### Revision to the 

## New Hampshire State Implementation Plan



# Maintenance Plan for Former 1-Hour Ozone NonattainmentAreas in Cheshire, Hillsborough, Merrimack, Rockingham,

and Strafford Counties

March2, 2012

'NEW

HAMPSHIRE AV ` DEPARTMENT OF



# nmental Services Air Resources DivisionNew Hampshire Ozone Maintenance SIP Page i TABLE OF CONTENTS 1. INTRODUCTION. .. . . . . . .. . . . . . .. . . . . . .. . . . . .. . . . . . .. . . . .. . . . . . .. . . . . .. . . . . . .. . . . .. .. . . . . .. . . . . . ..... . .. . . .. . .. . ..1 1 .1 Background. . . .. . . . . . .. . . . . .. .. . . . .. . . . . . .. . . . . . .. . . . . .. . . . .. . . . . .. . . . . . . .. . . . . . . .. . . . .. . . . . ..... . . .. . . . . .. . ..1 1 .2 National Ozone Standards. .. . . . .. . . . . . . .. . . . . .. . . . . .. . . . . .. . . . . . .. . . . . .. . . . . . . .. . . .. .. . ..... . . . . .. . . . . .. . ..1 1 .3 Attainment Status. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . .2 1 .4 SIP Revisions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . .6 1 .5 Maintenance Plan Components. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . ... . . . . .7 2. ATTAINMENT INVENTORY AND MAINTENANCE DEMONSTRATION. . . ... . . . . . . . . . . . . .. . . . . . .8 2.1 2002 Attainment Inventory. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . .8 2.2 2012 and 2014 Projected Inventories. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . ., ..9 2.3 Maintenance Demonstration. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10 3. AMBIENTAIRQUALITYMONITORING. . . . . .. . . . . . . .. . . .. .. . . . . .. . . . . .. . . . . . .. . . . . . .. . . . . . .. . . ., .. . ... .13 4 . CONTINGENCY PLAN. . . .. .. . . . . .. . . . . .. . . . . . .. . . . . .. . . . . .. . . . . .. . . . . . .. . . . . .. . . . . .. . . . . .. .. . . . . .. . . . ..... . ...14 4.1 ICI Boilers (at Major Point Sources) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 4.2 Emulsified Asphalt Paving. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . 15 4.3 Consumer Products. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... IS 4.4 Additional Controls on Boilers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . ... . . . . . . . . .16 4.5 Other Contingency Measures. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17 5. VERIFICATIONOF CONTINUEDATTAINMENT. . . . . . .. . . . . . .. . . . .. . . . . .. .. . . . . .. . . . . .. . ... . .. . . . . .. .18 6 . ADMINISTRATIVE DOCUMENTS. .. . . . . .. .. . . . . .. . . . . .. . . . . . .. . . . . .. . . . . .. . . . . .. . . . . . .... . . . . .. . .. . .. . . ...18 7. SUMMARY. . . .. . . . . .. . . . . . . . .. . . . . .. . . . . . .. . . . . .. . . . . .. . . . .. . . . . . . .. . . . . . .. . . . . . .. . . .. . . . . . .. . . . ... .. . . . . .. . . . .. .18 LIST OF FIGURES Figure 1-1 New

Hampshire 1-hour and 8-hour Nonattainment Areas. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . .5

LIST OF TABLES Table 1-1 New

Hampshire Designations/Classifications for 1-Hour Ozone Standard Revisedas ofJuly 1, 2002 (40CFR81 .330) . . . . . .. . . . . .. . . . . .. . . . . . . .. . . . . .. .. . . . .. . ... .. .. . . .... . ...3 Table 1-2 New

Hampshire Designations/Classifications forthe 1997 8-Hour Ozone Standard Effective June 15, 2004 (FR6923857) . . . . . . .. . . . . .. . . . . . .. . . . . .. . . . . . .. . . . . . .. . . . .. . . . . ... . . ... .. ....4 Table 1-3 1-Hour Ozone Nonattainment/Maintenance Areas Designated Unclassifiable/

Attainment forthe 1997 8-Hour Standard as ofJune 15, 2004. . . . .. . . . . . .. . . . . .. . . . .. . . . . .. .. ...7 Table 2-1 2002 vs. 2012 and 2014 NOxand VOCEmissions for Cheshire, Hillsborough,

Merrimack, Rockingham, and Strafford Counties. . . . .. . . . . . .. . . . . . . .. . . . .. . . . . .. . . . . .. . . . .. . ....10 Table 3-1 8-Hour Ozone Monitoring Data: 2012 Threshold Values and 2010-2011 Design

Values Based on Fourth-Highest Annual Maxima. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Table 4-1 Estimated Emission Reductions fromThree BOTW Control Measures. . . .. . . . .. .. . . .. . . ......14 Table 4-2 Potential Contingency Measures for Reducing Ozone Levels. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 LIST OF ATTACHMENTS AttachmentA 2002 Attainment Inventory and 2012 and 2014Projected Inventories Attachment B Administrative DocumentsNew Hampshire Ozone Maintenance SIP Page ii

This page intentionally left blank .New Hampshire Ozone Maintenance SIP Page 1 l . INTRODUCTION This maintenance plan, presented as a revision to New Hampshire's State Implementation Plan (SIP), addresses the anti-backsliding provisions of the Clean Air Act, Section 110(a)(1), with respect to the former 1-hour ozone standard after promulgation of the 1997 8-hour ozone standard. The maintenance plan (also known as "maintenance SIP") applies to former 1-hour ozone nonattainment areas constituting all of Cheshire County and portions of Hillsborough, Merrimack, Rockingham, and Strafford Counties. 1 .1 Background Under Section 110(a)(1), states are required to implement, maintain, and enforce national primary ambientair quality standards: "Each State shall, afterreasonable notice and public hearings, adoptand submit to the Administrator, within 3years (or such shorterperiod as the Administrator may prescribe) afterthe promulgation ofa national primary ambient air quality standard (or any revision thereof) under section 109 for any air pollutant, a plan which provides for implementation, maintenance, and enforcement of such primary standard in each air quality control region (or portion thereof) within such State. . ." States are expected to meet these requirements through individualized State Implementation Plans. SIPs are dynamic documents describing the state's statutory and regulatory (i .e., enforceable) emission control measures that will be implemented to ensure compliance with the national standards. SIPs must be periodically reviewed and updated to meet administrative requirements, changing air quality conditions, changing emissions, and new or amended federal programs. 1.2 National OzoneStandards Since the 1970s, EPA has established and periodically reviewed/revised the national ambient air quality standards (NAAQS) for ground-level ozone. The original 1-hour primary standard of 0 .08 parts per million (ppm) for photochemical oxidants, promulgated by EPA in 1971 (Federal Register, 36 FR 8186), was revised in 1979 to a 1-hour standard of 0 .12 ppmfor ozone (44 FR 8202) . In 1993, after a lengthy period of scientific review, litigation, and public input, EPAdecided to retain the 0

.12 ppmstandard (58 FR 13008) . (Note: The secondary ozone standard was set identical to the primarystandard.) On July 18, 1997, EPA published a final rule for a new8-hour ozone standard of 0 .08 ppmto replace the 1-hour standard (62 FR 38855), effective on September 16, 1997. This change was basedon further scientific studyconcluding that the 1-hour standard did not provideadequate health protection against extended periods of moderately elevated ozone levels. The 1997 8-hour ozone NAAQS bore a more direct relationship to ozone concentrations associated with health effects. As part of the transition to the more protective 8-hour standard, the agency issued rules determining that the 1-hour standard no longer applied in certain areas. EPAsubsequently rescinded this action in response to litigation that created uncertainty as to when and whether the 8-hour standard would be fully implemented

. Arule reinstating the 1-hour standard was published on July 20, 2000, and implementation of the newer standard was delayed for several years pending resolution ofthe legal issues. The Phase 1 implementation rule for the 8-hour ozone standard was published in final form on April 30, 2004 (69 FR 23857) . On June 15, 2005, EPArevoked the 1-hour ozone standard for most areas of the country (including all of New Hampshire) and replaced it with the 8-hour ozone standard (69 FR23857 and 70FR44470) .New Hampshire Ozone Maintenance SIP Page 2 In 2008, EPA further strengthened the 8-hour NAAQS for ground-level ozone to 0 .075 ppm, effective on May 27, 2008 (73 FR 16435) . After reconsideration of the scientific evidence, on January 6, 2010, EPA proposed to reduce the standard to 0 .060-0.070 ppm(75 FR 2938) . In its final determination, however, headquarters clarified that "EPA fully intends to implement this current standard [0.075 ppm] as required under the Clean Air Act," (memo fromGina McCarthy, Assistant Administrator, to the Regional Air Division Directors, September 22, 2011) . While this provides historical context, the 2008 revision of the ozone NAAQS is irrelevant to the antibacksliding provisions that serve as the reason for this maintenance plan. This plan is therefore unaffected by EPA's most recent actions to strengthen the 8-hour ozone standard. 1.3 Attainment Status The 1990 amendments to the CleanAir Actestablishedan area classification systemfor attainment ofthe 1-hour ozone NAAQS. Under this system, all areas of the United States were designated as attainment, nonattainment, or unclassifiable, depending on the available monitoring data for those areas. In addition, attainment areas could be either classified or unclassifiable according to the adequacy ofthe monitoring data. Nonattainment areas were further classified as marginal, moderate, serious, severe, or extreme, to represent progressive levels of exceedance of the 1-hour ozone standard. The 1990 amendments also established mandatory SIP submission requirements based on the ozone nonattainment designation. New Hampshire's area designations and classifications for the 1-hour ozone standard are codified at 40 CFR81 .330 (Table 1-1) . Counties in the northern and central parts ofthe state were designated as unclassifiable/attainment areas for 1-hour ozone. The more populous southeastern counties of Strafford, Rockingham, and Hillsborough, were designated as serious nonattainment areas. Southcentrally located Merrimack County was classified as a marginal nonattaimnent area. Cheshire County, in the state's rural southwest corner, was designated as a nonattainment area on the basis of incomplete data. With the 1-hour area classifications already reinstated, onJuly 24, 2000, NHDES submitted to EPA its attainment classification recommendations for the newer, 8-hour standard. This submittal was followed by another, on July 15, 2003, that included consideration of Consolidated Metropolitan Statistical Area (CMSA) boundaries and other regional considerations in making recommendations for determining nonattainment areas for 8-hour ozone. Final attainment classifications for the 8-hour ozone standard appeared in the Federal Register on April 30, 2004 (69 FR 23857), with an effective date ofJune 15, 2004. EPAdesignated the New Hampshire portion ofthe Boston-Manchester-Portsmouth area as a moderate nonattainment area for the 8-hour ozone NAAQS (Table 1-2) with a maximumattainment date of June 15, 2010 . It is worth noting that no monitor in New Hampshire had an 8-hour ozone design value equal to or greater than 0

.092 ppm, a situation that normally would have put the nonattainment area in the marginal classification. However, NHDES agreed to the moderate classification to provide regional consistency with contiguous nonattainment areas extending fromsouthern Maineto Massachusetts.New Hampshire Ozone Maintenance SIP Page 3 Table 1-1 . New

Hampshire Designations/Classifications for 1-Hour Ozone Standard Revised as ofJuly 1, 2002 (40CFR81 .330) Area County Cities and Towns Included -7 Designation/ Classification NonattainmentAreas Manchester Area Merrimack (all) Allenstown, Andover, Boscawen, Bow, Bradford, Nonattainment**/ Canterbury, Chichester, Concord, Danbury, Marginal** Dunbarton, Epsom, Franklin, Henniker, Hill, Hooksett, Hopkinton, Loudon, New London, Newbury, Northfield, Tilton, Pembroke, Pittsfield, Salisbury, Sutton, Warner, Webster, Wilmot Hillsborough (part) Antrim, Bedford, Bennington, Deering, Francestown, Nonattainment**/

Goffstown, Greenfield, Greenville, Hancock, Marginal** Hillsborough, Lyndeborough, Manchester, Mason, New Boston, New

Ipswich, Peterborough, Sharon, Temple, Weare, Windsor Rockingham(part) Auburn, Candia, Chester, Deerfield, Epping, Fremont, Nonattainment**/

Northwood, Nottingham, Raymond Marginal** Boston-Lawrence- Hillsborough (part) Pelham, Amherst, Brookline, Hollis, Hudson, Nonattainment*/ Worcester Area Litchfield, Merrimack, Milford, Mont Vernon, Serious** Nashua, Wilton. Rockingham(part) Atkinson, Brentwood, Danville, Derry, East Kingston, Nonattainment**/

Hampstead, Hampton Falls, Kensington, Kingston, Serious** Londonderry, Newton, Plaistow, Salem, Sandown, Seabrook, South Hampton, Windham Portsmouth-Dover- Rockingham(part) Exeter, Greenland, Hampton, New Castle, Newfields, Nonattainment**/ Rochester Area Newington, Newmarket, North Hampton, Portsmouth, Serious** Rye, Stratham Strafford (all) Barrington, Dover, Durham, Farmington, Lee, Nonattainment**/

Madbury, Middleton, Milton, New Durham, Serious** Rochester, Rollinsford, Somersworth, Strafford Cheshire County Cheshire (all) Alstead, Chesterfield, Dublin, Fitzwilliam, Gilsum, Nonattainment**/ Harrisville, Hinsdale,Jaffrey, Keene, Marlborough, Incomplete Marlow, Nelson, Richmond, Rindge, Roxbury, Data** Stoddard, Sullivan, Surry, Swanzey, Troy, Walpole, Westmoreland, Winchester Unclassifiable/Attainment Areas Belknap County Belknap all Unclassifiable/ Attainment Sullivan County Sullivan all Unclassifiable/ Attainment AQCR 107Androscoggin Coos all Unclassifiable/ Valley Interstate Attainment AQCR 149Central New Carroll all Unclassifiable/ Hampshire Interstate Attainment Grafton all Unclassifiable/ Attainment * October 18, 2000 ** January 16, 2001New Hampshire Ozone Maintenance SIP Page 4 Table 1-2

. New Hampshire Designations/Classifications forthe 1997 8-Hour OzoneStandard

EffectiveJune 15, 2004 (FR6923857) Area County Cities and Towns Included Designation/ Classification NonattainmentAreas Boston-Manchester- Hillsborough (part) Amherst, Bedford, Brookline, Goffstown, Hollis, Hudson, Nonattainment Portsmouth Area Litchfield, Manchester, Merrimack, Milford, Nashua, Pelham Subpart2/Moderate (Southeast New Merrimack(part) Hooksett Nonattainment HampshireArea) Subpart 2/Moderate

Rockingham(part) Atkinson,Auburn,Brentwood, Candia,Chester, Danville, Nonattainment

Derry, E. Kingston, Epping,Exeter, Fremont, Greenland, Subpart 2/Moderate Hampstead, Hampton, HamptonFalls, Kensington, Kingston,Londonderry, New Castle, Newfields, Newington, Newmarket, Newton, North Hampton, Plaistow, Portsmouth, Raymond, Rye, Salem, Sandown, Seabrook, SouthHampton, Stratham, Windham Strafford (part) Dover, Durham, Rochester, Rollinsford, and Somersworth Nonattainment Subpart 2/Moderate Unclassifiable/Attainment Areas Hillsborough County Hillsborough (part) Antrim, Bennington, Deering, Francestown, Greenfield, Unclassifiable/ Greenville, Hancock, Hillsborough, Lyndeborough, Mason, Attainment MontVernon, New

Boston, New

Ipswich, Peterborough, Sharon, Temple, Weare,Wilton, Windsor MerrimackCounty Merrimack (part) Allenstown, Andover, Boscawen, Bow, Bradford, Unclassifiable/ Canterbury, Chichester, Concord, Danbury, Dunbarton, Attainment Epsom, Franklin, Henniker, Hill, Hopkinton, Loudon, New London, Newbury, Northfield, Pembroke, Pittsfield, Salisbury, Sutton, Warner,Webster, Wilmot RockinghamCounty Rockingham(part) Deerfield, Northwood, Nottingham Unclassifiable/ Attainment Strafford County Strafford (part) Barrington, Farmington, Lee, Madbury, Middleton, Milton, Unclassifiable/ New Durham, Strafford Attainment Belknap County Belknap all Unclassifiable/ Attainment Carroll County Carroll all Unclassifiable/ Attainment Cheshire County Cheshire all Unclassifiable/ Attainment Coos County Coos all Unclassifiable/ Attainment Grafton County Grafton all Unclassifiable/ Attainment Sullivan County Sullivan all Unclassifiable/ Attainment The nonattainment areas listed above for the 1-hour and 8-hour ozone standards are represented graphically in the map ofFigure 1-1 . Note that these area classifications applied at specific dates during the first half of the previous decade. Because of regional progress in reducing emissions, some locations formerly identified as nonattainment areas have since achieved attainment. Also, because of recent improvements in monitoring, some locations formerly designated as unclassified attainment areas could now be redesignated as classified attainment areas. The classifications as listed here are relevant to this maintenanceSIP

.New Hampshire Ozone Maintenance SIP Figure 1-1 . New

Hampshire 1-hour and 8-hour NonattainmentAreas



# State of New

Hampshire Ozone Nonattainment Areas

Nonattainment Area for 1-hour Ozone (July 1, 2002) = Section 110(a)(1) Maintenance Planning Area Nonattainment Area for Both 1-hour Ozone (July 1, 2002) and 8-hour Ozone (June 15, 2004) Page 5New Hampshire Ozone Maintenance SIP Page 6 1 .4 SIPRevisions On June 30, 1998, NHDES submitted to EPA an ozone attainment demonstration for the New Hampshire portion of the Boston-Lawrence-Worcester 1-hour ozone serious nonattainment area. As required under the CleanAirAct, this SIPrevision was a plan for achieving attainment ofthe 1- hour ozonestandard in the affected area. The final rule approving theattainment demonstration SIP was published on December 6, 2002 (67 FR72574), and became effective onJanuary 6, 2003. The final rule set an attainment date of November 15, 2007, and also approved the attainment-level vehicle emissions budgets for NOx and VOC for the NewHampshire portion of the BostonLawrence-Worcester serious nonattainment area for use in meetingtransportation conformity. On December 30, 2004, NHDES submitted the required mid-course review for the New

Hampshire portion of the Boston-Lawrence-Worcester 1-hour ozone serious nonattainment area. EPA gave notice, on October 12, 2005 (70 FR 59338), that New Hampshire had submitted an acceptable midcourse review

and fulfilled its commitment made in the attainment demonstration plan. On December 14, 2011, EPApublished a proposed rule (76 FR 77739) determining that the BostonLawrence-Worcester MA-NH serious one-hour ozone nonattainment area met the November 15, 2007, deadline for attaining the one-hour NAAQS for ozone, based on quality-assured, certified data for the 2005-2007 monitoring period. When the attainment classifications for the 1997 8-hour ozone standard were issued in mid-2004, some locations in New Hampshirethat were previously found to be in nonattainment for the 1-hour ozone standard were determined to be in attainment for the 8-hour ozone standard. Although the 8- hour standard superseded the 1-hour standard, anti-backsliding provisions established at 40 CFR 51 .905 required states to develop maintenance plans to prevent degradation of air quality in former nonattainment areas that were reclassified to attainment. In this instance, a maintenance plan was required for: Any attainment area or unclassifiable area for the 8-hour ozone standard that was formerly in nonattainment for the 1-hour ozonestandard, or Any attainment area or unclassifiable area for the 8-hour ozone standard that was formerly in nonattainment for the 1-hour ozone standard but that achieved attainment with an approved maintenance plan. Table 1-3 lists the specific locations in New Hampshirethat meet thesequalifications andare covered by this maintenance SIP . They include all, or portions of, the following five southern New Hampshire counties: Cheshire, Hillsborough, Merrimack, Rockingham, and Strafford (see the green-shaded area inthe mapofFigure 1-1) .New Hampshire Ozone Maintenance SIP Table 1-3. 1-Hour Ozone Nonattainment/MaintenanceAreas Designated Unclassifiable/Attainment for the 1997 8-Hour Standard as ofJune 15, 2004 (= Maintenance Planning Area)' Page 7

Area County Cities and Towns Included Boston-Lawrence- Hillsborough (part) Mont Vernon, Wilton Worcester Area Manchester Area Hillsborough (part) Antrim, Bennington, Deering, Francestown, Greenfield,Greenville, Hancock, Hillsborough, Lyndeborough, Mason, New Boston, New Ipswich, Peterborough, Sharon, Temple, Weare, Windsor Merrimack(part) Allenstown,Andover, Boscawen, Bow, Bradford, Canterbury, Chichester, Concord, Danbury, Dunbarton, Epsom, Franklin, Henniker, Hill, Hopkinton, Loudon, New London, Newbury, Northfield, Pembroke, Pittsfield, Salisbury, Sutton, Warner, Webster, Wilmot RockinghamCounty Rockingham(part) Deerfield, Northwood, Nottingham Strafford County Strafford (part) Barrington, Farmington, Lee, Madbury, Middleton, Milton, New Durham, Strafford Cheshire County Cheshire (all) Alstead, Chesterfield, Dublin, Fitzwilliam, Gilsum, Harrisville, Hinsdale, Jaffrey, Keene, Marlborough, Marlow, Nelson, Richmond, Rindge, Roxbury, Stoddard, Sullivan, Surry, Swanzey, Troy, Walpole, Westmoreland, Winchester 1.5 Maintenance Plan Components The maintenance plan must be in theformofa SIP revision providing for continued maintenanceof the 8-hour ozone NAAQS in the planning area for 10 years fromthe effective date of the area's designation as unclassifiable/attainment. The maintenance plan must contain, at a minimum, the following elements:

. an attainment inventory, a maintenancedemonstration, provisions for continued ambient air quality monitoring, acontingency plan, and verification ofcontinued attainment. Therequired plan elements are addressed in the sections whichfollow .

' Source: Table 2 of EPA's "Maintenance Plan Guidance Document for Certain 8-hour Ozone Areas under Section I 10(a)(1) ofthe Clean AirAct," May 20, 2005.New Hampshire Ozone Maintenance SIP Page 8 2 . ATTAINMENT INVENTORYANDMAINTENANCE DEMONSTRATION The maintenance plan must demonstrate that the planning area will remain in compliance with the 8-hour ozone standard for the 10-year period following the effective date of designation as unclassifiable/attainment. To make this demonstration, a state may use either an emissions inventory approach or other methods such as modeling. New Hampshire is using the emissions inventory approach to demonstrate that future emissions of ozone precursors (NOx and VOC) will not exceed attainment inventory levels. Thus, the analysis requires development of a baseline attainment inventory as well as an inventory of future emissions for the projection year, at a minimum

. For areas (including New Hampshire) with an effective attainment designation date of June 15, 2004, for the 1997 8-hour ozone standard, the maintenance plan must project attainment for 2014. In addition, an emissions inventory wasdevelopedfor an interim year (2012) to demonstrate that maintenanceoftheozonestandard is likely to continue throughout the 10-year period. New Hampshire's 2002 attainment inventory and projected 2012 and 2014 inventories presented in this section are divided into thefollowing general emissions categories: Point Sources, which represent discrete facilities. These sources must usually meet certain emission thresholds to be included as point sources and therefore generally represent larger facilities. Area Sources, which represent facilities and activities too numerous and widespread to be inventoried individually butwhichcollectively may account for significant emissions. Non-Road Mobile Sources, including aircraft, locomotives, commercial marine vessels, construction vehicles, lawn &garden equipment, and other mobile vehicles and equipment that are not meantto be operated on roadways. On-Road Mobile Sources, including cars, trucks, buses, motorcycles, and othervehicles that operate on public roadways. To complete the inventories, NHDES followed EPA guidance for making emission estimates of NOx and VOCon a typical summer day. The inventories were prepared for the five southern New Hampshire counties of Cheshire, Hillsborough, Merrimack, Rockingham and Strafford. Note, however, that the maintenance planning area includes only parts of Hillsborough, Merrimack, Rockinghamand Strafford Counties. It is sometimesdifficult or impractical to apportion emissions to a resolution finer than the county level ; andthe irregular geography ofthe maintenance planning area presented a particular challenge in this regard. However, because the maintenance planning area constitutes a large geographic portion of the entire 5-county area, NHDES reasoned that emission trends in the five southern counties would serve as an acceptable proxy for emissions trends in the maintenance planning area; the additional effort required to extract the estimates specific to the planning area would add little value to the analysis. Therefore, to the extent that the inventory data showdeclining emissions in the 5-county area as a whole, the data also reflect improvingair qualitywithin the maintenanceplanning area. 2 .1 2002 Attainment Inventory The maintenance plan starts with a baseline attainment inventory of emissions, which details the volatile organic compounds (VOC) and oxide ofnitrogen (NOx) emissions for the planning area on a "typical summer day." The Phase 1 implementation rule for the 8-hour ozone standard specifies that the 10-year maintenance period begins on the effective date of the 8-hour ozone NAAQSNew Hampshire Ozone Maintenance SIP Page 9 designation. Although a state may use any of the three years upon which the 8-hour ozone designation was based (i .e., 2001, 2002 and 2003), EPA recommends that areas use 2002 as the attainment inventory base year.2 NHDES previously prepared a 2002 Periodic Emissions Inventory for ozone precursors to satisfy New Hampshire's obligations under the Consolidated Emissions Reporting Rule (CERR) . NHDES formally submitted its 2002 Periodic Emissions Inventory to EPA on June 7, 2007 (cover letter to Robert Varney) . For the purposes of this maintenance plan, New Hampshire is usingthat inventory as a basis for its 2002 attainment inventory for all source categories. Affected point-source facilities in New Hampshire are required to report their emissions on an annual basis. The reporting requirements are specified under New Hampshire's air regulations, air permitting program, and the CERR . The data submitted by these point-source facilities are extensively cross-checked and quality assured by NHDES staff before eventual submittal to EPA . Further details regarding NewHampshire point source data collection and quality assurance programs are available in Section A, "Point Sources," of the documentation for New Hampshire's 2002 Periodic Emissions Inventory. The methodologies that New Hampshire used to prepare its 2002.periodic area source emissions inventory came primarily from EPA's Emissions Inventory Improvement Program (EIIP) . Methodologies for specific area source categories can be found in EIIP Volume 3, Area Sources, available at http://www .epa.jzov/ttn/chief/eiip/techreport/volume03/index .html . Calculations for many area source categories are based on variables such as population, employment, and fuel consumption data. Detailed descriptions of the methodologies used in the 2002 area source inventory can be found in Section B, "Area Source Emissions," of the documentation for New Hampshire's 2002Periodic Emissions Inventory. For the non-road mobile category, New Hampshire used the appropriate models for estimating nonroad vehicle emissions, including the Federal Aviation Agency's (FAA's) Emissions &Dispersion Modeling System (EDMS) for aircraft and airport ground service equipment and EPA's NONROAD model for other non-road equipment types. New Hampshire also used applicable references and methodologies for estimating emissions for those equipment types not included in the EDMS and NONROADmodels such as locomotives and CMVs. Detailed descriptions ofthe methodologies used by New Hampshire in its 2002 non-road mobile inventory can be found in the non-highway mobile sources portion of Section B, "Area Source Emissions" of the documentation for New Hampshire's 2002Periodic Emissions Inventory. For on-road mobile sources, NewHampshire used vehicle-miles-traveled (VMT) data obtained from the NewHampshire Department of Transportation and EPA's MOVES motor vehicle emission factors model . 2.2 2012 and 2014 Projected Inventories In accordance with EPA guidance, NHDES prepared an estimate of ozone-precursor emissions projected to 10 years after June 15, 2004, the effective date of the 8-hour ozone attainment designation. NHDES also prepared emission estimates for the interim year 2012. For both projected inventories, NHDES used the Economic Growth and Analysis System(EGAS) Version Z EPA's Consolidated Emissions Reporting Rule (CERR) already requires the development of a 2002 inventory (40 CFRPart 51, Subpart A, 67 FR39602, June 10, 2002) .New Hampshire Ozone Maintenance SIP Page 10 5.0 to develop the applicable growth factors (except for NONROAD model sources and on-road mobile sources, as noted below) . These growth factors were matched to the appropriatepoint, area, and mobile source categories using Source Classification Codes (SCC) . With respect to area sources, New Hampshire has adopted or is evaluating various control measures for a number of VOCsource categories such as solvent cleaning, architectural surface coating, etc. For those measures that are not yet SIP-approved, the attendant emission reductions benefits are omitted fromthe 2012 and 2014 inventories. As a consequence ofthis conservative approach, it is anticipated that the actual projected emissions in those years will be lower than the projected emissionspresented herein. Because analysis year is an inherent input into the NONROAD model, projected 2012 and 2014 non-road mobile emissions were estimated directly for those non-road equipment categories that are included in the model . For other non-road mobile categories such as aircraft, locomotives, and CMVs, the appropriate EGAS growth factors were used. For commercial aircraft and airport ground service equipment, the EGAS growth factors were applied to the specific activities (e.g., aircraft landing-takeoffoperations) ; andthe growth-adjusted values were then input into the EDMS model . (Note: The EDMS model uses the analysis year toselect theappropriate emission factors.) Foron-road mobile sources, future-year VMTdata was derived usingtrends in historical VMT from the Federal Highway Administration (FHWA) and fromthe Metropolitan Planning Organizations (MPOs) that represent New Hampshire's ozone nonattainment area. The transportation demand models used by the MPOs utilize population, employment, and other economic factors to growthadjust future-year VMT. Vehicle population data was adjusted for subsequent years using the growth factors fromTable 3-14 of MOVES2010 Highway Vehicle Population and Activity Data, EPA-420-R-10-026, November 2010. 2.3 Maintenance Demonstration Table 2-1 summarizes the 2002 attainment inventory and the projected 2012 and 2014 inventories for the five southern New Hampshire counties that encompass the Section 110(a)(1) maintenance planning area. As the inventory data show, total emissions of NOx and VOCare anticipated to decrease significantly throughthe period ending in 2014. Table 2-1. 2002 vs. 2012 and 2014 NOx and VOCEmissions for Cheshire, Hillsborough,

Merrimack, Rockingham, and Strafford Counties (pounds perday) NOx VOC Source Category 2002 2012 2014 2002 2012 2014 Point 67,347 48,358 50,739 15,898 6,696 7,005 Area 10,516 9,091 9,134 93,778 85,443 91,068 Non-Road Mobile 49,787 36,131 31,215 68,223 40,210 35,121 On-Road Mobile 261,303 75,202 62,347 87,161 36,904 34,245 Total 388,953 168,782 153,435 265,060 169,253 167,439 The figures shown above for the 2002 attainment inventory differ somewhat fromthose previously submitted for the 2002 Periodic Emissions Inventory. The reasons for these differences are as follows:New Hampshire Ozone Maintenance SIP Page I I

0 The on-road mobile emissions estimates for the maintenance plan were calculated with MOVES, which was not available at the time that the 2002 Periodic Emissions Inventory was prepared. On-road mobile emissions estimates for the 2002 Periodic Emissions Inventory were calculated using MOBILE6 .2 emission factors. Similarly, emissions estimates for Stage II vapor recovery vehicle refueling (SCC 25-01- 060-100) for the maintenance plan were calculated with MOVES and were included and reported in the on-road mobile category. Stage II emissions estimates for the 2002 Periodic Emissions Inventory were calculated using MOBILE6.2 emission factors and were reported in the area source category. Since this category is nowcalculated with MOVES and included under on-road mobile, the MOBILE6 .2-based Stage 11 refueling emissions estimates were removed fromthe area source inventory. This resulted in an adjustment to the 2002 maintenance plan area source inventory of -2,638 pounds per day of VOCwhen compared with the previously submitted 2002 Periodic Emissions Inventory. In compiling the 2002 figures for the maintenance plan, it was discovered that emissions estimates for the industrial wood combustion category (SCC 21-02-008-000) should not have been calculated and reported under the area source category. All industrial wood combustion in 2002 would have occurred at permitted point source facilities, and making an area source estimate for this category caused double-counting. Therefore, the area source estimate for industrial wood combustion was removed. This resulted in a correction to the 2002 maintenance plan area source inventory of -25,357 and -880 pounds per day of NOx and VOC respectively when compared with the previously submitted 2002 Periodic Emissions Inventory. The projected reductions in 2012 and 2014 are due to the various federal and state programs to control emissions fromnon-road and on-road mobile sources and to the gradual replacement over time ofolder, more pollutingvehicles with newer, cleaner ones. Contributing to projected emission reductions fromthe non-road mobile sector are thefollowing federal programs:

0 "Control of Air Pollution; Determination of Significance for Nonroad Sources and Emissions Standards for NewNonroad Compression Ignition Engines at or above 37 Kilowatts," 59 FR 31306, June 17, 1994. "Control of Emissions of Air Pollution from Nonroad Diesel Engines," 63 FR 56967, October 23, 1998. "Control of Emissions from Nonroad Large Spark-Ignition Engines and Recreational Engines (Marine and Land-Based)," final rule, 67 FR 68241, November 8, 2002. "Control ofEmissions ofAir Pollution fromNonroad Diesel Engines and Fuel ." final rule, April 2004. Also contributing to projected emission reductions are the following federal/state onroad mobile source control measures: " Reformulated gasoline in Hillsborough, Merrimack, Rockingham, andStrafford Counties;

. An enhanced safety inspection program, including a vehicle anti-tampering inspection for vehicles less than 20years old;New Hampshire Ozone Maintenance SIP Page 12 On-board diagnostics testing for 1996 and newer vehicles in lieu of the anti-tampering inspection; Participation in the National Low Emission Vehicle (Northeast) program ; The Federal Tier II vehicle standards and reducedgasoline sulfur limits. Regarding stationary sources, it should be noted that two relatively large VOC-emitting sources (Batesville Manufacturing, Inc. and Venture Holdings) have closed since the time of the 2002 inventory. However, because NHDES has retained the emission reduction credits fromthese facility closures for possible future use, these emissions have been retained in the 2012 and 2014 inventories. The inventory data clearly demonstrate that total emissions of ozone precursors within the fivecounty region are projected to decline between 2002 and 2014, indicating continued attainment of the 1997 8-hour ozone standard in the maintenance planning area. All of the technical data files associated with the 2002 attainment inventory and the 2012 and 2014 projected inventories are enclosed on CD-ROM

as Attachment A

. Section 110 of the Clean Air Act requires individual states to prevent air pollution emissions that would cause nonattainment of the NAAQS in downwind states. As NHDES has previously observed, over 92 percent of air pollution is transported into the state fromother areas during periods of poor air quality.3 , Through active participation in the Ozone Transport Commission (OTC), the Northeast States for Coordinated Air Use Management (NESCAUM), and other regional organizations, NHDES has cooperated extensively with upwind states and EPAto reduce emissions and achieve attainment ofthe 8-hour ozone standard. While New Hampshire's continued attainment of this standard will depend on the success of in-state control measures, future attainment will depend to an even greater degree on theefficacy of super-regional control measures that reduce ozoneand ozone-precursor transport into New Hampshire.

3 New Hampshire Department of Environmental Services, "Air Pollution Transport and How It Affects New

Hampshire," May2004.New Hampshire Ozone Maintenance SIP Page 13 3 . AMBIENT AIRQUALITY MONITORING The maintenance plan for the 1997 8-hour ozone standard must include provisions for the operation of an ambient air quality modeling network to verify continued maintenance of the 8-hour ozone standard in the planning area. NHDES has monitoring stations throughout the state that record criteria pollutant levels and other air quality data. Table 3-1 presents 8-hour ozone monitoring data for the most recent three-year period frommonitors in the five southernmost counties of Cheshire, Hillsborough, Merrimack, Rockingham, and Strafford. The 2010-2011 design values and 2012 threshold values provide further indication that the maintenance area is likely to continue meeting the 1997 8-hour ozone standard for the duration ofthe planning period. Based on quality-assured data through for the 2011 ozone season, the most recent design values were in the low- to mid-60's parts per billion (ppb) range for most sites, and none was higher than 70ppb. Table 3-1. 8-Hour Ozone Monitoring Data: 2012ThresholdValues and 2010-2011 Design

Values Based on Fourth-Highest Annual Maxima (ppb) Monitor AQS 4`h HighestValue Design Value* 2012 Threshold Most Recent Year at

or above Threshold Location Number 2008 : 2009 : 2010 : 2011 2010 2011 Value** 0Highest 4`h Highest Keene 330050007 68 62 64 62 64 62 129 None None Peterborough 330115001 76 72 77 62 75 70 116 None None Nashua 330111011 67 66 67 65 66 66 123 None None Manchester 330110020 64 ' 60 63 *** 62 *** *** None None Concord 330131007 67 64 68 64 66 65 123 None None Portsmouth 330150014 69 70 66 64 68 66 125 1988 None Rye 330150016 75 68 66 66 69 66 123 1991 None * Example: The 2010design value is the 3-year average of the annual fourth-highest 8-hourozone concentration forthe period 2008-2010

. ** The 2012 threshold value is the fourth-highest monitored daily maximum 8-hour ozonevalue during the 2012 ozone season that would cause the 2012 design value to exceed the 1997 8-hour ozone NAAQS . *** No data; monitor was moved to Londonderry in 2011 . New Hampshire is committed to the continuing operation of an effective air quality monitoring network to verify the area's attainment status in accordance with 40 CFRPart 58, to the extent that federal funding assistance remains sufficient for this purpose. NewHampshire proposes no modifications to the existing monitoring network at this time. Any future proposal to modify the monitoring network will be accompanied by supporting technical and statistical analyses as necessary. Final monitoring network design shall be subject to the approval ofthe EPARegional Administrator.New Hampshire Ozone Maintenance SIP Page 14 4 . CONTINGENCY PLAN As established at 40 CFR 51 .905(a)(3)(iii) and (4)(ii)), the maintenance plan must include contingency provisions to correct any NAAQS violation that occurs after redesignation of an area. EPAguidance4 on this subject calls for contingency measures in the SIP, alongwith a schedule and procedure for adoption and implementation, that can be implemented in a timely fashion once they are triggered. The schedule should be as expeditious as practicable, but no longer than 24 months. The state should also identify specific indicators, or triggers, for setting the contingency plan into action. Possible triggers would be a monitored exceedance of the 8-hour ozone standard or an exceedance ofa precursor emission level onwhichmaintenance is based. Despite NewHampshire's best efforts to maintain compliance with air quality standards, the possibility exists that ambient ozone concentrations might at some future date exceed the NAAQS. Therefore, in accordance with the requirements of Section 175A(d), New Hampshire has identified various contingency measures that could be taken following an ozone "trigger" event and is committedto pursuing the following protocol : 1. At the conclusion of each ozone season, NHDES will evaluate whether the 8-hour ozone design value for any ozone monitor in the planning area is above or below the 1997 8-hour ozone standard (the "trigger") . The design value, in the case ofthis standard, is defined as the average of the annual 4th highest daily maximum8-hour average concentration for the preceding 3-year period. 2 . Ifthe design valueis abovethe standard for anyozone monitor, NHDESwill investigate the causeanddetermine whether the exceedance is dueto: a . an increase in emissions fromlocal, in-state sources; b. an increase in emissions fromupwind, out-of-state sources; or c. exceptional eventas defined in 40CFR50 .1 . 3. Ifan increase in in-state emissions is determined to be acontributing factor to the exceedance, NHDES will evaluate the projected in-state emissions for the next ozone season. If the projected in-state emissions are notexpected to decrease enough in the next ozone season to mitigate the violation, NewHampshire will implement one or more of the contingency measures listed below

or will substitute other VOCor NOx control measures as necessary to achieve additional in-state emission reductions. 4 . The contingency measures(s) will be selected by the Governor or the Governor's designee within six months ofthe endofthe ozone season forwhich contingency measures have been determined to be needed. New Hampshire will then initiate acourse ofaction to implement enforceable control measure(s) to rectify the problem . New rulemaking can typically be adopted and implemented within a 12-month timeframe. NHDES will update the maintenance plan as necessary and develop and implement required regulations as soon as practicablewithintheguidelines established in the New Hampshire Administrative Procedures Act, but no later than 18 months after selection ofthe appropriate measure. New Hampshire is studying an array of possible contingency measures that would achieve further reductions in NOx and VOC emissions, including the following emission controls previously proposed by the Northeast states: 4See reference in footnote 1 .New Hampshire Ozone Maintenance SIP Page 15 " NOxcontrols for industrial, commercial, and institutional (ICI) boilers;

. VOCcontrols for emulsified and cutbackasphalt paving; and

. VOCcontrols for consumer products. These contingency measures are among several OTCcontrol measures5 exceeding current on-thebooks/on-the-way (OTB/OTW) emission controls and serving as a subset of potential additional controls measures called beyond-on-the-way (BOTW). Details on BOTW control measures may be found in MACTEC's report "Development of Emission Projections for 2009, 2012 and 2018 for NonEGU Point, Area and Nonroad Source in the MANE-VU Region," Final Report, February 2007. Estimated emission reductions for New Hampshire fromthe three named control measures are given in Table 4-1 . Table 4-1. Estimated Emission Reductions fromThree BOTW Control Measures Control Measure Pollutant 2009 Estimated Emission Reductions (tons per day) ICI Boilers (OTC 2006 Model Rule) NOx 1 .9 Emulsified Asphalt Paving (OTCguidelines) VOC 4.4 Consumer Products (OTC 2006 Model Rule) VOC 0.3 Source: MACTEC, 2007 These potential contingency measures arefurther described in subparts 4 .1 through 4

.3, below . 4 .1 ICI Boilers (at Major Point Sources) In 2006, the OTCcommissioners recommended that the OTCmember states pursue "as necessary and appropriate" state-specific rulemakings to establish required emission reduction percentages, emission rate performance standards, or control technologies to reduce emissions from industrial, commercial, and institutional boilers (OTC Resolution 06-02) . The approximately 2-ton-per-day reduction in NOx emissions fromICI boilers reported in Table 4-1 was based on implementation of OTC's recommended control levels on boilers of 25-250 MMBtu/hr heat input capacity at major point sources in New

Hampshire. 4.2 Emulsified Asphalt Paving NHDES is currently evaluating the proposed contingency measure for emulsified asphalt paving. OTC's guideline would limit the VOCcontent of emulsified asphalt to 2percent or less. The VOC content ofemulsified asphalt in New Hampshire is assumed to be 2.5 percent at present. Thus, the estimated VOCemission reduction fromthis source category would be approximately 20 percent during the ozone season. 4.3 Consumer Products The contingency measure for consumer products included in Table 4-1 would replace the OTC 2001 VOC model rules with the OTC 2006 model rules, which provide amendments (adopted by

5 MACTEC Federal Programs, "Identification and Evaluation ofCandidate Control Measures," Final Technical Support Document, Ozone Transport Commission, February 28, 2007.New Hampshire Ozone Maintenance SIP Page 16 the California Air Resources Board (CARB) in July 2005. The amendments revise the existing VOClimit for contact adhesives and create VOClimits for nine new source categories (adhesive removers, electrical cleaner, electronic cleaner, fabric refresher, footwear or leather care, graffiti remover, hairstyling products, toilet care, and wood cleaner) . Based on estimates developed by CARB for 2009, these amendments would reduce VOCemissions by about 2 percent. 4 .4 Additional Controls on Boilers New Hampshire andthe other OTCstates have continued to investigate the possibility of additional controls on ICI boilers and utility boilers as stationary sources with the highest potential for NOx emission reductions. The additional controls would cover a wider range of boilers and would be more stringent than those described in the MACTEC report for non-EGU point sources and area sources in New

Hampshire. More specifically, recent OTCproposals being considered by NHDES wouldprovideadditional NOx controls on thefollowing boiler categories:

.

0 Oil- and gas-fired boilers serving EGUs (OTC 2010 Model Rule) : This proposed rule would impose the following NOx emission limitations on oil- and gas-fired utility boilers with a nameplate capacity of 25 MW or greater: for gas only, 0 .08 lb/MMBtu; for oil or oil/gas, 0.151b/MMBtu. Newsmall natural-gas-fired boilers and water heaters (OTC 2010 Model Rule) : This proposed rule would establish NOx emission standards for various devices ranging in size from75,000to 5,000,000 Btu/hr. ICI boilers: Stricter NOx emission standards would be extended to any ICI boiler above a certain size threshold, e.g., 25 MMBtu/hr. Since 2006, OTC and the Lake Michigan Air Directors Consortium (LADCO) have worked collaboratively to assess the technical and economic feasibility of enhanced emission controls on ICI boilers of all sizes.6 ANESCAUM studY7 fromthe same time period examined a variety of technologies available to reduce NOx emissions fromICI boilers with heat input ratings fromas low as 10 MMBtu/hr to as high as 1,000 MMBtu/hr. It was determined that emission reductions of 5 to 90 percent are achievable, depending on boiler size, fuel type, and chosen technology. Generally, the higher control efficiencies are applicable to larger ICI boilers, of which New Hampshire has relatively few . NHDES is gathering data on New Hampshire's current stock of ICI boilers by size, fuel type, and existing control level . Preliminary data indicate that approximately 80 percent of ICI boilers in the state have heat input ratings less than 25 MMBtu/hr and lack NOx controls. Another 13 percent have heat input ratings less than 50 MMBtu/hr and lack NOx controls. These units - most ofthem burning fuel oil - account for more than half of all NOx emissions fromICI boilers in the state. Boilers with heat input ratings above 100 MMBtu/hr; while far fewer in number, would generally have some existing level of NOx controls. Given all ofthese facts, NHDES anticipates that any reasonable control programfor ICI boilers in New Hampshire would be capable ofreducing overall NOxemissions fromthis sector by 25 percentor more. 6 OTCand LADCO, "Evaluation ofControl Options for Industrial, Commercial and Institutional (ICI) Boilers," Technical Support Document, Final, May 14, 2010 . 7 NESCAUM, Applicability andFeasibility ofNOx, SGz, andPM Emission Control TechnologiesforIndustrial, Commercial, andInstitutional (ICI)Boilers, November 2008.New Hampshire Ozone Maintenance SIP Page 17 Ongoing state and regional initiatives to control boiler emissions are overlain by EPA's proposed or final rules pertaining to National Emission Standards for Hazardous Air Pollutants (NESHAP) for industrial, commercial, and institutional (ICI) boilers at major sources and area sources; NESHAP for coal- and oil-fired electrical generating units; and New Source Performance Standards (NSPS) for fossil-fuel-fired electric utility and ICI boilers. Under these rules, affected sources would be subject to mandatory new emission limits and/or periodic boiler tune-ups that would yield direct emission reductions or indirect co-benefitswith respect to NOx andVOCcontrol . 4.5 Other Contingency Measures NHDES is evaluating other potential NOx and VOC control measures that could be applied, if necessary, to further reduce ozone levels in the maintenance area. Thesecontrol measures are listed in Table 4-2 alongwith the previously mentioned contingency measures for boilers, asphalt paving, andconsumer products.

Table 4-2

. Potential Contingency Measures for Reducing Ozone Levels Control Measure 

# T Source Category

NOxControl Measures Oil and Gas Boilers Serving EGUs (OTC2010 Model Rule) Major Point New Small Natural-Gas-Fired Boilers and Water Heaters (OTC2010Model Rule) Area* ICI Boilers Areaor Major Point Stationary Generators (OTC 2010 Model Rule) Area Motor Vehicle Anti-Idling (mandatory, not voluntary) Onroad Mobile California Low-Emission Vehicles (CALEV) Standards Onroad Mobile Low-Carbon Fuel Standard (regional) Onroad Mobile/ Nonroad VOCControl Measures Large above-Ground Storage Tanks (OTC2010Model Rule) Major Point Emulsified and Cutback Asphalt Paving (OTCguidelines) Area Adhesives and Sealants Application (OTC2006 Model Rule) Area Architectural and Industrial Maintenance Coatings (OTC2009Model Rule) Area Solvent Cleaning (OTC2009 Model Rule) Area Consumer Products (OTC2006 Model Rule) Area Consumer Products (OTC2010Model Rule) Area Motor Vehicle and Mobile Equipment Non-Assembly Line Coatings Operations (OTC2009 Model Rule) Area Stage 11 Vapor Recovery** Area *Areasources include minor emission sources, typically large in number and widely distributed. ** Stage 11 VaporRecovery would serve as a contingency measure upon determination ofwidespread use of ORVR .New Hampshire Ozone Maintenance SIP Page 18 5 . VERIFICATION OF CONTINUEDATTAINMENT EPAguidance calls upon the state to showhow it will track the progress of the maintenance plan, i .e., demonstrate that compliance with the 8-hour ozone standard is being maintained during the 10- year planning period. Tracking is necessary because the emission projections that formthe basis of the maintenance demonstration depend on assumptions of point and area source growth and implementation of specific emission control measures. One option for tracking maintenance is to make periodic updates to the emissions inventory projections. Such an update could be based, in part, on the annual update of EPA's national emissions inventory (NEI) database and could indicate new source growth and other changes fromthe attainment inventory (such as changes in vehicle miles traveled or in traffic patterns) . New Hampshire will track the maintenance of attainment by analyzing air quality trends at local monitors and annually updating the state's emissions inventories. NHDES routinely reviews air quality monitoring data and keeps charts showing trends in air quality at individual monitor sites. As required by law, New Hampshire produces comprehensive emissions inventories on a three-year cycle. The latest one, the 2008 inventory, will be completed this year, to be followed by formal inventories for 2011 and 2014. For the off-years, New Hampshire revises the inventories annually using updated emissions data~for the largest sources. 6 . ADMINISTRATIVE DOCUMENTS In accordance with the requirements for SIPsubmissionsestablished in 40 CFR51 .103, thefollowing documentationis herewith provided as integral to this maintenanceplan: Aformal letter of submittal fromthe Governor or his designee, requesting EPAapproval of this SIP revision; Evidence that the NHDES has the necessary legal authority under state lawto adopt and implement the plan. Evidence that public notice was given of the proposed change consistent with procedures approved by EPA, including the date ofpublication ofsuch notice. Certification that public hearing(s) were held in accordance with the information provided in the public notice and the state's laws and constitution, if applicable and consistent with the public hearing requirements in 40CFR51 .102. Compilationofpublic comments andthe state's response thereto. Documentation of legal authority, public notice, certification of the public process, and public comments and responses are provided in Attachment B. 7. SUMMARY The State of New

Hampshire is committed to achieving and maintaining air quality standards for ground-level ozone and its chemical precursors. The entire maintenance planning area is currently in attainment ofthe 1997 8-hour ozone NAAQS of 0 .08 parts per millionand is projected to stay in attainment for the duration ofthe 10-year planning period that ends onJune 15, 2014.New Hampshire Ozone Maintenance SIP Page 19 With this SIP revision, NewHampshire has met all Section 110(a)(1) maintenance plan requirements. The maintenance plan provides for continued compliance with the 8-hour ozone NAAQS in' all areas that were classified as nonattainment areas for the former 1-hour ozone standard, as evidenced by thefollowing plan elements: 1. Attainment Inventory. New Hampshire compiled and used a 2002 baseline inventory of NOx andVOCemissions in accordance with EPA's Consolidated Emissions Reporting Rule. 2 . Maintenance Demonstration. New Hampshire prepared 2012 and 2014projected inventories of NOx and VOC emissions for comparison with the 2002 baseline inventory. These inventories indicate a sustained downward trend in NOx and VOC emissions within the maintenance planning area, demonstrating that the 1997 8-hour ozone standard will be maintained through at least 2014. The downward trend in NOx and VOC emissions is reinforced by ozone monitoring data, which show asimilar, steady downward trend . (Note: New Hampshire recently prepared a 2008 Periodic Emissions Inventory as required by the CleanAir Act. This inventory has been submitted electronically to EPAfor inclusion in the 2008 National Emissions Inventory. It is also being submitted to EPA for SIP approval along with New

Hampshire's redesignation request for the 1997 8-hour ozone nonattainment area. The 2008 inventory, although not directly related to the maintenance plan, is consistent with the stated trend in NOxandVOCemissions.) 3. AmbientAir Quality Monitoring. New Hampshire is committed to the continued operation of an effective air quality monitoring network to verify maintenance ofthe planning area's attainment status. 4 . Contingency Plan. New Hampshire has developed a contingency plan to ensure that any violations of the 8-hour ozone NAAQS, should they occur, are addressed and promptly corrected. 5. Verification of Continued Attainment. NewHampshire is committed to tracking the maintenance of attainment at least annually - a frequency that would enable the implementation of contingency measures within a short timeframe, should such measures become necessary. Verification will be based on analysis of air quality trends and changes in emissions inventories.New Hampshire Ozone Maintenance SIP Page 20

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