on March, 11, 2008. As that document observed, states must include prov isions in their implementation plans to prohibit any source or activity from emitting air p ollutants in amounts that would interfere with another state’s ability to prevent significant deterioration of air quality and visibility. The long-term strategy presented herein is designed to protect visibility in New Hampshire as well as areas downwind from New Hampshire.



### 11.1 Overview of Strategy Development Process

The regional strategy development process identifie d reasonable measures that would reduce emissions contributing to visibility impairment at Class I areas by 2018 or earlier. The process of identifying potential emission reduction measures and the technical basis for the long-term strategy are discussed in this section. As a MANE-VU member and participant, New Hampshire supported several technical analyses undertaken to assist the MANE-VU states in deciding which regional haze control meas ures to pursue. These analyses are documented in the following reports:

• NESCAUM, “Contributions to Regional Haze in the Nor theast and Mid-Atlantic United States,” August 2006, otherwise known as the Contribution Assessment (Attachment B).

• ICF Resources, L.L.C., “Comparison of CAIR and CAIR Plus Proposal Using the Integrated Planning Model®,” Final Draft Report, Ma y 30, 2007, otherwise known as the CAIR Plus Report (Attachment BB);

• MACTEC Federal Programs, Inc., “Assessment of Reaso nable Progress for Regional Haze in MANE-VU Class I Areas,” Final, July 9, 2007 , otherwise known as the Reasonable Progress Report (Attachment Y);

• NESCAUM, “Five-Factor Analysis of BART-Eligible Sou rces: Survey of Options for Conducting BART Determinations,” June 1, 2007 (Atta chment W); andNew Hampshire Regional Haze SIP Revision Page 117

• NESCAUM, “Assessment of Control Technology Options for BART-Eligible Sources: Steam Electric Boilers, Industrial Boilers , Cement Plants and Paper and Pulp Facilities,” March 2005, otherwise known as the BAR T Report (Attachment Z).

MANE-VU reviewed a wide range of potential control measures aimed at reducing regional haze by the 2018 milestone. The process of choosin g a set of control measures started in late 2005. OTC selected a contracting firm to assist wi th the analysis of ozone and regional haze control measure options and provided the contractor with a master list of some 900 potential control measures based on experience and previous s tate implementation plan work. With the help of an internal OTC Control Measures Workgroup, the contractor narrowed the list of regional haze control measures for further consider ation by MANE-VU.

MANE-VU then developed an interim short list of pos sible control measures for regional
haze. The identified control measures can be divid ed into three general categories:

• Beyond-CAIR sulfate reductions and related control measures targeted at specific electrical generating units (EGUs) in the eastern U nited States,

• Low-sulfur heating oil for industrial, commercial, institutional (ICI) boilers and residential sources (i.e., boilers and furnaces), and

• Emission controls on ICI boilers (both coal- and oi l-fired); lime and cement kilns; residential woodstoves; and outdoor wood burning (i ncluding outdoor wood boilers).

The next step was to further refine this list, with the aid of several of the reports named above. The ICF CAIR Plus Report (Attachment BB) documents MANE-VU’s assessment of the costs of CAIR and provides a cost analysis for addi tional SO 2 and NO X controls in the eastern United States. The Reasonable Progress Report docu ments the assessment of control measures for EGUs and the other source categories s elected for analysis. Further analysis is provided in the second of the two NESCAUM documents referenced above pertaining to Best Available Retrofit Technology (BART) controls.

The beyond-CAIR strategy for EGUs rose to the top o f the list because the Contribution Assessment showed that EGU sulfate emissions have, by far, the largest impact on visibility in the MANE-VU Class I Areas. Similarly, a low-sul fur oil strategy gained traction after a
NESCAUM-initiated conference with refiners and fuel -oil suppliers concluded that such a strategy could realistically be implemented within the next 10 years. Thus, the low-sulfur heating oil option for the residential and commerci al sectors and the control measures option for the oil-fired ICI boiler sector merged into an overall strategy requiring the use of lowsulfur oil. Under this strategy, low-sulfur oil wo uld be required for all residential and commercial heating units and all ICI boilers burnin g #2, #4, or #6 fuel oils.

During MANE-VU’s internal consultation meeting in M arch 2007, member states reviewed
the interim list of control measures to make additi onal refinements. States determined, for example, that there may be too few coal-fired ICI b oilers in MANE-VU for these sources to be included in a regional strategy, but that they c ould be covered in programs adopted by
individual states. The member states also decided that lime and cement kilns, of which there are few in the MANE-VU region, are most likely to b e handled via the BART determination process. Residential wood burning and outdoor wood boilers remained on the list for those states where localized visibility impacts are a con sideration even though emissions from these sources are primarily organic carbon and direct par ticulate matter. Finally, it was decided that the issue of outdoor wood burning should be examine d further on a state-by-state basisNew Hampshire Regional Haze SIP Revision Page 118

because of concerns related to enforcement and pene tration of existing state regulations. New Hampshire is currently considering additional regul ation of this sector.



### 11.2 Technical Basis for Strategy Development

40 CFR 51.308(d)(3)(iii) requires New Hampshire to document the technical basis for the state’s apportionment of emission reductions necess ary to meet reasonable progress goals in each Class I area affected by New Hampshire’s emiss ions. New Hampshire relied on technical analyses developed by MANE-VU to demonstr ate that New Hampshire’s emission reductions, when coordinated with those of other st ates and tribes, are sufficient to achieve reasonable progress goals in Class I areas located in New Hampshire and in other Class I areas affected by emissions originating in New Hamp shire.

The emission reductions necessary to meet reasonabl e progress goals in Class I areas affected by New Hampshire are described in the following doc uments:

• NESCAUM, “Baseline and Natural Background Visibilit y Conditions: Considerations and Proposed Approach to the Calculation of Baselin e and Natural Background Visibility Conditions at MANE-VU Class I Areas,” De cember 2006 (Attachment L);

• NESCAUM, “The Nature of the Fine Particle and Regio nal Haze Air Quality Problems in the MANE-VU Region: A Conceptual Descr iption,” Final, November 2, 2006 (Attachment CC);

• NESCAUM, “Contributions to Regional Haze in the Nor theast and Mid-Atlantic United States,” August 2006, otherwise known as the Contribution Assessment (Attachment B).

• ICF Resources, L.L.C., “Comparison of CAIR and CAIR Plus Proposal Using the Integrated Planning Model®,” Final Draft Report, Ma y 30, 2007, otherwise known as the CAIR Plus Report (Attachment BB);

• MACTEC Federal Programs, Inc., “Assessment of Reaso nable Progress for Regional Haze in MANE-VU Class I Areas,” Final, July 9, 2007 , otherwise known as the Reasonable Progress Report (Attachment Y);

• NESCAUM, “Five-Factor Analysis of BART-Eligible Sou rces: Survey of Options for Conducting BART Determinations,” June 1, 2007 (Atta chment W);

• NESCAUM, “Assessment of Control Technology Options for BART-Eligible Sources: Steam Electric Boilers, Industrial Boilers , Cement Plants and Paper and Pulp Facilities,” March 2005, otherwise known as the BAR T Report (Attachment Z);

• NESCAUM, “MANE-VU Modeling for Reasonable Progress Goals: Model Performance Evaluation, Pollution Apportionment, and Control Me asure Benefits,” February 7, 2008 (Attachment G); and

• NESCAUM, “2018 Visibility Projections,” May 13, 200 8 (Attachment Q).

As described in Subsection 11.1, above, New Hampshi re worked with other members of the Ozone Transport Commission and MANE-VU to evaluate a large number of potential emission reduction strategies covering a wide range of sources of SO 2 and other pollutants contributing to regional haze. 40 CFR 51.308(d)(3) (v) requires states to consider severalNew Hampshire Regional Haze SIP Revision Page 119

factors in developing their long-term strategies. Operating within this framework and using available information about emissions and potential impacts, the MANE-VU Reasonable Progress Workgroup selected the following source ca tegories for detailed analysis:

• Coal and oil-fired electric generating units (EGUs) ;

• Point and area source ICI boilers;

• Cement kilns and lime kilns;

• Sources capable of using low-sulfur heating oil; an d

• Residential wood combustion and open burning.

These efforts led to the selection of the emission reduction strategies presented in this SIP.



### 11.3 Existing Commitments / Expected Measures to Reduce Emissions

40 CFR Section 51.308(d)(3)(v)(A) requires New Hamp shire to consider emission reductions from ongoing pollution control programs. In develo ping its long-term strategy, New Hampshire considered air pollution programs being i mplemented between the 2002 baseline year and 2018. The emission reduction programs des cribed in Parts 11.3.1, 11.3.2, and 11.3.3, below, represent commitments already made b y New Hampshire and other states to implement air pollution control measures for EGU po int sources, non-EGU point sources, and area sources, respectively. These control measures are the very same measures that were included in the 2018 emissions inventory and used i n the modeling. While these control measures were not designed expressly for the purpos e of improving visibility, the pollutants they control include those that contribute to visib ility impairment in MANE-VU Class I Areas.

MANE-VU’s 2018 beyond-on-the-way (BOTW) emissions i nventory accounts for emission controls already in place as well as emission contr ols that are not yet finalized but are likely to achieve additional emission reductions by 2018. Th e BOTW inventory was developed based on the MANE-VU 2002 Version 3.0 inventory and the M ANE-VU 2018 on-the-books/on-theway (OTB/OTW) inventory. Inventories used for othe r RPOs reflect anticipated emissions controls that will be in place by 2018. The invent ory is termed BOTW because it includes control measures that were developed for ozone SIPs that were not yet on the books in some states. For some states, BOTW also included contro ls that were under consideration for regional haze SIPs that have not yet been adopted. More information may be found in the following documents:

• MACTEC Federal Programs, Inc., “ Development of Emissions Projections for 2009, 2012, and 2018 for NonEGU Point, Area, and Nonroad Sources in the MANE-VU Region,” Final Report, February 28, 2007, otherwise known as the Emission Projections Report (Attachment N);

• Alpine Geophysics, LLC, “Documentation of 2018 Emis sions from Electric Generating Units in the Eastern United States for M ANE-VU’s Regional Haze Modeling,” Final Report, August 16, 2009 (Attachmen t H);

• NESCAUM, “MANE-VU Modeling for Reasonable Progress Goals: Model Performance Evaluation, Pollution Apportionment, an d Control Measure Benefits,” February 7, 2008 (Attachment G); and

• NESCAUM, “2018 Visibility Projections,” May 13, 200 8 (Attachment Q).New Hampshire Regional Haze SIP Revision Page 120

11.3.1 Controls on EGUs Expected by 2018

The following EGU emission reduction programs were included in the modeling used to develop the reasonable progress goals. These progr ams represent the greatest opportunities for reducing SO 2 emissions at Class I areas in the MANE-VU region an d serve as the starting point for MANE-VU’s long-term strategy to mitigate regional haze.

Clean Air Interstate Rule (CAIR) : This major federal rule has been remanded to EPA to correct deficiencies. The original CAIR imposed pe rmanent emissions caps on sulfur dioxide (SO 2 ) and nitrogen oxides (NO X ) in the eastern United States by 2015. When fully effective, this program was expected to reduce SO 2 emissions in the CAIR region by up to 70 percent. To predict future emissions from EGUs after impleme ntation of CAIR, MANE-VU used the Integrated Planning Model (IPM®) 29 . Adjustments to the IPM output were made to provi de a more accurate representation of anticipated control s at specific EGU sources as documented in the Alpine Geophysics report listed above. In m aking these adjustments, emission controls originating from the following state and regional p rograms were considered:

Connecticut EGU Regulations : Connecticut adopted the following regulations gove rning
EGU emissions:

• Regulations of Connecticut State Agencies (RCSA), s ection 22a-174-19a , limiting the

SO 2 emission rate to 0.33 lb/MMBtu for fossil-fuel-fir ed EGUs greater than 15 MW that are also Title IV sources (effective, 2007).

• RCSA, section 22a-174-22 , limiting the non-ozone seasonal NO X emission rate to 0.15 lb/MMBtu for fossil-fuel-fired EGUs greater than 15 MW (effective, 2007).

• RCSA, section 22a-199 , limiting the mercury (Hg) emission rate to 0.0000 006 lb/MMBtu for all coal-fired EGUs, or alternatively coal-fired EGUs can meet a 90- percent Hg emission reduction (effective, 2008).

Delaware EGU Regulations : Delaware adopted the following regulations govern ing EGU
emissions:

• Reg. 1144, Control of Stationary Generator Emission s , requiring emission controls for

SO 2 , PM, VOC, and NO X state-wide, effective January 2006.

• Reg. 1146, Electric Generating Unit (EGU) Multi-Pol lutant Regulation, requiring SO 2 and NO X emission controls state-wide, effective December 2 007. SO 2 reductions will be more than regulation specifies

• Reg. 1148, Control of Stationary Combustion Turbine Electric Generating Unit

Emissions , requiring SO 2 , NO X , and PM 2.5 emission controls state-wide, effective January 2007.

29 The IPM model runs also anticipated the implementa tion of EPA’s Clean Air Mercury Rule (CAMR), which was recently vacated by the courts. However, MANE-VU believes t hat the adjustments made to the predicted SO 2 emissions from electric generating units (EGUs) will have a larger effect on the air quality modeling analysis conduc ted for this SIP than
will the vacatur of the CAMR rule. The emission ad justments were based on states’ comments on the act ual levels of SO 2 controls expected to be installed in response to st ate-specific regulations and EPA’s CAIR rule. MANE -VU believes these adjustments improve the reliability of both the emi ssions inventory and modeling results.New Hampshire Regional Haze SIP Revision Page 121

Delaware estimates that these regulations will resu lt in the following emission reductions for
affected units: SO 2 emissions of 32,630 tons in 2002 will decline to 8 ,137 tons in 2018 (a 75- percent reduction); NO X emissions of 8,735tons in 2002 will decline to 3,7 40 tons in 2018 (a 57-percent reduction).

Also, Delaware anticipates the following reductions resulting from the consent decree with Valero Refinery Delaware City, DE (formerly Motiva, Valero Enterprises): SO 2 emissions of 29,747 tons in 2002 will decline to 608 tons in 201 8 (a 98-percent reduction); NO X emissions in 1,022 in 2002 will decline to 102 tons in 2018 ( a 90-percent reduction).

Maine EGU Regulations : Chapter 145, NO X Control Program , limits the NO X emission rate to 0.22 lb/MMBtu for fossil-fuel-fired units greate r than 25 MW built before 1995 with a heat input capacity between 250 and 750 MMBtu/hr, and al so limits the NO X emission rate to 0.15 lb/MMBtu for fossil-fuel-fired units greater than 2 5 MW built before 1995 with a heat input capacity greater than 750 MMBtu/hr (effective, 2007 ).

Massachusetts EGU Regulations : Based on the Massachusetts Department of Environm ental Protection’s 310 CMR 7.29, Emissions Standards for Power Plants, adopted in 2001, six of the largest fossil-fuel-fired power plants in Massa chusetts must comply with emissions
limitations for NO X , SO 2 , Hg, and CO 2 . These regulations will achieve an approximately 50- percent reduction in NO X emissions and a 50- to 75-percent reduction in SO 2 emissions. Depending on the compliance paths selected, the aff ected facilities will meet the output-based

NO X and SO 2 standards between 2004 and 2008. This regulation a lso limits the six grandfathered EGUs to a CO 2 emission rate of 1,800 lb/MWh.

New Hampshire EGU Regulations : New Hampshire adopted the following regulations governing EGU emissions (inclusive of the New Hamps hire Clean Power Act):

• Chapter Env-A 2900, Multiple Pollutant Annual Budge t Trading and Banking Program , capping NO X emissions at 3,644 tons per year, SO 2 emissions at 7,289 tons per year, and CO 2 emissions at 5,425,866 tons CO 2 per year for all existing fossil-fuelfired steam units by December 31, 2006.

• Chapter Env-A 3200

, NO X Budget Trading Program , limiting ozone season NO X emissions on all fossil-fuel-fired EGUs greater tha n 15 MW to 0.15 lb/MMBtu, effective November 2, 2007.

• RSA 125-O, Multiple Pollutant Reduction Program , requiring the installation and operation of a flue gas desulfurization system (scr ubber) on PSNH Merrimack Station Units MK1 and MK2 to reduce mercury emissions by at least 80 percent, with the cobenefit of SO 2 emission reductions (90 percent expected minimum).

New Jersey New Source Review Settlement Agreements : The New Jersey settlement agreement with PSEG required the following actions for specific EGUs:

• Bergen Unit #2 : Repower to combined cycle by December 31, 2002.

• Hudson Unit #2 : Install dry FGD or approved alternative technolog y by Dec. 31, 2006, to control SO 2 emissions and operate the control technology at al l times the unit operates to limit SO 2 emissions to 0.15 lb/MMBtu; install SCR or approve d alternative technology by May 1, 2007, to control NO X emissions and operate the control technology year-round to limit NO X emissions to 0.1 lb/MMBtu; and install aNew Hampshire Regional Haze SIP Revision Page 122

baghouse or approved alternative technology by May 1, 2007, to control and limit PM
emissions to 0.015 lb PM/MMBtu.

• Mercer Unit #1 : Install dry FGD or approved alternative technolo gy by Dec. 31, 2010, to control SO 2 emissions and operate the control technology at al l times the unit operates to limit SO 2 emissions to 0.15 lb/MMBtu; and install SCR or app roved alternative technology by 2005 to control NO X emissions and operate the control technology during ozone season only in 2005 and yea r-round by May 1, 2006, to limit

NO X emissions to 0.13 lb/MMBtu.

• Mercer Unit #2 : Install dry FGD or approved alternative technolo gy by Dec. 31, 2012, to control SO 2 emissions and operate the control technology at al l times the unit operates to limit SO 2 emissions to 0.15 lb/MMBtu; and install SCR or app roved alternative technology by 2004 to control NO X emissions and operate the control technology during ozone season only in 2004 and yea r-round by May 1, 2006, to limit

NO X emissions to 0.13 lb/MMBtu.

The New Jersey settlement also requires that units operating an FGD use coal having a monthly average sulfur content no greater than 2 pe rcent.

New York EGU Regulations : New York adopted the following regulations govern ing EGU
emissions:

• Title 6 NYCRR Parts 237, Acid Deposition Reduction NO X Budget Trading Program

, limits NO X emissions on all fossil-fuel-fired EGUs greater th an 25 MW to a nonozone season cap of 39,908 tons in 2007.

• Title 6 NYCRR Parts 238, Acid Deposition Reduction SO 2 Budget Trading Program

, limits SO 2 emissions from all fossil-fuel-fired EGUs greater than 25 MW to an annual cap of 197,046 tons per year starting in 2007 and a n annual cap of 131,364 tons per year starting in 2008.

North Carolina Clean Smokestacks Act : Enacted in 2002, this legislation requires that c oalfired EGUs achieve a 77-percent cut in NO X emissions by 2009 and a 73-percent cut in sulfur
dioxide SO 2 emissions by 2013. This act also established annu al caps on both SO 2 and NO X emissions for the two primary utility companies in North Carolina, Duke Energy and Progress Energy. These reductions must be made in North Car olina, and allowances are not saleable.

Consent Agreements in the VISTAS region : The effects of the following consent agreements
in the VISTAS states were reflected in the emission s inventories used for those states:

• Santee Cooper : A 2004 consent agreement calls for Santee Cooper in South Carolina to install and commence operation of continuous emissi on control equipment for

PM/SO 2 /NO X emissions; comply with system-wide annual PM/SO 2 /NO X emissions limits; agree not to buy, sell, or trade SO 2 /NO X allowances allocated to Santee Cooper System as a result of this agreement; and to comply with emission unit limits of this
agreement.

• TECO : Under a settlement agreement, by 2008, Tampa Ele ctric in the state of Florida will install permanent emission control equipment t o meet stringent pollution limits; implement a series of interim pollution reduction m easures to reduce emissions while the permanent controls are designed and installed; and retire pollution emissionNew Hampshire Regional Haze SIP Revision Page 123

allowances that Tampa Electric or others could use, or sell to others, to emit additional

NO X , SO 2 , and PM.

• VEPCO : Virginia Electric and Power Co. agreed to spend $1.2 billion by 2013 to eliminate 237,000 tons of SO 2 and NO X emissions each year from eight coal-fired electricity generating plants in Virginia and West Virginia.

• Gulf Power 7 : A 2002 agreement calls for Gulf Power to upgrade its operation to cut
NO X emission rates by 61 percent at its Crist 7 genera ting plant by 2007 with major reductions beginning in early 2005. The Crist plan t is a significant source of NO X emissions in the Pensacola, Florida, area.

11.3.2 Controls on Non-EGU Point Sources Expected b y 2018

For non-EGU sources within MANE-VU, New Hampshire r elied on MANE-VU’s Version 3.0 Emission Inventory for 2002. MACTEC conducted an analysis of various control measures as documented in the Emission Projections Report (Attachment N). Control factors were applied to the 2018 MANE-VU inventory for non- EGUs to represent the following national, regional, or state control measures:

• NO X SIP Call Phase I (NO X Budget Trading Program) (except ME, NH, VT);

• NO X SIP Call Phase II (except ME, NH, VT);

• NO X RACT in 1-hour Ozone SIPs (already included in the 2002 inventory);

• NO X OTC 2001 Model Rule for ICI Boilers;

• 2-, 4-, 7-, and 10-year MACT Standards;

• Combustion Turbine and RICE MACT (NO X co-benefits were not included and assumed to be small);

• Industrial Boiler/Process Heater MACT 30 ; and

• Refinery Enforcement Initiative (Fluid catalytic cr acking units and fluid coking units, process heaters and boilers, flare gas recovery, le ak detection and repair, and benzene (wastewater)).

In addition, states provided control measure inform ation about specific non-EGU sources or regulatory programs in their states. MANE-VU used the state-specific data to the extent it was available. For example, several states develop ed additional control measures in the course of their planning efforts to reduce ozone wi thin the Ozone Transport Region (OTR). These control measures were included by MANE-VU in the inventories used for regional haze modeling. (The affected states may or may not have committed to adopting these measures in their ozone SIPs.) For specific states , the ozone-reduction strategies included in the modeling would reduce NO X emissions from the following non-EGU point sources :

• Asphalt production plants in Connecticut, New Jerse y, New York, and the District of Columbia;

• Cement kilns in Maine, Maryland, New York, and Penn sylvania; and

30 The inventory was prepared before the MACT for Ind ustrial Boilers and Process Heaters was vacated. C ontrol efficiency was assumed to be 4 percent for SO 2 and 40 percent for PM. The overall effects of inc luding these reductions in the inventory are estimated to be minimal.New Hampshire Regional Haze SIP Revision Page 124

• Glass and fiberglass furnaces in Maryland, Massachu setts, New Jersey, New York, and Pennsylvania.

For other regions, MANE-VU used emission inventory data developed by the RPOs for those regions, including VISTAS’s Base G2, MRPO’s Base K, and CenRAP’s emissions inventory. Non-EGU source controls incorporated into the model ing include those required under the following consent agreements as reflected in the VI STAS inventory:

• Dupont : A 2007 agreement calls for E. I. Dupont Nemours & Co.’s James River plant to install dual absorption pollution control equipm ent by September 1, 2009, resulting
in SO 2 emission reductions of approximately 1,000 tons an nually. The James River plant is a non-EGU located in the state of Virginia

.

• Stone Container : A 2004 agreement calls for the West Point Paper Mill in Virginia owned by Smurfit/Stone Container to control SO 2 emissions from its #8 Power Boiler by using a wet scrubber. This control device shoul d result in reductions of over 3,500
tons of SO 2 in 2018.

11.3.3 Controls on Area Sources Expected by 2018

For area sources within MANE-VU, New Hampshire reli ed on MANE-VU’s Version 3.0 Emissions Inventory for 2002. In general, MANE-VU developed the 2018 inventory for area sources by applying growth and control factors to t he 2002 Version 3.0 inventory. Area source control factors were developed for the follo wing national or regional control measures:

• Phase 1 of MANE-VU’s low-sulfur fuel oil strategy for the inner-zone states (New Jersey, New York, Delaware, and Pennsylvania, or po rtions thereof) to reduce the
sulfur content of:

− #2 distillate oil to 0.05 percent (500 ppm) sulfur, by weight, by no later than 2012;

− #4 residual oil to 0.25 percent sulfur, by weight, by no later than 2012;

− #6 residual oil to 0.3-0.5 percent sulfur, by weigh t, by no later than 2012;

• Phase 1 of MANE-VU’s low-sulfur fuel oil strategy for the outer-zone states (the rest of the MANE-VU region) to reduce the sulfur content of:

− #2 distillate oil to 0.05 percent (500 ppm) sulfur, by weight, by no later than 2014;

− #4 residual oil to 0.25-0.50 percent sulfur, by wei ght, by no later than 2018;

− #6 residual oil to 0.5 percent sulfur or less, by w eight, by no later than 2018;

• The Ozone Transport Commission’s VOC Model Rules (f or consumer products, architectural and industrial maintenance coatings, portable fuel containers, mobile equipment repair and refinishing, and solvent clean ing);

• Stage I vapor recovery systems at vehicle refueling stations in all New Hampshire counties and Stage II vapor recovery systems at veh icle refueling stations in the four
southern counties classified as ozone nonattainment areas (Rockingham, Strafford, Hillsborough, and Merrimack);

• New Jersey post-2002 area source controls; and

• Residential woodstove NSPS.New Hampshire Regional Haze SIP Revision Page 125

The following additional control measures were incl uded in the 2018 analysis to reduce NO X and VOC emissions for the following area source cat egories for some (identified) states:

• NO X control measures for combustion of coal; natural g as; and #2, #4, and #6 fuel oils (CT, NJ, and NY only);

• VOC control measures for adhesives and sealants (al l MANE-VU states except New Jersey 31 and VT);

• VOC control measures for emulsified and cutback asp halt paving (all MANE-VU states except ME and VT);

• VOC control measures for consumer products (all MAN E-VU states except VT); and

• VOC control measures for portable fuel containers ( all MANE-VU states except VT).

Some of the area-source control measures listed abo ve may have been developed by states for the primary purpose of reducing ozone within the O zone Transport Region (OTR) – see Part
11.3.2 for information on other measures included i n states’ ozone SIPs.

11.3.4 Controls on Mobile Sources Expected by 2018

For the on-road mobile source emission inventory, N ew Hampshire relied on MANE-VU’s Version 3.0 emission inventory, which included the following emission control measures for New Hampshire:

• Use of reformulated gasoline in the four southern c ounties classified as ozone nonattainment areas: Rockingham, Strafford, Hillsbo rough, and Merrimack;

• An enhanced safety inspection program, including an anti-tampering inspection for motor vehicles less than 20 years old;

• On-board diagnostics testing for 1996 and newer veh icles in lieu of the anti-tampering inspection;

• Federal On-Board Refueling Vapor Recovery (ORVR) Ru le;

• Federal Tier 2 Motor Vehicle Emissions Standards an d Gasoline Sulfur Requirements;

• Federal Heavy-Duty Diesel Engine Emission Standards for Trucks and Buses; and

• Federal Emission Standards for Large Industrial Spa rk-Ignition Engines and
Recreational Vehicles

Similar programs in other MANE-VU states were inclu ded in the on-road mobile source emission inventory, where applicable. The last fou r items listed above are federal programs, briefly described here:

On-Board Refueling Vapor Recovery (ORVR) Rule : The 1990 Clean Air Act (CAA) Amendments contain provisions that require passenge r cars to capture refueling emissions. In 1994, EPA published the ORVR Rule establishing stan dards for refueling emissions controls for passenger cars and light trucks. The onboard c ontrols were required to be phased in for all

31 New Jersey’s emission reductions from control meas ures for adhesives and sealants apply only to area sources. No reductions for point sources (SCC 4-02-0007-xx) were included to avoid inventory double-counting.New Hampshire Regional Haze SIP Revision Page 126

new car production by 2000 and for all light trucks by 2006. The rule established a refueling emission standard of 0.20 grams per gallon of dispe nsed fuel, which was expected to yield a 95 percent reduction of VOC emissions over uncontro lled levels. The CAA authorizes EPA to allow state and local agencies to phase out Stag e II programs, even in the worst nonattainment areas, once EPA has determined that o nboard systems are in widespread use.

Tier 2 Motor Vehicle Emissions Standard s : Tier 2 is a fleet-averaging program modeled
after the California LEV II standards. Manufacture rs can produce vehicles with emissions ranging from relatively dirty to zero, but the mix of vehicles a manufacturer sells each year must have average NO X emissions below a specified value. The Tier 2 regu lations also require reduced gasoline sulfur levels. The reduct ion in sulfur levels contributes directly to
cleaner air and has additional beneficial effects o n vehicle emission control systems. The Tier 2 standards became effective in the 2005 model year and are included in the assumptions used for calculating mobile source emissions inventories used for 2018.

Heavy-Duty Diesel Engine Emission Standards for Tru cks and Buses : EPA set a PM emissions standard of 0.01 grams per brake-horsepow er-hour (g/bhp-hr) for new heavy-duty diesel engines in trucks and buses, to take full ef fect in the 2007 model year. This rule also
includes standards for NO X and non-methane hydrocarbons (NMHC) of 0.20 g/bhp-h r and 0.14 g/bhp-hr, respectively. These NO X and NMHC standards will be phased in together
between 2007 and 2010. Sulfur in diesel fuel must be lowered to enable modern pollutioncontrol technology to be effective on the trucks an d buses that use this fuel. EPA will require a 97-percent reduction in the sulfur content of highw ay diesel fuel from its current level of 500 parts per million (low-sulfur diesel) to 15 parts p er million (ultra-low sulfur diesel).

Emission Standards for Large Industrial Spark-Ignit ion Engines and Recreational
Vehicles : EPA has adopted new standards for emissions of NO X , hydrocarbons (HC), and carbon monoxide (CO) from several groups of previou sly unregulated non-road engines. Included are large industrial spark-ignition engine s and recreational vehicles. The affected spark-ignition engines are those powered by gasolin e, liquid propane, or compressed natural gas rated over 19 kilowatts (kW) (25 horsepower). These engines are used in commercial and industrial applications, including forklifts, elect ric generators, airport baggage transport vehicles, and a variety of farm and construction ap plications. Non-road recreational vehicles include snowmobiles, off-highway motorcycles, and a ll-terrain vehicles. These rules were initially effective in 2004 and will be fully phase d-in by 2012.

11.3.5 Controls on Non-Road Sources Expected by 201 8

For non-road emission sources, New Hampshire used V ersion 3.0 of the MANE-VU 2002 Emissions Inventory. Because the NONROAD Model use d to develop the non-road source emissions did not include aircraft, commercial mari ne vessels, and locomotives, MANE-VU’s contractor, MACTEC, developed the inventory for the se sources. Non-road mobile source emissions for the 2018 emission inventory were calc ulated with EPA’s NONROAD2005 emissions model as incorporated into the NMIM2005 ( National Mobile Inventory Model)
database. The NONROAD model accounts for emissions benefits associated with federal non-road emission control requirements such as the following:

• “Control of Air Pollution: Determination of Signifi cance for Nonroad Sources and Emissions Standards for New Nonroad Compression Ign ition Engines at or above 37 Kilowatts,” 59 FR 31306, June 17, 1994.New Hampshire Regional Haze SIP Revision Page 127

• “Control of Emissions of Air Pollution from Nonroad Diesel Engines,” 63 FR 56967, October 23, 1998.

• “Control of Emissions from Nonroad Large Spark-Igni tion Engines and Recreational Engines (Marine and Land-Based),” Final Rule, 67 FR 68241, November 8, 2002.

• “Control of Emissions of Air Pollution from Nonroad Diesel Engines and Fuel,” Final Rule, April, 2004.

As noted above, inventory data for other regions we re obtained from those regions’ RPOs.



### 11.4 Additional Reasonable Measures

As required under 40 CFR 51.308(d)(1)(i)(A), New Ha mpshire and the other MANE-VU states applied four-factor analysis to potential co ntrol measures for the purpose of establishing reasonable progress goals (see Subsection 10.2 for detailed description). Reasonable
measures include those that the affected states hav e already committed themselves to implementing, as described in Subsection 11.3, abov e. In addition, the MANE-VU states
have identified other control measures that were fo und to be reasonable and were included in the modeling that was used to set reasonable progre ss goals. (These additional measures surpass the “beyond-on-the-way” emission controls a nd inventories.) All of the control
measures – those embodied in the states’ commitment s to existing or planned programs and
the additional reasonable control measures describe d below – comprise the long-term strategy for improving visibility at MANE-VU Class I Areas.

Specifically, the New Hampshire/MANE-VU long-term s trategy includes the following additional measures to reduce pollutants that cause regional haze.

• Timely implementation of BART requirements.

• Phase 2 of MANE-VU’s low-sulfur fuel oil strategy to further reduce the sulfur content of distillate oil to 15 ppm by no later tha n:

− 2016 for the inner-zone states (New Jersey, New Yor k, Delaware, and Pennsylvania, or portions thereof); and

− 2018 for the outer-zone states (the rest of the MAN E-VU region).
(Schedule would be contingent on fuel supply and av ailability.)

• A 90-percent or greater reduction in sulfur dioxide (SO 2 ) emissions from each of the EGUs identified by MANE-VU as reasonably anticipate d to cause or contribute to impairment of visibility in each mandatory Class I area in the MANE-VU region. (This requirement affects 167 point sources, or sta cks, at EGU facilities in the eastern United States.) If it is infeasible to achieve thi s level of SO 2 reductions from specific EGUs, equivalent alternative measures will be pursu ed in the affected states.

• Continued evaluation of other control measures, inc luding energy efficiency, alternative clean fuels, other measures to reduce S O 2 and nitrogen oxide (NO X ) emissions from all coal-burning facilities by 2018, and new source performance
standards for wood combustion.New Hampshire Regional Haze SIP Revision Page 128

This suite of additional control measures are those that the MANE-VU states have agreed to pursue for the purpose of mitigating regional haze. The corollary is that the MANE-VU Class I states (Maine, New Hampshire, Vermont, and New Je rsey) are asking states outside the MANE-VU region that contribute to visibility impair ment inside the region to pursue similar
measures. The control measures that non-MANE-VU st ates choose to pursue may be directed
toward the same emission source sectors identified by MANE-VU for its own emission reductions, or they may be equivalent measures targ eting other source sectors. Under MANEVU’s long-term strategy, states will be allowed up to ten years to pursue adoption and implementation of proposed control measures. While some measures that states pursue may not represent enforceable commitments immediately, they may become enforceable in the future as new laws are passed, rules are written, a nd facility permits are issued.

11.4.1 BART

Implementation of the BART provisions of the Region al Haze Rule (40 CFR 51.308(e)) is one of the reasonable strategies included in this S IP. For electrical generating units, EPA determined that CAIR (before its remand) would fulf ill BART requirements for this sector. However, New Hampshire’s approach is consistent wit h the MANE-VU long-term strategy; i.e., it goes beyond the original CAIR standards by requiring BART controls on all BARTeligible sources in the state. Proposed control me asures for New Hampshire’s two BARTeligible sources, both of which are EGUs, are descr ibed in Section 9 of this SIP. These two sources are also addressed in MANE-VU’s targeted EG U strategy (see Part 11.4.3, below).

To assess the benefits of implementing BART control s for MANE-VU’s non-EGU sectors, NESCAUM included in the final 2018 CMAQ modeling an alysis anticipated emission reductions for the region’s BART-eligible facilitie s, as described previously in Part 10.2.2 of this SIP. It is anticipated that twelve units at e ight BART-eligible sources in MANE-VU would be controlled as a result of BART requirement s alone (see Table 10.3).

Note that additional emission reductions will occur at many other BART-eligible facilities within MANE-VU as a result of controls achieved by other programs that serve as BART but are not specifically identified as such (e.g., RACT control measures). While not specifically identified as being attributable to BART, these add itional emission reductions were fully accounted for in the 2018 CMAQ modeling.

Further visibility benefits are likely to result fr om installation of new emission controls at BART-eligible facilities located in neighboring RPO s. However, the MANE-VU modeling
did not account for BART controls in other RPOs and , consequently, did not include visibility improvements at MANE-VU Class I Areas that would be likely to accrue from such measures.

11.4.2 Low-Sulfur Oil Strategy

The important assumption underlying MANE-VU’s low-s ulfur fuel oil strategy is that refiners can, by 2018, produce sufficient quantities of home heating and other fuel oils with lower sulfur content than current fuel supplies at only a small increase in price to the end user. The expected reductions in sulfur content range from 50 percent for the heavier grades (#4 and #6 residual) to a minimum of 75 percent and maximum of 99.25 percent for #2 fuel oil (also known as home heating oil, distillate, or diesel fu el). As much as three-fourths of the total sulfur reductions achieved by this strategy will co me from using low-sulfur #2 distillate for space heating in the residential and commercial sec tors. The costs of these emissions reductions are estimated at $550 to $750 per ton, a s documented in the MANE-VUNew Hampshire Regional Haze SIP Revision Page 129

Reasonable Progress Report. While the costs of the low-sulfur fuel oil strategy remain somewhat uncertain, they appear to be reasonable wh en measured against the costs of controlling other sectors.

Currently there are logistical issues in supplying large quantities of low-sulfur oils to the PADD1B (northern New England region). This oil is supplied by PADD1A and barged into the region in quantities that allow for blending wi th high-sulfur fuels to produce 1-percent sulfur fuels. Current capacities are limited by Fe deral restrictions that prevent large ships from transferring fuels between two U.S. ports. Th e states of this region intend to build full capacity for 0.5-percent-sulfur #6 fuel oil by 2018

.
The MANE-VU states agree that a low-sulfur oil stra tegy is reasonable to pursue in the next ten years. NHDES will review the details of this s trategy within five years, coincident with New Hampshire’s first regional haze SIP progress re port, to ascertain that requiring the use of low-sulfur fuel remains viable for implementation b y 2018.

11.4.3 Targeted EGU Strategy

MANE-VU has identified emissions from the top 167 E GU emission points, including three in New Hampshire, that contribute the most to visib ility impairment at MANE-VU Class I Areas (see Figure 10.2). Controlling emissions fro m these contributing facilities is crucial to mitigating haze pollution in wilderness areas and n ational parks of the Northeast states.

MANE-VU’s agreed regional strategy for the EGU sour ce sector is to pursue a 90-percent
control level on SO 2 emissions from the 167 identified stacks by 2018. MANE-VU has concluded that pursuing this level of sulfur reduct ion is both reasonable and cost-effective. For some units, actual SO 2 removal efficiencies would be expected to approach or exceed 95 percent. The costs of SO 2 emission reductions will vary by unit. MANE-VU’s R easonable Progress Report (Attachment Y) summarizes the avail able control methods and costs, which range from $170 to $5,700 per ton (2006 dollars), d epending on site-specific factors such as size of unit, combustion technology used, and type of fuel burned.

As shown in Table 11.1, the three targeted EGUs in New Hampshire are projected to reduce
their SO 2 emissions, in the aggregate, by 87 percent between 2002 and 2018.

Table 11.1: Projected SO 2 Emission Reductions from Targeted EGUs in New Hamp shire

2002 SO 2 Emissions SO 2 Emission
Reductions 2018 SO 2

Emissions Facility Name/Unit Targeted
EGU BARTEligible Fuel

Type (tons) Proposed
Control
Method (%) (tons) (tons)
Merrimack Station MK1 yes no coal 9,754 scrubber 90 8,779 975

Merrimack Station MK2 yes yes coal 20,902 scrubber 90 18,812 2,090

Newington Station NT1 yes yes fuel oil/ natural gas 5,226 0.50 lb/MMBtu
S emission limit 67 3,484 1,742

TOTALS 35,882 87 31,075 4,807

Notes: All 2002 values are based on continuous emi ssions monitoring (CEM) data. For Newington Statio n, additional SO 2 emission reductions beyond the stated value may occur with a switch to 0.5-percent low-sulfur oil under MANE-VU ’s low-sulfur oil strategy.New Hampshire Regional Haze SIP Revision Page 130

These projections are conservative estimates for at least two reasons:

• The actual performance of scrubbers to be installed on PSNH’s Merrimack Station Units MK1 and MK2 is expected to match or exceed MANE-VU’ s Ask level of 90-percent

SO 2 from targeted EGUs. (Note that MANE-VU’s Assessme nt of Control Options for BART-Eligible Sources, Attachment Z references 95-p ercent control reductions. However, this rate applies to EGUs at power plants having capacities above 750-MW, i.e., facilities larger than PSNH’s. Also, note th at the overall SO 2 control level for the three PSNH units would be greater than stated if th e baseline reduction resulting from
use of lower-sulfur coal were included in the effic iency calculation.)

• PSNH’s Newington Station Unit NT1, being primarily an oil-fired EGU, is expected
to have low utilization rates well into the future because of the economics associated with the cost of fuel. In 2007, high fuel costs ca used this unit to operate only 5 percent of the time. In fact, the most recent IPM modeling predicts that this unit will be shut down permanently by 2018. (Note that MANE- VU, from the outset, never envisioned that this oil-fired unit would be capabl e of achieving a control level equal to the presumptive norm for large EGUs.)

Given these considerations, there is a high probabi lity that New Hampshire will actually surpass MANE-VU’s goal of a 90-percent overall redu ction in SO 2 emissions from targeted EGUs by 2018. However, in the event that New Hamps hire is unable to attain this level of emission reductions, equivalency could be demonstra ted by alternative methods. For example:

• Credit could be taken for SO 2 emission reductions resulting from the recently completed fuel conversion of Schiller Station Unit 5 from coal to wood and from any similar fuel conversions that might occur for other New Hampshire EGUs in the future.

• Additional SO 2 emission reductions could be achieved before 2018 b y requiring all
sources that burn residual fuel oil to switch to re sidual fuel oil with a sulfur content of 0.5-percent (or lower), if economics and supplies a llow. New Hampshire intends to investigate this possibility further.

The anticipated benefits to regional visibility tha t will result from using FGD technology on New Hampshire’s largest EGUs are an intended conseq uence of New Hampshire’s Multiple Pollutant Reduction Program, which was established by law in RSA Chapter 125-O. This program requires aggressive reductions in SO 2 , NO X , mercury, and carbon dioxide (CO 2 ) while simultaneously allowing state-level SO 2 credits for over- or early- compliance. Under this program, emission controls for SO 2 and mercury are scheduled to be installed and operational at New Hampshire’s PSNH Merrimack Stati on Units MK1 and MK2 by July 1, 2013. In the meantime, NHDES will continue to eval uate other control measures for EGUs to determine whether it is reasonable to implement add itional controls on those sources by that date. NHDES will provide an update on its determin ations in New Hampshire’s first regional haze SIP progress report.

Several other states within and outside the MANE-VU region have implemented state-specific EGU emission reduction programs that will help MANE -VU meet visibility improvement goals. Many of the state programs that will contri bute to meeting the targeted EGU strategy
are identified in Part 11.3.1 of this section. Lis ted below are other state programs not previously identified that will also contribute to meeting this strategy. These other programs may yield additional benefits by controlling emissi ons at certain EGUs not listed among theNew Hampshire Regional Haze SIP Revision Page 131

top 167 EGU stacks. The listed programs represent existing commitments by the states and, as such, were included in MANE-VU’s most recent mod eling.

Maryland Healthy Air Act : Maryland adopted the following requirements gove rning EGU
emissions:

• For NO X : Phase I (2009) sets unit-specific annual caps to taling 20,216 tons

and ozone-season caps totaling 8,900 tons.
Phase II (2012) sets unit-specific annual caps tota ling 16,667 tons and ozone-season caps totaling 7,337 tons.

• For SO 2 : Phase I (2010) sets unit-specific annual caps tot aling 48,818 tons.

Phase II (2013) sets unit-specific annual caps tota ling 37,235 tons.

• For mercury: Phase I (2010) requires a 12-month-ro lling-average minimum

removal efficiency of 80 percent.
Phase II (2013) requires a 12-month-rolling-average minimum removal efficiency of 90 percent.

The specific EGUs included are: Brandon Shores (Uni ts 1 and 2), C.P.Crane (Units 1 and 2), Chalk Point (Units 1, and 2), Dickerson (Units 1, 2 , and 3), H.A. Wagner (Units 2 and 3) Morgantown (Units 1 and 2), and R. Paul Smith (Unit s 3 and 4). No out-of-state trading of emission allowances, no inter-company trading of al lowances, and no banking of allowances from year to year were included in the analyses.

New Jersey Mercury MACT Rule : Under this rule all coal-fired EGUs in New Jersey will have a mercury removal efficiency of 90 percent. ( Some SO 2 reductions may occur as a cobenefit of mercury emission controls.)

Consent Agreements in the VISTAS region : The following consent agreements in the
VISTAS states were reflected in the emissions inven tories used for those states:

• East Kentucky Power Cooperative : A July 2, 2007, consent agreement between EPA and East Kentucky Power Cooperative (EKPC) requires the utility to reduce its SO 2 emissions by 54,000 tons per year and its NO X emissions by 8,000 tons per year, by installing and operating selective catalytic reduct ion (SCR) technology; low-NO X burners, and PM and mercury continuous emissions mo nitors at the utility’s Spurlock, Dale, and Cooper Plants. According to the EPA, tot al emissions from the plants will decrease between 50 and 75 percent from 2005 levels . As with all federal consent decrees, EKPC is precluded from using reductions re quired under other programs such as CAIR to meet the reduction requirements of the c onsent decree. EKPC is expected to spend $654 million to install pollution controls

.

• American Electric Power : Under this agreement, American Electric Power (AE P) will spend $4.6 billion dollars for emission controls at sixteen plants located in Indiana, Kentucky, Ohio, Virginia, and West Virginia. These control measures will eliminate 72,000 tons of NO X emissions each year by 2016 and 174,000 tons of SO 2 emissions each year by 2018 from the affected facilities.New Hampshire Regional Haze SIP Revision Page 132



### 11.5 Source Retirement and Replacement Schedules

40 CFR Section 51.308(d)(3)(v)(D) of the Regional H aze Rule requires New Hampshire to consider source retirement and replacement schedule s in developing reasonable progress goals. Source retirement and replacement were cons idered in developing the 2018 emissions inventory described previously in Subsection 10.3, Reasonable Progress Goals for Class I
Areas in the State. See also Table B-5 in the Emis sion Projections Report (Attachment N).

The following sources in New Hampshire were shut do wn (or replaced) after the 2002 base year and therefore were not included in the 2018 in ventory:

• Batesville Manufacturing, Inc. (Nashua, NH)

• PSNH Schiller Station, Unit No. 5 boiler replacemen t (Portsmouth, NH)

• Groveton Paperboard, Inc. (Groveton, NH)

• Wausau Paper Printing & Writing, LLC (Groveton, NH)

Since the 2002 and 2018 inventories were developed and the modeling analyses performed, the following major source has also shut down:

• Fraser N.H. LLC (Berlin, NH)



### 11.6 Measures to Mitigate the Impacts of Constructi on Activities

40 CFR 51.308(d)(3)(v)(B) of the Regional Haze Rule requires New Hampshire to consider measures to mitigate the impacts of construction ac tivities on regional haze. MANE-VU’s
consideration of control measures for construction activities is documented in “Technical Support Document on Measures to Mitigate the Visibi lity Impacts of Construction Activities in the MANE-VU Region,” Draft, October 20, 2006,” ( Attachment DD).

The construction industry is already subject to req uirements for controlling pollutants that contribute to visibility impairment. For example, federal regulations require the reduction of

SO 2 emissions from construction vehicles. At the stat e level, New Hampshire’s Code of Administrative Rules Env-A 1002, Fugitive Dust, req uires the control of direct emissions of particulate matter (primarily crustal material) fro m mining, transportation, storage, use, and removal activities. These requirements apply to su ch sources as quarries, unpaved roads, cement plants, construction sites, rock-crushing op erations, and general earth-moving activities. Controls may include wet suppression, covering, vac uuming, and other approved means.

MANE-VU’s Contribution Assessment (Attachment B) fo und that, from a regional haze perspective, crustal material generally does not pl ay a major role. On the 20 percent bestvisibility days during the 2000-2004 baseline perio d, crustal material accounted for 6 to 11 percent of particle-related light extinction at MAN E-VU Class I Areas. On the 20 percent worst-visibility days, however, the ratio was reduc ed to 2 to 3 percent. Furthermore, the crustal fraction is largely made up of pollutants o f natural origin (e.g., soil or sea salt) that are not targeted under the Regional Haze Rule. Neverth eless, the crustal fraction at any given location can be heavily influenced by the proximity of construction activities; and construction activities occurring in the immediate vicinity of MANE-VU Class I Areas could have a noticeable effect on visibility.New Hampshire Regional Haze SIP Revision Page 133

For this regional haze SIP, New Hampshire considere d additional measures to mitigate the impacts of construction activities but decided to d efer evaluation of further controls. Future deliberations on potential control measures for con struction activities and their possible implementation will be documented in the first regi onal haze SIP progress report in 2013.



### 11.7 Agricultural and Forestry Smoke Management

40 CFR 51.308(d)(3)(v)(E) requires New Hampshire to consider smoke management techniques related to agricultural and forestry man agement in developing the long-term strategy. MANE-VU’s analysis of smoke management i n the context of regional haze is documented in “Technical Support Document on Agricu ltural and Forestry Smoke Management in the MANE-VU Region, September 1, 2006 ,” (Attachment V).

As that report notes, fires used for resource benef its are of far less significance to the total inventory of fine-particle pollutant emissions than other sources of wood smoke in the region. The largest wood smoke source categories, with resp ect to PM 2.5 emissions, are residential wood combustion (73 percent); open burning (15 perc ent); and industrial, commercial, and institutional wood combustion (9 percent). Unwante d fires involving buildings and wild lands make up only a minor fraction of wood burning emissions and cannot be reasonably
addressed in a SIP. Fires that are covered under s moke management plans, including agricultural and prescribed forest burning, constit ute less than one percent of total wood smoke
emissions in MANE-VU.

Moreover, smoke emissions from all sources represen t only a minor fraction of fine-particle mass that is the cause of regional haze. MANE-VU’s Contribution Assessment (Attachment B) found that elemental carbon, the main ingredient of smoke, contributed only 3 to 4 percent of fine-particle mass on days of worst and best vis ibility. Additionally, elemental carbon absorbs light more readily than it scatters light. It is therefore reasonable to conclude that smoke emissions from controlled agricultural and fo restry burning contribute, on average, only a small fraction of one percent of total light extinction on days of both good and poor visibility. NHDES has no information to indicate t hat this situation would change significantly
over the next decade.

Nevertheless, New Hampshire intends to consult with the Forest Protection Bureau of the New Hampshire Department of Agriculture and with th e New Hampshire Department of Resources and Economic Development (DRED) to consid er smoke management in agricultural and forestry practices to address visi bility effects at MANE-VU Class I Areas. In addition, New Hampshire will consider ways to impro ve the inventory of smoke emissions and to achieve a better understanding of the relati ve importance of agricultural and forestry sources (versus residential wood stoves, in particu lar) as contributors to regional haze. The
results of these efforts will be documented in the first regional haze SIP progress report in
2013.



### 11.8 Estimated Effects of Long-Term Strategy on Vis ibility

40 CFR 51.308(d)(3)(v)(G) requires New Hampshire to consider, in developing its long-term strategy, the anticipated net effect on visibility due to projected changes in point, area, and mobile source emissions over the period addressed b y the long-term strategy. NESCAUM conducted modeling to evaluate the expected improve ments to visibility at affected Class I areas by 2018 as a consequence of implementing MANE -VU’s long-term strategy. ThoseNew Hampshire Regional Haze SIP Revision Page 134

visibility improvements will result, in part, from the efforts identified in this SIP to reduce emissions that originate in New Hampshire.

All Class I states affected by emissions originatin g in New Hampshire have (or will have) established reasonable progress goals for 2018 for each of their Class I areas. The control measures included in this SIP represent the reasona ble efforts of New Hampshire, in conjunction with the efforts of other MANE-VU state s, toward achieving the reasonable progress goals established by the affected states.

Based on the most recent MANE-VU modeling, the prop osed control measures will reduce sulfate levels at affected Class I areas by about o ne-third on the worst visibility days and by 6 to 31 percent on the best visibility days by 2018 . Nitrate and elemental carbon levels will
also show substantial reductions across all areas f or both best and worst days, while smaller reductions in organic carbon levels will occur. Sm all increases are predicted for the fine soil component of regional haze. There is a possibility that the predicted increases in this component are not real but, rather, related to stru ctural differences in the data sets used in the modeling for the baseline and future years. (Speci fically, the fire emissions inventory used in VISTAS for the base year relied on an earlier versi on of fire emissions data than the one used for the 2018 inventory.) No changes are predicted for sea salt because the model does not track this component.

The 2000-2004 visibility readings at affected Class I areas provide the baseline against which future visibility readings will be measured to asse ss progress deriving from implementation of New Hampshire’s regional haze SIP and those of the other MANE-VU states. To determine baseline visibility for affected Class I areas, NHD ES used the 2000-2004 IMPROVE monitoring data to calculate the average deciview v alues for the 20 percent best visibility days and the 20 percent worst visibility days over that period. (Note that both natural conditions and baseline visibility for the 5-year period were calculated in conformance with an alternative method recommended by the IMPROVE Steer ing Committee – see Subsection 4.1) Thus, the 20 percent best day and 20 percent worst day values represent average visibility conditions for the top and bottom quintiles.

To create the series of visibility graphs which fol low, 2018 visibility estimates were made in accordance with EPA modeling guidance. First, 2002 daily average baseline concentrations were multiplied by their corresponding relative red uction factors to obtain 2018 projected concentrations for each day. The 2018 projected co ncentrations were then used to derive daily visibility in deciviews. As a final step, th e deciview values for the 20 percent of days having best visibility were averaged, and the proce ss repeated for the 20 percent of days having worst visibility. The resulting averages represent the projected upper and lower quintiles of visibility in 2018.

The following is provided to assist with interpreta tion of the line graphs in Figures 11.1 and Figures 11.3 through 11.6. Note that lower decivie w values indicate better visibility.

• The irregular blue line ( 

# ~ ) represents the 20 percent best visibility average value as
determined from monitoring data for each year of th e period 2001-2005.

• The irregular red line ( 

# ~ ) represents the 20 percent worst visibility averag e value as
determined from monitoring data for each year of th e period 2001-2005.New Hampshire Regional Haze SIP Revision Page 135

• The straight orange line (

▬ ) represents the 20 percent best visibility average value as determined from monitoring data for the 5-year peri od of 2000-2004. (This line represents the 20 percent best visibility baseline condition .)

• The straight blue line (

▬ ) represents the 20 percent worst visibility averag e value as determined from monitoring data for the 5-year peri od of 2000-2004. (This line represents the 20 percent worst visibility baseline condition .)

• The straight broken line (
▪ ▪ ▪ ) is a continuation of the 20 percent best visibili ty baseline, representing the 20 percent best visibility conditi on as it would be with no further degradation or improvement.

• The straight green line (

▬ ) represents the 20 percent worst visibility values that establish the uniform rate of progress for the peri od 2004-2064. (This line is
sometimes referred to as the uniform progress line , or “glide slope.” It was created by linear interpolation between the average 20 percent worst visibility baseline value from 2000-2004 and the 20 percent worst visibility value under natural conditions in 2064. If visibility improvements match this rate o f progress, actual visibility will return to natural conditions in 2064. Visibility v alues used for the calculation of uniform rate of progress may be found in Table 10.1 .)

• The light-green dash (

▬ ) shown at 2064 represents the theoretical 20 perce nt best visibility value under natural conditions (i.e., no anthropogenic emissions).

• The purple star (  ) represents the 20 percent best visibility value i n 2018 after implementation of MANE-VU’s long-term strategy, as predicted by the CMAQ model. (This value is a reasonable progress goal .)

• The blue star (  ) represents the 20 percent worst visibility value in 2018 after implementation of MANE-VU’s long-term strategy, as predicted by the CMAQ model. (This value is a reasonable progress goal .)

Figure 11.1 illustrates predicted visibility improv ements at Great Gulf Wilderness. Observe that the blue star lies below the green line, indic ating that, by 2018, the long-term strategy of this SIP will result in visibility improvements sur passing the uniform rate of progress on days of worst visibility. Similarly, the position of th e purple star below the dashed line indicates that visibility requirements will be met, i.e., the re will be no further degradation from baseline conditions on days of best visibility.

Figure 11.2 presents bar graphs depicting expected improvements in haze-causing pollutant levels at Great Gulf Wilderness. (The data employe d for these graphs also apply to Presidential Range - Dry River Wilderness.) The gr aph on the left shows concentrations of visibility-impairing pollutants on days of best vis ibility for the 2000-2004 baseline period, 2018 modeled year, and natural background condition . The graph on the right is a similar plot for days of worst visibility. The graphs show that almost all of the expected improvements
will result from reductions in sulfate concentratio ns. If the states adhere to MANE-VU’s reasonable progress goals, sulfate levels (as a fra ction of the total pollutant burden) will fall from about 60 percent in 2000-2004 to no more than 50 percent in 2018 and to less than 10 percent (natural conditions) in 2064.New Hampshire Regional Haze SIP Revision Page 136

Figure 11.1: Expected Visibility Improvement at Gr eat Gulf Wilderness

Based on Most Recent Projections 32

0 5 10 15 20 25 3019851990199520002005201020152020202520302035204020452050205520602065

YearDecivews 20% Worst Observed
20% Best Observed
20% Worst Baseline 20% Best Baseline Uniform Progress No Degradation CMAQ 20% Worst CMAQ 20% Best
20% Best 'Natural'

Figure 11.2: Expected Improvements in Pollutant Co ncentrations at Great Gulf

Wilderness on Best and Worst Days

32 The visibility improvement estimate for Great Gulf Wilderness also serves as an estimate for Presiden tial Range - Dry
River Wilderness. 20% Best Days 20% Worst Days

0 1 2 3 4 5

2000-2004

Baseline 2018 CMAQ Natural Background

ConditionsMass (ug/m3)

Sulfate Nitrate EC OC Sea Salt Soil 0 5 10 15 20 25

2000-2004

Baseline 2018 CMAQ Natural Background

ConditionsMass (ug/m3)

Sulfate Nitrate EC OC Sea Salt SoilNew Hampshire Regional Haze SIP Revision Page 137

Figures 11.3 through 11.6 are line graphs showing a nticipated visibility improvements for the other MANE-VU Class I Areas. All locations are projected to meet or exceed their uniformrate-of-progress goals for 2018. In addition, all areas are expected to see improvements in best-day visibility relative to baseline values.

Figure 11.3: Expected Visibility Improvement at Ac adia National Park

Based on Most Recent Projections

0 5 10 15 20 25 3019851990199520002005201020152020202520302035204020452050205520602065

YearDecivews 20% Worst Observed
20% Best Observed
20% Worst Baseline 20% Best Baseline Uniform Progress No Degradation CMAQ 20% Worst CMAQ 20% Best
20% Best 'Natural'

Figure 11.4: Expected Visibility Improvement at Br igantine National Wildlife Refuge Based on Most Recent Projections

0 5 10 15 20 25 30 3519851990199520002005201020152020202520302035204020452050205520602065

YearDecivews 20% Worst Observed
20% Best Observed
20% Worst Baseline 20% Best Baseline Uniform Progress No Degradation CMAQ 20% Worst CMAQ 20% Best
20% Best 'Natural'New Hampshire Regional Haze SIP Revision Page 138

Figure 11.5: Expected Visibility Improvement at Ly e Brook Wilderness

Based on Most Recent Projections

0 5 10 15 20 25 3019851990199520002005201020152020202520302035204020452050205520602065

YearDecivews 20% Worst Observed
20% Best Observed
20% Worst Baseline 20% Best Baseline Uniform Progress No Degradation CMAQ 20% Worst CMAQ 20% Best
20% Best 'Natural'

Figure 11.6: Expected Visibility Improvement at Mo osehorn National Wildlife Refuge Based on Most Recent Projections 33

0 5 10 15 20 2519851990199520002005201020152020202520302035204020452050205520602065

YearDecivews 20% Worst Observed
20% Best Observed
20% Worst Baseline 20% Best Baseline Uniform Progress No Degradation CMAQ 20% Worst CMAQ 20% Best
20% Best 'Natural'

33 The visibility improvement estimate for Moosehorn Wilderness also serves as an estimate for Roosevelt /Campobello
International Park.New Hampshire Regional Haze SIP Revision Page 139



### 11.9 New Hampshire’s Share of Emission Reductions

40 CFR 51.308(d)(3)(ii) of the Regional Haze Rule r equires New Hampshire to demonstrate that its implementation plan includes all measures necessary to obtain its share of emission reductions needed to meet the reasonable progress g oals. The modeling analyses referenced in Subsection 11.8, above, demonstrate that the New Hampshire/MANE-VU long-term strategy is sufficient to meet these visibility goa ls.

The basis for the long-term strategy is a statement adopted by MANE-VU on June 20, 2007 (see Part 3.3.3, The MANE-VU “Ask”). This document provides that each state will have up to 10 years to pursue adoption and implementation o f reasonable control measures for NO X and SO 2 emission reductions. New Hampshire’s regional haz e SIP is wholly consistent with this long-term strategy. To meet its obligation, N ew Hampshire agrees to pursue the following general and specific emission reduction m easures:

• Timely implementation of BART requirements at the t wo BART-eligible units in the
state: PSNH Merrimack Station Unit MK2 and PSNH New ington Station Unit NT1;

• Participation in a regional low-sulfur fuel oil str ategy that will result in SO 2 emission reductions from one oil-fired electrical generating unit, namely, PSNH Newington Station, as well as from ICI boilers and residentia l heating units across the state;

• Emission controls on targeted in-state EGUs that co ntribute to visibility impairment at Class I areas in the region – more specifically, co mpliance with New Hampshire law RSA 125-O, Multiple Pollutant Reduction Program, wh ich mandates the installation
of scrubbers on PSNH Merrimack Station Units MK1 an d MK2 by July 1, 2013, to
control SO 2 and mercury emissions. These controls will reduce SO 2 emissions at these units by at least 90 percent from 2002 levels. It is anticipated that the scrubber will be optimized for mercury emission reductions and there fore may not meet the 95 percent

SO 2 reduction rate that is typical for scrubbers. How ever, the 90-percent minimum requirement effectively means that actual SO 2 emission reductions must exceed 90 percent on average. To the extent that these highe r rates can be realized, they will be applied against the less than 90-percent SO 2 reduction expected at Newington station
in order to fulfill the state’s commitment to MANE- VU’s targeted EGU strategy.

• Continued evaluation of other possible control meas ures for haze-causing emissions.

Implementation of the long-term strategy will produ ce significant changes in New Hampshire’s emissions inventory by the end of the first plannin g period, 2018. Changes to the emissions inventory will also occur as a result of population growth; changes in land use and transportation; development of industrial, energy, and natural resources; and other air pollution control measures not directly related to regional h aze. However, it is the expected reductions
in SO 2 emissions that will have the greatest effect on vi sibility improvement at MANE-VU Class I Areas; and those reductions will be largely due to implementation of the control measures developed for this SIP. (As a precursor t o sulfate, SO 2 emissions are responsible for most of the fine-particle mass on the haziest days at MANE-VU Class I Areas. See Section 8, Understanding the Sources of Haze-Causing Pollutant s.)

Current and projected SO 2 emissions for the various source categories in New Hampshire and, for comparison, all of MANE-VU are summarized in Ta bles 11.2 and 11.3. These emissions represent the majority of all haze-causing pollutan ts originating within the state and region.New Hampshire Regional Haze SIP Revision Page 140

Further information on New Hampshire’s emissions in ventory, including other pollutants that contribute to visibility impairment, is available i n Section 6, Emissions Inventory.

Table 11.2: SO 2 Emissions from Point, Area, and Mobile Sources

in New Hampshire (tpy)

Source Category Baseline
2002 Projected

2018 % Reduction

2002-2018 Area 7,072 972 86.3
Non-EGU Point 2,436 1,084 55.5
EGU Point 44,124 10,766 75.6

On-Road Mobile 777 537 30.9

Non-Road Mobile 891 246 72.4
TOTAL 55,300 13,605 75.4

Table 11.3: SO 2 Emission from Point, Area, and Mobile Sources

in all of MANE-VU (tpy)

Source Category Baseline
2002 Projected

2018 % Reduction

2002-2018

Area 286,921 129,656 54.8

Non-EGU Point 264,377 91,438 65.4

EGU Point 1,643,257 368,717 77.6

On-Road Mobile 40,090 8,757 78.2

Non-Road Mobile 57,257 8,643 84.9

TOTAL 2,291,902 607,211 73.5

The projected overall reduction of 75.4 percent for SO 2 emissions originating in New Hampshire exceeds by a small amount the projected a verage reduction of 73.5 for all of MANE-VU. This comparison indicates that New Hampsh ire will meet its share of anticipated

SO 2 emission reductions within the region by 2018.



### 11.10 Emission Limitations and Compliance Schedules

40 CFR 51.308(d)(3)(v)(C) requires New Hampshire to establish emission limitations and compliance schedules to meet reasonable progress go als. While emission limitations and compliance schedules are already in place for some New Hampshire control measures outlined in Subsections 11.3 and 11.4, other such p rovisions will need to be established by law (Revised Statutes Annotated, RSA) or codified i n New Hampshire Rules Governing the Control of Air Pollution (Env-A 100 - 4300); specif ically:

• Best Available Retrofit Technology (BART) : The emission limitations and compliance schedule for New Hampshire’s two BART-el igible sources are detailed in
Section 9. The BART emission limitations will be e nforceable through a combination of existing permit conditions, existing administrat ive rules, and a proposed administrative rule to be adopted as Chapter Env-A 2300 Mitigation of Regional Haze (see draft rule, Attachment GG). The tentative sch edule for development and adoptionNew Hampshire Regional Haze SIP Revision Page 141

of this new rule begins with initial rulemaking in early 2012 and concludes with an effective date of July 1, 2013. All BART provision s will have this compliance date.

• Low-Sulfur Fuel Oil Requirements : New Hampshire commits to revising Part EnvA 1604, Sulfur Content Limitations for Liquid Fuels , of the New Hampshire Code of Administrative Rules to require widespread use of l ow-sulfur fuel oil in accordance with the MANE-VU strategy. A draft copy of the pro posed rule change is included in
Attachment FF. The schedule for this rule revision matches the schedule stated above for Env-A 2300 Mitigation of Regional Haze. Phase 1 requirements for suppliers and
users of low-sulfur fuel oil would take effect on J uly 1, 2013. Phase 2 requirements would be effective on July 1, 2017. (Note: Because New Hampshire’s regulations sunset every five years, the state is unable to ado pt requirements now with a compliance date of 2017.)

• Emission Reductions from Specific EGUs : PSNH Merrimack Station Units MK1 and MK2 and PSNH Newington Station Unit NT1 are inc luded in MANE-VU’s targeted EGU strategy. The Merrimack plant is requ ired by New Hampshire law to install a flue gas desulfurization system (scrubber ) to remove SO 2 and other major pollutants by July 1, 2013 (see temporary permit fo r Units MK1 and MK2, Attachment EE). This control measure will simultaneously sati sfy BART requirements for Unit MK2. PSNH Newington Station Unit NT1, which is als o subject to BART limitations, will find it necessary to control fuel sulfur level s in order to achieve a more stringent
SO 2 emission limit than is currently allowed (see BART Analyses for Sources in New Hampshire, Attachment X, and Title V operating perm it, Attachment II). The BART compliance date of July 1, 2013, matches the effect ive date for Phase 1 of the low-sulfur fuel oil strategy. The BART and low-sulfur fuel re quirements are intended to complement each other.

NHDES will continue to evaluate all measures includ ed in the long-term strategy to ascertain whether they remain reasonable for New Hampshire to implement by the end of the SIP planning period (2018) and will formalize that dete rmination with the submission of the first regional haze SIP progress report in 2013. New Hampshire intends to adopt all reasonable control measures as expeditiously as practicable, i n a manner consistent with state law, so that they may be in place by the indicated complian ce dates.



### 11.11 Enforceability of Emission Limitations and Co ntrol Measures

40 CFR 51.308(d)(3)(v)(F) requires New Hampshire to ensure that emission limitations and control measures used to meet reasonable progress g oals are enforceable. All control measures incorporated into law or codified in admin istrative rules will be enforceable. Any facility subject to state or federal permit require ments, including BART-eligible and Title V facilities, will be required to comply with the spe cific permit conditions that reference the applicable provisions of those laws and rules.

In New Hampshire, the authority to create rules, is sue permits, and enforce laws related to regional haze are established in Revised Statutes A nnotated (RSA) 125-C Air Pollution Control. Under RSA 125-C:6, Powers and Duties of t he Commissioner, the NHDES
Commissioner is authorized to enforce the state’s a ir laws, establish a permit program, accept and administer grants, and exercise all incidental powers necessary to carry out the statutory obligations.New Hampshire Regional Haze SIP Revision Page 142

Sections of New Hampshire law of particular relevan ce to the regional haze SIP are:

• RSA 125-C:4, Rulemaking Authority; Subpoena Power, which establishes requirements by which the Commissioner shall adopt rules related (but not limited) to:

− primary and secondary ambient air quality standards ;

− prevention, control, abatement, and limitation of a ir pollution;

− procedures to meet air pollution emergencies,

− establishment and operation of a statewide permit s ystem;

− notification and public hearings on permit applicat ions;

− fees and procedures for permit application and revi ew; and

− procedures for air testing/monitoring and recordkee ping;

and which authorizes the Commissioner to issue subp oenas requiring the attendance of witnesses, production of evidence, and taking of te stimony as he may deem necessary.

• RSA 125-C:11, Permit Required, which authorizes the creation of a permit program and the issuance of permits requiring specific emis sion control measures, including enforceable emission limitations;

• RSA 125-C:12, Administrative Requirements, which au thorizes the Commissioner to collect fees to recover the costs of reviewing and acting upon permit applications and enforcing the terms of permits issued; and

• RSA 125-C:15, Enforcement, which authorizes NHDES t o issue orders to correct violations of RSA 125-C and establishes the legal a uthority for the enforcement of New Hampshire Rules Governing the Control of Air Po llution (Env-A 100 - 4300).

The New Hampshire rules provide for enforceable emi ssion control measures and compliance schedules to meet the applicable requirements of th e Clean Air Act and rules promulgated by EPA. The New Hampshire rules also define the permi t program and fee structure for stationary sources, to ensure that national ambient air qualit y standards are achieved; specifically:

• Chapter Env-A 600, Statewide Permit System (effecti ve 4-26-03, 7-28-04, 6-8-06, 4-3- 08, and 4-22-09), provides for the issuance of temp orary permits, state permits to operate, and Title V operating permits. Part Env-A 619 of this chapter addresses the prevention of significant deterioration of air qual ity and visibility protection, in accordance with the requirements of 40 CFR 51.166, 40 CFR 52.21 and RSA-125-C.

• Chapter Env-A 700 Permit Fee System (effective 4-26 -03 and 6-26-04) provides for the payment of fees to cover the reasonable costs o f administering the permit program and of implementing and enforcing the terms and con ditions of any permit.

With respect to specific control measures for visib ility improvement under the Regional Haze Rule, the following enforceable provisions will app ly:

• PSNH Merrimack Station Units MK1 and MK2, is requir ed to install an FGD system by July 1, 2013, to achieve major emission reductio ns in SO 2 and other pollutants as established under New Hampshire law RSA 125-O, Mult iple Pollutant Reduction Program, and as set forth in Temporary Permit No. T P-0008, issued March 9, 2009 (Attachment EE).New Hampshire Regional Haze SIP Revision Page 143

• PSNH Newington Station Unit NT1 will be required to meet a new SO 2 emission limit of 0.50 lb/MMBtu by July 1, 2013, for any fuel or c ombination of fuels burned, as provided in New Hampshire’s proposed rule Env-A 230 0 Mitigation of Regional Haze (Attachment GG).

• Statewide use of low-sulfur fuel oil for all emissi on sources, consistent with MANEVU’s low-sulfur fuel strategy, will be required fol lowing adoption of revisions to New Hampshire’s existing rule Env-A 1604 Sulfur Content Limitations for Liquid Fuels (Attachment FF) by no later than July 1, 2013.

Ultimately, New Hampshire’s Regional Haze SIP is de pendent on the implementation of
enforceable emission limitations and control measur es, both within the state and in other states identified as contributing to visibility imp airment at New Hampshire’s Class I Areas. Because New Hampshire has no jurisdiction over othe r states, the attainment of regional progress goals will, to a large extent, be predicat ed on the good-faith efforts of contributing upwind states to meet their fair share of emission reductions through implementation of their own enforceable control measures. While New Hampsh ire can provide assurances regarding the implementation of in-state emission controls, t he bulk of regional-haze-causing pollutants over New Hampshire will continue to come from out-o f-state sources.



### 11.12 Prevention of Significant Deterioration

Part Env-A 619 of Chapter Env-A 600 of New Hampshir e’s Rules spells out the Prevention of Significant Deterioration (PSD) requirements of the Statewide Permit System. PSD is applicable to all major sources (or existing source s making a major modification) located in
an area that is in attainment with the National Amb ient Air Quality Standards. A major source is an emissions source that has the potentia l to emit more than 100 tons per year of any pollutant. One of the purposes of the PSD program is to protect air quality in national parks, wilderness areas, and other areas of special natura l, scenic, or historic value. The PSD permitting process requires a technical air quality analysis and additional analyses to assess the potential impacts on soils, vegetation, and vis ibility at Class I areas.

PSD permit applicants are required to conduct such analyses, and may do so in consultation with NHDES and the relevant Federal Land Manager (F LM). Recommended procedures for evaluating the impacts of a proposed PSD source on air quality and visibility at Class I areas are provided in NHDES’ “Guidance and Procedure for Performing Air Quality Modeling in New Hampshire,” July 2006. New major sources and e xisting sources making major modifications will be constructed and operated so a s not to degrade air quality or visibility. The PSD permitting program, as set for under Env-A 619, is an integral part of New Hampshire’s long-term strategy for meeting its regi onal haze goals.New Hampshire Regional Haze SIP Revision Page 144



### 12. Administrative Materials

On May 25, 2009, NHDES published in a statewide new spaper, the Manchester, NH, Union
Leader , a public notice soliciting comment on New Hampshi re’s Regional Haze SIP Revision. The notice also announced the opportunity to reques t a public hearing for the SIP revision. A public hearing was held at NHDES headquarters on We dnesday, June 24, 2009. A copy of the public notice is presented in Attachment JJ. D ocumentation certifying the public process is provided in Attachment KK. Evidence of legal au thority to create and submit this SIP revision may be found in Attachment LL.

NHDES received written comments from EPA and the Fe deral Land Managers on June 26,
2009. NHDES also received written comments from th e Appalachian Mountain Club on that
date. NHDES has addressed all comments in the SIP revision. Comments from EPA and the FLMs, and NHDES’s formal responses to those comment s, are included in Attachment I. Comments from AMC and responses to those comments a re included in Attachment J.New Hampshire Regional Haze SIP Revision

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